2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
Brisbane’s
NPDES
stormwater
discharge
permit,
as
well
as
the
provisions
of
Draft
EIR
Mitigation
Measures
4.C-2a
through
4.C-2c
so
as
to
protect
water
quality
in
the
lagoon.
The
full
text
of
the
6
th
bullet
in
Mitigation
Measure
4.C-1g
reads,
“any
increase
in
impervious
surface
area
shall
include
establishment
of
vegetated
swales,
permeable
pavement
materials,
preserve
vegetation,
re-plant
with
native
vegetation
and
appropriate
measures
should
be
evaluated
and
implemented
where
appropriate.”
The
bullet
point
referred
to
in
the
comment
is
one
of
several
options
for
implementation
of
a
SWPPP.
Any
construction
of
diversion
dikes
or
drainage
swales
would
need
to
be
in
compliance
with
the
Brisbane’s
NPDES
stormwater
drainage
permit,
the
mitigation
measures
set
forth
in
Draft
EIR
Sections
4.C,
Biological
Resources
,
and
Section
4.H,
Surface
Water
Hydrology
and
Water
Quality
,
to
ensure
that
both
wetland
areas
and
water
quality
are
protected.
The
purpose
of
Mitigation
Measure
4.C-1g
is
to
reduce
overall
increases
in
runoff
from
the
Baylands
Project
site,
as
well
as
to
minimize
the
potential
for
urban
pollutants
to
enter
the
lagoon
and
San
Francisco
Bay.
In
such
cases
as
the
potential
for
runoff
from
the
site
to
impact
water
quality
in
the
lagoon,
to
address
the
heating
effects
of
large
paved
areas,
the
Draft
EIR
will
identify
areas
anticipated
to
have
large
impermeable
surfaces,
and
recommend
mitigation
measures
that
may
include
requirements
for
use
of
permeable
surfaces.
Because
each
of
the
four
scenarios
evaluated
in
the
Draft
EIR
have
only
been
designed
at
a
concept
level,
the
Baylands
EIR
cannot
provide
a
precise
delineation
of
where
permeable
and
impermeable
surfaces
will
be
developed
until
site-specific
development
projects
are
actually
designed
and
proposed.
At
that
time,
the
specific
impacts
of
using
permeable
or
impermeable
surface
materials
can
be
evaluated
in
relation
to
the
program-level
evaluations
contained
in
the
present
EIR
for
Baylands
development.
This
level
of
detail
in
the
project
design
facilitates
a
much
more
detailed
analysis
of
biological
resources
and
the
mechanisms
and
potential
for
project-specific
impacts
to
occur,
including
the
placement
of
permeable
and
impermeable
surfaces
within
the
developments.
It
is
likely
that
a
combination
of
subsurface
drainage
combined
with
surface
filtration
mechanisms
will
be
utilized
as
a
means
of
providing
passive
treatment
to
runoff
without
promoting
infiltration
into
underlying
materials
such
as
the
waste
layer.
As
noted
in
Response
the
purpose
of
Mitigation
Measure
4.C-1g
is
to
reduce
overall
increases
in
runoff
from
the
Baylands
Project
site,
as
well
as
to
minimize
the
potential
for
urban
pollutants
to
enter
the
Lagoon
and
San
Francisco
Bay.
By
minimizing
increases
in
runoff,
sediments,
and
urban
pollutants
entering
the
Lagoon,
impacts
on
sensitive
plants
and
animals
will
likewise
be
minimized.
Brisbane
Baylands
Final
EIR
2.9.2-47
May
2015