2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
requires
implementation
of
an
open
space
plan
that
addresses
the
entirety
of
the
Baylands
Project
Site
to
integrate
habitat
configurations
that
facilitate
wildlife
movement
and
provide
wildlife
habitat,
including
specialized
habitats
for
avian
and
aquatic
species
such
as
seasonal
wetlands
and
riparian
habitats.
Mitigation
Measure
4.C.4-1b
requires
implementation
of
a
Marsh
Habitat
Management
Plan
that
would
address
all
portions
of
the
Baylands
Project
Site
subject
to
tidal
action,
including
and
aquatic
species
that
occur
in
tidal
wetlands.
Performance
standards
are
built
into
these
mitigation
measures,
as
well
as
in
Mitigation
Measure
4.C-2c
to
support
the
Draft
EIR’s
conclusion
that
the
ultimate
configuration
of
wetlands
within
the
Baylands,
following
the
restoration
required
by
the
Draft
EIR
will
exceed
the
habitat
values
present
under
existing
conditions.
If
any
offsite
mitigation
is
proposed,
it
would
be
at
a
higher
replacement
ratio
than
the
onsite
ratio
established
during
regulatory
consultation,
and
would
need
to
be
consistent
with
General
Plan
Policy
130.5,
which
specifies
the
City’s
preference
is
for
onsite
mitigation.
It
is
recognized
that
improvements
will
not
be
immediate,
and
that
habitat
restoration
and
improvements
will
take
a
number
of
years
to
establish.
In
addition
to
the
meeting
the
requirements
and
performance
standards
in
the
mitigation
measures
set
forth
in
the
Baylands
EIR,
Baylands
remediation
and
development
activities
that
would
impact
existing
wetlands
will
be
subject
to
the
requirements
of
state
and
federal
regulatory
agencies
that
do
not
approve
permits
or
implementation
of
mitigation
actions
without
stringent
performance
standards
for
plant
survival,
vegetation
coverage,
and
mitigation
area
acreage
specified
in
agency-approved
Mitigation
and
Monitoring
Plans.
The
comment
notes
that
the
State’s
no
net
loss
of
wetland
policy
includes
“area,”
and
that
both
State
criteria
and
the
Brisbane
General
Plan
policy
have
the
goal
of
“increasing”
function
and
value.
Through
implementation
of
the
open
space
and
marsh
enhancement
plans
and
the
regulatory
agency
permitting
requirements
cited
in
Response
along
with
implementation
of
the
Brisbane
General
Plan
as
part
of
the
City’s
planning
review
process
will
ensure
that
no
net
loss
of
wetland
function
and
value
occurs
as
part
of
the
Project
Site
development.
See
3
and
5
for
discussion
of
mitigation
monitoring
requirements
and
implementation
of
legal
applicable
requirements,
such
as
regulatory
permitting
for
potential
impacts
to
wetlands.
By
achieving
no
net
loss
of
wetland
area,
function,
or
value,
wetlands
impacts
resulting
from
proposed
Baylands
development
would
be
less
than
significant.
Chapter
4.O
of
the
Draft
EIR
describes
the
proposed
water
transfer
agreement
in
detail;
provides
background
information
on
SFPUC
water
supply,
distribution,
and
water
quality;
OID
water
supply
and
water
rights;
the
mechanisms
for
transferring
the
water
from
OID
through
MID
and
SFPUC
to
Brisbane;
and
a
water
supply
assessment
(Draft
EIR
Appendix
L)
prepared
for
proposed
Project
Site
development.
In
addition,
the
Brisbane
Baylands
Final
EIR
2.9.2-49
May
2015