2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
jurisdictional
boundaries
or
sphere
of
influence
of
the
City
of
Brisbane,
if
feasible.”
There
are,
however,
no
provisions
of
the
Brisbane
General
Plan
policies
that
prohibit
the
use
of
offsite
mitigation
banks
(see
Brisbane
General
Plan
Policies
81,
81.1,
82,
and
85).
Mitigation
Measure
4.C-2c
provides
the
potential
for
offsite
mitigation
through
an
approved
mitigation
bank
as
an
alternative,
explicitly
states
that
the
mitigation
banking
option
may
result
in
a
higher
mitigation
ratios
for
compensation.
Ultimately,
whether
the
use
of
offsite
banking
is
acceptable
is
a
policy
decision
to
be
made
by
the
City
of
Brisbane,
and
that
on-site
replacement
and
mitigation
for
habitat
loss
would
be
preferred
and
therefore
pursued
as
part
of
the
site-wide
habitat
plans
called
for
in
Mitigation
Measure
4.C-4a.
The
sensitive
natural
communities
listed
in
Mitigation
Measure
4.C-2c
include
coastal
scrub,
willow
scrub,
tidal
marsh,
freshwater
emergent
wetlands,
and
lined
manmade
drainages
that
have
bed
and
bank
characteristics,”
since
these
are
the
onsite
communities
for
which
temporary
or
permanent
loss
would
constitute
a
significant
impact.
As
stated
in
Response
“impacts”
as
used
in
this
mitigation
measure
takes
into
account
indirect
impacts,
which
means
impacts
to
adjacent
uplands
that
would
reduce
or
impact
the
hydrologic
conditions
needed
to
support
existing
wetlands.
It
is
in
that
context
that
uplands
adjacent
to
wetland
habitats
are
addressed
during
environmental
analysis
and
permitting
for
site-specific
development
projects.
The
performance
standards
included
in
the
Draft
EIR
are
consistent
with
the
methods
utilized
by
State
and
Federal
regulatory
agency
mitigation
requirements,
compliance
with
which
represents
adequate
actions
resulting
in
a
reduction
of
impacts
to
a
level
that
is
less
than
significant.
However,
based
on
the
comment,
the
Draft
EIR
has
been
revised
as
follows:
The
performance
standards
in
the
third
bullet
of
Mitigation
Measure
4.C-2c
have
been
revised
as
part
9,
Identification
of
Wetlands
to
provide
for
90,
rather
than
70
percent
survival
of
installed
plants
for
each
of
the
first
three
years
following
planting
and
a
requirement
for
a
minimum
of
50
percent
vegetation
cover
in
Year
5.
Meeting
the
performance
standards
(success
criteria)
set
forth
in
Mitigation
Measure
4.C-2c
is
the
central
purpose
of
the
measure.
The
monitoring
effort
included
in
Mitigation
Measure
4.C-2c
is
intended
to
document
conditions
at
the
site
after
restoration
occurs
for
the
purpose
of
determining
if
the
mitigation
measure
has,
in
fact
been
implemented
(success
criteria
defined
in
the
permit
have
been
met)
and
requiring
additional
work
if
success
criteria
are
not
met.
To
meet
the
requirements
of
this
mitigation
measure,
as
well
as
for
regulatory
agency
permitting,
the
site
must
meet
the
success
criteria
at
the
five-year
monitoring
event.
If
mitigation
fails
to
meet
the
success
criteria,
then
re-planting,
re-grading/re-contouring,
or
other
alterations
that
would
lead
to
long-term
success
would
be
required.
The
wetland
mitigation
Brisbane
Baylands
Final
EIR
2.9.2-52
May
2015