2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
As
stated
9,
biologists
mapped
the
maximum
and
minimum
expressions
of
wetlands
and
identified
a
midpoint
or
average
wetland
area.
The
result
clearly
demonstrated
that
the
wetland
habitat
boundaries
identified
in
the
Draft
EIR
are
in
line
with
the
20-year
average
wetland
expression
at
the
Baylands,
and
substantiates
the
adequacy
of
the
Draft
EIR
baseline
characterization
of
wetlands
on
the
Baylands.
The
site
conditions
addressed
on
Draft
EIR
page
4.C-1
refer
to
biological
resources.
Three
field
surveys
were
conducted
at
the
Baylands
site
between
2007
and
2013
in
order
to
observe
plant
and
animal
life
present,
as
discussed
on
Draft
EIR
pages
4.C-1
and
4.C-2.
The
results
of
these
surveys
provided
biologists
with
the
data
necessary
to
determine
whether
biological
resources
conditions
had
changed
during
that
time.
The
biologists
concluded
that
“no
appreciable
changes
in
distribution
or
condition
of
existing
habitats
(occurred)
between
2007
conditions
and
2011…”
Thus,
whatever
topographic
changes
may
have
occurred
between
2007
and
2011
did
not
appreciably
affect
onsite
biological
resources.
No
changes
to
the
Draft
EIR
are
required.
The
use
of
the
CNDDB
to
evaluate
specific
species
and
their
potential
based
on
known
occurrences
within
a
five-
mile
radius
is
standard
practice
in
the
biological
assessment
process.
The
reports
generated
by
the
CNDDB
are
considered
the
accurate
and
useful
in
predicting
the
potential
for
occurrence
of
special
status
species
and
biologists
use
them
as
an
accepted
standard
practice
to
supplement
site-specific
biological
surveys.
In
the
case
of
Baylands
biological
resources
analyses,
CNDDB
searches
were
used
to
supplement
onsite
characterization
of
habitats
before
determining
the
likelihood
a
sensitive
species
would
have
of
occurring
within
the
Baylands
Project
site.
In
general,
direct
observation
of
a
particular
species
is
not
required
to
support
a
determination
that
the
species
has
a
moderate
or
high
potential
to
occur;
this
is
a
precautionary
approach
in
favor
of
the
species.
The
comment
is
correct
in
stating
that
most
grasses
in
the
Bay
Area
are
non-native.
Since
the
text
cited
in
the
Draft
EIR
describes
conditions
within
the
Baylands
Project
site,
the
revision
requested
in
Comment
is
unnecessary.
The
last
sentence
of
the
first
full
paragraph
on
page
4.C-4
is
revised
to
read
as
follows.
“Even
though
biologists
observed
that
the
Johnny
jump-up
plants
had
been
grazed
by
herbivores
such
as
deer
rabbits
or
other
fossorial
rodents,
these
plants
represent
a
potential
host
for
the
callippe
silverspot
butterflies.
Brisbane
Baylands
Final
EIR
2.9.3-40
May
2015