2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
See
for
discussion
of
the
stickleback
fish.
Regarding
California
red
legged
frog,
Table
4.C-1
states
that
aquatic
habitat
exists
in
freshwater
wetlands
in
the
old
railyard,
in
the
Roundhouse
wetland
and
the
westernmost
drainage
and
associated
wetlands,
but
that
these
wetlands
are
contaminated
with
hazardous
materials
that
are
potentially
damaging
to
amphibians.
The
table
also
notes
that
extant
upstream
populations
are
absent
on
San
Bruno
Mountain,
and
habitat
fragmentation,
primarily
in
the
form
of
development,
freeways,
and
other
infrastructure,
act
as
barriers
to
prevent
access
to
the
Baylands
Project
site
from
other
potentially
suitable
habitat,
or
other
extant
populations.
The
Brisbane
Baylands
are
outside
of
the
range
of
the
Salt
Marsh
Mouse,
which
need
not
be
addressed
in
the
Draft
EIR,
since
it
does
not
have
the
potential
to
occur
within
the
Baylands
Project
site.
The
salt
marsh
harvest
mouse,
which
occurs
in
suitable
habitat
in
the
San
Francisco
Bay,
is
not
present
at
the
Baylands
as
stated
in
the
Draft
EIR.
Although
it
is
not
clear
from
Comment
what
the
commenter
would
consider
a
“full
biological
assessment,”
CEQA
does
not
require
specific
survey
methodologies
to
support
analysis
and
conclusions
in
an
EIR.
(Association
of
Irritated
Residents
v.
County
of
Madera
(2003)
107
Cal.App.4th
1383,
1396.)
Nor
does
CEQA
require
a
lead
agency
to
conduct
every
test
or
perform
all
possible
research,
study,
and
experimentation
recommended
by
commenters
on
an
EIR.
(CEQA
Guidelines
Section
15204(a).)
The
collected
research
and
surveys
described
in
the
Draft
EIR
and
throughout
these
responses
to
comments
provide
substantial
evidence
in
support
of
the
analysis
and
conclusions
in
the
Final
EIR.
However,
for
clarity,
the
conclusions
paragraph
on
page
4.C-36
is
revised
to
read
as
follows:
Conclusions:
Special
status
plant
species
are
assumed
to
occur
within
the
Project
Site
onlywhere
where
suitable
conditions
occur
on
Icehouse
Hill.
Damage
to
or
mortality
of
special-status
plants
caused
by
construction
of
trails
on
Icehouse
Hill
and
an
anticipated
post-construction
increase
in
recreation-related
activities
including
equestrian
uses
would
be
a
significant
impact.
Adherence
to
performance
standards
during
construction
and
operation
of
the
proposed
trails
set
forth
in
Mitigation
Measures
4.C-1a
and
4.C-1b
would
reduce
the
impacts
on
special-status
plants
to
a
less-than-significant
level.
This
comment
cites
the
statement
in
the
Draft
EIR
that
calls
for
“establishing
a
buffer
zone
of
no
less
than
25
feet…”
Brisbane
Baylands
Final
EIR
2.9.3-45
May
2015