2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
adjacent
to
construction
areas,
and
raises
the
concern
that
dust
and
fine
particulate
matter
are
known
to
impact
the
health
of
the
Callippe
silverspot
butterfly
and
its
host
plant
(
Viola
pendunculata
).
The
comment
also
addresses
the
difficulty
of
habitat
restoration
for
these
species.
Through
continuing
efforts
of
the
teams
engaged
in
management
and
maintenance
of
habitats
at
the
San
Bruno
Mountain
State
Park,
the
knowledge
of
species’
requirements
and
effective
enhancement
measures
continue
to
evolve.
Throughout
the
20-year
build-out
proposed
at
the
Baylands,
adaptive
management
and
further
refinement
of
effective
management
measures
may
become
known
and
may
be
incorporated
by
reference
or
directly
into
any
future
CEQA
analysis
for
Baylands
project-specific
analysis.
For
some
projects,
concurrence
or
permits
from
federal
and
state
regulatory
agencies
with
jurisdiction
over
plant
and
wildlife
resources
may
be
required.
This
means
that
direct
and
indirect
impacts,
including
potential
impacts
of
project-specific
dust
production,
would
be
addressed
and
mitigated
using
current
knowledge
and
practices
at
the
time
of
project
implementation.
Consistent
with
this
comment,
revisions
to
Mitigation
Measure
4.c-1b
are
set
forth
in
Final
EIR
Chapter
3.0
that
would
require
site-specific
analysis
of
development
projects,
including
the
potential
for
dust
generation
to
determine
appropriate
buffer
distances.
The
proposed
fencing
would
occur
along
the
perimeter
of
the
open
space
area.
The
fence
is
not
intended
to
impede
wildlife
movement
within
the
wildlife
movement
and
open
space
areas
designated
at
the
site,
but
instead
is
intended
to
prevent
access
to
and
from
wildlife
movement
areas
and
other
adjacent
uses
that
might
introduce
non-native
species
or
pets.
The
fence
would
not
impede
access
to
the
open
space
areas
by
avian
species
or
butterflies.
Mitigation
Measures
4.C-1a
and
4.C-1b
address
impacts
of
potential
trail
use
on
Icehouse
Hill,
and
permit
trail
construction
only
if
trail
routing
and
construction
can
be
accomplished
in
a
manner
than
will
not
deplete
habitats
on
Icehouse
Hill.
The
trails
proposed
for
the
four
development
scenarios
are
intended
to
be
for
hiking
only
(non-
equestrian).
The
Draft
EIR
includes
performance
standards
that
require
on-going
maintenance
and
management
of
open
space
areas,
which
includes
management
and
removal
of
invasive
species.
In
addition,
Mitigation
Measures
4.C-4b
and
4.C-4c
provide
for
implementation
on
restrictions
on
pets
within
the
Baylands.
The
mitigation
requirements
cited
in
the
comment
are
consistent
with
current
regulatory
agency
requirements
related
to
protection
of
sensitive
species
and
implementation
of
the
Migratory
Bird
Treaty
Act.
Compliance
with
the
Migratory
Bird
Treaty
Act
would
reduce
impacts
to
a
less
than
significant
level
to
avian
species
and
their
young
by
Brisbane
Baylands
Final
EIR
2.9.3-46
May
2015