2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
preventing
removal
or
trimming
of
trees
if
occupied
nests
are
present.
Compliance
with
General
Plan
Guidelines
requiring
replanting
trees
removed
would
result
in
less
than
significant
impacts
since
the
loss
of
habitat
is
temporary
and
since
avian
species
are
mobile
and
can
access
habitats
adjacent
and
in
the
vicinity
until
such
time
as
replanted
trees
can
be
occupied
for
nesting.
Compliance
with
the
Fish
and
Game
Code
as
described
in
the
Draft
EIR
pertaining
to
burrowing
owl
mitigation
includes
utilization
of
passive
removal
techniques
under
specific
conditions
during
non-nesting
periods
and
reduces
impacts
to
the
species
to
a
less
than
significant
level.
See
9
pertaining
to
specificity
of
biological
resources
studies
for
a
discussion
of
surveys
for
special
status
species.
Mitigation
measure
4.C-1g
provides
for
control
of
runoff
to
protect
water
quality
in
the
lagoon,
consistent
with
the
commenter’s
recommendation.
In
addition,
all
concept
scenarios
include
implementation
of
erosion
control
and
other
best
management
practices
to
avoid
and
minimize
introduction
of
run-off
or
sediment
into
the
lagoon
.
.
.
consistent
with
NPDES
permit
conditions.
(See
Draft
EIR
page
4.C-45,
second
full
paragraph.)
See
1
for
discussion
regarding
the
programmatic
nature
of
the
Draft
EIR.
For
purposes
of
flood
management,
use
of
permeable
surfaces
is
preferred
over
impermeable
surfaces,
which
would
tend
to
increase
overall
runoff
and
flooding
hazards.
Thus,
the
Draft
EIR
calls
for
use
of
impermeable
surfaces
where
feasible.
However,
Title
27
closure
of
the
former
landfill
within
the
Project
site
will
require
that
stormwater
not
be
permitted
to
infiltrate
into
the
landfill.
Thus,
development
within
the
former
landfill
area
will
require
impermeable
underground
barriers
and
drainage
systems
to
prevent
such
infiltration
from
landscaped
areas
and
other
impermeable
surfaces.
The
full
text
of
the
6
th
bullet
in
Mitigation
Measure
4.C-1g
reads,
“any
increase
in
impervious
surface
area
shall
include
establishment
of
vegetated
swales,
permeable
pavement
materials,
preserve
vegetation,
re-plant
with
native
vegetation
and
appropriate
measures
should
be
evaluated
and
implemented
where
appropriate.”
The
bullet
point
referred
to
in
the
comment
is
one
of
several
options
for
implementation
of
a
SWPPP.
Any
construction
of
diversion
dikes
or
drainage
swales
would
need
to
be
in
compliance
with
the
Brisbane’s
NPDES
stormwater
drainage
permit,
the
mitigation
measures
set
forth
in
Draft
EIR
Sections
4.C,
Biological
Resources
,
and
Section
4.H,
Surface
Water
Hydrology
and
Water
Quality
,
to
ensure
that
both
wetland
areas
and
water
quality
are
protected.
Brisbane
Baylands
Final
EIR
2.9.3-47
May
2015