2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
purpose
of
Mitigation
Measure
4.C-1g
is
to
reduce
overall
increases
in
runoff
from
the
Baylands
Project
site,
as
well
as
to
minimize
the
potential
for
urban
pollutants
to
enter
the
lagoon
and
San
Francisco
Bay.
In
such
cases
as
the
potential
for
runoff
from
the
site
to
impact
water
quality
in
the
lagoon,
to
address
the
heating
effects
of
large
paved
areas,
the
Draft
EIR
will
identify
areas
anticipated
to
have
large
impermeable
surfaces,
and
recommend
mitigation
measures
that
may
include
requirements
for
use
of
permeable
surfaces.
Because
each
of
the
four
scenarios
evaluated
in
the
Draft
EIR
have
only
been
designed
at
a
concept
level,
the
Baylands
EIR
cannot
provide
a
precise
delineation
of
where
permeable
and
impermeable
surfaces
will
be
developed
until
site-specific
development
projects
are
actually
designed
and
proposed.
At
that
time,
the
specific
impacts
of
using
permeable
or
impermeable
surface
materials
can
be
evaluated
in
relation
to
the
program-level
evaluations
contained
in
the
present
EIR
for
Baylands
development.
This
level
of
detail
in
the
project
design
facilitates
a
much
more
detailed
analysis
of
biological
resources
and
the
mechanisms
and
potential
for
project-specific
impacts
to
occur,
including
the
placement
of
permeable
and
impermeable
surfaces
within
the
developments.
It
is
likely
that
a
combination
of
subsurface
drainage
combined
with
surface
filtration
mechanisms
will
be
utilized
as
a
means
of
providing
passive
treatment
to
runoff
without
promoting
infiltration
into
underlying
materials
such
as
the
waste
layer.
Landfill
closure
under
the
regulatory
authority
of
the
RWQCB
will
require
capping
of
the
landfill
to
prevent
infiltration
of
storm
water.
The
mitigation
measure
is
consistent
with
regulatory
agency
requirements
used
to
implement
provisions
of
the
Clean
Water
Act
and
Endangered
Species
Acts,
both
of
which
require
offsetting
loss
of
habitat.
Also,
since
Mitigation
Measure
4.C-2c
requires
in
kind
replacement
for
loss
of
sensitive
habitats
and
Mitigation
Measures
4.C-4a
and
4.C-4b
require
preparation
and
implementation
of
open
space
and
marsh
enhancement
plans
that
will
define
the
future
configuration
of
open
space
for
biological
habitats
within
the
site,
and
thereby
define
the
locations
where
habitat
would
be
lost
as
part
of
site-specific
development,
adding
an
additional
requirement
to
Mitigation
Measure
4.C-4g
for
replacement
of
habitat
is
not
needed.
In
terms
of
bat
habitat,
which
at
the
Baylands
includes
abandoned
structures
and
large
trees,
Mitigation
Measure
4.C-4a,
specifies
that
placement
of
boxes
or
substrate
for
roosting
bats
in
passive
recreational
areas.”
Icehouse
Hill
is
the
single
location
in
the
Baylands
that
has
the
potential
to
support
the
Callippe
butterfly.
In
its
current
configuration
Ice
House
Hill
sustains
sufficient
water
through
Brisbane
Baylands
Final
EIR
2.9.3-48
May
2015