2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
to
mitigate
potential
water
quality
degradation
of
runoff
from
all
portions
of
the
completed
development,
and
shall
clearly
identify
the
funding
sources
for
the
required
ongoing
maintenance.”).
As
described
on
pages
4.H-19
to
-24,
the
combination
of
BMPs
under
a
SWPPP
that
are
required
for
construction
and
post-construction
NPDES
requirements
would
be
designed
to
protect
water
quality
of
receiving
waters.
Although
nonpoint
source
pollutants
are
considered
the
greatest
threat
to
water
quality,
maintenance
of
drain
inlets
and
removal
of
trash
is
also
important
and
would
be
included
as
part
of
the
Final
Stormwater
Management
Plan
required
by
Mitigation
Measure
4.H-1c
(“The
SMP
shall
provide
operations
and
maintenance
guidelines
for
all
of
the
BMPs
identified
in
the
SMP,
including
LID
measures
and
other
BMPs
designed
to
mitigate
potential
water
quality
degradation
of
runoff
from
all
portions
of
the
completed
development,
and
shall
clearly
identify
the
funding
sources
for
the
required
ongoing
maintenance.”).
See
also
As
noted
on
Draft
EIR
page
4.H-12,
the
Risk
Level
at
a
site
is
evaluated
by
determining
the
project
sediment
risk
(based
on
the
location
and
duration
of
construction
activities)
and
the
receiving
water
risk
(based
on
whether
a
project
drains
to
a
sensitive
water
feature)
which
would
be
determined
by
the
construction
contractor
in
accordance
with
the
General
Construction
Permit
requirements.
The
risk
level
determined
for
a
project
by
the
RWQCB
will
dictate
the
water
monitoring
and
sampling
requirements
associated
with
a
project.
This
overall
risk
assessment
is
part
of
the
General
Permit
Application
process
and
final
determination
of
the
Risk
Level
would
be
made
as
part
of
that
permit
process
(as
described
in
Draft
EIR
Mitigation
Measure
4.H-1a:
“Prior
to
issuance
of
a
grading
permit,
an
applicant
for
any
site
specific
development
project
to
be
constructed
within
the
Project
Site
shall
file
a
Notice
of
Intent
to
the
RWQCB
to
comply
with
the
statewide
General
Permit
for
Discharges
of
Storm
Water
Associated
with
Construction
Activities
and
shall
prepare
and
implement
a
SWPPP
for
construction
activities
on
the
Project
Site
in
accordance
with
the
NPDES
General
Construction
Permit”).
Because
the
required
sediment
risk
assessment
will
be
undertaken
as
part
of
the
General
Permit
Application
process,
the
third
paragraph
on
page
4.H-12
is
modified
to
read
as
follows:
The
General
Construction
Permit
authorizes
the
discharge
of
storm
water
to
surface
waters
from
construction
activities
that
result
in
the
disturbance
of
one
or
more
acres
of
land,
provided
that
the
discharger
satisfies
all
permit
conditions.
The
General
Construction
Permit
establishes
three
possible
levels
of
risk
for
a
construction
site:
Risk
Level
1,
Risk
Level
2
and
Risk
Level
3.
The
Risk
Level
is
calculated
in
Brisbane
Baylands
Final
EIR
2.9.3-81
May
2015