2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
two
parts:
(1)
project
sediment
risk,
and
(2)
receiving
water
risk.
Project
sediment
risk
is
based
on
the
location
and
duration
of
construction
activities.
Receiving
water
risk
is
based
on
whether
a
project
drains
to
a
sediment-sensitive
water
body
that
(1)
is
on
the
most
recent
303d
list
for
water
bodies
impaired
for
sediment,
(2)
has
a
U.S.
EPA-approved
TMDL
implementation
plan
for
sediment,
or
(3)
has
the
beneficial
uses
of
cold,
spawn,
and
migratory.
The
risk
level
calculated
for
Project
Site
development
will
dictate
monitoring
and
sampling
requirements.
Project
sediment
risk
requires
site
specific
calculations
based
on
a
number
of
factors
which
have
not
been
calculated
for
the
Project
Site,
but
will
likely
end
up
as
Risk
Level
2.
Structural
BMPs
could
include
use
of
flow
through
planters
for
roof
runoff
or
bioswales
for
parking
lot
runoff.
Nonstructural
BMPs
could
include
maintenance
practices
such
as
street
sweeping/catch
basin
cleaning
or
priorities
on
maximizing
open
spaces.
As
stated
on
Draft
EIR
page
4.H-15,
BCDC
has
jurisdiction
within
100
feet
of
the
shoreline
and
all
areas
of
tidal
action.
This
means
that
BCDC’s
area
of
jurisdiction
will
move
as
sea
levels
rise
and
the
shoreline
moves
landward.
Beyond
this
shoreline
boundary,
there
is
no
direct
agency
with
jurisdiction
regarding
sea
level
rise.
However,
FEMA
is
responsible
for
updating
their
FIRM
flood
hazard
maps
and
the
City
of
Brisbane
and
San
Mateo
County
must
meet
the
requirements
necessary
to
remain
in
the
National
Flood
Insurance
Program
(NFIP)
administered
by
FEMA.
Provision
C.3
of
the
San
Mateo
Countywide
Water
Pollution
Prevention
Program
requires
that
drainage
improvements
include
LID
measures
that
could
include
rainwater
harvesting
(use
of
planter
boxes,
vegetated
swales,
etc.).
Site-specific
drainage
control
features
have
not
yet
been
designed
for
the
proposed
development
within
the
Baylands
as
is
typical
for
large
scale
development,
but
would
be
required
prior
to
approval
of
site-specific
development
projects
pursuant
to
Mitigation
Measure
4.H-1c
(“Applicants
for
site-specific
development
projects
to
be
constructed
within
the
Project
Site
shall
prepare
and
implement
a
Final
Stormwater
Management
Plan
(SMP)
in
accordance
with
the
most
recent
NPDES
C.3
requirements
to
be
reviewed
and
approved
by
the
City
Engineer
prior
to
approval
of
final
design
plans.”).
As
discussed
on
page
4.H-22
and
-23
of
the
Draft
EIR,”
the
project
applicant
would
incorporate
LID
strategies,
such
as
stormwater
reuse,
onsite
infiltration,
and
evapotranspiration
as
initial
stormwater
management
strategies.
Secondary
methods
would
include
the
use
of
natural,
landscape
based
stormwater
treatment
measures,
as
identified
by
Provision
C.3.
Brisbane
Baylands
Final
EIR
2.9.3-82
May
2015