2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
and
4.H-4c)
to
require
the
proposed
drainage
improvements
to
adequately
handle
the
increased
runoff
even
during
heavy
storms
such
that
the
impact
is
less
than
significant.
As
stated
in
Mitigation
Measure
4.H-
1a,
the
notice
of
intent
to
comply
with
the
NPDES
General
Construction
permit
and
the
required
SWPPP
would
be
submitted
to
the
RWQCB
who
has
regulatory
oversight
authority
of
the
NPDES
program.
In
addition,
the
mitigation
requires
that
the
SWPPP
include
measures
such
as
the
Erosion
and
Sediment
Control
Plan
as
per
the
City’s
grading
permit
requirements.
All
monitoring
and
reporting
requirements
are
contained
within
these
permit
requirements
and
both
agencies
can
enforce
corrective
actions
if
performance
standards
are
not
met.
See
also
See
5
for
discussion
of
reliance
on
regulations
as
mitigation.
The
statements
in
the
3
rd
bullet
item
from
Draft
EIR
Mitigation
Measure
4.C-1g
and
statements
made
on
Draft
EIR
page
4.H-22
regarding
increases
in
impervious
surfaces
are
not
contradictory.
The
discussion
on
page
4.H-22
identifies
an
impact
related
to
proposed
development
increasing
the
amount
of
impervious
surface
area
onsite,
while
Mitigation
Measure
4.C-1g
addresses
how
such
an
increase
would
be
mitigated.
Both
the
3
rd
bullet
from
Mitigation
Measure
4.C-1g
and
the
statements
on
page
4.H-22
indicate
the
priority
of
ensuring
that
any
increases
in
impervious
surfaces
also
include
LID
features
such
as
vegetated
swales
and
flow-through
planter
boxes,
which
would
be
required
as
part
of
Provision
C.3
requirements
of
the
NPDES
permit.
While
rooftop
materials
can
contain
urban
pollutants,
impervious
surfaces
themselves
do
not
contribute
as
much
pollution
as
the
activities
and
uses
they
promote
such
as
automobile
and
landscaping
uses
(e.g.,
pesticides,
herbicides,
and
fertilizers).
However,
as
stated
in
the
Draft
EIR,
the
proposed
improvements
would
be
required
to
include
LID
development
measures
which
would
limit
the
amount
of
impervious
surfaces
and
use
features
such
as
permeable
paving,
vegetated
swales,
and
landscaping
where
possible.
While
environmental
analysis
under
CEQA
requires
evaluation
of
both
direct
and
indirect
impacts
of
a
project,
it
would
be
speculative
to
determine
construction
material
sources
for
a
building
program
that
will
occur
over
20
years,
and
CEQA
does
not
require
an
EIR
to
evaluate
speculative
impacts.
As
stated
on
Draft
EIR
page
4.H-25,
groundwater
at
the
Baylands
Project
site
is
not
currently
used
for
water
supply
purposes
and
proposed
development
within
the
Baylands
would
not
include
any
extraction
of
groundwater
supplies
beyond
temporary
dewatering
activities
during
construction.
The
Baylands
Project
site
is
in
close
proximity
to
San
Francisco
Bay
and
recharge
to
the
site
occurs
not
only
from
infiltration
of
Brisbane
Baylands
Final
EIR
2.9.3-84
May
2015