2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
“Master
Response”
referred
to
in
this
comment
is
from
the
Final
EIR
prepared
by
the
City
of
Burlingame
for
the
300
Airport
Boulevard
project,
which
is
located
more
than
10
miles
south
of
the
Baylands.
For
additional
discussion
regarding
the
significance
threshold
applied
in
the
Baylands
Draft
EIR,
see
in
this
document.
While
it
is
correct
that
there
is
no
wind
speed
reduction
significance
threshold
adopted
by
the
City
of
Brisbane,
there
is
also
no
relevant
threshold
in
CEQA
Guidelines
Appendix
G
with
which
to
analyze
wind
impacts
at
sailboarding
areas.
Evaluation
of
impacts
on
windsurfing
was
added
to
the
Baylands
EIR
to
address
comments
received
from
the
San
Francisco
Boardsailing
Association
in
response
to
the
Baylands
Notice
of
Preparation.
There
was
no
request
from
any
person
or
group
to
use
(or
not
use)
a
specific
criterion
to
assess
the
level
of
impact
to
the
CPSRA
windsurfing
area
received
by
the
City
of
Brisbane
in
response
to
Notices
of
Preparation
distributed
in
2006,
2010,
and
2012,
nor
is
there
a
requirement
under
CEQA
for
the
City
of
Brisbane
to
formally
adopt
a
new
CEQA
threshold
before
analyzing
windsurfing
impacts
in
the
Baylands
EIR.
As
noted
in
Response
and
the
Baylands
EIR
used
the
threshold
and
methodology
used
in
a
CEQA
analysis
conducted
by
the
City
and
County
of
San
Francisco
for
the
Executive
Park
project,
which
considers
wind
impacts
on
the
same
windsurfing
area
(CPSRA)
as
the
Baylands
EIR.
The
comment
provides
no
substantial
evidence
to
show
that
the
threshold
of
significance
used
in
the
Draft
EIR
failed
to
consider
potentially
significant
impacts
of
Project
Site
development.
See
regarding
the
significance
criterion
used
in
the
EIR.
Proposed
Baylands
development
will
not
affect
gale
and
lull
wind
speeds,
since
gales
and
lulls
are
weather-related
events.
For
additional
discussion,
see
In
addition,
although
statistical
correlations
can
be
made
between
project
turbulence
intensity
and
mean
wind
speed
and
naturally
occurring
gust
and
lull
wind
speeds,
correlations
do
not
prove
causation
(see
also
Simply
evaluating
the
changes
in
relative
wind
speed
and
turbulence
intensity,
factors
that
are
proven
to
be
caused
by
a
change
in
upwind
surface
roughness,
is
necessary.
Furthermore,
the
application
of
the
models
used
to
relate
wind
turbulence
intensity
with
gust
factors
in
CPA’s
suggested
“Sailable
Day
Impact
Analysis”
is
not
supported
by
evidence.
CPA
does
not
demonstrate
that
models
based
on
Brisbane
Baylands
Final
EIR
2.9.4-24
May
2015