2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
result
in
impacts
to
nearly
all
of
the
existing
habitats
at
the
Baylands
when
existing
soils
are
removed
or
remediated
in
place,
the
landfill
is
capped
and
formally
closed,
and
clean
fill
material
is
brought
in
to
establish
a
new
substrate.
Performance
standards
included
in
mitigation
measures
in
the
Draft
EIR
include
implementation
of
an
Open
Space
Plan,
which
is
specified
to
include
habitats
and
wildlife
movement
corridors
as
part
of
the
design
criteria.
A
marsh
habitat
enhancement
plan
is
also
required
to
be
prepared,
approved
by
the
City,
and
implemented
prior
to
site
development.
These
two
plans,
included
in
Mitigation
Measures
4.C-4a
and
4.C-4b,
will
result
in
reconfiguration
of
planned
development
areas
in
the
selected
concept
plan
scenario,
and
are
required
in
addition
to
compliance
with
and
implementation
of
the
regulatory
permitting
process
overseen
by
state
and
federal
resources
agencies,
which
share
the
“no
net
loss”
of
wetlands
mandate
referenced
in
the
Draft
EIR.
Please
see
Draft
EIR
Section
3.0,
Project
Description
,
and
the
concept
plan
scenario
maps
which
show
at
a
conceptual
level
what
proposed
protection
of
the
site’s
most
valuable
resources
including
Icehouse
Hill,
Visitacion
Creek,
and
the
Brisbane
Lagoon
might
include.
On
March
2,
2007;
June
20,
2007;
April
20,
2011;
and
April
19,
2013
reconnaissance-level
field
surveys
covering
the
entire
Baylands
Project
Site
were
conducted
by
ESA
biologists.
The
surveys
were
timed
to
maximize
opportunities
to
see
average
conditions
across
all
the
habitats
on-site
and
were
not
aimed
at
any
one
habitat
type
or
species.
This
type
of
reconnaissance
survey,
combined
with
a
review
of
existing
data
pertaining
to
the
site
dating
back
to
the
early
2000’s
is
sufficient
to
support
analysis
of
the
Baylands
development
program
which
will
result
in
construction
actions
spanning
an
approximately
20-year
period.
The
analysis
describes
the
habitats
present,
the
species
likely
to
occur
or
use
such
habitats,
and
includes
performance
standards
and
mitigation
measures
to
protect,
enhance
and
restore
habitats
impacted
as
part
of
site
build-out.
See
1
for
discussion
of
the
programmatic
nature
of
the
Draft
EIR
and
8
for
discussion
regarding
the
level
of
detail
required
for
biological
resources
analysis.
The
comment
references
a
brief
description
of
the
history
of
the
Baylands
Project
site
related
to
analysis
presented
in
Section
4.C,
Biological
Resources
,
of
the
Draft
EIR,
but
does
not
address
or
comment
on
the
analysis
presented
in
the
Draft
EIR.
Description
of
baseline
conditions
and
analysis
in
the
Draft
EIR
is
consistent
with
this
comment
Section
4.H,
Surface
Hydrology
and
Water
Quality
,
of
the
Draft
EIR
discusses
the
mid
and
southern
portions
of
the
project
site
as
supporting
two
primary
open
water
features,
Visitacion
Creek
and
the
Brisbane
Lagoon.
Common
wildlife,
especially
shore
birds,
that
inhabit
Visitacion
Creek
and
Brisbane
Lagoon
are
discussed
under
the
tidal
marsh
and
tidal
drainage
habitat
section
of
the
Draft
EIR.
(Draft
EIR,
page
4.C-10.)
These
2.9.8-4
Brisbane
Baylands
Final
EIR
May
2015