2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
Mitigation
Measure
4.G-2c
sets
forth
the
required
contents
of
the
mitigation
plan,
and
includes
a
performance
standard
(meeting
applicable
BAAQMD,
OSHA,
and
CalOSHA
requirements).
It
does
not,
therefore,
constitute
deferred
mitigation.
See
1
for
discussion
of
the
programmatic
nature
of
the
Brisbane
Baylands
Draft
EIR
and
environmental
reviews
for
subsequent
site-specific
development
proposals.
Compliance
with
Mitigation
Measure
4.H-1c
would
be
required
prior
to
approval
of
final
design
plans
for
future
site-specific
development.
Consistent
with
CEQA’s
requirements
for
mitigation
measures,
the
measure
sets
for
the
required
contents
of
the
stormwater
management
plan,
and
specifies
performance
standards
that
must
be
met
in
order
to
ensure
that
impacts
are
mitigated.
These
include
meeting
applicable
NPDES
C.3
requirements,
implementing
best
available
technology
economically
available,
and
best
conventional
control
technology
in
accordance
with
the
General
Industrial
Permit).
The
water
quality
impacts
of
proposed
Baylands
development
are
clearly
described
in
Draft
EIR
Section
4.H,
Hydrology
and
Water
Quality
.
These
impacts
include
the
potential
for
erosion
during
and
following
site
construction
and
increases
in
urban
pollutants
in
site
stormwater
runoff.
Compliance
with
applicable
NPDES
C.3
requirements,
including
implementation
of
best
technology
economically
available,
and
best
conventional
control
technology
in
accordance
with
the
General
Industrial
Permit
would
reduce
water
quality
impacts
to
less
than
significant.
See
5
for
discussion
regarding
compliance
with
the
law
and
applicable
regulations
as
mitigation
under
CEQA.
In
addition,
Title
27
landfill
closure
would
provide
for
assurance
that
leachate
from
the
former
landfill
would
not
seep
into
the
lagoon
in
violation
of
applicable
water
quality
standards.
Thus,
the
Draft
EIR
provides
sufficient
analysis
to
allow
the
public
to
understand
the
likely
water
quality
impacts
of
proposed
site
development.
See
1
for
discussion
of
the
programmatic
nature
of
the
Draft
EIR
and
the
provision
of
analysis
at
a
level
of
detail
commensurate
with
level
of
detail
available
at
this
early
planning
stage.
Contrary
to
the
commenter’s
assertion,
the
level
of
detail
included
in
Mitigation
Measure
4.H-4a
is
consistent
with
program-level
environmental
analysis,
which
requires
consideration
of
broad
programmatic
issues
for
related
actions
at
an
early
stage
of
the
planning
process.
See
1
for
a
detailed
discussion
of
program
EIRs
and
requirements
for
analysis
of
future
site-specific
development
projects.
Consistent
with
CEQA’s
requirements
for
mitigation
measures,
MM
4.H-4a
includes
specific
performance
standards
to
be
met
to
ensure
that
impacts
are
mitigated.
Specifically,
the
measure
requires
that
all
increased
runoff
associated
with
the
Project
be
accommodated
and
requires
drainage
improvements
to
convey
25-year
storm
event
completely
within
a
piping
system,
and
convey
100-year
storm
Brisbane
Baylands
Final
EIR
2.9.9-9
May
2015