2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
waterways.
The
few
cases
that
have
discussed
obstruction
to
navigation
focused
on
physical
impediments
such
as
dams,
which
deprive
otherwise
navigable
waters
of
sufficient
water
to
permit
navigation
at
all,
or
other
physical
impediments
to
all
forms
of
navigation.
Project
Site
development
poses
no
such
physical
impediment
to
navigation
of
the
Bay
within
the
CPSRA
area.
Thus,
Article
X,
Section
4
does
not
affect
the
wind
analysis
of
Project
Site
development
under
CEQA,
and
similarly,
the
San
Francisco
Bay
Plan
and
San
Francisco
Bay
Area
Water
Trail
Act
have
no
effect
in
determining
whether
the
significance
criterion
used
in
the
Draft
EIR
is
correct
for
assessing
impacts
to
wind-related
recreation.
See
for
additional
discussion
of
the
CEQA
thresholds
used
in
the
Draft
EIR
analysis.
The
wind
analysis
in
the
Draft
EIR
recognizes
the
CPSRA
as
an
important
windsurfing
area.
A
description
of
windsurfing
use
patterns
and
the
unique
nature
of
the
Candlestick
Point
State
Recreation
Area
(CPSRA)
is
included
on
Draft
EIR
page
4.M-5.
Therefore,
the
threshold
of
significance
and
methods
that
were
used
in
the
Draft
EIR
were
appropriate
for
this
windsurfing
area.
See
for
a
discussion
of
the
significance
criterion
used
in
the
analysis.
See
See
The
wind
analysis
in
the
Draft
EIR
recognizes
CPSRA
as
an
important
windsurfing
area
(see
Draft
EIR
page
4.M-5).
The
Draft
EIR
provides
analysis
of
the
physical
effects
of
proposed
Baylands
development.
The
importance
of
the
windsailing
resource
and
consistency
with
applicable
regional
and
state
policies
will
be
considered
as
part
of
the
planning
review
undertaken
for
the
Baylands.
See
regarding
the
CEQA
thresholds
used
in
the
Draft
EIR
analysis.
The
suitability
of
wind
tunnel
testing
is
discussed
in
detail
31
and
in
responses
to
the
individual
comments
on
wind
testing
in
comment
letter
CPA
2.
As
noted
in
the
Response
above,
the
Draft
EIR
focused
on
the
physical
changes
in
wind
speed
and
turbulence
in
the
CPSRA
windsurfing
resource
that
would
result
due
to
the
project.
Conflating
these
identifiable
changes
with
highly
variable
natural
wind
conditions
would
obscure
the
actual
changes
due
to
proposed
Baylands
development.
Brisbane
Baylands
Final
EIR
2.9.10-3
May
2015