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2.15 Biological Resources

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2.15 Biological Resources zChapter IX 2. Comments and Responses 2.15 BIOLOGICAL RESOURCES 2.15.1 BASELINE ASSUMPTIONS Comments Section IV.M (“Biological Resources”) begins with an assessment of the current setting of the Treasure Island-Yerba Buena Island (TI-YBI) setting. While accurate that TI was heavily used for decades when the base was functioning, the Biological Resources section does not appear to account for the decrease in use after the closure of the base. The suitability of TI-YBI and its adjacent waters for wildlife may depend on overall resident and transient (especially work- related) human population on the island. It is not appropriate to consider the “baseline” as the conditions at the base during its peak operations. Rather, the environmental assessment should be based on the use and population exists today. The proposed development will increase use and population on the island much more significantly over current use than it might have over the historical use of the island. (Mike Lynes, Conservation Director, Golden Gate Audubon Society) [32.2] The DEIR states that the non-native plants incorporated into landscaping result in a habitat type that is “of low value” to wildlife. (DEIR at IV.M.4). The DEIR provides no means to assess the scale of the habitat’s value; in other words, how are “high value” and “low value” habitats measured, respectively—by species diversity, density, breeding success, population demographics, individual lifespan? Moreover, the only citation provided for this assessment is the San Francisco Planning Department (presumably the 2005 EIR). This is not an adequate citation for such a broad characterization, especially given that it does not even cite to a specific page or other reference in the 2005 EIR (or some other verifiable document). While the human-altered landscape of TI could be greatly improved for wildlife, it is likely that it currently provides better habitat for wildlife than it will after the completion of the project. If the DEIR downplays the importance now, it is easier to show no significant impact to wildlife, and therefore avoid minimization or mitigation measures required by law. Therefore, if such assessments are to be made in the DEIR, they must be supported by a quantifiable and verifiable metric of “habitat value”. We also note that while the DEIR emphasizes that TI is of “low value” for habitat for wildlife, it offers no such blanket assessment for YBI. (Mike Lynes, Conservation Director, Golden Gate Audubon Society) [32.5] Response The “baseline” or environmental setting against which the impacts of a project are measured normally consists of physical conditions as they exist at the time the lead agency publishes the Notice of Preparation (“NOP”) for a project (CEQA Guidelines, § 15125(a)). CEQA authorizes agencies to use an alternative baseline where the project at issue consists of a reuse plan for a military base; under this section, the “baseline” may instead consist of conditions as they existed at the time the Federal government made the base closure decision (CEQA Section 21083.8.1.) In this case, however, this “alternative baseline” was not used. Rather, baseline conditions were defined as those that existed at the time of the NOP, which was in January 2008. This approach is more conservative than the approach authorized by CEQA Section 21083.8.1. The biological surveys April 21, 2011 2.15.1 Treasure Island / Yerba Buena Island Case No. 2007.0903E Redevelopment Project Final EIR zChapter IX 2. Comments and Responses 15. Biological Resources and analyses prepared for the EIR were performed in 2008-2010; these surveys and analyses thus reflect the existing environmental conditions of the project site. The history of the Islands is included as context and explanation for many of their current biological attributes. This history is not provided to suggest that the baseline for the analysis is the period of its heaviest use. It is true, however that the construction and operation of a military facility is now reflected in conditions less than optimal for plants and animals. Treasure Island, for example, has 90 acres in developed open space, used primarily for active recreation, and the balance in residential, institutional and community, retail and office, industrial, parking and roads.1 While the comment is correct in assuming that the proposed development would increase use and population on Treasure Island, the Proposed Project would provide 300 acres of parks and open space, including a created wetland on about 10-15 acres. The proposed open space program includes developing approximately 95 acres of natural open space on Treasure Island and restoring, enhancing and protecting approximately 80 acres of natural open space and habitat areas on Yerba Buena Island. Thus, there would be substantially more natural open space with the Proposed Project than existed with Navy use or than exists now under baseline conditions. The comment is correct in stating that the human-altered landscape of Treasure Island could be greatly improved for wildlife. However, the biological surveys and analyses prepared for the EIR do not support the comment’s contention that the existing conditions on Treasure Island provide better habitat for wildlife than it would after the completion of the Proposed Project. The open space improvements included in the Proposed Project would provide larger areas of continuous open space uninterrupted by buildings and streets compared to existing open spaces on Treasure Island. The landscaping in the Proposed Project would have more California native plants and smaller areas of exotic, non-native plants on Treasure Island than currently exist. These and other features would provide better wildlife habitat than is found under existing baseline conditions. Under CEQA, the lead agency must make determinations as to the value of existing habitat, based on established ecological principles. In this case, based on the knowledge and expertise of trained biologists, the EIR found that the Islands’ ruderal habitats comprising non-native species and a built environment, are of relatively low biological value based on a number of measures: e.g., habitat for sensitive species, species diversity, and community stability over time. A comment notes that no such assessment is made for Yerba Buena Island, and indeed the designation of “low value” on p. IV.M.4 of the EIR does not apply to the remaining natural habitats on Yerba Buena Island, rather, the “low value” designation is specific to Treasure Island. The EIR text describing Yerba Buena Island states that it is “markedly different from Treasure Island” and notes that the description of existing biological resources that follows is for Yerba Buena Island unless otherwise indicated. The text then goes on to describe multiple relatively 1 San Francisco Planning Department, 2005. Transfer and Reuse of Naval Station Treasure Island; Final Environmental Impact Report. State Clearinghouse No. 1996092073. April 21, 2011 2.15.2 Treasure Island / Yerba Buena Island Case No. 2007.0903E Redevelopment Project Final EIR zChapter IX 2. Comments and Responses 15. Biological Resources rich habitats. Appendix H to the EIR is a survey of flora on Yerba Buena Island; the survey illustrates the diversity of plant life on the island. The clearest available metric for supporting the relative determinations is the nesting bird diversity counts for the two areas reported in the San Francisco Breeding Bird Atlas,2 with Treasure Island reporting 22 species and Yerba Buena Island 32. The Atlas observes that more species occur in areas with more natural habitats. The citation referred to in the comment is footnote 15 on EIR p. IV.M.4, which is a reference to the 2005 EIR; the full reference is in footnote 1 on EIR p. IV.M.1. Footnote 15 is clarified to provide a more specific citation (new text is underlined): 15 San Francisco Planning Department, 2005, op.cit., Section 3.8, Biological Resources, and specifically pp. 3-94. 2.15.2 SETTING 2.15.2.1 Setting – General Comments 2. The DEIR cites at p. 1V.M.50, Stenzel, et al., Abundance and Distribution of Shorebirds in the San Francisco Area, however, does the DEIR rely on any more specific studies than this? If so, please give the author and title of such materials. 3. Please provide a description of each and every species of (a) migrating bird, (b) resident bird, for which the project could have potential impact or affect, and for each and every species the nature and scope of such impact or affect. (Judy Irving, Executive Director, Pelican Media) [14.2] 18. Which bird species would be considered to have a known or high potential to nest on any of the project’s proposed high-rise towers? (Judy Irving, Executive Director, Pelican Media) [14.9] The description of the wetlands on YBI is minimal, at best. (See DEIR at IV.M.30). It would be appropriate to at least quantify the amount of wetlands on YBI, rather than referring it to a “small band” of indeterminate size. (Mike Lynes, Conservation Director, Golden Gate Audubon Society) [32.10] The TI-YBI development must be considered within the context of cumulative impacts throughout the Bay Area (or, at a minimum, the Central Bay). In order to best understand these cumulative impacts, readers must be provided with a more complete assessment of the regional setting. As a first step, the Regional Setting section would be improved with a statement regarding the current state of baylands (as defined in the section) and open water habitats in the Bay Area. The Bay Area has lost more than 90% of its historic wetlands and 40% of its open water habitat. (See Bay Conservation and Development Commission, San Francisco Bay Plan (2008), at 15) Similarly, the Bay Area has suffered the loss of considerabl[e] amounts of coastal prairie, coastal 2 San Francisco Breeding Bird Atlas.
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