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VIII. Hydrology and Water Quality, continued Discussion; VIII (b): The conversion of older industrial and commercial uses to residential uses could change the amount of impervious surface coverage in the City. 'This could affect the surface area available for groundwater recharge. Impacts would generally be positive, as housing would have less impervious surface coverage than most commercial and industrial uses. Housing in San Leandro does not rely on the local aquifer as a water supply source; thus, there would be no impacts to groundwater associated with increased pumping or consumption. The Midtown Specific Plan EIR concluded that there would be no groundwater impacts from that Plan's adoption. VIII (c): Housing construction could create the potential for erosion and sedimentation if soil is not properly stockpiled and contained. The Midtown Specific Plan and the San Leandro General Plan both contain policies and standards to ensure that Best Management Practices are followed during construction to avoid such impacts. The City implements a number of regulatory programs which prevent construction sediment from reaching local waterways. The Midtown Specific Plan EIR likewise concluded that existing regulatory programs were sufficient to reduce this impact to a less than significant level. VIII(d): Redevelopment of older commercial and industrial sites for housing, as advocated by the Housing Element, could alter drainage patterns and increase surface runoff on some properties. The net change in runoff rates would be minimal because the impervious surface coverage on the City's future housing sites is akeady high. The Element does not propose altering residential development standards in a manner which would cause runoff to increase (for instance, increasing allowable lot coverage or reducing setbacks), and it does not propose changes to local drainage plans. The Midtown Specific Plan EIR likewise determined that this impact would be less than significant, due to planned alterations of the drainage system included in the Specific Plan itself. VIII(e): The Element includes an action program to waive or reduce on-site stormwater detention requirements for infill and transit-oriented housing projects in the Midtown area. It also promotes the development of a centralized stormwater detention pond. The purpose of these actions is to avoid the need to dedicate land on each future housing site for stormwater retention, thereby maximizing the potential number of units that can be built. The City will continue to work with the Regional Water Quality Control Board to explore the feasibility of these measures. Drainage impacts for individual projects will continue to be evaluated on a case-by-case basis. V1II(f): The Housing Element promotes additional housing and population in San Leandro to achieve the City's regional fair share assignment. The additional residents could increase the potential for water pollution through vehicle use, household activities, construction, wastewater disposal, etc. Continued implementation of stormwater pollution prevention measures (such as public education, illicit discharge control, construction BMPs, etc.) should reduce impacts to less than significant levels. VIII(g), (h)and (i): A number of the housing sites are located within a shallow flood plain (Zone AO). The City requires fill to be imported on these sites prior to construction, thereby raising the base elevation and ensuring that the structures themselves are relatively free from flood hazards. The Housing Element also indicates that a number of drainage improvements are underway along Berryessa Creek which will remove several housing sites from the flood plain. The Element proposes no land use map or zoning changes that would increase development potential in flood prone areas. The Midtown Specific Plan EIR conf`umed that no mitigation was required for this impact, as existing flood hazards do not pose a risk to life or property, and enforcement of the Flood Plain Management Ordinance and FEMA guidelines sufficiently reduce future hazard levels. Initial Study* San Leandro Housing Element Update* Page 16 November 12, 2002