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EXPLANATION: <br />a) Adoption of the Housing Element itself will not violate any water quality standards or waste discharge requirements. <br />The Element is a policy document that would not increase the level of housing production beyond what is already <br />permitted by the 2002 San Leandro General Plan and 2007 TOD Strategy. The impacts of that level of housing <br />production on water quality have already been analyzed in the environmental impact reports for those two plans, and <br />mitigation measures have already been prescribed and are in effect. General Plan policies 32.01 through 32.08 all <br />provide program-level guidance to mitigate potential water quality impacts. Implementation of the Housing Element <br />would not exceed waste discharge requirements established by the Regional Water Quality Control Board, and would <br />not violate the NPDES Permit for stormwater discharge. As appropriate, individual development projects will be <br />subject to environmental review and project-specific measures may be required to mitigate water quality impacts. <br />b) The Housing Element would not impact groundwater recharge areas or have an impact on the water table. All of its <br />proposals are consistent with the 2002 General Plan and 2007 TOD Strategy. The impacts of these two plans on <br />groundwater were analyzed in previous EIRs and mitigation measures have already been prescribed in the form of <br />policies and action programs. General Plan Policy 32.10 protects San Leandro's groundwater from the potential <br />adverse effects of urban uses, and will remain in effect for the duration of the Housing Element planning period. <br />c) The updated Housing Element would enable continued development on vacant and underutilized properties, which <br />could in turn lead to greater amounts of stormwater runoff and increased impervious surface area. However, the <br />RHNA assignment (1,630 units) is well within the margin of development that was previously analyzed by TOD <br />Strategy and General Plan EIRs. Each of these EIRs included mitigation measures to reduce potential development <br />impacts on stormwater drainage. The General Plan itself includes policies to minimize siltation and erosion from <br />construction, and recommends the use of best management practices on individual development sites. Depending on <br />site location and project attributes, additional environmental review and compliance with applicable regulations may be <br />required for individual development proposals in the future. <br />d) There would be no alteration of drainage patterns as a result of Housing Element adoption, and no increased risk of <br />flooding. Drainage impacts were analyzed in the EIRs for the General Plan and TOD Strategy and the Housing <br />Element does not propose development beyond the levels analyzed by those documents. The housing sites are <br />generally located on sites where drainage impacts can be fully mitigated by connecting to the City's storm drain <br />system. In addition, the Housing Element supports green roofs, rain gardens, and other forms of low impact <br />development which would retain a greater quantity of stormwater on-site. These policies maybe applied to existing <br />development as well as proposed development, resulting in net environmental benefits. <br />e) See Response "d" above. The Housing Element by itself will not contribute runoff that would exceed the capacity of <br />existing or planned storm drainage systems. Future development may have impacts on runoff, but these impacts have <br />been analyzed in the General Plan EIR and the TOD Strategy EIR. Policies and actions in the General Plan reduce the <br />severity of potential impacts. Future development will be subject to environmental review and may be required to <br />conduct additional analysis and mitigation of runoff impacts. <br />f) There would be no additional impact on water quality beyond those described above. No increases in development <br />above what was anticipated by the General Plan and TOD Strategy would occur as a result of Housing Element <br />adoption. Consistent with the San Leandro General Plan, the Alameda County Clean Water Program, and the City's <br />engineering design standards, all future housing projects will be required to incorporate best management practices <br />(BMPs) to reduce water quality impacts. BMPs are typically prescribed at the time that specific developments are <br />proposed and reflect the characteristics of each site and project. <br />g) Only one of the 86 sites identified in the Housing Element is located in a 100 year flood plain. The site corresponds to <br />the surface parking lots around the Bayfair BART station. According to FEMA's Flood Insurance Rate Maps, <br />portions of this site are in Zone AH which is defined as having water depths of 1 to 3 feet in a 100-year flood. The <br />remainder of the site is in Zone X, which is the 500-year flood plain. The site is designated for public use in the <br />General Plan. Due to its proximity to BART, the Housing Element recommends that it be considered a suitable site <br />for high density housing. Action 53.01-B in the proposed Housing Element recommends that consideration be given <br />to amending the General Plan designation for this site from "Public" to indicate the city's intent to pursue high density <br />mixed use development in the future. Any subsequent General Plan Amendment would be subject to further study <br />and CEQA review, including an evaluation of flooding impacts and mitigation measures. No other flood-related <br />impacts are expected <br />Housing Element Initial Study and Negative Declaration ] 2 February 2010 <br />