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CITY OF SAN LEANDRO RE: Exhibit -CONSISTENCY MEMORANDUM FOR THE SLTC MIXED-USE PROJECT (PLN16-oo67) J U LY 27, 2017 Regional Permit Provision C.3.d by utilizing a high flow -rate media filter within the building to treat all roof drainage, a Silva cell unit to treat road runoff, as well as bioretention within the landscaping for all other hardscape areas surrounding the building. The end result is 32,128 SF (23%) of Non -LID Treatment, 10,372 SF (8%) of LID Treatment, and 94,047 SF (69%) of self -treating or exempt area. The project will be subject to hydromodification per Chapter 7 of the Alameda County C.3 Stormwater Technical Guidance, and section C.3.9 of the California Regional Water Quality Control Board (SF Bay Region) Municipal Regional Stormwater NPDES Permit (Order No. R2-2015-0049, NPDES Permit No. CAS6120o8). Construction Water Quality Impacts Construction activities would disturb and expose soils to erosion, increasing the amount of silt and debris entering downstream waterways. In addition, refueling and parking of construction equipment and other vehicles on-site during construction could result in oil, grease, or related pollutant leaks and spills that may discharge into storm drains. Improper handling, storage, or disposal of fuels and materials or improper cleaning of machinery close to on-site drainages could cause water quality degradation. The project would be designed to complywith San Leandro Municipal Code Title 3, Chapter 3-15, Storm Water Management and Discharge Control, which is intended to protect the water quality of water bodies in the city. The ordinance implements the legal requirements of the National Pollutant Discharge Elimination System (NPDES) permit issued to the City of San Leandro bythe San Francisco Bay Regional Water Quality Control Board (Permit No. CA0029831). The ordinance requires the implementation of BMPs during construction, such as site preparation and management, erosion control, runoff control, and sediment retention, which would prevent unwanted material from entering storm drains in the project vicinity. The project would disturb more than one acre of soil at the project site and therefore would also be required to obtain coverage under the state's Construction General Permit and Stormwater Pollution Prevention Plan (SWPPP). The SWPPP includes best management practices to be implemented during the project's construction phase such as site preparation and management, erosion control, runoff control, and sediment retention, which would prevent unwanted material from entering storm drains in the project vicinity. The effectiveness of BMPs has been recognized in the California Stormwater Quality Association's Stormwater Best Management Practice Handbooks. The TOD Strategy EIR found that impacts related to construction water qualityfor General Plan buildout would be less than significant, and the project would be consistent with this finding. As such, no further analysis is needed, and the project would be consistent with the City's TOD Strategy EIR. Operational Water Quality Impacts Project operation could result in direct surface water quality impacts from landscaping activities associated with the use of fertilizers, herbicides, and pesticides, as well as from motor vehicle/truck operation on the project site. The project would create and/or replace approximately 51,993 square feet of impervious surface and would therefore be required to comply with the San Francisco Bay Municipal Regional Stormwater Permit (MRP) (Permit No. CAS612oo8) administered by the San Francisco Bay Regional Water Quality Control Board. Provision C.3 of the MRP requires new and redevelopment projects that create or replace 1o,000 square feet or more of impervious surface to implement certain measures to protect water quality and prevent erosion by minimizing sediment and other pollutants in site runoff and so that post -project runoff will not exceed pre -project rates and durations.