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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 43 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx common plan of development that disturbs 1 acre or more of soil must obtain NPDES permit coverage under the Construction General Permit by filing an NOI and SWPPP with the RWQCB prior to commencement of construction. The NPDES permit requires that there be no net increase in stormwater rates and runoff at a development site. Because the SWPPP provisions are more stringent than those included in the Vineyard Avenue Corridor Specific Plan, they would ensure that development on Site 27 (PUSD-Vineyard) would be consistent with the “Water Quality and Protection Requirements Relating to Construction” included in the Vineyard Avenue Corridor Specific Plan. also be required to comply with the California Green Building Standards Code (CALGreen) which requires the incorporation of BMPs for materials and waste storage, handling, equipment and vehicle maintenance, and fueling to reduce potential discharge of polluted runoff from construction sites. The General Plan includes policies and programs that protect water quality during construction. Water Element Program 11.4 encourages site planning and design techniques to minimize water quality impacts, including minimizing land disturbance, minimizing impervious surfaces, clustering development, preserving open space, and maintaining riparian areas with buffer zones to reduce runoff into waterways. Additionally, Program 11.6 requires the use of BMPs during construction activities and ongoing business operations to prevent contaminants from entering the storm drain system. Program 8.4 of the Water Element requires new development to improve local storm drainage systems and to accept appropriate design-year flows resulting from new development, as determined by the City Engineer. The Municipal Code also contains rules and regulations to protect water quality during construction. Section 9.14.080 (Reduction of pollutants in stormwater) identifies construction-related BMPs to reduce pollutants entering the City storm sewer system. Section 15.36.040 (Permit conditions) discusses the conditions in which a wastewater discharge permit is required. Site plans, design, and BMPs for residential and nonresidential projects consistent with the Housing Element Update, including those that disturb less than 1 acre of soil, would be required to demonstrate proper compliance with applicable water quality regulations as project proponents apply for development permits and applicable NPDES permits. Compliance would be ensured by the City and/or the San Francisco Bay RWQCB. Consistent with Water Element Program 8.4, development proposals, including grading and drainage plans, would be reviewed by the City’s Engineering Department for compliance with City ordinance codes regarding water quality standards. Further, Water Element Program 11.3 requires the use of the CEQA process to evaluate the development effects on stormwater runoff and ensure any potentially significant impacts are mitigated as appropriate. Operation: An increase in impervious surfaces could result in a corresponding increase in urban runoff pollutants and first flush hardscape contaminants, as well as an increase in nutrients and other chemicals from landscaped areas. These constituents could result in water quality impacts to on-site and off-site drainage flows to area waterways. Compliance with NPDES and MS4 permits for future residential development, as well as successful implementation of a site-specific SWPPP features, would reduce the potential for pollution from incidental spills of vehicle oils and other chemicals that can be conveyed by storm and landscape irrigation flows during operation. Additionally, CALGreen requires source controls for outdoor material storage areas, outdoor trash storage/waste handling areas, outdoor loading/unloading dock areas, and building materials areas to