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August 7, 2025 <br />Page 5 BKF ENGINEERS <br />project would need to be primarily residential and have a minimum gross density of 40 dwelling units per acre. For <br />a 15 acre site, this would require at least 600 dwelling units; the project is currently projected to have a maximum <br />of 1,300 dwelling units, which would meet this requirement. The project would need to be considered a preserved <br />housing project with deed restriction running at least 55 years, at rent/mortgage rates (including utilities) no greater <br />than 30 percent of the area median household income (AMI) limits adjusted for household size. Additionally, the <br />project would need to demonstrate the technical or economic infeasibility of treating the stormwater with on-site, <br />off-site, or regional LID treatment measures, including demonstrating technical constraints that preclude the use of <br />any onsite landscaped areas for LID treatment. <br /> <br />If the project meets these requirements, it would be eligible for LID treatment reduction credits based on the <br />percentage of dwelling units that are in each Area Median Household Income (AMI) category. If all units are free to <br />tenants and do not charge any rent / mortgage, up to 100% of the stormwater may be treated with non-LID <br />treatment methods. Refer to Appendix E for the Special Projects Worksheet used within Alameda County to <br />determine the LID treatment reduction credits a project may qualify for. <br /> <br />If the project does not meet the criteria for LID treatment reduction or treatment with a proprietary stormwater <br />media filter is not preferred, the project will need to install LID treatment such as bioretention areas. Assuming the <br />14.9 acre site is 85% impervious, the estimated required treatment facility area for the project is approximately <br />22,000 square feet (0.5 acres). <br /> <br />12. Hydromodification Management <br />Changes in the timing and runoff from a site, known as hydromodification, can damage or erode natural creeks and <br />channels. Since 2007, Hydromodification Management (HM) techniques have been required in the Bay Area in areas <br />susceptible to hydromodification. The project site is located in an area susceptible to hydromodification, based on <br />the susceptibility map included in Appendix F. Projects in this area are required to comply with HM requirements if <br />they create and/or replace one acre of more of impervious surface and increase impervious surface over pre-project <br />conditions. <br /> <br />In order to comply with HM requirements, the project would need to implement flow duration stormwater control <br />measures (such as large detention systems) to ensure that post-project stormwater discharge rates and durations <br />match pre-project discharge rates and durations. Analysis using the Bay Area Hydrology Model would also be <br />required. Since the existing site discharges stormwater to two different storm drain systems and multiple outfalls to <br />Hewlett Canal, the analysis would need to show that discharge rates and durations are not increased at any of the <br />existing outfall locations. This may require separate flow duration stormwater control measures for each outfall. <br /> <br />Since the existing project site is mostly impervious, we recommend that the project seek to decrease the total <br />impervious area on the site, so that the project will not be subject to HM requirements. Decreasing the impervious <br />area can be achieved by providing landscaped areas, bioretention areas, and / or green roofs. If needed, the project <br />may also implement pervious pavement to further decrease the impervious area of the site. <br /> <br />DRA <br />F <br />T