LID adoption

Easing the Adoption of Low Impact Development in the Bay Area
A Report by San Francisco BayKeeper
August 2013

ABSTRACT
! San Francisco Bay Area cities are required to meet stormwater pollution and
management standards set by the National Pollutant Discharge Elimination System
(NPDES) permit requirements. Many pollution prevention programs have been
established by Bay Area cities, but further water quality improvement can be achieved
by adopting Low Impact Development (LID) practices directly into the language of
municipal codes and policies. LID practices are based around the principle that utilizing
on-site natural hydrology is the best way to reduce urban runoff pollution and improve
the water quality of downstream receiving waters. To mimic pre-development hydrology,
LID techniques aim to minimize site disturbance, minimize the amount of impervious
surfaces, and maximize the amount of native vegetation and soil. There are many
barriers to be found in municipal codes that require adjustments and amendments for
proper adoption of LID practices. Most barriers are found in the comprehensive plan
goals and policies, the zoning codes, and the development codes and standards. Case
studies based on the LID practices for municipal codes suggested by the Center for
Watershed Protectionʼs Codes and Ordinances worksheet were conducted on the Bay
Area cities of San Jose, Hayward, San Rafael, San Mateo, and Pleasanton. Analysis of
these case studies found that there is signiﬁcant opportunities to adopt LID practices
into the municipal codes of these Bay Area cities. San Mateo and Pleasanton both have
very limited information available on their public municipal code websites, which
indicates the need to adopt LID techniques into their public city codes and policies so
that developers and inhabitants can do their best to reduce urban runoff pollution. Each
city must amend their municipal codes with policies that aim to minimize impervious
area, conserve native vegetation and soil, cluster built areas and open spaces, minimize
site disturbance, and provide flexibility for the use of pervious material and LID best
management practices (BMPs) such as bioretention swales and rain gardens. With the
adoption of LID practices, Bay Area cities can supplement their stormwater
management efforts and improve the water quality of the San Francisco Bay and the
Pacific Ocean.
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TABLE OF CONTENTS
Page
Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
List of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
General LID Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Barriers to LID Adoption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4
Particular Constraints to LID Adoption in the Bay Area . . . . . . . . . . . . . . . . . . . . . . . . . .7
Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14
Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
Literature Cited . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Appendix A. Center for Watershed Protection: Codes and Ordinances Worksheet . . . 19
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LIST OF FIGURES
Figure Page
1 The Natural Water Cycle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2
2 The Urban Water Cycle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3 Conventional vs. LID Community Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
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INTRODUCTION
! For the last ten to twenty years, Bay Area cities have increasingly encouraged
the adoption of Low Impact Development (LID) as a means of achieving water quality
improvements in urban creeks and San Francisco Bay. Increased interest in LID is
primarily due to regulatory requirements, pursuant to Phase I Municipal Separate
Stormwater Sewer System (MS4) permits, though interest in and adoption of LID has
not been uniform across the region. This is due to a number of reasons, but this paper
will focus on the barriers to LID adoption posed by current application of historic building
codes, rules, and ordinances in Bay Area cities.
! Stormwater management is continuously affected by new development and
redevelopment projects in the Bay Area, and can be improved by proper application of
Low Impact Development (LID) techniques. LID approaches to stormwater management
can minimize impacts from runoff, and protect water quality and stream ecosystems by
mimicking pre-disturbance hydrology (Stockwell 2009). This is achieved by utilizing the
on-site natural features and emphasizing conservation and green site planning (Puget
Sound Partnership 2012). Imitation of pre-development hydrology aims to minimize
impervious surfaces, which have been a necessary but destructive factor of
urbanization that disrupt watershed function (Stockwell 2009). LID has the potential to
reduce stormwater pollution, stream bank erosion, and further ﬂood controls. In addition,
LID can lower construction costs, add aesthetic value, and preserve wildlife habitats by
retaining natural landscaping (EPA 2009).
! Many barriers for adoption of LID in development and redevelopment projects
are found in city ordinances and building codes. This can be overcome by including LID
practices in the language of speciﬁc codes and policies. This report will focus on LID
adoption in the Bay Area, particularly the cities of San Jose, Hayward, San Rafael, San
Mateo, and Pleasanton.
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GENERAL LID PRACTICES
! LID techniques are site-dependent in application but always follow the same
guidelines to achieve the goals of minimizing impervious cover and mimicking natural
hydrology. Utilizing LID will improve the condition of downstream receiving waters,
which are directly affected by the amount of impervious area (EPA 2009). The more
impervious area there is, the less inﬁltration and evapotranspiration can occur, which
increases the amount of stormwater runoff and thus increases the amount of pollutants
that are carried to downstream receiving waters (Stockwell 2009). LID addresses the
issues of urban runoff pollution by emphasizing natural hydrology and by reducing the
adverse effects of built areas and urbanization (EPA 2013).
Figure 1. The Natural Water Cycle (Puget Sound Partnership 2012).
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Figure 2. The Urban Water Cycle (Puget Sound Partnership 2012).
! General LID practices include careful site planning, soil and vegetation
protection, landscaping, substituting impermeable for permeable surfaces, minimizing
site disturbance, and accommodating LID best management practices (BMPs). Careful
assessment of a site before development occurs is necessary to understand the site
hydrology, soils, and vegetation, which will affect how the site is cleared and graded
(Puget Sound Partnership 2012). Cluster development design is important for the
minimization of development impacts and the conservation of natural landscapes (South
Burlington Stormwater Utility 2009). Healthy soil is essential for absorbing and treating
stormwater, and thus needs protection and restoration where possible. Native
vegetation and landscaping provide similar inﬁltration functions as soil while also
supplying wildlife habitat and site aesthetics. In the case that the amount of hard
surfaces cannot be reduced, permeable surfaces are preferable to impermeable
surfaces as they help reduce stormwater runoff. Minimizing site disturbance can apply
to the maximal retention of native vegetation and soils as well as to the minimization of
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building, parking lot, and driveway dimensions, reducing setbacks, and the clustering of
built areas. Best management practices for stormwater systems include filter boxes and
strips, bioretention swales, and rain gardens (Puget Sound Partnership 2012).
Figure 3. Conventional vs. LID Community Design (Puget Sound Partnership 2012).
! There are many benefits to introducing LID practices into development and
redevelopment projects. Improving stormwater infiltration will lead to improved water
quality and will reduce the occurrence of flooding events. Retaining native vegetation
preserves wildlife habitats and reduces soil erosion. Economic costs are lowered by
cutting out the need to install alternate forms of stormwater treatment, and aesthetic
value of communities are improved with the emphasis of natural vegetation and the
minimization of built areas (EPA 2013). As LID practices utilize small-scale treatment
systems and natural vegetation, they are generally low budget and low maintenance
(South Burlington Stormwater Utility 2009).
BARRIERS TO LID ADOPTION
! Californiaʼs State Water Resources Control Board (SWRCB) and nine Regional
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Water Quality Control Boards (RWQCBs) have the responsibility of developing and
enforcing water quality standards in the state. The Porter-Cologne Water Quality Control
Act along with the Federal Clean Water Act require all municipalities that discharge
stormwater into the Pacific Ocean or San Francisco Bay to have a National Pollutant
Discharge Elimination System (NPDES) permit, which sparked the creation of many
pollution prevention programs in Bay Area cities. The state and regional boards require
MS4 stormwater permittees to develop Standard Urban Storm Water Mitigation Plans
(SUSMPs), but the language of these permits and plans does not specifically require
amendments to existing building codes and city ordinances that hinder LID practices
(Gearheart 2007).
! When assessing building codes and city ordinances for where changes are
necessary to integrate LID techniques, the main areas to consider are the
comprehensive plan goals and policies, the zoning codes, and the development codes
and standards (Puget Sound Partnership 2012). The comprehensive plan goals and
policies of a city may be adjusted so that it provides support for LID practices and
flexibility of definitions and requirements so that, for example, bioretention swales could
be installed or a permeable material may be used in place of an impermeable material.
Environmentally friendly policies should also be plainly encouraged. Barriers to LID
found in zoning codes are usually related to requirements for landscaping, open space,
impervious surface standards, dimension standards, and parking. Zoning codes often
contain instructions that encourage the reduction of negative visual impacts and the
improvement of community aesthetics. These codes should be amended to specifically
require native vegetation preservation, as well as provide flexibility for what may count
towards the required amount of landscaping so that BMPs such as bioretention swales
can be included. Tree preservation codes usually require heritage tree preservation, but
an LID practice would emphasize the protection of conifers due to their stormwater
retention abilities during winter. Zoning design codes should be flexible enough to allow
for LID options such as increased landscaping and the use of pervious pavements.
Street and parking standards are set in zoning codes to provide specific ratios and
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dimensions. The LID approach to street and parking standards is to reduce street and
driveways widths, eliminate sidewalk requirements, allow for the use of permeable
pavements, and reduce parking ratios and dimensions. Building codes and open space
requirements should call for cluster development designs to support the reduction of
built areas and the preservation of native vegetation for natural hydrology. Development
codes and standards also present barriers to LID, particularly in the clearing and
grading standards and engineering standards of a city. Clearing and grading should
ensure minimal site disturbance and native vegetation and soil preservation.
Development engineering encompasses the design of streets, open spaces, parking
areas, buildings, and more. These standards can be amended to reduce total
impervious surfaces and providing flexibility in the design of streets, sidewalks, parking
lots, etc. to allow for maximal landscaping and minimal impervious pavement while still
meeting fire and safety code requirements (Puget Sound Partnership 2012).
! As LID techniques follow certain guidelines to reach the goal of improved
stormwater management, city ordinances and building codes must follow specific
guidelines to successfully adopt LID practices. Local policies should be flexible enough
for developers to meet multiple requirements at once while abiding by stormwater
management standards and water quality goals (EPA 2010). Once it is understood
where barriers to LID adoption may exist, a gap analysis can be performed to clearly
identify the codes that must be amended. These gaps should be filled with policies that
emphasize the preservation of native vegetation and soils, the reduction and clustering
of built areas and impervious material, the maximization of landscaping, minimization of
site disturbance, and the flexibility needed to allow for LID options such as permeable
pavements, rain gardens, and bioretention swales to be utilized (Puget Sound
Partnership 2012). Developers may be more likely to utilize LID practices if they are
clearly stated in the city codes and policies, especially if the LID practices coincide with
requirements that the developers must already meet (EPA 2010).
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PARTICULAR CONSTRAINTS TO LID ADOPTION IN THE BAY AREA
! Case studies have been conducted for this report on five different Bay Area cities
(San Jose, Hayward, San Rafael, San Mateo, and Pleasanton) that have not yet been
fully saturated with development, as is the case with San Francisco. The Codes and
Ordinances Worksheet (COW) was used as a guideline to determine the strength of
stormwater management practices in these cities (Appendix A, Center for Watershed
Protection 1998). Some checkpoints of the COW were omitted after analysis of the local
city codes if all of the cities failed to include them and/or if they were deemed irrelevant.
Each case study is essentially a gap analysis performed on the public municipal codes
of the individual cities, following the numerical order of the COW.
1. San Jose
! San Jose has adapted a comprehensive stormwater program to meet the
Municipal Regional Stormwater Permit requirements that promotes smart growth
projects and vegetation and infiltration-based stormwater controls (EPA 2010). There is
still room for improvement in the cityʼs municipal codes, however.
! The city of San Jose provides a very thorough Code of Ordinances on their
public city website. Street widths and lengths are not specified in the zoning codes,
which could provide flexibility for LID techniques or could have the opposite effect and
allow developers to create bigger streets than necessary. The right of way and cul-de-
sac widths both meet the minimum suggested by the COW, which is important for the
reduction of impervious surfaces. There is established design criteria for swales
(minimum 2.5% grade along ditch, 5% grade toward ditch) that can provide stormwater
quality treatment. Construction of curbs and gutters require permits, which may
discourage the construction of additional impervious surfaces but it is not specified what
dimension requirements the permit applicants must meet. The parking ratio minimum
set by the COW is met for shopping centers and single family residences in San Jose,
but not for office buildings. The parking ratios in the municipal code are set as
minimums, which could be amended to be set as maximums to promote LID practices.
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The surface of off-street parking areas is required to provide a “mud-free and dustless
surface,” which does not specify but could imply the use of permeable pavement.
Parking areas with six or more parking spots are required to include “drainage facilities
adequate to dispose of all surface water accumulated within the vehicle parking area
and shall be designed in conformance with current city policy related to post-
construction storm water quality control” (City of San Jose 2010). The minimum
dimensions for a standard parking space set by the COW are met, and while the codes
includes minimum dimensions for compact cars it does not state a minimum required
percentage of parking spaces for compact cars. The parking codes could also be
amended to promote shared parking arrangements, to reduce the parking ratio in areas
near mass transit, and to provide incentives for garage parking lots in place of surface
parking lots. These amendments could support the overall reduction of parking lot areas
and thus reduce the amount of impervious surfaces. The policies on open spaces in
San Jose clearly state allowable and unallowable uses of the open space and specify
“the continued availability of land for the preservation of natural resources” as a main
objective (City of San Jose 2010). Minimum setbacks and lot area sizes are defined for
open spaces, but to better incorporate LID practices there should be policies that
encourage cluster development designs and minimum percentage of natural vegetation
in open spaces. San Jose meets the COW’s minimum requirement for rear setbacks on
a half-acre residential lot (25 feet), but the front and side setbacks should be lowered
and a minimum frontage distance should be included to support LID techniques. There
is no mention in the codes about sidewalk dimension requirements or if they are
mandatory, but the zoning codes do state that the construction of sidewalks require a
pre-approved permit. This could be amended to include alternative options for sidewalks
and minimum sidewalk widths to promote the reduction of impervious surfaces. The city
driveway width requirements exceed the minimums suggested by the COW and thus
should be lowered; the driveway policies could also be amended to clearly state LID
alternatives such as the use of permeable pavement and shared driveways. The rooftop
runoff policies are very LID friendly and are a great example of how city codes can be
flexible enough for developers to meet their design requirements while improving
8

stormwater management. The code requires that “all roof rain leaders and down spouts
shall be disconnected from the storm drain system and shall drain to splash blocks that
flow to onsite landscaped areas,” and includes specific examples for alternative
methods to preventing stormwater from flowing to storm drain systems (City of San
Jose). The clearing and grading codes do not specifically require native vegetation
preservation at residential development sites, but the tree protection policies do state
that it is illegal to remove street trees and heritage trees without permission. Finally, in
support of LID practices, the city requires that all development projects must have a
storm water pollution prevention plan and must include BMPs to “control the discharge
of stormwater pollutants including sediments associated with construction
activities” (City of San Jose 2010).
According to the analysis of San Jose’s codes and policies guided by the COW,
San Jose receives a score of 30 points out of the adjusted total of 67 points. This result
supports the fact that San Jose’s Code of Ordinances has many opportunities to adopt
LID practices and thus improve its stormwater management. Aside from the COW
analysis, San Jose had a very forward-thinking Urban Runoff Management plan that
provides developers with incentives to reduce the amount of impervious surface and
encourages urban green space. One unique and effective policy is the exemption of
new development and redevelopment projects from the Urban Runoff Management
requirements if they are under 10,000 square feet, which encourages developers to
reduce impervious surface and remain under the 10,000 square feet limit (EPA 2010).
2. Hayward
Similar to San Jose, the city of Hayward has adopted a Stormwater Management
and Urban Runoff Control Ordinance to meet the requirements of the EPA and the San
Francisco Regional Water Quality Control Board (Alameda Countywide Clean Water
Program 2013). Aside from this ordinance, the policies in the rest of the municipal code
of Hayward have many areas in need of LID adoption.
The Hayward municipal codes do not include specifications for street widths and
lengths or cul-de-sac widths, and do not meet the COW suggested minimum width for
9

right of way streets. Adding in these details to the zoning codes would support the
reduction of impervious surface. The minimum parking ratios set by the COW are met
for shopping centers and single-family residences, but not for office buildings. To
encourage LID practices, the parking ratio requirements should be set as maximums
instead of minimums. Shared parking is permitted upon approval, and the parking
policies state that the parking ratio is reduced if mass transit is nearby. The parking
space dimension do not meet the COW suggested minimums, and there is no mention
of required compact car spaces or the option of using permeable pavement. Amending
the parking codes to require a certain percentage of landscaping in parking lots and
incentives for parking garages rather that surface parking lots would improve
stormwater management by allowing more stormwater infiltration and less impervious
surfaces. The intended uses of open spaces are defined, and it is clearly stated that a
priority of open space districts is for preservation of wetlands, habitat refuge areas, etc.
Minimum setbacks and lot area sizes are defined for open spaces, but there should be
policies that encourage cluster development designs and minimum percentage of
natural vegetation in open spaces to better incorporate LID practices. Hayward meets
the frontage requirement front and rear setback requirements suggested by the COW,
but is missing a requirement for side sidebacks. The minimum sidewalk width
requirement set by the COW is also met, but the zoning codes are lacking policies on
alternate options for sidewalks and if sidewalks are mandatory on both sides of the
street. Minimum driveway widths and lengths in Hayward do not meet the minimums set
by the COW, and the policies need to be amended to include alternatives such as
shared driveways and using pervious material. There are no policies specific to rooftop
runoff, but Hayward does require that “all development and redevelopment Projects
shall include Stormwater Treatment Measures to reduce water quality impacts of urban
runoff from the entire project site for the life of the project” (City of Hayward 2013). The
clearing and grading codes state that clearing and grading permits “are subject to
preservation and protection of existing and other forms of vegetation,” which fully
supports LID practices. All trees, particularly heritage trees, require an approved permit
if they are to be removed and must be replaced by the permittee. Hayward follows the
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Bay-Friendly Landscaping Guide to encourage water conservation, the use of pervious
surfaces, and LID BMPs such as bioretention swales and rain gardens.
The COW analysis awards Hayward a score of 21 out of 67, which means that
there are significant opportunities for Hayward to improve its stormwater management
by adopting LID practices into its municipal code. Hayward has made strides towards
improved stormwater management with its Stormwater Management and Urban Runoff
Control Ordinance, which requires stormwater treatment measures to be taken during
development and redevelopment projects. The ordinance also calls for the use of BMPs
on development and redevelopment sites “to effectively prohibit the entry of pollutants
into the storm water system” (Alameda Countywide Clean Water Program 2013).
3. San Rafael
San Rafael participates in the Marin County Stormwater Pollution Prevention
Program (MCSTOPPP), which encourages LID practices by requiring BMP quality to
reduce pollution from urban runoff (San Rafael 2011). These efforts could be
supplemented by adopting LID techniques directly into the municipal code.
The minimum pavement width in residential streets of San Rafael is much higher
than the COW recommends for LID practices, but cul-de-sac and right of way minimum
pavement widths do meet the COW minimums. All subdivision action is required to have
an erosion and sediment control plan, which encourages the installation of grass swales
or other retention structures. The parking ratios for shopping centers and residential
homes are in agreement with those set by the COW, but the office space parking ratio is
stated as one space per employee rather than per square area. To follow LID
techniques, the parking ratios should be written as maximum spaces per square
footage. The zoning codes allow parking ratio reductions in the case of shared parking
as long as the total amount of parking is never less than the amount that would be
required for one of the independent uses. Only the parking dimensions in downtown
San Rafael meet the COW-recommended dimensions; these dimensions should be
made uniform for parking lots in the whole city. The code should be amended to make
the required compact parking spaces a minimum percentage rather than a maximum
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percentage. Larger parking lots have specific landscaping requirements such as
providing at least one tree for every four parking spaces and planting areas that are at
least thirty-six square feet, which are great LID practices. The open space codes clearly
state that nature conservation is a priority of the city, and while cluster design is not a
specific requirement, the city does “coordinate the use of its open space lands with
other public and quasi-public lands that are contiguous to or otherwise
interrelated” (Municode 2009). The uses for open space are clearly defined, but there is
no mention of a required minimum percentage of natural vegetation. The addition of
regulations on setbacks and frontages would further support LID techniques. The
sidewalk width in residential areas meets the COW minimum of four feet, but in
commercial or industrial areas it is a minimum of six feet which should be reduced to
four. Sidewalks are required on both sides of public and private streets unless the city
engineer deems it unnecessary or impractical, which does not follow LID practices.
There is no mention of sidewalk grading requirements or alternative options to
sidewalks. The minimum driveway widths should be lowered to meet the COW
recommendations, and encouragement of utilizing shared driveways and pervious
pavement should be included in the policies. Developers are required to “establish
controls on the volume and rate of stormwater runoff from new developments and
redevelopment as may be appropriate to minimize peak flows or total runoff
volume” (Municode 2009). The clearing and grading policies requires all trees near
construction sites to have guards placed around them for protection. Tree removal
requires an approved permit from the city, but fire code does require the removal of
combustable vegetation and any vegetation in the vicinity of chimney outlets and fire
roads. San Rafael requires a Stormwater Pollution Prevention Plan (SWPPP) for all
subdivisions with an area of five acres or greater, as well as for subdivisions smaller
than five acres if located in environmentally sensitive areas. Developers are also
instructed to “implement appropriate BMPs to prevent the discharge of construction
wastes or contaminants from construction materials, tools and equipment, or any other
pollutants, from entering the storm drain system” (Municode 2009).
The assessment of San Rafael’s LID practices in terms of its municipal codes
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produces a score of 28 out of 67 points. As specifically pointed out above, there are
great opportunities for LID adoption in the city codes and policies. With the help of the
MCSTOPPP, San Rafael prioritizes water quality improvement by encouraging public
education and participation as well as the use of BMP measures to reduce urban runoff
pollution (2011). These efforts will be maximized with the amendment of certain city
codes to include LID techniques.
4. San Mateo
The amount of information in the San Mateo Municipal Code provided to the
public is unfortunately very limited, and thus allows for a limited gap analysis. This could
be the first indication that there is a need to adopt LID techniques into the public city
codes and policies so that developers and inhabitants of San Mateo can do their best to
reduce urban runoff pollution. The city does provide ample information on the San
Mateo County Water Pollution Prevention Program (SMCWPPP), which meets the
Municipal Regional Permit (MRP) requirements for stormwater management and water
quality for development and redevelopment sites (SMCWPPP 2013).
The zoning codes require driveways to be a minimum of eight feet long, which
meets the COW recommendation, but do not have any mention of shared driveway
options or encouragement to use permeable pavement. The clearing and grading codes
require developers to obtain a site development permit if there is to be any major
vegetation removal. Drainage structures may be required if they are necessary to
prevent erosion damage. Cuts and fills on construction sites and along public roads may
be require planting to act as erosion control and to “blend into the natural
surroundings” (City of San Mateo 2013). Buildings and open parking areas are required
to provide at least one tree per 400 square feet. Heritage trees and existing trees must
be protected with every reasonable effort, and must be replaced on-site or off-site if they
are removed.
San Mateo earned 12 points out of 67 on the COW-guided assessment of its city
codes and LID practices. This is primarily due to the missing information on parking,
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open spaces, minimum pavement width requirements, setbacks and frontages, and
more. Secondarily, the codes and policies of San Mateo are in dire need of
incorporating LID techniques directly into the language of the municipal code.
5. Pleasanton
Similar to San Mateo, the municipal code for Pleasanton provides very limited
information and so the gap analysis was performed to the best ability with the given
codes and policies. Pleasanton has implemented a Clean Water Program, which aims
to protect the city’s waterways and drainage systems from pollution by encouraging the
use of BMPs (City of Pleasanton 2013a).
The open space policies include details on the allowable and unallowable uses of
open space areas, and require that all usable open space “shall be planted area, or
shall have a dust-free surface, or shall be water surface” (City of Pleasanton 2013b). In
addition, at least ten percent of the usable group open spaces to be landscaped. There
is no mention of encouraging cluster design or prioritizing land conservation in open
space areas. Parking lots are required to have a minimum of five percent of the area be
landscaped. The tree protection policies require a person to have an approved permit if
they are to remove any trees, plants, soil, etc.
As the publicly-available municipal code lacked most of the information needed to
conduct a complete gap analysis, Pleasanton received eight out of 67 points.
Pleasanton needs to provide additional information on zoning codes and policies for
parking, streets and driveways, setbacks and frontages, clearing and grading, rooftop
runoff, and more. These policies should be complete with details for using BMPs of LID
techniques such as reducing the amount of impervious surface and promoting native
vegetation and soil conservation.
DISCUSSION
The gap analyses performed on select Bay Area cities support the fact that there
is significant room for improving stormwater management by adopting LID techniques
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directly into city codes and policies. San Jose, Hayward, San Rafael, San Mateo, and
Pleasanton all have many common areas in their municipal codes that lack support for
LID practices. Across the board, these cities should make the following amendments to
their codes and policies: identifying and minimizing allowable street, right of way, and
cul-de-sac widths; setting parking ratio requirements as maximums rather than
minimums and including a required percentage of compact spaces; encouraging shared
parking and garage parking; reducing parking space and driveway dimensions; clearly
promoting the clustering of open space areas and built areas; identifying and minimizing
requirements for setbacks and frontages; enforcing native vegetation and tree
preservation at construction sites; promoting the use of BMPs such as bioretention
swales and rain gardens in parking lots and other built areas; and clearly encouraging
the use of alternatives to impervious surfaces such as permeable instead of
impermeable pavement and dirt trails in place of sidewalks. Each of these amendments
would contribute to the minimization of impervious surface, the conservation of native
vegetation and soil, the minimization of site disturbance, and the promotion of LID
BMPs (Puget Sound Partnership 2012). San Mateo and Pleasanton should also allow
their entire municipal codes to be available to the public online, so that developers and
inhabitants alike are able to access them and thus maximize the potential for improving
stormwater management. It is important for the municipal codes to be flexible enough
for developers to be able to meet multiple requirements at once while applying as many
LID techniques as possible (EPA 2010). With these suggested amendments to city
codes and policies, cities all around the Bay Area can supplement their stormwater
management efforts and achieve significant water quality improvements.
CONCLUSION
Despite efforts to meet the NPDES permit requirements, there are still many
improvements to stormwater management in the Bay Area to be made. By incorporating
LID practices into certain areas of municipal codes, Bay Area cities can better control
urban runoff pollution and protect the water quality of receiving waters like the San
15

Francisco Bay and the Pacific Ocean (EPA 2009). Case studies of San Jose, Hayward,
San Rafael, San Mateo, and Pleasanton identified specific areas of their municipal
codes that would benefit from the adoption of LID techniques. These LID practices are
focused around the principles of imitating on-site natural hydrology, which is achieved
by retaining native vegetation and soil and minimizing site disturbance and impervious
surfaces (EPA 2013). Adopting LID practices directly into city codes and policies will
give developers and city planners the opportunity to apply LID techniques to
development and redevelopment projects and therefore improve stormwater
management.
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LITERATURE CITED
Alameda Countywide Clean Water Program. “What Hayward Residents and Businesses
Should Know About Stormwater Management and Urban Runoff Control.” 2013.
http://www.hayward-ca.gov/BROCHURES-&-HANDOUTS/
Stormwater_Management_and_Urban_Runoff_Control_Flyer.pdf
Center for Watershed Protection. 1998. Codes and ordinances worksheet. Center for
Watershed Protection, Maryland. http://www.cwp.org/Resource_Library/
Center_Docs/BSD/COWForm.pdf.
City of Hayward. “Municipal Code.” Access Hayward. 2013. http://www.hayward-
ca.gov/CITY-GOVERNMENT/DEPARTMENTS/CITY-CLERK/
City of Pleasanton. “Clean Water Program.” 2013a.
http://www.cityofpleasantonca.gov/services/utility/cleanwater.html
City of Pleasanton. “Pleasanton Municipal Code.” Quality Code Publishing, Seattle, WA.
2013b. http://qcode.us/codes/pleasanton/
City of San Jose. “San Jose, CA Code of Ordinances.” American Legal Publishing
Corporation, 2010. http://sanjose.amlegal.com/nxt/gateway.dll/California/
sanjose_ca/title20zoning*1?f=templates$fn=default.htm
$3.0$vid=amlegal:sanjose_ca
City of San Mateo. “San Mateo City Charter and Municipal Code.” Quality Code
Publishing, Seattle, WA. 2013. http://qcode.us/codes/sanmateo/
Environmental Protection Agency. “Low Impact Development (LID).” 20 June 2013.
http://water.epa.gov/polwaste/green/
Environmental Protection Agency New England. “Managing Stormwater with Low
Impact Development Practices: Addressing Barriers to LID.” Report
EPA 901-F-09-003. April 2009. http://www.epa.gov/region1/npdes/
stormwater/assets/pdfs/AddressingBarrier2LID.pdf
Environmental Protection Agency Office of Wetlands, Oceans and Watersheds. “Green
Infrastructure Case Studies: Municipal Policies for Managing Stormwater with
17

Green Infrastructure.” Report EPA-841-F-10-004. August 2010. http://
water.epa.gov/polwaste/green/upload/gi_case_studies_2010.pdf
Gearheart, Greg. “A Review of Low Impact Development Policies: Removing
Institutional Barriers to Adoption.” LID Policy Analysis. December 2007.
http://extension.ucdavis.edu/unit/center_for_water_and_land_use/pdf/
CA_LID_Policy_Review_Final.pdf
Municode. “San Rafael, California - Code of Ordinances”. Municipal Code Corporation,
Tallahassee, FL. 2009. http://library.municode.com/index.aspx?clientId=16610
Puget Sound Partnership, 2012, “Integrating LID into Local Codes: A Guidebook for
Local Governments”, prepared by AHBL for the Puget Sound Partnership, July
2012. http://www.psp.wa.gov/downloads/LID_Guidebook/
20120731_LIDguidebook.pdf
San Mateo Countywide Water Pollution Prevention Program. 2000 Alameda De Las
Pulgas, Suite 100, San Mateo, CA 94403. 2013. http://www.flowstobay.org/
San Rafael. “Air and Water Quality: Our Natural Resources.” 2011.
http://acm.cityofsanrafael.org/Assets/CDD/16.+Air+and+Water+Quality
+Element.pdf.pdf
South Burlington Stormwater Utility. “Low Impact Development Guidance Manual.” May
2009. http://www.sburlstormwater.com/wp-content/uploads/downloads/
manuals/SB_Low_Impact_Development_Manual.pdf
Stockwell, Abbey. "Analysis of Barriers to Low Impact Development in the North Coast
Redwood Region, California." Environment. December 2009.
http://humboldt-dspace.calstate.edu/xmlui/bitstream/handle/2148/595/
stockwell_thesis_2.12.10_FINAL2.pdf?sequence=1
18

Appendix A. Center for Watershed Protection: Codes and ordinances worksheet.
19

Appendix A. Center for Watershed Protection: Codes and ordinances worksheet
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