Item 18 - Appeal Application Nos. 2023-02 and 2023-03 for Cabrillo Town Center project

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individuals, wastes and dirt from construction and renovation or demolition, fecal droppings from animals, oil and various residues contributed by vehicular traffic, and fallout of air -borne particles. Discretionary projects would require the preparation of a Water Quality Management Plan (WQMP). A WQMP would be specific to the expected pollutants that would be present in the stormwater flow from project sites after completion of construction. The WQMP would incorporate the requirements of DAMP Section 7, including all feasible recommended BMPs. It would include site design, source control, and treatment control BMPs to address the specific pollutants anticipated from the project and project site and would detail the specific operation and maintenance of each BMP. The WQMP would outline a routine maintenance schedule for each BMP, in compliance with the DAMP and local regulations. In addition, as discussed previously, developments within the City would be subject to the provisions of the City's Water Pollution Ordinance. Further, as is required for construction activities, operation of new development or redevelopment projects are required to comply with provisions set forth the City's LIP and the DAMP, including the implementation of appropriate BMPs to control stormwater runoff so as to prevent any deterioration of water quality. Compliance with Mitigation Measure MM-OZ 4.7-1, NPDES permits requirements, the DAMP, and the City's LIP and Municipal Code would reduce the risk of water degradation within the Overlay Zone from the operation of new developments to the maximum extent practicable. Therefore, since violation of waste discharge requirements or water quality standards would be minimized, this impact was determined to be less than significant. Groundwater Recharge/Conflict with Groundwater Management Plan The Certified EIR stated that construction activities would primarily occur as part of infill/redevelopment, with the exception of the potential for development on the limited number of vacant sites in the Overlay Zone. According to the City's General Plan, Santa Ana does not serve as the main spreading basin for groundwater recharge. Depending on the groundwater table at particular project sites within the Overlay Zone, pile driving, dewatering, and other construction activities that would encounter groundwater could potentially occur. While the insertion of support and foundation structures in the groundwater may reduce the storage capacity of groundwater, the displaced volume would not be substantial relative to the volume of the Basin. Likewise, while dewatering would remove groundwater, the volume of water removed would not likely be substantial relative to groundwater pumping for water supply. Also, water used during construction for cleaning, dust control, and other uses would be nominal. Thus, construction activities would not substantially deplete groundwater supplies nor interfere substantially with groundwater recharge. This impact was determined to be less than significant. Future development under the Overlay Zone would lead to increases in water consumption, particularly because residential uses typically use more water than commercial and office uses (which characterize the area). However, because the majority of the Overlay Zone area is developed with existing uses, the potential future development would not substantially reduce areas of ground percolation and recharge because the existing uses would simply be replaced Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 583 10/3/2023