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

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with new uses. The City does not serve as the main spreading basin for groundwater recharge. Thus, any development on the limited undeveloped land within the Overlay Zone, groundwater recharge would not substantially affect groundwater recharge. Therefore, because the majority of the Overlay Zone is already developed and because the Overlay Zone area is not used for groundwater recharge, the operation of future development under the Overlay Zone would not interfere substantially with groundwater recharge. This impact was determined to be less than significant. Erosion/Siltation The Certified EIR stated that construction activities under the Overlay Zone would involve stockpiling, grading, excavation, paving, and other earth -disturbing activities, which could result in the alteration of existing drainage patterns. These types of activities would constitute a temporary alteration of drainage patterns. However, future development would be required to comply with the DAMP and the City's corresponding LIP, which serves as the primary policy and implementation document for compliance with the NPDES Stormwater permits. Compliance with NPDES regulations and the City's Municipal Code would reduce the risk of short-term erosion resulting from drainage alteration during construction to a less -than -significant impact. The majority of the Overlay Zone is developed with office and commercial uses. The introduction of new uses throughout the Overlay Zone is not anticipated to result in substantial changes to the existing drainage patterns because existing drainage facilities would continue to be used and the amount of drainage would remain similar to present levels. However, it is possible that future development in the Overlay Zone could result in minor alterations to drainage, such as changes in ground surface permeability via paving, or changes in topography via grading and excavation. The above discusses applicable regulations that would limit pollutant discharges from future development in the Overlay Zone. In addition, all development in the Overlay Zone would be subject to the provisions of the City's LIP and Orange County DAMP. These regulations include the implementation of appropriate BMPs including a range of methods that could minimize off - site erosion, including but not limited to hydrodynamic devices, swales/biofilters, basins, and various filters. In addition, as required by Mitigation Measure MM-OZ 4.7-1, future developments would be required to prepare a storm drain plan and WQMP. Implementation of these plans would reduce the volume of sediment -laden runoff discharging from sites within the Overlay Zone. Consequently, because future projects in the Overlay Zone are not anticipated to substantially alter drainage patterns in comparison to existing conditions in the area, and because adherence to existing requirements would reduce erosion and siltation during operation, this impact was determined to be less than significant. Onsite and Offsite Flooding/Contribution of Runoff The Certified EIR stated that future development in the Overlay Zone would generally result in infill development or redevelopment. As such, most of the future projects would not result in new Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 584 10/3/2023