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

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would be less than significant, and accordingly, would not result in any new or increased significant impacts beyond those already identified in the Certified EIR. Water Quality The Project would implement Mitigation Measure MM-OZ 4.7-1, which requires preparation and implementation of a SWPP that would incorporate BMPs and other City requirements to eliminate polluted runoff until all construction work for the Project is complete. Additional Mitigation Measure MM-OZ 4.7-1 requires the preparation and maintenance of a WQMP in compliance with the adopted NPDES program. The WQMP would incorporate water quality measures for all phases of the Project. Further, the Project would be subject to the provisions of the City's Water Pollution Ordinance and provisions set forth the City's LIP and the DAMP. Thus, the Project would not result in any new or increased significant impacts related to water quality beyond impacts already identified in the Certified EIR. Groundwater Recharge/ Conflict with Groundwater Management Plan The Project Site is currently developed with impervious surfaces and is not a source of groundwater recharge. The Project would not change this. Thus, the Project would not result in any new or increased significant impacts related to water quality beyond impacts already identified in the Certified EIR. Erosion/Siltation The Project would be required to implement Mitigation Measure MM-OZ 4.7-1, which requires preparation of a WQMP in compliance with NPDES regulations, the DAMP, and the City's Municipal Code and would reduce the risk of erosion. 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. Thus, the Project would not result in any new or increased significant impacts related to erosion and siltation beyond impacts already identified in the Certified EIR. Onsite and Offsite Flooding/ Contribution of Runoff As previously discussed, the Project would incorporate Mitigation Measure MM-OZ 4.7-1, which requires the preparation of a WQMP and implementation of appropriate BMPs, which could incorporate stormwater detention facilities and would reduce the volume of runoff generated (and potential for flooding). However, to conservatively confirm no potential impacts, the Project would also incorporate Mitigation Measure MM-OZ 4.7-2, which requires preparation of a Hydrology and Hydraulic Study to ensure the existing storm drain capacity could accommodate the Project and that the Project would not result in on- or off -site flooding. Thus, the Project would not result in any new or increased significant impacts related to on- or off -site flooding beyond impacts already identified in the Certified EIR. Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 587 10/3/2023