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<br />The Bowery Mixed-Use Project CEQA Findings of Fact <br /> <br />City of Santa Ana 24 <br />May 2020 <br />Plans, Program and Policies <br />PPP WQ-1: NPDES/SWPPP. As listed previously. <br />PPP WQ-2: WQMP. As listed previously. <br />Impact Finding: The Project would not substantially alter the existing drainage pattern of the site <br />or area, including through the alteration of the course of a stream or river or through the addition <br />of impervious surfaces, in a manner which would substantially increase the rate or amount of surface <br />runoff in a manner which would result in flooding on- or off-site (Draft EIR at p. 5.8-15). <br /> <br />Facts in Support of Findings: <br />Construction <br />As described previously, implementation of the Project requires a SWPPP (included as PPP WQ-1) <br />that would address site specific drainage issues related to construction of the Project and include <br />BMPs to eliminate the potential of flooding or alteration of a drainage pattern during construction <br />activities. This includes regular monitoring and visual inspections during construction activities. <br />Compliance with the Construction General Permit and a SWPPP prepared by a QSD and <br />implemented by a QSP (per PPP WQ-1) as verified by the City through the construction permitting <br />process would prevent construction-related impacts related to potential alteration of a drainage <br />pattern or flooding on or off-site from development activities. Therefore, impacts would be less <br />than significant. <br /> <br />Operation <br />The Project would maintain the existing drainage pattern by collecting runoff in roof drains, curbs, <br />and area drains and conveying it to one of four Modular Wetland System units for treatment. <br />Treated runoff would be conveyed to the existing 84-inch drain located within Red Hill Avenue. <br /> <br />Although the Project related runoff conditions (flow rates and durations) would increase from <br />predevelopment conditions (shown in Draft EIR Table 5.8-1), the Project would manage the <br />increased flow with Modular Wetland System units that have been designed to accommodate the <br />increased volume pursuant to the MS4 permit and DAMP requirements. The units would retain, filter, <br />and slowly discharge runoff into the existing off-site drain. As part of the permitting approval <br />process, the proposed drainage design and engineering plans would be reviewed by the City’s <br />Engineering Division to ensure that the proposed drainage would accommodate the appropriate <br />design flows. Overall, the proposed drainage system and adherence to the existing MS4 permit <br />and DAMP regulations would ensure that Project impacts related to alteration of a drainage pattern <br />or flooding from operational activities would be less than significant. <br /> <br />Plans, Program and Policies <br />PPP WQ-1: NPDES/SWPPP. As listed previously. <br /> <br />PPP WQ-2: WQMP. As listed previously. <br /> <br />Impact Finding: The Project would not substantially alter the existing drainage pattern of the site <br />or area, including through the alteration of the course of a stream or river or through the addition <br />of impervious surfaces, in a manner which would create or contribute runoff water which would <br />exceed the capacity of existing or planned stormwater drainage systems or provide substantial <br />additional sources of polluted runoff (Draft EIR at p. 5.8-16). <br /> <br />3-46