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The Bowery Mixed-Use Project CEQA Findings of Fact City of Santa Ana 25 May 2020 Facts in Support of Findings: Construction Implementation of the Project requires a SWPPP (included as PPP WQ-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to increases in run-off and pollution from development activities. Therefore, impacts would be less than significant. Operation The Project would manage increased stormwater flow with Modular Wetland System units that have been designed to accommodate the increased volume pursuant to the MS4 permit and DAMP requirements. The units would retain, filter, treat, and slowly discharge runoff into the existing off- site drain. Additionally, the City permitting process would ensure that the drainage system accommodate new flows and that specifications adhere to the existing MS4 permit and DAMP regulations, which would ensure that pollutants are removed prior to discharge. Overall, with compliance to the existing regulations as verified by the City’s permitting process, Project impacts related to the capacity of the drainage system and polluted runoff would be less than significant. Plans, Program and Policies PPP WQ-1: NPDES/SWPPP. As listed previously. PPP WQ-2: WQMP. As listed previously. Impact Finding: The Project would substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows (Draft EIR at p. 5.8- 17). Facts in Support of Findings: The Project site does not include, and is not adjacent to, a stream or river. Implementation of the Project would not alter the course of a stream or river. In addition, according to the FEMA FIRM for the Project area (06059C0279J), the Project site is located within “Zone X,” which is an area determined to be outside of the 0.2 percent annual chance flood. Therefore, there is a low potential for onsite flooding to occur. The Project would maintain the existing drainage pattern; and drainage would be accommodated by onsite by Modular Wetland System units that have been sized to accommodate the DAMP required design storm. Therefore, the Project would not result in impeding or redirecting flood flows by the addition of the impervious surfaces. As detailed previously, the City’s permitting process would ensure that the drainage system specifications adhere to the existing MS4 permit and DAMP regulations, and compliance with existing regulations would ensure that impacts would be less than significant. Plans, Program and Policies PPP WQ-1: NPDES/SWPPP. As listed previously. PPP WQ-2: WQMP. As listed previously. 3-47