Key Components of the ARC Nature-based Alternative:

1. Verify Current Conditions

Current plans for ASWRP have been based on Enhanced Watershed Management Program (EWMP) and Load Reduction Strategy (LRS) plans designed to remedy conditions found in 2010 (Crest Study), fifteen years ago. It has taken far too long to clean up the stream, and there has been considerable progress since then in developing green infrastructure and nature-based approaches that would do so.

San Rafael Creek (AS-41) was selected by Pasadena as a priority outfall for cleaning up contamination in the Arroyo Seco, but that designation should be reviewed before proceeding with a costly and destructive treatment program. The EWMP and LRS programs provide for an adaptive approach to meet Total Maximum Daily Load (TMDL) requirements that could include other sites, pollution prevention, conservation, best management practices, and other tools to reduce the contaminant load throughout the Arroyo Seco area. Other storm drain outfalls are discharging significantly higher levels of bacteria than San Rafael Creek. Changing conditions need to be evaluated to verify the best way to meet the water quality goals for the Arroyo Seco in the era of climate change. Planners should update contaminant sources in the Arroyo Seco and consider other sites and measures to achieve the Arroyo Seco TMDL bacteria goal.

2. Enhance the Nature and Biodiversity of the Arroyo Seco

San Rafael Creek in the southwest corner of Pasadena is more than a storm drain outlet. It is the last relatively natural tributary of the Arroyo Seco. The San Pascual site in Los Angeles an South Pasadena is a small but valuable preserve that fosters abundant birds and wildlife. Instead of employing industrial facilities and artificial wetlands, ASWRP should utilize methods that will enhance and restore the natural character of the Arroyo and the watershed in this important transition zone from the mountains to downtown Los Angeles.

Nature-based solutions are a high priority goal of the LA County Safe Clean Water Program (SCWP) which is providing most of the funding for the ASWRP. SCWP has recently established a task force to ensure that funded projects prioritize nature-based solutions. Steps like source reduction, bioswales and natural wetlands can reduce, if not eliminate, the bacteria and other contaminants in San Rafael Creek. If it is necessary to use mechanical treatment to reduce contaminants, ASWRP should do so in a way that minimizes the impact on habitat and natural stream hydrology. Clean the water; put it back in the stream.

3. Water Quality

Green infrastructure and nature-based methods can produce water quality improvements that meet regulatory standards. A comprehensive program to identify pollutant sources and treat them at the source with on-site retention, bioremediation, public education, and other best management practices can reduce or eliminate pollution in a cost-effective, nature-based way. These measures can also address nonpoint source pollution. The nature-based alternative can meet regulatory goals using green best-management prractices that can enhance natural habitat, wildlife, and hydrology in this vital tributary of the Los Angeles River.

4. Community Engagement

The EIR should promote community involvement and the energetic participation of stakeholder groups, such as Stewards of the Arroyo Seco, the Council of Arroyo Seco Organizations, Save San Pascual Park, and local agencies, including the City of Los Angeles. There needs to be a comprehensive program of community and stakeholder engagement throughout the planning process. It is not sufficient to wait to announce planning results when the draft EIR is issued. Community engagement is another key goal of the Safe Clean Water Program. ASWRP planners should utilize extensive community education and engagement during the EIR preparation.

5. Water Rights

South Pasadena does not have a water right to divert water from the Arroyo Seco, which is a fully appropriated stream. That means there is no more water to export from the stream, and the State Water Resources Control Boards cannot consider new diversion permits. Instead, Pasadena and South Pasadena should work together to provide sufficient water for Arroyo Park in South Pasadena and the Golf Course by reducing turf area, utilizing native-based landscaping, improving irrigation efficiency, and capturing local precipitation and runoff. South Pasadena cannot divert flow for irrigation, so planners should consider alternatives that do not divert water for illegal uses.

6. Barriers to Fish Passage

Current ASWRP plans would create new barriers to fish and wildlife passage at both the San Rafael site and the San Pascual site. There are thousands of native rainbow trout in the upper watershed of the Arroyo Seco that occasionally are released into the Lower Arroyo stream through Devil’s Gate Dam. These trout are genetically the same as the endangered Southern California Steelhead that is listed by both the federal and state government as an endangered species. The ASWRP grey infrastructure facilities would create new barriers for the rainbow trout and for the recovery of the endangered southern steelhead. ASWRP planners must consider alternatives and adopt a plan that does not kill endangered steelhead trout.

7. Preserve Precious Habitat

Rich riparian and coastal sage scrub habitat currently exist in the project area at both the San Rafael Confluence and the San Pascual site. ASWRP should protect the high-quality riparian habitat in the project area rather than bull-dozing it. Lined artificial ponds and manufactured wetlands will not produce genuine riparian habitat. Instead of bulldozing and replanting those sites, the project should remove the invasive species and debris and enhance the high-quality habitat that is already there.

Removing the short concrete lining in San Rafael Creek just above the confluence with the Arroyo Seco would allow the stream flow to create a natural wetland and provide for a wide natural connection to the Arroyo Seco stream. This will help restore natural stream hydrology and promote biodiversity. Let nature do its work.

ASWRF should restore stream hydrology and protect and produce genuine riparian habitat and benefits for wildlife.

8. Hire a Consulant Experienced in Nature-based Restoration

There have been a series of planning programs in the last twenty-five years that have identified the ASWRP sites as excellent candidates for stream restoration.

• Pasadena's Lower Arroyo Seco Master Plan (2003) calls for naturalizing the stream.
• In 2006 North East Trees developed a conceptual plan for the restoration of the ARC area that was included in the state-approved Arroyo Seco Watershed Management Plan.
• The Arroyo Seco Watershed Assessment prepared by CDM-Smith in 2011 contains a detailed list of watershed restoration improvements for the ARC.
• In 2019, an impressive group of scientists and watershed planners from Stillwater Sciences met with Pasadena and South Pasadena city officials to inspect the San Rafael and San Pascual sites and discuss nature-based approaches to restoring the project area. The Stillwater scientists proposed a comprehensive and professional approach to the project that would certainly be award-winning.

Instead of pursuing a nature-based approach, Pasadena Public Works Department five years ago retained engineering-oriented consultants with only limited understanding of nature and biology.

Summary - Restore the Arroyo Seco

Pasadena and South Pasadena need to rethink the ASWRP plan and bring in new consultants experienced in nature-based restoration to develop a plan that will conform to the goals of the Safe Clean Water program and modern stream management in the era of climate change.

 

For more information, please contact: stewards@arroyoseco.org