Stewards of the Arroyo Seco

WHAT THE EXPERTS SAY about the
ARROYO SECO WATER REUSE PROJECT and the DEIR:

Jenny Newman, Regional Water Quality Control Board

The new diversion of dry-weather and of some of the wet-weather flows at the San Raphael site would result in potentially significant impacts to beneficial uses within San Raphael Creek and in the downstream receiving waters in all but the highest flow conditions, which should be analyzed. The DEIR (Draft Environmental Impact Report) should consider cumulative impacts of projects that would collectively contribute to water quality impacts, including beneficial uses. For example, there are currently several stormwater diversion projects planned along the Arroyo Seco that will decrease the amount of water in the stream (e.g., Arroyo Park Infiltration Gallery). The cumulative impact that these projects will have on beneficial uses in downstream waters should be evaluated. However, the proposed DEIR does not include such comprehensive analysis. The project will not assist in compliance with the TMDL (total Maximum Daily Load) in wet weather. View the Regional Board Letter

Travis Longcore, Los Angeles Audubon, PHD, Conservation Co Chair

The project proposes the permanent removal of 1.23 acres of a Sensitive Natural Community (Coast Live Oak-Western Sycamore Woodland) and proposes the planting of saplings as a design feature offsetting this loss. Saplings do not offset loss of mature woodland on any time frame relevant to the impacts. Mature woodlands provide irreplaceable services such as foraging, roosting, and nesting habitat that cannot be replaced through new plantings. In a public park, there should not be loss of Sensitive Natural Communities at all, but rather avoidance of significant impacts… Capture of 320 acre-feet per year from currently perennial and intermittent flows (including from natural, spring-fed sources) could materially reduce dry-season base flows available to riparian vegetation, invertebrates, and wildlife. Longcore Audubon Comments

Ysabel Jurado, LA City Councilmember District 14

I am writing this letter to express my strong opposition to the Arroyo Seco Water Reuse Project (Project) and to urge that the City of Pasadena vote not to certify the Draft Environmental Impact Report (DEIR). I recognize the importance of promoting greater stormwater capture, regional water supply reliability, and improving water quality; and appreciate the effort undertaken by the City of Pasadena in preparing the DEIR, however I remain deeply concerned that the DEIR does not adequately disclose, analyze, or propose suficient mitigation measures for several significant impacts associated with the proposed project that our community members and local Tribal governments have made clear to our office and the general public. Councilmember Jurado's Letter

Clara Solis, Save San Pascual Park

Despite dozens of requests during scoping that the DEIR address source contamination, the document fails to address the issue. Source contamination can be found throughout the Arroyo Seco by a mere walk through, yet the preparers of this document fail to document it or even discuss it as an alternative. Solis Contamination Comments

Tim Brick, Stewards of the Arroyo Seco

The Arroyo Seco Water Reuse Project, as proposed, is not the right solution. It relies on outdated assumptions, fails to apply the updated Load Reduction Strategy Adaptation framework, does not prioritize pollution source reduction on San Rafael Creek, mischaracterizes engineered infrastructure as nature-based restoration, burdens the San Pascual neighborhood, fails to respect Gabrieleño Kizh sacred lands, and presents an inadequate alternatives analysis. Restore the Arroyo Seco rather than cluttering it with plumbing and a reservoir for a golf course. Stewards of the Arroyo Seco Comments

Barbara Eisenstein, South Pasadena Nature Park

CEQA requires that a cumulative impacts analysis consider the combined effects of past, present, and reasonably foreseeable future projects, not just the Project under review in isolation. In addition to South Pasadena's three other planned Arroyo Seco Parkland sites, the analysis must also account for other current and planned projects within the City of Pasadena that affect flow, water quality, and habitat along the Arroyo Seco and its tributaries, including the Hahamongna Watershed Park sediment management and restoration efforts and any other Pasadena stormwater capture, flood control, or habitat projects in the watershed. Please identify all such projects considered in the cumulative impacts analysis and explain the methodology used to assess their combined effect on downstream flow and ecological conditions. Eisenstein Comments

Margo Griswold PHD, Habitat restoration and Land Management expert

The DEIR does not adequately characterize the existing ecological functions of the Project site, resulting in an underestimation of the project's biological impacts. Without a more complete assessment of habitat function for both the San Rafael and San Pasqual sites, the lack of bat surveys, and the long-term temporal loss associated with mature plant removal, the DEIR does not provide decision makers with sufficient information to evaluate the Project's environmental consequences under CEQA. Griswold Biology Comments

Tony Tucci, Citizens for Los Angeles Wildlife (CLAW)

The project area currently contains a mature, established canopy and functioning habitat that cannot be immediately replaced through new plantings. Native plants are an important component of habitat restoration, but it should not be assumed that newly planted vegetation provides the same ecological value as mature trees, which may offer nesting opportunities, shelter, and foraging resources for wildlife. The Arroyo Seco serves as one of the few remaining riparian corridor systems in the Los Angeles Basin. As such, greater attention should be given to the ecological consequences of converting an established habitat into a newly created one.

Ken Kules, PE and Alexandra Huttinger Ntazinda, MPH, MPhil, PhD Candidate

The DEIR has failed to provide substantial evidence supporting its conclusions regarding existing water-quality conditions, expected project performance, long-term infiltration behavior, potential groundwater impacts, and the effectiveness of the selected project configurations. Water Quality Comments

Victoria Tang, Environmental Program Manager, South Coast Region, STATE OF CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE

The Project does not consider downstream impacts to reasonably foreseeable restoration projects within the LA River watershed and does not consider future water reduction projects in the LA River. The reduction of flows and water availability in the Arroyo Seco and LA River may significantly affect the hydrologic regime within the immediate area and downstream of the Project location. Significant impacts to biological resources could occur, especially during dry years and/or droughts. The Project has the potential to substantially alter the hydrologic flows of the LA River and may impact downstream restoration projects that depend on instream flows. Fish and Wildlife Comments

Adele Slaughter, Chair, Los Angeles Community Forest Advisory Committee (CFAC)

The replacement trees take years to provide comparable ecological functions. The protected, native, and significant, non-native plant species create a functional habitat and support a wide variety of wildlife. The DEIR dismisses this habitat as a "disturbed" area with "no value" due to its mixed composition. It dismisses its connectivity as a wildlife corridor between the San Gabriel Mountains and Debs Park. By minimizing the value of the habitats, the impacts are declared insignificant. Urban heat island effects will result from the removal of mature trees. Impacts on remaining trees from grading, compaction, and irrigation changes. The trees protected in place will lose connectivity to water, other trees, and nutrients due to construction…The DEIR fails to evaluate whether increased diversions could reduce flows, affect downstream ecosystems, alter channel conditions, create unintended hydrologic impacts, and compromise the outdated concrete Arroyo Seco Channel. Community Forestry Comments

G. Mathias Kondolf, PhD, Professor of Environmental Planning, Fluvial Geomorphologist and Professor of Environmental Planning in UC Berkeley's Department of Landscape Architecture

From a scientific perspective, the proposed project is unsound. From a policy perspective, it represents a regrettable step backwards. The proposal can be seen as the result of multiple incremental decisions, prejudice towards heavy-handed engineering approaches, and the strong political pull of providing water to the golf course, which is unrelated to solving the originally cited TMDL regulatory compliance issue. The project as currently proposed illustrates a well-meaning public program gone astray. If implemented as proposed in the DEIR, the result will be a poor use of public funds, and a tragic lost opportunity to realize true ecosystem restoration in one of the few places where that is still possible in the Los Angeles River basin. Professor Kondolf's Comments

Max Freida, Graduate Student, UC Berkeley

The City's own adopted planning documents point in a different direction. Both the 2003 Lower Arroyo Master Plan and the 2006 Arroyo Seco Watershed Management and Restoration Plan call for restoring the natural character of the Lower Arroyo and specifically discuss removal of the concrete lining at the San Rafael Creek confluence, contingent upon reductions in upstream flows. In addition, a 2019 site reconnaissance conducted by Stillwater Sciences for the Cities of Pasadena and South Pasadena concluded that restoring this reach was achievable. Frieda Comments

Jane Tsong

Yael Pardess, Save San Pascual Park

The DEIR has not adequately and realistically addressed how the massive tree removal will impact the area in terms of wildlife loss, worsening air quality, loss of shade, permanent heat island, dust, and light pollution that will last years. Labeling this impact as non significant is unrealistic and irresponsible. No amount of mitigations will replace this habitat. Pardess Save San Pascual Comments

WHAT THE EXPERTS SAY about theARROYO SECO WATER REUSE PROJECT and the DEIR: