Re: Opposition to Unmanaged Goat Grazing in the Arroyo Seco Due to Ecological Harm and Improper Timing
From: Kristy Brauch
Date: Mon, Jun 8, 2026
To: Koko, vgordo, Office, Araceli, thampton, jjones, cole, gmasuda, jrivas, smadison, jlyon, Matthew, Jose, Melchor
Dear Koko,
Thank you for your response regarding the goat grazing initiative in the Arroyo Seco. While I appreciate your engagement, the oversight parameters detailed suggest that the operational reality on the ground is being misjudged. As a certified California Naturalist, local resident, and lead participatory scientist, I recently conducted active field surveys within this exact sector of the Arroyo Seco to track our region's target special-status species for the California Bumble Bee Atlas and regional Monarch monitoring projects under my authorization as a CA Scientific Collecting Permit holder. Having just evaluated the baseline health of this habitat firsthand, I cannot stand by while an unmonitored project inflicts environmental degradation. Deploying over 600 goats from Capra Environmental Services has induced structural instability and habitat collapse, exposing the City to severe regulatory and physical liabilities.
While launched as a wildfire fuel modification pilot, the project is achieving the opposite result:
Invasive Seed bank: Stripping perennial native vegetation and intense hoof-churning creates loose topsoil. This establishes a highly disturbed seedbed for fast-growing, flammable annual weeds like Black Mustard to outcompete native flora. Mustard is already re-sprouting across many of the cleared locations, demonstrating that this method is actively accelerating weed proliferation rather than suppressing it.
Dead Fuel Load: Heavy tree girdling has left open bark wounds with active sap seepage (Photographic evidence available upon request.) This elevates vulnerability to lethal pathogens like the Invasive Shot Hole Borer, which is already active in the adjacent Eaton Fire burn scar. Any resulting dieback will rapidly increase the canopy fire risk.
Microclimate Shifts: Total shrub clearing removes soil coverage, driving up ground temperatures and the local heat index.
Field Context: I personally assisted university researchers with post-fire field surveys here in the spring of 2025 under the UC Agriculture and Natural Resources burn scar tree surveys led by Dr. Chris Shogren, and can confirm the high vulnerability of this system.
Compounding this topsoil destabilization is the broader climate outlook:
Meteorological Forecasts: Since late 2025, NOAA has predicted a strong, high-precipitation El Niño pattern bringing atmospheric-river storms to Southern California.
Slope Failure: Stripping 100 acres of stabilizing native root systems immediately prior to heavy rain poses severe risks for mudslides, slope failures, and watershed siltation. Running jute matting, mulch, or hydro-seeding cannot shore up slopes that have lost their deep, anchoring native root networks.
Trail Hazards: The physical herd impact has already compromised public thoroughfares. During my recent field survey, I experienced significant soil sloughing that sent baseball-sized rocks tumbling directly onto the public trail in close proximity to where I stood.
The intense ground-tilling activity has systematically decimated the micro-habitats of legally protected special-status insects documented in the City of Pasadena Arroyo Seco Water Reuse Project Draft EIR (Section 3.3, Biological Resources):
Crotch's Bumble Bee (Bombus crotchii): A State Candidate Endangered Species under the California Endangered Species Act (CESA) and federally imperiled. They are obligate underground nesters relying on stable soil, rodent burrows, and alluvial scrub (California Buckwheat, Lupinus, and Salvia species) that has been completely cleared.
Evidence: iNaturalist Observation 213285287. I also hold a CDFW Scientific Collection Permit and documented this species in the adjacent county burn scar during peak nesting season.
Legal Mandate: Projects in their historical range require site-specific focused surveys. Detecting a queen or nest mandates project alterations or an Incidental Take Permit (ITP) from the California Department of Fish and Wildlife (CDFW) to avoid severe legal penalties.
Sonoran Bumble Bee (Bombus sonorus): Globally vulnerable and under review for Federal Endangered Species Act protection. Total removal of foraging biomass eliminates their resource base.
Evidence: Unobscured iNaturalist records anchor active colonies directly within the Brookside Park and adjacent wash perimeter.
Western Monarch Butterfly (Danaus plexippus): A California Species of Special Concern and state-protected insect. The herd cleared vital larval host plants (Milkweed) and nectar sources, undermining regional restoration efforts like the Arroyos & Foothills Conservancy Monarch Recovery Project.
CEQA Triggers: Under the California Environmental Quality Act, destroying a significant stand of native milkweed or a documented breeding ground without a biological assessment flags a "significant adverse impact" on a special-status species.
The sudden removal of insect and caterpillar biomass has severely disrupted local avian breeding success. I have documented and photographed two recent mortalities within the grazing boundary: a juvenile California Scrub-Jay (Aphelocoma californica) and a nestling tentatively identified as a goldfinch (Spinus sp.) (Photographic evidence available upon request.)
The deployment of over 600 goats directly conflicts with state and federal laws protecting nesting birds during the peak Southern California breeding season from February 1 to August 31:
Federal MBTA Breach: The Migratory Bird Treaty Act is a strict liability statute. It makes any unpermitted destruction of native birds, nests, or eggs illegal, regardless of intent.
State Code Violation: California Fish and Game Code Section 3503 strictly prohibits the needless destruction of bird nests or eggs.
Oversight Failure: Standard legal compliance requires a professional nesting bird survey 3 to 7 days before any clearing. Active nests require a mandatory 300-foot buffer zone.
Please provide written clarification on the following immediate operational items:
Wildlife Salvage & Testing: I request that the City immediately deploy a qualified biologist to collect all deceased avian specimens and submit them to the CDFW or USDA to evaluate environmental stress, nutritional deprivation, or disease as the primary cause of death.
Avian Compliance Verification: Was the Migratory Bird Treaty Act and the California Fish and Game Code nesting window factored into this deployment? Please provide the dates, survey transect logs, and names of the biologists who completed the pre-clearing nesting bird surveys before the herd was released.
Erosion Mitigation & Contingency: Please provide the anticipated timeline plan for deploying jute matting or equivalent erosion-control measures, alongside the City's specific contingency plan should initial stabilization measures fail.
Restoration Criteria: What specific mitigation measures were established to protect ground-nesting CESA-candidate species and monarch host plants? Please provide the vetted, regionally appropriate native seed mix list and the comprehensive restoration plan intended to reclaim these stripped alluvial slopes during Phase 2.
To understand how an operation of this scale was permitted without standard regulatory safeguards, please provide formal, written responses to the following:
Personnel and Administrative Responsibility: Who is the specific individual, department, or consultant responsible for deploying this herd without a dedicated ecologist on-site and a comprehensive biological pre-survey?
Consultant Identification and Sign-off: Please provide the names, business entities, and professional credentials of the staff biologists or environmental consultants who evaluated and signed off on the specific boundaries of this grazing zone.
CEQA Compliance Documentation: Under what specific CEQA filing was this project executed? If a Notice of Exemption was filed, please provide the administrative record and legal findings used to justify the exemption despite the documented presence and removal of special-status species and native milkweed without prior surveys.
Prior Knowledge of CESA Status: Was the City or its contracted operators aware of the documented presence of the CESA-candidate Bombus crotchii within this sector prior to deployment? If yes, please provide the specific avoidance and minimization protocols given to handlers to prevent prohibited "take" under the California Fish and Game Code.
Agency Consultation Records: Did the City initiate formal or informal consultation with the CDFW regarding potential impacts to special-status invertebrates, nesting birds, or riparian canopy buffers before clearing began? If so, please provide the dates and outcomes.
To protect the City from severe regulatory complications regarding CESA violations and federal migratory insect protections, and to preserve public safety ahead of the predicted El Niño storms, I highly recommend that the City temporarily pause all phases of this operation and retain an independent ecologist to conduct a formal post-grazing impact survey and map out proper Phase 2 restoration parameters.
Out of civic responsibility and a desire to see this data properly integrated into regional wildlife management, I am making available specific field coordinates, photographic logs, and avian mortality findings with the California Department of Fish and Wildlife (CDFW) for their immediate review.
I look forward to your prompt response to the questions listed above.
Sincerely,
Kristy Brauch
Deeply Concerned Resident of Pasadena
Good afternoon, Ms. Brauch,
The goats have moved on from Arroyo. The goal of the pilot grazing program was to clear the dense, invasive understory that had accumulated over decades. This initial work created the access and visibility needed for our crews and contractors to shift from broad brush clearance to targeted invasive-species management. We can now focus on high-priority woody threats such as Tree of Heaven and Castor Bean, species that require precise mechanical removal and were previously hidden beneath six feet of mustard.
The grazing served as essential site preparation, removing layers of debris and biomass. Phase 2 is an engineering-driven stabilization effort, including potential for jute netting for structural reinforcement, tackifier mulch for surface protection, and native seed / hydroseeding for long-term ecological recovery. Together, these components form a comprehensive strategy to make the Arroyo more stable, more fertile, and more fire-resilient.
These efforts are part of a dynamic, long-term restoration process. Our goal is to break the reactive cycle of cutting invasive mustard year after year. By aggressively seeding native species now, we're shifting to a proactive model, one that outcompetes invasives at the seed level and establishes a self-sustaining native landscape. This approach reduces long-term maintenance costs while lowering wildfire risk and improving ecological health.
I have copied our Superintendent, Jose Mireles, who would be happy to discuss the program and the upcoming phase with you further.
Thank you,
Koko Panossian
Director, Parks, Recreation and Community Services Department
City of Pasadena
Office: 626-744-4386
kpanossian@cityofpasadena.net
www.cityofpasadena.net/parks-and-rec
From: Kristy Brauch
Sent: Friday, May 8, 2026 11:45 AM
To: Panossian, Koko
Subject: Re: Opposition to Unmanaged Goat Grazing in the Arroyo Seco Due to Ecological Harm and Improper Timing
Good morning Koko and Matthew,
I am writing in strong opposition to the current goat grazing operation underway in the Arroyo Seco. While I understand and support the urgent need for thoughtful wildfire mitigation in our region, this project, as implemented, reflects a deeply troubling lack of ecological oversight, seasonal timing awareness, and understanding of the living systems it is impacting.
As an ecological educator and UC ANR Certified California Naturalist, I serve as the UCCE Master Gardener LA Pollinator Team Lead and UC Environmental Stewards Instructor, working in collaboration with researchers, conservation organizations, and community science programs focused on biodiversity, wildfire recovery, pollinator conservation, and habitat restoration. Since April 2025, beginning with Los Angeles County–supported tree surveys in the Altadena burn scar and continuing through my current role leading biodiversity data collection within and adjacent to the Eaton Fire burn scar, I have been documenting post-fire ecological recovery, pollinator activity, habitat shifts, and species resilience in real time. This work has provided firsthand insight into how fragile and interconnected these recovering ecosystems truly are.
The Arroyo is not an empty lot of "fuel." It is a living ecological corridor supporting native plant communities, pollinators, birds, reptiles, mammals, and complex soil systems that have developed over thousands of years. What is occurring now is not precision vegetation management. It is broad-scale disturbance during one of the most ecologically sensitive periods of the year. The adjacent burn scar also depends on these surrounding intact habitats as source populations for ecological recovery, including seed dispersal, insect recolonization, and wildlife movement.
The timing of this grazing operation is unacceptable.
Spring is when native plants are actively flowering, setting seed, and reproducing. It is when caterpillars, native bees, butterflies, and countless other insects are emerging and breeding. Many of our native pollinators, including the majority of California's native bee species, nest directly in the soil. Repeated trampling from a large number of ungulates compacts and disturbs these underground nesting sites, likely destroying developing brood chambers and future generations of pollinators before they ever emerge. This soil disturbance also increases the risk of fall and winter erosional flooding, as vegetation cover is reduced and soils become destabilized.
This damage extends far beyond insects.
When flowering plants are removed before reproduction, future native plant regeneration declines. When caterpillars and pollinators disappear, birds lose critical seasonal food sources needed to raise young. When soil structure is disrupted, erosion increases and invasive species gain a foothold. In wildfire-prone landscapes already destabilized by drought and recent fire impacts, these cascading ecological effects matter enormously.
Ironically, unmanaged or poorly timed grazing can also worsen future fire conditions by destabilizing soils, reducing perennial native cover, and encouraging invasive annual grasses that dry out rapidly and become highly flammable fuels themselves.
This project had the potential to do good if approached with ecological precision, seasonal restrictions, habitat mapping, rotational targeting, and consultation with local ecologists, entomologists, fire scientists, and restoration experts. Instead, goats appear to have been allowed to roam extensively through sensitive habitat areas for days on end with insufficient safeguards, monitoring, or transparency regarding ecological impacts.
The City cannot afford to repeat the same mistakes that have historically treated biodiversity as expendable in the name of simplified vegetation management.
Wildfire resilience and ecological resilience must go hand in hand.
Pasadena has an opportunity and a responsibility to lead as a model of environmental stewardship and conservation. Other cities, counties, and states are watching the decisions being made here. The continuation or failure to halt this project will have long-lasting regional implications for how urban ecological corridors and wildfire mitigation are balanced across California and beyond, with Pasadena either cited as a model of what to avoid, or as a jurisdiction that acted with timely ecological insight and accountability.
I urge the City Council to immediately pause and reassess this grazing operation and implement the following before any continuation:
The Arroyo Seco is one of Pasadena's most important urban ecological corridors. Once these interconnected systems are disrupted, recovery can take years or even decades at significant expense.
We should not be sacrificing long-term biodiversity, pollinator health, and ecosystem stability for the appearance of short-term fire management.
Respectfully,
Kristy Brauch
Pasadena Resident, District 5
Kristy Brauch (she/her)
Cynergetic Learning Lab, Founder | Ecological Educator
UC Environmental Stewards Instructor
Certified Cal Naturalist, UCANR
Master Gardener Pollinator Team Lead, UCCE
Certified Steward, Pollinator Partnership
World Wildlife Fund Ambassador & Climate Policy Activist
Center for Lyme Policy Advocate
monarch@ikristy.com
I respectfully acknowledge the Tongva and Southern Chumash Tribes of Los Angeles County and Region, in whose ancestral homelands we are guests. 'Wiishmey nepuushten'— "Love is my strength"