Arroyo Seco Water Reuse Project EIR Comment
Christina Monde,
These comments pertain to the San Pascual (South Pasadena / Los Angeles) side of the project.
This project seeks to replace a unique old growth oak/sycamore/palm/toyon/sumac/willow/elderberry riparian forest with an infiltration basin for polluted water when the state requirement has nothing to do with infiltration.
Truly historic aesthetic beauty lies behind a wall of invasives and deadwood. Fire-friendly natives are resprouting and regrowing all throughout the burn area.
It should be acknowledged that this site currently contains a thicket of cattails and I was told that cattails are the only part of the proposed system that will reduce the bacteria levels. This site already contains a thriving bioremediation system serving to reduce the Arroyo's TMDLs.
Trees & Plants
Tree 335 is a perfect specimen oak with perfect spacing and visual prominence and the plans call for it to be used for heavy machinery staging.
Heavy machinery will seriously impact the root systems of all protected trees in the vicinity.
Tree 326 – tree survey says remove – visual plans say otherwise.
There is no tree replacement plan. Where is the tree protection diagram as it pertains to the grading for the infiltration basin?
Cutouts for the infiltration basin remove massive amounts of native foliage across the entire site, disturb the geology and hydrology of the trees that remain and ultimately leave a boring pond in the winter and a barren gravel pit in the summer.
There is no landscape/planting plan. The entirety of our obligation to the state is to bioremediate and I was told by a representative at the EIR meeting in the South Pasadena community room that this is done exclusively by the cattails. There's no acknowledgement of the existing cattails nor an analysis of how many will be replanted and where.
Palms & Bats
The sweeping majority of the palms listed as Mexican Fan Palms (Washingtonia Robusta) are actually California Fan Palms (Washingtonia Filifera). The California Fan Palm is a native species. They keep their skirts, as is on display. Native bats live in their skirts. I witnessed bats flying over the channel. This is perfect bat habitat–palm skirts above a stream. I witnessed few to no night insects, definitely no mosquitos at the site at any point during the day, during dusk or into the late evening. Compare to me experiencing heavy mosquitos in my residential area one mile away at the same time of year (June).
Thanks to the native palms there are native bats and they are controlling the mosquito population and humans are sweating well into the evening immediately across the street seven days a week. Mosquitos carry deadly vectors. The current utility of those palms cannot be overstated.
Shrubs & Adolescent Trees
Not all native shrubs are listed. Any native shrub over 14' in height and with a single trunk greater than 4" DBH is protected according to SPMC Chapter 34. There are massive Laurel Sumacs that cover expansive square footage being completely left off any and all plans.
There are also hollyleaf cherry plants and other adolescent oaks and other natives trickled throughout the diverse ecosystem. There are many young palms to replace the few lost in the fire. Young california palms should be encouraged.
Fire
Fire damage should be accounted for, conservatively. Fire damaged natives should be protected wherever possible.
Water
The site's geology isn't conducive to infiltration as per the soils report. Existing alluvial soils are native soils and ideal for native trees. I've seen at least one geology overlay that showed the entire remainder of the South Pasadena arroyo basin being a good candidate for infiltration. The infiltration should be done literally anywhere else. The best place for it to go is at the end of a long series of remediation sites before infiltrating as clean as possible at the treeless driving range. As it stands right now the infiltration basin doesn't appear to benefit from the jellyfish filter.
Dirty water shouldn't be used for irrigation or infiltration.
How does dry weather flow get to a golf course sprinkler head? It also doesn't appear to touch the jellyfish.
What is the flow of the current system? What is the flow of the proposed system? Include:
"tile tunnel"
parts of the golf course – stream, storage container, filtration
return to the arroyo seco channel
overflow plumbing to the nature park as this project site is a non-trivial component of the overall interconnected system spanning the minimal extent of South Pasadena's channel adjacency
water pipe on the East side of the site just on the South Pasadena side of the city boundary (where does it originate? possibly the grate across the baseball field? where does that originate? natural stream or dry weather runoff?)
series of weep holes on channel side?
Then and only then can you gauge the net TMDL reduction this project will account for.
Is the input clogged? What is the aperture of the exit at the damn to the tile tunnel? How can plumbing be repaired or manipulated in place to restore damn spillover to facilitate the riddance of swampy anaroebic decomposition?
There's already cattails. How much square footage is there currently? How much square footage does the new plan call for?
We need current water tests from all sites involved. How does a ten million dollar project not have a baseline of tests.
Is the golf course currently using the water to irrigate? Documents say no but outfall flow hints otherwise.
Will water be cleaned enough by this system to be used for irrigation?
Describe the different states – dry and wet weather – with diagrams showing water elevations, water management practices at play and protected and proposed replacement trees and plants.
Animals
Animals are present, thriving and reproducing. Besides bats and their important role, I've personally witnessed a Black-crowned Night Heron hunting in the stream, a family of Red-Eared Sliders (turtles) living in the primary outlet, a catfish-esque fish at least a foot in length, a 6" crawfish, fence lizards galore, cottontail rabbits, a coyote, a family of mallards, dragonflies, oak galls (implying wasps), ravens, hawks, kestrels, owls, parrots of all varieties. There is a notably consistent as is diverse selection of parrot species. Many more miscellaneous bird species thriving off the berries of the shrubs in the vast understory set to be removed in its entirety. Birds love poison oak berries.
It looks like there was or possibly still is a large nest in the burnt brazilian pepper tree adjacent to the sycamore near the center of the site. The Heron is a protected species.
Unnatural
The 12' access road is entirely unnecessary and unnatural. It perfectly exemplifies the lack of attention to environmental impact. The straight exterior channel-side path is entirely unnatural and non-immersive, windy, exposed, never to be used by anyone, ever.
My estimate is that the site's ecosystem would be a total loss given the current plans with the final replacement plantings being as poorly designed as the project has been designed thus far.
This site needs to be given the respect that it deserves, cleaned up as it is, tested and put back to work with as minimal an impact as is possible for all living things involved. Tacking on infiltration to fulfill grant criteria is wrong–scope creep at its worst. Manually bucket out polluted soil in sections, fix the flow, plant more cattails and more tightly integrate with the remaining plans for water treatment in the South Pasadena arroyo basin.
Thank you,
Angelo Gladding
South Pasadena resident