Public Comment for Item #14

I oppose the proposed goat grazing item. Please deny the item as the City has not completed lawful, evidence-based environmental review.

Environmental

CEQA protects biological resources, soils, hydrology and water quality, wildfire safety, scenic/open-space values, recreation, and cumulative environmental conditions. This project implicates several of those protected areas, yet the staff report contains no CEQA analysis at all.

CEQA requires the City to consider cumulative impacts, not just the immediate footprint of one grazing event. Repeated vegetation disturbance on these hillsides can compound erosion, habitat degradation, invasive weed expansion, and fire-risk problems over time.

Unless the City has already completed a legally adequate CEQA determination that is missing from the public materials, approval of this item would be unlawful. The City cannot approve first and analyze later. The staff report contains no CEQA determination, no exemption finding, no environmental review, and no evidentiary record supporting approval of a physical vegetation-management project on steep hillside open space. Council should deny the item.

Fire

Goat grazing should not be assumed to reduce fire risk where the hillside is mostly evergreen, naturally structured native shrubs with heavy mustard pressure filling the gaps. Grazing will significantly damage living native vegetation that holds slope, shades soil, and helps resist full conversion to annual weeds. If goats strip native shrubs and disturb soil while mustard is already poised to rebound, the project will replace a patchy, higher-moisture native shrub mosaic with more continuous, flashy fine fuels that dry early, ignite easily, and carry fire quickly.

The fire analysis cannot stop at “goats eat vegetation, so fuel is reduced.” The City must evaluate whether grazing actually improves fire safety in this habitat, or whether it damages mature natives, increases disturbance, accelerates mustard rebound, and worsens long-term fire hazard on steep slopes.

A rational fire and habitat strategy would protect the native edges first. Control mustard in the gaps around living native shrubs, prevent the multi-acre cores from expanding, and then work inward over multiple years. Do not open more ground than can be immediately stabilized, mulched, seeded, and maintained. Broad goat grazing reverses that logic by risking damage to the native structure while failing to solve the mustard seedbank.

Water

The Council should not authorize goats on steep hillside habitat above and below homes without first studying slope stability and mudflow risk. The City has notice of historical mudslide impacts, recent red-tag instability, pier-supported homes near the proposed graze area, and a developing El Niño winter. Removing or damaging shrub cover, disturbing soil with hooves, and exposing slopes before a wet season could create exactly the kind of foreseeable risk CEQA is meant to evaluate before approval, not after damage occurs.

Administrative

The agenda materials themselves show why this item is not ready for approval. The project map is sloppily drawn and appears to include private property parcels, which raises basic questions about the project boundary, landowner authority, liability, fencing and access. The staff report boasts a $29,000 price tag, but that number is not a restoration plan, a CEQA analysis, a biological survey, a slope-stability review, a mustard or Tree of Heaven control plan. This is not a simple purchase order. It requires real budget, administration, mapping, monitoring, ecological knowledge, and long-term follow-up.

The City’s own conduct shows the scale of the issue. Fire Chief Gregory Lloyd sought $500,000 from FEMA for vegetation management in our new high fire hazard zones, yet this item proposes to treat complex hillside open space with a low-cost grazing contract and an inadequate staff record or simply fall back to the status quo of minimal yearly clearance that has accumulated the significant problem that we see today. Neither the Fire Department nor Public Works should be expected to improvise ecological restoration on steep native habitat without proper expertise, environmental review, and a defensible implementation plan. Public Works Director Julian Lee and Fire Chief Lloyd may have operational responsibilities, but this project requires specialized habitat, erosion, invasive-plant, and restoration planning that is neither present in the agenda materials nor has ever been evident in past actions.

I have lived adjacent to Lot 117 for twenty years. I have traversed these hillsides, documented species, soils, vegetation patterns, invasive plants, slope conditions, and habitat conditions, and repeatedly offered to assist the City, staff, and Council with analysis and implementation. The refusal to use local site knowledge, while advancing a poorly mapped, poorly analyzed goat grazing proposal, is not responsible governance. At minimum, it reflects a political decision to ignore the people most familiar with the land.

Political

This Council is not considering this proposal in a vacuum. Mayor Rossi and Mayor Pro Tem Ferguson were told on day one of their Council tenures that goat grazing would be a terrible fit for these hillsides. Since then, Pasadena has run a pilot with this same grazing company, Capra Environmental, in the Arroyo Seco, and the result has raised serious public concern. Residents and members of Pasadena’s Environmental Advisory Commission and Recreation and Parks Commission have expressed alarm about the damage and the decision-making process in their city. South Pasadena now has the benefit of that warning. If the City proceeds anyway, it cannot later claim the risks were unforeseeable.

The City should also be concerned about contractor transparency and public accountability. When I asked Paul Abess about the claimed multi-year Pasadena contract, he refused to confirm it, became irate, and directed me to take up this particular inquiry with the Fire Chief. He also responded to questions about the RFP materials by asking, “Is that letter addressed to you?” That is not the posture the City should accept from a contractor being considered for work on public open-space habitat. If this project is truly justified, the contractor, scope, contract history, performance record, and environmental safeguards should withstand public scrutiny before approval.

The proposal appears to include intact habitat behind Monterey Hills Elementary School that has no demonstrated or evident invasive-plant problem. This appears to be a political project, not an evidence-based fire, habitat, or restoration plan.

I demand that I be included in any future site analysis, mapping, invasive-plant strategy, restoration planning, and implementation discussions. The City should not approve a broad goat grazing project over the objection of the resident most familiar with the site, especially when the project map is defective and the CEQA record is absent.

The urgency is real, and that is exactly why the City must act swiftly to do the right thing. The immediate fire problem is the invasive, dry, flashy fuel load. Black mustard is by far the most prevalent and difficult to control of these invasives. Secondarily the spread of Tree of Heaven among the mustard contributes greatly to an invasive live/dead fuel mixture during peak fire season. The intact evergreen native shrubland that helps stabilize and protect the hillside requires only modest, judicious and informed control.

The City must protect neighboring homes, Monterey Hills Elementary, and everyone living in the hills from all foreseeable risks, including fire, erosion, slope failure, habitat damage, and preventable long-term degradation. Please deny this item and return with a targeted invasive-fuel and restoration plan that is lawful, evidence-based, and worthy of the land and the people it is supposed to protect.

This is not a goats or fall back to the status quo moment. The next fiscal year's budget is themed Path to Sustainability and the City is asking for a quarter of a billion dollars of funding for improvements all around town. This is the time to move towards a permanent, sustainable solution to this problem. Let me help and let's get it accomplished.

Respectfully,

Angelo Gladding
Twenty year resident adjacent to Lot 117