Public Comment for Item #19

Council,

You must oppose this item. This plan is reckless and destructive. This is not targeted grazing of invasives. This is broad goat grazing of everything inside of fences with follow up by an unknown and assumed untrained crew with unspecified pruning and removal goals and practices. One must assume that this is tantamount to removals of mature and significant protected species across 40-50% of my community's beloved open space. My estimate is in the hundreds.

This map shows 100 foot defensible space radii and a best representation of the grazing area of lot 117 as specified by the City. The grazing area is rendered as 70' but the inconsistent material provided in the staff report alludes to 100'. What is rendered is the conservative estimate of the grazing acreage for only one of the open spaces.

Environmental Review

My original CEQA complaints were valid. The claim "CEQA does not apply to any actions necessary to prevent or mitigate an emergency" is erroneous. The cited code covers urgent actions to stop imminent active threats–active fire, active flood, etc.

The crux of the City's justification is in using newly enacted exemptions for 200' of defensible space and firebreak clearing that is most certainly not intended for use in such small acreages. Enactment of this exemption follows the fires in Altadena and Pacific Palisades, both of which started in mountainous regions containing thousands upon thousands of acres of fuel, far steeper slopes and complete lack of access. These open spaces are not similar.

The City has not justified extending defensible space beyond the traditional 100'.

Most importantly our tree ordinance must still be followed.

21080.49. This division does not apply to any of the following wildfire risk reduction projects, if the project is in compliance with all other applicable laws, ordinances, and zoning requirements

Our tree ordinance requires an arborist report for all removals and ANSI pruning practices be adhered to.

Goats Destroy Shrubs and Trees

Goats strip bark. This is referred to as girdling. A girdled trunk or branch dies. The sweeping majority of shrubs and trees inside of Pasadena's grazing acreage has had bark stripped. Easily half of the specimens are fully girdled and will die back to the stump.

Invasives

Invasives are not targeted. Everyone I have spoken to points to the cured invasives as the problem. Everyone. Every single person that I have spoken to. This plan bypasses most of the invasives and specifically targets areas not yet infested.

When native plants are removed the adjacent invasives infiltrate the space. This is called "type conversion".

Our fire chief wants to type convert 50% of our open space from native shrubland, coastal sage scrub and walnut/oak woodland to non-native annual grassland.

The City has failed to control the invasives that already exist. The only path forward will be continued reliance upon goats over ever increasing acreages.

Erosion and Sediment in Waterways

The slopes are so very delicate and very much still in tact. One grazing event will do untold damage. Repeated grazing events will break the geological system completely.

These photos depict goat legs sunken completely into the softened and eroded slopes.

This stormwater control implement is installed at the base of lot 117, inside of the grazing area, at the site of a historical mudslide.

Stump Cutting Shrubbery

Stump cutting, often opportunistically referred to as "coppicing", is not an ANSI standard pruning practice.

Wikipedia states "This creates long, straight poles which do not have the bends and forks of naturally grown trees." The practice was used in the 18th century to provide sustainable firewood.

There is a technique called "rejuvenation pruning" whereby a shrub is cut back heavily but this requires specific circumstances, defined objectives and followup treatment by a trained professional.

This is one of the shrubs that Omari Ferguson removed in November. The weakly attached and poorly structured sprouts have lurched straight up creating a bushy ember catcher that is all but guaranteed to ignite completely, a disproportionately tall flame length antagonistic to defensible space concerns on a slope, and a lack of horizontal growth to out-compete weeds. It is also aesthetically displeasing.

Lifting

The practice of lifting shrubs to prevent "ladder fuels" continues to be perpetuated as best practice. I have implored our fire chief and Pasadena's fire chief to justify themselves. They have both outright refused repeatedly! It is an incorrect reading of defensible space literature that is actually counterintuitive to fire safety. Lifted shrubs become a stressed out management nuisance. See a City owned and lifted Toyon on Pasadena Ave. The growth at the base is the stress response growth that has filled back in in an fire unsafe manner that will need to be managed perpetually to keep it in this state of deformity.

The poor practice creates deadwood and decay all throughout as well.

Politics

Nobody wants this. The one resident who voiced support for the goats referred to all of the "brown" (cured invasives) she could see from her vantage. The plan is repeatedly deliberately misleading. The consequences will be immediately permanent and unrecoverable across half of the acreage. This is not a "pilot" and we cannot wait to see what comes of it.

Pasadena is already saying that they are looking at alternative methods of control moving forward. What an embarrassing moment for them.

And remember just because the action is exempted it does not mean that the City is absolved of all consequences of their actions. One mudslide will render the cost effectiveness of this action moot.

Stop this insanity!

Have Parkwood remove the cured invasives inside of the 100' defensible space zones while avoiding the native plants and invasive trees. Have a qualified herbicide applicator treat the invasive trees–Tree of Heaven, Castor Tree, Tobacco Tree–in late Summer when it is recommended. Use defensible space actions today to start the restoration process today. This is what a path to sustainability looks like.

Send this to NREC as the chair has already requested review. Ask that staff receive my input in a formal setting.

Please do the right thing and keep South Pasadena Beautiful while you keep my community safe.

Thank you,
Angelo Gladding
1856 Hanscom Drive