On Thursday, December 16th I attended a meeting (see Monrovia Patch) convened by the LA County Department of Public Works in response to the public outcry about the destruction of the Arcadia Woodland for use as a sediment dump site. The meeting followed the unanimous approval by the LA County Board of Supervisors of a minimum 30 day delay brought up by Supervisor Michael D. Antonovich. Take notice that you and I can have an impact!
The fight, though, has just begun. I implore you to communicate your feelings about this project to your supervisors. This project sets a precedence. If the value of mature habitat is minimized then every available piece of land will be at risk as silt continues to accumulate in the foothill dams. Use of already degraded land such as the pits in Irwindale and other solutions will be deemed as having more negative environmental impacts than dumping the stuff on the few remaining bits of pristine wildland.
I have spent much of the weekend reading the May 2009 Environmental Impact Statement and trying to come up with a concise letter expressing my concerns. The more I read the longer my letter grew. I thought I’d post it here before sending it off to Supervisor Antonovich. Your comments are welcome.
LETTER TO SUPERVISOR MICHAEL ANTONOVICH
Dear Supervisor Antonovich,
Thank you for bringing forward the motion for a moratorium of a minimum of 30 days for the Santa Anita Dam project. I am writing to you now to present my concerns regarding this project that would result in the destruction of approximately 11 acres of oak woodland and alluvial fan sage scrub. I realize that maintenance of the dam is not only required by the state but is also necessary to ensure the safety of down stream residents, and to facilitate ground water infiltration needed for future water supplies. I also realize that if there were simple solutions to the problems of an aging and unsustainable infrastructure then they would have been considered. However, the solution that is to be put into place and the Environmental Impact Statement in support of it are unreasonable and illogical.
It is a poor decision to permanently destroy a functioning habitat as a temporary solution to an ongoing and increasing problem. As we have all been told, the Station Fire is likely to result in a dramatic increase in debris deposited in dams. Destroying the Arcadia Woodland does not address this much bigger issue. Massive amounts of sediment will still need to be removed after the trees are gone. Will our policy makers just look for more habitat to destroy until all is gone and the problem remains bigger than ever?
It should be noted that this small piece of land is quite unusual. It is a woodland that is biologically rich yet easily accessible and walkable. It could be open to the public to provide much needed recreational opportunities for the elderly, physically handicapped individuals, children and others who are unable to enjoy wildlands due to the steepness of most hiking trails.
The Environmental Impact Statement of May 2009 that defends the destruction of this land is flawed in many ways. I’d like to lay out a few of the issues that I find most troubling.
1. There was inadequate notification for the public scoping meeting held in the summer of 2007 as evidenced by the low attendance, “approximately 10 citizens” as noted in the EIR, p. 1.5-1.7. Local environmental organizations including the Pasadena Group of the Sierra Club, the San Gabriel Mountains Chapter of the California Native Plant Society, the International Oak Foundation, among others, did not receive notice of the project or the meeting.
2. Citizens were misled during the original public scoping meeting held in 2007. During the recent public meeting on December 16, 2010 several individuals who attended the earlier meeting stated that they were unaware that sediment from other dams was going to be trucked to the SPS in the project area. They also stated that project was presented as though the choice was dumping sediment in the middle SPS (destruction of oak woodland) or excessive truck traffic through neighborhoods adversely affecting air quality. As one citizen put it, if it means having trucks roll by schools all day long spewing exhaust or destroying the oak woodland, the woodland goes. This trade off – destruction of woodland versus adversely affecting the health of the children of the neighborhood – does not take into consideration the possible use of less polluting methods of transporting silt off site, such as using “greener” vehicles – as exemplified in the Long Beach port area, or conveyance through flood control channels and roads as was done for the building of the 210 Freeway. Nor does this take into account the additional truck traffic resulting from conveyance of silt from other dams to the SPS on this site.
3. Mitigation presented in the EIR is inadequate. Habitat destruction of over 11 acres of primarily coast live oak/sycamore woodland on a topographically level site and riversidean alluvial fan sage scrub is to be remediated with 3 separate mitigation areas:
a. 2 parcels equaling 4.9 acres in adjacent land of steep slopes and canyons of chaparral with some oaks;
b. 6.9 acres in the Big Tujunga mitigation site over 15 miles northwest of the Arcadia site that does not include any oak woodland;
c. Revegetation of the lower SPS, 8 acres of silt deposit.
It is highly debatable that the lower SPS can ever be “remediated” as suggested and it in no way compensates for the loss of such high quality habitat. Being told at the recent public meeting that LA-DPW would maintain the lower SPS for the 7 to 10 years it takes to create a functioning habitat further indicates the lack of understanding of the value of mature habitat and the length of time it takes for it to evolve. The dump site will be better suited for the growth of non-native invasive weeds than anything else regardless of ongoing maintenance efforts.
The exchange of more than 11 acres of valuable habitat for approximately 11 acres of land of which more than half is not local to the affected community, along with another 8 acres consisting of a replanted dump site is highly inequitable.
4. Contrary to the conclusions of the EIR, it was stated that the existing lower and upper SPS could hold nearly all of the sediment from the Santa Anita Dam in a report by Bart Stryker, an engineer hired by Monrovia Planning Commissioner, Glen Owens.
5. The comparison of the environmental impact of permanent habitat loss with that caused by temporary truck traffic was flawed. Although extensive computations were made regarding the air quality impacts from the temporary trucking of the silt off site, no mention was made of the permanent loss of carbon sequestration resulting from removal of century old trees, nor of the increase in runoff from the site after the native flora has been removed.
6. The environmental impacts of the construction and operation of the conveyor belt were not fully and honestly compared with that of removing the silt from the site. The noise and air pollution generated by the construction of an enormous conveyor belt system and the transportation of silt on this belt – Will water trucks be needed to wet down the material to reduce dust levels? – will be significant and may compare quite unfavorably with trucking the silt off-site to the Manning Pit in Irwindale.
7. Regional and local conditions were so altered by the Station Fire that the EIR no longer represents the current environmental status of the area.
In summary, this project should be re-evaluated because:
1. destruction of habitat to provide a quick-fix for a long-term and increasing problem is a bad idea,
2. the woodland in question is rare and valuable both environmentally and as public recreational space,
3. the county did not adequately inform the public of the project,
4. the conclusion that temporary truck traffic would have larger environmental impacts than the permanent loss of habitat is fallacious,
5. the full consequence of implementing the project was not honestly described,
6. mitigation offered for destruction of habitat was inadequate,
7. an independent report states that the silt removal may be accommodated using already impacted SPS,
8. changes in conditions due to the Station Fire require that the project and its environmental impacts be restudied.
The existing sediment placement sites (lower and upper) should be re-evaluated to determine their true capacity. Sediment only from the Santa Anita Dam should be stored in those sites, and other off-site possibilities should be considered for the remaining silt. The county should also investigate sustainable uses for the silt, such as landscapes, construction, and rebuilding beaches. Finally, planners, engineers, environmentalists, and all other stakeholders should work together to find a solution to this significant regional problem.
Horticultural Outreach Consultant
Cc: LA Department of Public Works