Proposed Alternative #5 To The Santa Anita Dam Riser Modification and Reservoir Sediment Removal Project Findings of Fact and Statement of Overriding Considerations By Camron Stone December 21, 2010

Yuccas appear to be guarding the sycamores in this wonderful shot by Cam Stone

1.Overview

The Los Angeles County Department of Public Works (DPW), after several years of study, has embarked on a Project to excavate the excess sediment behind the Santa Anita Dam above the cities of Arcadia and Monrovia (“The Project”). The conclusion of the above referenced “Findings of Fact” is that the best alternative for placement of the 500,000 cubic yards of excavated sediment is to erect a conveyor system to transport the sediment to the currently operating Sediment Placement Site (SPS) in Northeast Arcadia. The approved “Project” would place 250,000 yards of the sediment on the existing Lower SPS Area, filling it to its designed capacity at which time it will be sculpted and planted with native vegetation and oaks.

The remaining 250,000 yards would be paced on what is called, in the “Findings of Fact”, the “Middle SPS Area.” The Middle SPS Area is a misnomer. It is, in actuality, a pristine fragment of native oak and sycamore wilderness woodland comprising approximately 26 acres. It is the only surviving untouched example of the flatland woodlands that once thrived within the alluvial fans exiting the San Gabriel Mountain Range. This small wilderness has now been named “The Arcadia Woodlands.”

The approved Project calls for the eradication and removal of 179 Coast Live Oaks and approximately 70 Sycamores and its associated native under-story habitat on13 acres of this pristine and historic woodland. After the eradication of this woodland, 250,000 yards of sediment will be placed on this site extending the Upper SPS southward about 450 feet.

another amazing image courtesy of Cam Stone

In recent weeks, there has been significant public objection to the portion of the Project that will destroy the Arcadia Woodlands. The EIR and “Findings of Fact” had previously slipped through the limelight of public scrutiny precisely because the public has been prohibited from entry into the Arcadia Woodlands for the last 60 years. Every gated entrance to the area has a sign posted saying that trespassing will result in a $1000 fine and/or six months in prison. In short, very few people, other than LA County employees, were aware of the existence of the Arcadia Woodlands. This fact alone allowed the EIR, ”Findings of Fact” and final project approval to slip through with very little, if any, public scrutiny.

On December 4, 2010, after several newspaper reports finally informed the public about the real scope of the sediment removal Project and the resulting destruction of the Woodlands, the first public walk-through of the area in over 60 years took place. This event was well attended by LA County DPW personnel. The public saw and experienced what the EIR and “Findings of Fact” could not possibly describe in thousands of typewritten pages: The Arcadia Woodlands is a fully functioning and pristine example of the native oak woodlands that once stretched across the San Gabriel Valley.

It is very interesting to note here that not a single photograph, taken within the Woodlands, is included in either the EIR or Findings of Fact for this Project. The only photographs included in the reports are from satellites or from very far away. In summary, the public was never fully informed by the County of the true environmental impact of the Project. The true wilderness beauty of this site, named “The Middle SPS” in the reports, has been hidden from public view for over 60 years and it was hidden from the public throughout the EIR process. The public has now been fully informed – they have seen and experienced the Woodlands in person and hundreds of beautiful photographs of this magical place are now circulating on the internet.

The LA County DPW as well as the City of Arcadia now have a serious public relations problem. This report: “Alternative # 5” details an alternative plan for the sediment removal Project that not only has a minimum impact on the existing approved and contracted plan but also eliminates the need to destroy the woodlands and provides a precedent for the future of the DPW’s sediment placement needs. This alternative has been circulated to the public and interested organizations that object to the Project as it now stands and has received their approval and support.

2.Omissions, Inconsistencies and Untruths within the EIR and Statement of Fact

Both the EIR and Statement of Fact have serious flaws that have inevitably led to the approval of the Project as it now stands. These flaws also produced the four “Alternatives” discussed and rejected within the documents. No alternatives, other than “Alternative #1: No Project,” were put forward that would save the Arcadia Woodlands from destruction.

The LA County DPW admits that one of the core objectives of this Project is to open the Middle Sediment Placement Site (SPS) for deliveries of
truckloads of sediment from other locations around the County not related to the Santa Anita Dam Sediment Removal Project according to the Final EIR. It is easy to see why the County rejected any alternative that did not include cutting down the oaks. It was this mission to prepare the Santa Anita SPS as a receptacle for sediment from other sites that steered the County into
rejecting alternatives that preserved the woodlands, not any concern
over cost or the impacts of truck traffic on residents. In effect, this Project is more about staking claim to additional sediment dumping areas for future truck traffic into the site from debris basins outside the area than the actual sediment removal from behind the Santa Anita Dam. The EIR and Statement of Fact make scant mention of the real goal of this Project and are in fact deceptive in regards to this goal.

This section identifies the flaws and omissions within the EIR and Statement of Fact that allowed the DPW to eliminate any alternative that did not raze the Woodlands and make way for a longer future of truck traffic through Arcadia’s neighborhoods and into the Santa Anita SPS:

2.1. Upper SPS Capacity

The EIR has the following statements regarding the Upper SPS:

“The Upper SPS area, located in the northerly end of the SPS, is an already disturbed area, but does not have sufficient capacity for the anticipated sediment to be removed from the reservoir.” (Final EIR, Page ES-2)

“The Upper SPS is a previously disturbed area that is filled to capacity with sediment from earlier cleanouts of the reservoir, debris basin, and other local flood protection facilities.” (Final EIR, Page 3.1-2)

“[The Upper SPS] has a remaining capacity of 250,000 cubic yards, but would not be used for sediment placement for this Project.” – (Final EIR Appendices, Biological Assessment and Biological Evaluation, page 23.)

The EIR has a confusing array of information regarding the actual remaining capacity of the Upper SPS. It seems that this is a closely guarded secret of the LA County DPW. Due to the inability to obtain accurate information, an independent soils engineer, G. Bart Stryker, has been hired by Glen Owens to evaluate the Upper SPS. Mr. Stryker performed all of the soils engineering for both phases of the Whispering Pines Development immediately above the Woodlands, so his familiarity with the area is excellent. His report (attached) states that the Upper SPS has a current capacity of 250,000 cubic yards, which would raise its current elevation by eight feet. This estimated capacity is constrained by the fact that the Upper SPS abuts property owned by the City of Monrovia. If the Upper SPS were allowed a relatively small encroachment on to this property, an additional 500,000 to 1,000,000 cubic yards of sediment capacity would be opened up for future disposal. During the study and EIR phase of this Project, the DPW (to our knowledge) never contacted the City of Monrovia to assess this possibility.

Even without the additional capacity to be had by encroachment, the combined capacity of the Upper SPS and the Lower SPS is over 500,000 cubic yards making the above statements in the EIR misleading at best.

In addition, there is a bowl shaped area of approximately 6 acres located about 100 yards Northeast of the Santa Anita Debris Basin spillway that could also be used for sediment placement in the future. This area is mostly within the city limits of Monrovia so an easement or encroachment would have to be negotiated with the city for its use. This area is also what the DPW calls “undisturbed,” but it is mostly chaparral with just a few Oaks.

2.2. Inadequate Public Notification and Outreach

The California Environmental Quality Act (CEQA) recommends that a lead agency consult directly with any person or organization that might be concerned with the environmental impact of the Project. The language of the law itself recommends these notices to prevent exactly what’s happening to the DPW’s Project now — fierce opposition when it’s discovered by a wider public. As evidenced by the lack of any responses from such an organization in the Final EIR, and the fact that the DWP did not describe any such notifications in the “Findings of Fact,” it is safe to assume that the DPW elected not to alert any potentially interested organizations to the Project. Instead, the Project was concealed from groups with an obvious interest – groups like the California Native Plant Society, the Sierra Club, the Los Angeles and San Gabriel Rivers Watershed Council, the Audubon Society, the San Gabriel Mountains Regional Conservancy, and Heal the Bay.

Not only did the DPW elect to keep news of this Project from any of
those organizations, but it appears they even kept it from neighboring
cities with a real interest in the Project. There are no responses in
the Final EIR from the City of Monrovia which has the Monrovia Hillside
Wilderness Preserve a few yards from the Middle SPS. There are no
responses in the Final EIR from the City of Sierra Madre, through which
the truck traffic would have traveled under some of the Project’s
alternatives.

As mentioned in the overview, The DPW made no effort to inform the public and the local homeowners association of the pristine nature of the Woodlands. The DPW, in all the documentation, calls this area “The Middle SPS” and describes it as “Undisturbed” and “A Significant Biological Area”. It is documented that the DPW, in its first meeting with local homeowners, gave the City of Arcadia only two choices: Its own and current vision of the Project or they would put 100,000 trucks on the streets of Arcadia. Given that very limited choice, the Highland Home Owners Association (HHOA) and the City of Arcadia chose the former alternative.

No offer was made to take the public and/or City and HHOA officials into the Project area. As noted earlier, no photographs of the woodland were included in any of the DPW documents including the EIR. The DPW knew that if the public ever found out about and saw what they wanted to destroy, their plans would be invalidated.

To the casual observer, it might appear as though the DPW was trying
to manipulate the local residents into supporting the preferred
alternative by linking it with the safety of the Santa Anita Dam and the
significant impacts of truck traffic. It might appear that the DPW
then published public notice in an obscure paper to reduce the Project’s
exposure to the public as much as possible, while publishing it with
only 28 days left in the comment period to further reduce the potential
for contentious comments. A casual observer might also assume that the
DPW decided not to notify any civic or environmental organizations of
the Project in an effort to keep opposition to the Project at a minimum.
It might even appear that neighboring cities were kept in the dark
because they might have objected to the Project.

3.Alternative #5: A Way Forward

The purpose of this report is to put forward into the public and DPW discourse a Fifth Alternative that was not included in the EIR or the “Findings of Fact.” Both documents outlined only four alternatives to the current Project including the “No Project” alternative (#1). For the purpose of clarity, these alternatives are summarized below:

Alternative #2: Convey to Wilderness Park, Truck to SPS

This alternative has no effect on the destruction of the Arcadia Woodlands and the Project as it now stands.

Alternative #3: Convey to the Clearing of the North SPS Site, Truck Off Site

This alternative would have saved the Woodlands but is designed to be an “All or nothing choice.” This is one of the two choices given to the HHOA. It can be summarized as “We’ll put 100,000 trucks on the streets of Arcadia.” All of the sediment in this alternative would be trucked to the Manning Pit SPS, which is one of the giant quarry holes located in Irwindale.

Alternative #4: Convey to Wilderness Park, Truck Off Site

This is essentially the same as Alternative #3 except that the truck route would be extended by one half mile

Each of these alternatives in the EIR were designed by the DPW to be untenable to the uniformed general public and to the City of Arcadia. The public and organizations that object to the current Project and the EIR as it now stands believes that there are additional alternatives that, if offered, would be acceptable to most of the public, the DPW and the County as a whole:

Alternative #5: Convey to the Upper and Lower SPS Sites, Truck Remainder of Sediment Off Site via the Sycamore Ave. Gate

This Alternative is structured to specifically address the present and future concerns of the DPW, the HHOA, local environmental organizations and residents living near the Santa Anita SPS. Most importantly, it saves the Arcadia Woodlands from immediate destruction so that the future of this wilderness can be discussed in public forums with input from all sides.

Alternative #5 has also been designed to have minimum impact to the existing Project now underway, the DPW and its Contractor for the Project, Quest Civil Constructors, Inc., of Phoenix, AZ.

The main aspects and explanations of Alternative #5 are listed below:

3.1. Convey 250,000 Cubic Yards of Sediment to the Lower SPS, Close this Site, Sculpt and Replant with Native Vegetation

This provision of Alternative #5 is exactly the same as in the current Project with the proviso that the sculpting and replanting of the Lower SPS with native plants is currently UNFUNDED by the County. This fact, verified by the DPW, leaves open the possibility that the topped off Lower SPS will remain a denuded eyesore for many years into the future.

The DPW has stated that the Project Contractor has already ordered the conveyor system and that the system is currently in transport to the site.. Alternative #5 (A#5) uses the soon to be delivered conveyor system “as is” with only a slight modification: The current system is designed to take sediment all the way from the Santa Anita Dam to the Lower SPS with a small spur conveyor to take sediment to the “Middle SPS” as well. A#5 would move this spur northward to take some of the sediment to the Upper SPS.

It should be noted here that the EIR approves the conveyor system track to follow the access road immediately to the East of the Santa Anita Channel with a possible alternative route that follows the easternmost existing road within the Woodlands. However, on-site evidence within the Woodlands shows survey markers for placement of the conveyor system placed within the “undisturbed” portion of the Woodlands in direct conflict with the approved EIR.

This provision of A#5 has minimal, if any, impact on the currently approved Project and disposes of half of the 500,000 cubic yards as planned.

3.2. Convey 125,000 Cubic Yards of Sediment to the Lower Area within the Upper SPS Site

The Upper SPS Site is currently divided into two areas by an elevation change. The upper part of the site (approximately 5 acres) is on the northern side of the Upper SPS. The lower part is approximately three acres, the top of which is at an elevation approximately 25 feet below the mesa formed by the upper area. This lower part of the Upper SPS, if filled to the existing level of the upper part, will hold approximately 125,000 cubic yards of sediment.

Once filled, this 125,000 cubic yard placement would leave approximately eight flat acres on the top of the Upper SPS for future deliveries of sediment from nearby debris basins. The elevation of the Upper SPS could be raised another eight feet (or 125,000 cubic yards) without encroaching on City of Monrovia property. As stated earlier, a small easement into the Monrovia property could increase the future capacity of the Upper SPS by another 500,000 cubic yards.

3. Truck the Remaining 125,000 Cubic Yards of Sediment Off Site Though the Sycamore Avenue Gate

It has now been established that one of the main (unstated) objectives of the DPW for this Project is to expand future sediment capacity at the Santa Anita SPS. The DPW’s solution for this objective is to destroy a highly unique wilderness resource. This solution, however, only delays the inevitable fact that at sometime in the future (20 years?), the Santa Anita SPS will be filled to capacity and nearby sediments will have to be trucked off site – more than likely to the Irwindale gravel pits.

The DPW is also well aware that local opposition to putting tens of thousands of trucks on neighborhood streets (i.e. Elkins and Santa Anita Avenue) is high and will probably increase in the future.

The DPW therefore needs to set an acceptable precedent for the trucking of sediment out of the Santa Anita SPS facility. The next time the Santa Anita Reservoir fills with sediment, the DPW will have no other option but to truck that sediment off site. Both the EIR and the Statement of Fact make no mention of using the Sycamore Gate at the extreme southern end of the Santa Anita SPS. The use of this gate for the trucking of sediment into and out of the SPS is highly preferable to the currently used Elkins Gate with the proviso that the Sycamore Gate be used only in the summer months when the nearby Foothills Middle School is not in session.

The use of the Sycamore Avenue Gate for the remaining 125,000 cubic yards of sediment has several advantages:

•The distance, on city streets, from the Sycamore Gate to the 210 Freeway onramp at Santa Anita Avenue is slightly less than one half mile with less than half of that distance passing by residences.
•The distance, on city streets, from the Elkins Gate to the 210 Freeway onramp is 2.0 miles. Almost the entire route passes by residences.
•The cost of street cleaning along this shorter trucking route would be significantly reduced.
•The chances of an accident along the shorter route would be significantly reduced.
•Successful implementation of sediment removal using the Sycamore Gate creates a precedent for future movement of sediment through this gate.
•All of the 125,000 cubic yards of sediment to be trucked off site can first be conveyed all the way to the Lower SPS. The Lower SPS can then be used as a staging area for the loading of trucks with the sediment.

There are some possible disadvantages to the use of this trucking route:

•The trucks would have to travel along the access road adjacent to the flood control channel. This road would probably have to be graded and/or additional roadbed might have to be added to handle the truck traffic. Fortunately the equipment and material for this purpose will be readily available during the course of the Project.
•About ¼ mile of the channel access road passes near the backyards of residences on Oakglen Ave. These residences are separated from the access road by fencing or walls.
•Dust mitigation water trucks would have to be used on the access road from the Lower SPS to the Sycamore Gate – a distance of approximately one half mile.

It should also be noted here that during the construction of the 210 Freeway in the early 1970’s, 400,000 cubic yards of fill dirt was quarried from the hills above the Whispering Pines development and trucked out to the construction sites through the Sycamore Avenue Gate.

4.Alternative #5 Summary

This Alternative to the Santa Anita Dam Riser Modification and Sediment Removal Project is presented to the LA County Department of Public Works in the hope that it will be seriously evaluated in light of the strong and growing public opposition to the Project as it now stands. The opposition to the current Project stems primarily from the current plan to destroy the pristine native oak and sycamore woodlands located in what the DPW calls the “Middle SPS” to make way for future sediment disposal.

The salient features of Alternative #5 are as follows:

•Saves the Arcadia Woodlands from destruction eliminating most, if not all, of the public opposition to the current Project plan. The high risk of possible future litigation in the courts would also be eliminated.

•Leaves the current plan’s erection of a conveyor system all the way to the Lower SPS in place with no impact.

•Preserves the current plan to place 250,000 cubic yards of sediment on the Lower SPS bringing the site to its maximum capacity. Sculpting and planting with native vegetation (currently unfunded) will continue as planned.

•Places 125,000 cubic yards of sediment on the Upper SPS immediately adjacent to the “Middle SPS” Woodlands, bringing this three acre area up to the same elevation as the rest of the Upper SPS. The spur off the main conveyor trunk currently planned to bring sediment to the Middle SPS would instead be moved 20-100 yards to the north to convey the sediment to the south end of the Upper SPS.

•The remaining 125,000 cubic yards of sediment would be trucked off site to the Manning Pit SPS in Irwindale through the Sycamore Avenue Gate. This will provide the DPW with a precedent for acceptable future trucking of sediment out of the Santa Anita SPS.

•The Upper SPS would be left with 125,000 CY of capacity – enough to handle anticipated needs for the next 2 – 5 years. This timeframe should be enough for the DPW to negotiate with the City of Monrovia and come to agreement allowing the county to encroach on City owned property. This could potentially increase the capacity of the Upper SPS by 500,000 to 1,000,000 cubic yards.

Alternative #5 offers the DPW a way forward and a way out of its current public relations problem with minimal impact to both cost and schedule. We urge the County of Los Angeles, The Department of Public works, the City of Arcadia and the City of Monrovia to seriously consider this proposed alternative and work together to save a precious natural treasure from being decimated. Future generations of LA County residents will remember and respect your decision to alter the Project to preserve The Arcadia Woodlands for the enjoyment of the people, trees, plants, animals and birds that use this area, both now and into the future.

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