Arroyo Seco Foundation October 11, 2000 Ms. Rosa Laveaga Arroyo Seco Park Supervisor Planning and Permitting Department 175 North Garfield Pasadena, California 91109 RE: Arroyo Seco Master Plan Initial Study Dear Ms. Laveaga: The Arroyo Seco Foundation would like to take this opportunity to comment on the Initial Study for the Arroyo Seco Master Environmental Report. We commend the City of Pasadena for undertaking a comprehensive planning process for the Arroyo Seco, but we find the Initial Study and the accompanying project description at best unclear and incomplete. After many years of participating enthusiastically in Arroyo Seco planning efforts, we reluctantly conclude that it is now premature to consider the Initial Study and the ASMEIR since the Master Plans for the Central Arroyo (CAMP) and the Lower Arroyo (LAMP) are not complete, the Rose Bowl Use Plan is missing and the design guidelines are incomplete and lacking in specificity. There is not at this time an Arroyo Seco Master Plan, nor is there a properly defined project or program for the EIR to consider. This lack of completion of the components of the ASMP makes it very difficult to comment in a meaningful way on the Initial Study or on the Master Plan. The project description includes a series of new staff-developed projects that have not previously been considered in the planning process or that were rejected by the community planning process, as well as several elements that were included in planning documents such as the Lower Arroyo Master Plan that are not included in the Initial Study s project description. City staff has described some of these projects included as worse case analysis, but in many cases more environmentally positive alternatives are not included and apparently will not be considered. Since the project description in the Initial Study is a road map for what will be considered in the EIR, we are concerned that the EIR will neglect some of the most important alternatives and impacts. This would be a sad result for a planning process that has been characterized by such broad community participation and support. Here are some of the elements that we feel need to be amplified or included in the plan. An analysis of the Arroyo Seco watershed (stream capacity, flood potential, sediment loading, erosion control, watershed management techniques, etc.) above the project area to evaluate its impact on the project and identify methods that could lessen adverse effects. 436 South Arroyo Boulevard, Pasadena, California 91105 (626) 577-6000
2 Assessment of the City s financial and organizational capability to maintain the new elements called for as well as the existing built, landscaped and natural facilities. An analysis of security and policing needs throughout the Arroyo including costs and personnel. Traffic planning and management programs both for special events and for the increased normal usage that is likely to result from population growth and expanded use of Arroyo sites. An analysis of the appropriateness and impacts of current and anticipated uses. A plan for stormwater retention and treatment as required by the Regional Water Quality Control Board. Water quality is listed as an insignificant impact, but there are serious impacts that should be studied, including the input from storm channels and other discharges, the use of pesticides and fertilizers on turf and landscaped areas that flow directly into the watercourse, and trash and sedimentation in the Arroyo Seco stream. Proper environmental review of unpermitted facilities such as Johnson Field and the VOC treatment plant in Hahamongna should be conducted. Terms such as enhance, restore, improve, naturalized, plant palette should be defined to remove any ambiguity about their significance. Not knowing the definition of these terms makes it difficult to comment on the impact of numerous project elements. The impacts of a new use of the Fanny Morrison buildings should be evaluated as part of this EIR. The project description refers to the Arroyo stream as channelized from Devil s Gate Dam to South Pasadena. This inaccurate assertion neglects two significant unchannelized stream areas that are of great natural value and establish that the stream does not need to be channelized throughout the Arroyo. Maintaining an adequate flow to sustain riparian values in the stream below Devil s Gate Dam is an important priority that the EIR should evaluate. Hahamongna Watershed Park Components Pp.1-8, 1-9, 1-20 Upgrade playfields, creating new playfields This is inconsistent with objectives of restoration and conservation of natural areas and optimizing water conservation. The construction scenario alone is unacceptable damage to natural areas either existing or eligible for restoration. We suggest that the earth movement required to build and improve the play fields constitutes new structures and is therefore prohibited by the Arroyo Seco Ordinance. Pg. 1-8 Pasadena is not currently participating in the nursery in Hahamongna described in this section. The Hahamongna Cooperative Nursery is a joint project of the US Forest Service and the Arroyo Seco Foundation. Pg 1-9 Define environmental play area It may have similar impact as playfields. Pg. 1-10 Define Naturalized landscaping The strict use of native plants would be more appropriate for habitat restoration and a natural open space. Pg. 1-11 Provide a cost benefit analysis and justification the of pump back system and the expansion of the spreading ponds. Pg. 1-11 All landscaping should be native in this area to maximize natural habitat values.
Central Arroyo Components 3 Pg 1-12 Arroyo Wards is misidentified and should be Arroyo Woods. Pg 1-12 Is walking loop around Area H on the pavement or the grass? How wide is it? Pg 1-13. 1-14 We are concerned about the new driveway to be constructed for the Fannie Morrison Center and the use of interior parking in Brookside Park? How wide will this road be? Opening up that path to cars and additional parking in the park interior negatively impacts the restful character of the park. Design guidelines call for materials suited to the Arroyo s natural character. Asphalt was not specified and would be inappropriate. Pg 1-13 Unpermitted area in a public park!! Please detail the City s requirements and plans for permitted uses, including a list of areas and uses that are permitted and those that are unpermitted. What percent of the park is allotted to casual, non-permitted uses by local residents who simply want to enjoy the outdoors or have a picnic in the park? Is the planned expansion of permitted areas part of the objective of increasing revenues? What are the anticipated revenues and the impact on casual local users? The Arroyo Seco Foundation urges the City to let Brookside Park be a park rather than trying to maximize revenues by special uses of the area. Pg 1-13 Multi-purpose turf area: Do the rectangles shown represent turf or non-turf areas? They appear to be very limiting. What are the multi-purposes intended for these fields? During periods of special events how will this area be used? The rectangular spaces are not aesthetically appealing especially at the entrance to the Rose Bowl. Pg 1-13 This plan calls for covering or decking the Arroyo stream. We would rather see the stream used as a design feature. Pg 1-14 Additional paved parking west of N. Arroyo is a further invasion of natural open space. An archeological survey should be conducted in this area due to the previous discover of Native American artifacts here. How will walkers and equestrians be accommodated? What materials would be used for the parking lot? Our understanding is that the design guidelines would preclude asphalt. Pg 1-14 Please define multi-purpose passive park? Pg 1-14, 1-15 New sidewalk on west side of Rosemont How does this relate to the 42 ft. rights of way separating cyclists and pedestrians? Is 42 feet correct for pedestrians and cyclists? How will the rights of way be denoted? Paint? Curbs? Other alternatives, such as limiting or eliminating auto traffic in this area should be studied. Pg 1-14 Special events traffic plan This section does not indicate if turf areas would be used for parking and if so in what order and under what conditions. Pg 1-15, 1-16 VIP parking on overpavement of Arroyo stream. The Arroyo stream is the main natural feature of the Arroyo Seco. It should be celebrated and used as a positive design feature, rather than hidden and disguised. The City should also study environmentally appropriate alternatives to stream flood management, especially watershed management and stream restoration. On page 1-16 and the fold out plan the notes indicate that the Master Plan will install irrigation, top soil and turf above channel slab. Which is it? Parking or turf? If cars are intended to use the VIP parking, what is the proposed access? The golf course will lose land. Where is the land recaptured? What is the cost of decking the channel and the proposed VIP parking area and how will it be paid for? Pg 1-15 New entrance plaza, etc. This element appears attractive. Pg 1-16 New concrete sidewalk This does not meet design guidelines. A more natural material would be appropriate.
Pg 1-16 Planting of barren hillside slopes. The natives must be carefully chosen for erosion control and fire safety, and an ongoing maintenance program should be developed. It is unclear what the expectation is for the amphitheater south of the Aquatic Center. The venue would be appropriate for nature lectures and intimate arts events, such as poetry or dramatic readings. Pg 1-16 Where would the replacement maintenance/storage area building be located? 4 Note: Discussion of the Central Arroyo hardly mentions the golf course at all. The golf course should be naturalized to enhance its habitat values and its unique natural setting. We request a review of the operational practices of the golf course and all other landscaped areas and the development of a plan to utilize the most current and environmentally sound methods of maintenance, limiting pesticides, overwatering and fertilization, and a plan to control runoff both in daily maintenance and during storm conditions. We object to landscaping practices that subject oak trees to destructive watering procedures. Lower Arroyo Components Pg 1-17 The Arroyo bank below La Casita is eroding and collapsing. Stabilization of the bank is necessary before any structural repair of the facilities. City engineers have reviewed the bank failure, and it must addressed in this EIR. There is no nursery plot in conjunction with La Casita. Vandalism and theft would preclude such an activity. Pg 1-18 The Arroyo Seco ordinance calls for no new structures, so building a nature center is not allowed. This option was specifically excluded in the 1996 Lower Arroyo Master Plan. A nature center requires staff which is not addressed in the EIR. The Lower Arroyo Seco is a cultural heritage landmark of the City, and the Cultural Heritage Commission must review any changes made. Pg 1-18 Expansion of the driveway into the Lower Arroyo would be an enormously destructive undertaking and would require invasion of weakened slopes. Pg 1-18 Native plants, not naturalized, must be used in the Lower Arroyo. We object to the use of the work naturalized to describe plant material as it indicates a lack of understanding about the habitat value of native plants. Pg 1-19 Most of these walls are rock or Arroyo boulder walls rather than rubble walls. They were constructed as part of Busch Gardens or during the Depression. Workers sponsored by the Scoville family constructed some of the walls near the Colorado Street Bridge at the time of the 1893 depression. Low Flow Stream Restoration The LAMP identifies a City goal of stream restoration in the Lower Arroyo. This project should be evaluated by this EIR. The wording in the project description indicates that this will be ignored, despite the overwhelming community support for this and repeated City promises. Rose Bowl Operations Components Pg 1-19 What is involved in 13 more events in the Rose Bowl? What are the lighting, noise and other neighborhood impacts? What is the parking and traffic management program for such events? Extensive traffic reduction steps such as high parking fees, offsite parking, extensive busing and carpool use must be considered as part of the mitigation for such a dramatic increase in Arroyo event.
5 Design Guideline Components Pg 1-19 What are the architectural guidelines? Pg 1-19 Maintenance and upgrade are used here as in many other places without clarification. These activities will require oversight. Pg 1-19 The definition calling of appropriate paving materials is positive. Environmental Checklist 2.1 d) Where in the plan is the new source of light addressed? Hahamongna, Central Arroyo, Lower Arroyo? 2.4 a), b) Both of these should be Potentially Significant as there in no real on site mitigation available. 2.8 a) Water quality impacts should be designated as Potentially Significantly impacted as noted above due to the development of new turf and landscaped areas, the expansionof paved area, and the attraction of more automobiles and people to the site causing increased trash, air-borne particulates and hydocarbon pollution flowing into the Arroyo Seco stream. 2.9 b) Potentially Significant Impact the placement of play fields (turf) in a natural river bed conflicts with the stated objectives of conserving natural areas. The Fannie Morrison project, acknowledged in this ISEIR is in violation of the City Charter since it displaces public park uses and was not accompanied by a popular vote. 2.16 e) Potentially Significant Impact increased landscaping, increased pavement will increase the load of water run-off. We would appreciate a written response to each of these comments to the Initial Study for the ASMEIR. Sincerely, Thomas Coston, President Arroyo Seco Foundation