Sample Letter

To:

Gail Farber, Director, County of Los Angeles Department of Public Works

Christopher Stone, Assistant Deputy Director, Water Resources Division

Attn: Reservoir Cleanouts Program

P.O. Box 1460

Alhambra, CA 91802-1460

Date: January ____, 2014

Re: Devil's Gate Reservoir Sediment Removal and Management Project DEIR – Los Angeles County Department of Public Works

Dear Ms. Farber:

On behalf of __If appropriate: Organization Name, number of members___, I am submitting comments and questions regarding the Draft Environmental Impact Report (DEIR) for the Devil's Gate Reservoir Sediment Removal and Management Project issued by the Los Angeles County Department of Public Works on October 23, 2013.

I/We find the DEIR inadequate and the proposed project unacceptable. The DEIR does not “adequately and properly” comply with the state environmental regulations by acknowledging and fully outlining the impacts of the proposed project. The impacts of the proposals outlined in the DEIR are devastating and for the most part unable to be mitigated, I/we find all of the alternative proposals to be unacceptable and therefore ask the Department of Public Works to rethink their sediment management program. It needs to be responsible and sustainable, not destructive to one of the most valuable local resources we have. I/We urge to County to find ways to work with natural forces in their management strategy, and to cooperate with the stakeholders to achieve this goal. I/We urge the County to consider at least one bona fide alternative to the proposed method of achieving additional reservoir capacity and the associated thorough analysis before taking any action on the EIR, and look forward to your response to the comments that follow.

Inadequacies of the Draft Environmental Impact Report

  1. Reservoir capacity/Sediment removal: The DEIR provides no scientific rationale for the quantity of sediment to be removed (2.4 to 4 million cubic yards), a quantity which is significantly increased from that originally called for in the Board of Supervisors' authorization of this project study (1.67 million cubic yards).
  2. Flood threat: The DEIR fails to identify and quantify the downstream flood threat as well as steps that could be taken to reduce that threat.
  3. Habitat destruction: The DEIR provides no rationale for permanent destruction of more than 50% of the biologically diverse habitat within the basin, a key piece of wildlife corridor revitalization planned in the US Army Corps Arroyo Seco Study and documented breeding home to avian endangered and sensitive species. The suggested replacement rate of 1:1 is significantly below the standard 3:1 or 5:1 replacement ratios typically required, and the suggestion that mitigation could be completed on site is unrealistic. A complete mitigation plan is required to evaluate the impact of this project.
  4. Air pollution: The DEIR does not address the health effects of long term exposure to air pollution for sensitive populations likely to be affected by the project, notably schoolchildren in the 10 nearby schools and residents in adjoining neighborhoods. The DEIR allows for a reversion to 2007 EPA standards for diesel trucks used in the project, and then states that even these standards may not be met due to availability, a problem the Ports of Los Angeles and Long Beach have successfully demonstrated can be overcome. Significant improvements in diesel emissions have been a priority in the SCAQMD due to the unmentioned link between diesel trucks and lung cancer.
  5. Biological survey: The biological section of the DEIR has serious flaws, relying on discrete site visits rather than data collected and verified over the past decade in numerous studies and monitoring projects. The Pasadena Audubon Society has documentation of breeding on site by endangered species, which should place constraints on this project and add to the impacts listed.
  6. Recreation impacts: The DEIR ignores recreation impacts, simply stating that they will be minimal. There are several children's camps and outdoor programs operating in the project area, whose activities will be severely impacted by the project, including the Tom Sawyer Camp and MACH One.
  7. Alternatives: The DEIR fails to provide genuine alternatives to the project by considering alternate methods of sediment management. FAST (Flow Assisted Sediment Transport) has been successfully used in the past at this location to move 1 million cubic yards of sediment within a single year, and new technology should provide further alternatives to trucked removal.
  8. Scoping comments: The DEIR is not responsive to numerous scoping comments offered by stakeholders. Some alternatives proposed in the scoping period included maintaining a permanent lake within the basin, which would provide habitat benefits superior to those provided in the current alternatives.

Problems with the Project

  1. Significant Increases in Air and Noise Pollution.
  2. Significant Increases in Traffic.
  3. Permanent Loss of Significant and Critical Habitat and Wildlife Corridors.
  4. Absent or Inadequate Mitigation of Habitat Loss.
  5. Permanent Loss of Recreational Facilities

To summarize, there are serious gaps in the current Draft Environmental Impact Report. I strongly urge you to reject the DEIR in its current form and instruct LA County Flood Control District to perform the required further environmental analysis in order to make the management program the best project it can be, and MUST be.

Thank you.

Lee Citizen

Lee Citizen
1234 Main Street
City, CA Zip Code