Appendix K - public notice comments RTC.pdf

Ten Year Operations and Maintenance Plan for the Glendale Narrows Reach of the Los Angeles River

Programmatic Environmental Assessment

Appendix K

Public Notice, Comments Received, and Response to Comments

PUBLIC NOTICE

U.S. ARMY CORPS OF ENGINEERS – LOS ANGELES DISTRICT

U.S. ARMY CORPS OF ENGINEERS BUILDING STRONG®

LOS ANGELES DISTRICT

Los Angeles River at Glendale Narrows 10-Year Operations and Maintenance Plan Programmatic Environmental Assessment

The U.S. Army Corps of Engineers (Corps) proposes to implement a 10-year operations and maintenance plan for the Glendale Narrows segment of the Los Angeles River (See attached map). The plan would remove accumulated excess sediment and manage vegetation to partially restore diminished flood conveyance capacity and reduce potential for breakout flows at bridge crossings during large storm events. Sediment removal would also facilitate inspection and repair of engineered structures in the river. There are approximately 337,719 cubic yards of excess sediment accumulated in sandbars throughout the Glendale Narrows. Most vegetation within this reach is found atop sandbars.

Alternatives considered for the proposed action include the No Action Alternative, Fifty Percent Sediment Removal Alternative, and a Full Sediment Removal Alternative.

Under the No Action Alternative, the 10-Year Operations and Maintenance Plan would not be implemented. Instead, site-specific sediment removal and vegetation management projects would continue to be implemented in critical areas as needs arise and to levels commensurate with available funding and resources.

Fifty Percent Sediment Removal Alternative is the preferred alternative. Under this alternative, up to half of the total accumulated sediment, approximately 168,860 cubic yards, would be removed over a period of 10 years as resources and funding allow. As shown in the attached cross section, sandbars located atop engineered structures would be the focus of removal. Trees on top of engineered structures and within the adjacent 15-foot vegetation free zone (VFZ) would be removed. Vegetation immediately upstream and downstream of bridge crossings would also be removed to reduce potential for breakout flows. Elsewhere in the channel, non-native vegetation would be removed. Native vegetation would be preserved to the extent practicable. Under this alternative, diminished flood conveyance capacity would be partially restored. Furthermore, vegetation management would enhance habitat and facilitate implementation of ecosystem measures associated with the forthcoming Los Angeles River Ecosystem Restoration Project.

Under the Full Sediment Removal Alternative, up to 337,719 cubic yards of excess sediment would be removed over a period of 10 years as resources and funding allow. As shown in the attached cross section, all sandbars and vegetation found atop shoaled areas would be removed. The design flood conveyance capacity of the river through Glendale Narrows would be fully restored.

Under both Fifty Percent and Full Sediment Removal Alternatives, sediment removal operations would start at the downstream terminus of Glendale Narrows, near Taylor Yard, and proceed incrementally towards the upstream terminus near Betty Davis Park over a period of 10 years.

Temporary staging areas for equipment and haul routes are shown in the attached map. All staging areas would be located on or near the left embankment (facing downstream). Use of the

PUBLIC NOTICE

U.S. ARMY CORPS OF ENGINEERS – LOS ANGELES DISTRICT

pedestrian/bicycle trail on the right embankment would remain unaffected. Some staging areas are sited within Corps’ rights-of-ways atop the levee, access roads, and access ramps. Other staging areas are located at small areas adjacent to Betty Davis Park and the Los Feliz Golf Course. The remaining staging areas are sited in the Bowtie Parcel and Taylor Yard. Haul routes have been selected to avoid or minimize hauling operations through residential streets. In cases where haul routes occur on residential streets, the duration of hauling will range between 3 to 9 days.

Marginal habitat for the federally endangered Least Bell's Vireo (Vireo bellii pusillus) is present in Glendale Narrows. Consultation pursuant to Section 7 of the Endangered Species Act with the U.S. Fish and Wildlife Service is underway.

Pursuant to the National Environmental Policy Act (NEPA), the Corps is preparing an Environmental Assessment (EA) to evaluate alternatives and potential environmental impacts for the proposed action. If the assessment identifies significant impacts that cannot be mitigated to a level that is less than significant, an Environmental Impact Statement would be prepared. Otherwise, the EA will be finalized and the NEPA process will conclude with a Finding of No Significant Impact.

Sediment removal activities would result in temporary discharges of dredged material within the Los Angeles River, a potential waters of the U.S. The activity is subject to Section 404 of the Clean Water Act. Although the Corps does not process and issue permits for its own activities, the Corps authorizes its own discharges of dredged or fill material by applying all applicable substantive legal requirements including demonstrating compliance with the Section 404(b)(1) guidelines.

The Corps is soliciting comments from the public, Federal, state, and local agencies, and other interested parties in order to consider and evaluate the impacts of the proposed action. Comments will be accepted from June 8, 2023 to July 8, 2023. Comments can be submitted electronically to:

kenneth.wong@usace.army.mil

Alternatively, comments can be mailed to:

U.S. Army Corps of Engineers Riverside Levees Repair Project Attn: Kenneth Wong, CESPL-PD-RQ 915 Wilshire Blvd., Los Angeles, CA 90017.

Possible Staging Area

Access Ramp

Haul Route

Glendale Narrows

Project Vicinity Map toe VFZ toeVFZNo Action Alternative (Existing Typical Cross Section)

Channel wide removal of accumulated sediment and trees, both native and non‐native toe VFZ toeVFZ

Full Sediment Removal Alternative (Conceptual Cross Section)

1. Not to scale 2. VFZ (Vegetation Free Zone)

Fifty Percent Sediment Removal Alternative (Conceptual Cross Section) toe VFZ toeVFZ

Clear sediment & vegetation from toe & 15’ vegetation free zone (VFZ)

Clear sediment & vegetation from toe & 15’ vegetation free zone (VFZ)

Remove non‐native trees, trim native trees 10 feet from bottom, & remove foreign objects and debris

1. Not to scale 2. VFZ (Vegetation Free Zone)

1. Not to scale 2. VFZ (Vegetation Free Zone)

July 13, 2023

RE: Los Angeles River at Glendale Narrows 10-Year Operations and Maintenance Plan Programmatic Environmental Assessment

Attn: Kenneth Wong, CESPL-PD-RQ

Many Atwater Village properties adjacent to the LA River have been in a Special Flood Hazard Area (SFHA). Many more could be included in a future SFHA, we understand the importance of sediment removal in the LA River. As you progress with your assessment, we need more details on the preferred alternative of 50% removal, including a timeline—any of the proposed 10-year plans will impact our 4 miles of LA River frontage and community members.

Currently, the LA River channel is in the process of delamination. This can clearly be seen south (or downstream) of the Los Feliz Bridge. We want to bring up this site to ensure that this repair is addressed during this assessment or sooner. Starting at Taylor Yard, as the plan indicates, may impact the safety of Atwater Village Residents if repairs are not addressed in order of need and magnitude.

Please keep in mind the following;

Closing the East Bank: Community members use the East Bank for recreation: walking, jogging, dog walking, and equestrian activities.

City’s North Atwater Village East Bank Riverway grant project and the Colorado Bridge undercrossing project. Over the last few years, The AVNC has sought to connect the East Bank of the LA River. These two projects are important to community members, providing connectivity, access, and an alternative route to the LA River Bike Path.

Flood Risk: High flood-risk areas should be identified and addressed first.

Los Feliz Bridge: Channel delamination issue - identify repairs and complete repairs first or concurrent with sentiment and vegetation removal at the south end, Taylor Yard.

[CONTINUED ON NEXT PAGE]

Storm drains: Bring existing storm drains in line with needed flood protection levels. Identify repairs and solutions for folks living in storm drains.

The legend on the map we received is unclear and we are hoping you could provide an updated version. We look forward to working with you as the plan and implementation progress.

Sincerely, Brett Kushner Atwater Village Neighborhood Council Chair

TO: U.S. Army Corps of Engineers FROM: Steven Appleton ATTN: Kenneth Wong, CESPL-PD-RQ RE: Los Angeles River Glendale Narrows 10-Year Operations and Maintenance Plan

Dear Sir:

Please find my public comments on the Los Angeles River Glendale Narrows 10-Year Operations and Maintenance Plan. I will focus on specific concerns and cast hope for collaborative efforts between USACE and local communities. I am a 23-year resident of the riverfront community of Elysian Valley, founder of Water Institute for Science Policy, and Owner of LA River Kayak Safari, and have worked closely with local government.

I break my comment down into three Sections:

1. Raise concern about some recent vegetative management and sediment removal projects in the Elysian Valley with the hope that lessons learned can be applied to the 10-year O+M Plan.

2. Discuss my concern that removal of native plants near the channel toe may be counter-productive to the flood control mission.

3. Discuss a promising method for use of a low-lying native willow to help control invasive species and stabilize low flow channels and the toe, with co-benefits for habitat and flood control.

Section 1:

a. A portion of land, approximately 4.5 acres in the LA River just downstream of the Taylor Yard Bridge, is owned by my organization. See Assessor’s parcel number 5445004001. This land was purchased with the intent to collaborate with community members and indigenous biologists on hand removal and control of invasives, as well as to manage and support native habitat. I bought the parcel with the hope of engaging my local community, youth, and others in constructive in-river management of plants.

In 2022 approximately 35 native willows were cut to the ground within this parcel at a time I was out of time due to extended family health issues. Members of my community took note and contacted me, but too late. While I recognize USACE’s authority for flood control, cutting of native trees to this extent should not be undertaken without notice to the public and the landowner. It seems that this work was done anticipating the planned removal of sediments anticipated in the 10-year plan. As such the cutting of these trees should have been considered part of that planning process and offered up for public review. This area is approximate to where I recorded Least Bell’s Verio in 2022. I am still reviewing my recording to determine if the very tree where it was recorded is one that was cut down.

Related, the current procedures of contractors to cut off any leaning trunks or branches will significantly shorten the life of that tree and prevent it from propagating in a natural fashion.

These trees are scaffolded by the support of leaning limbs to resist pressures in high water from rains. These trees also propagate from leaning limbs.

b. A 2018 sediment removal project near the 2-freeway impounded waters on river left, resulting in ongoing mosquito breeding over the course of years. While the impounded water is now moving adequately, it took five years to “cure” by natural processes. In the meantime, impounded water required treatment to mitigate mosquito breeding. I urge that any sediment removal activities proceed from plans that include detailed plans developed from topographic study to be followed up in the field to confirm adequate flows to avoid mosquito breeding.

In my experience O+M staff in the region are responsive, willing to listen and in service to the local river communities. I urge a careful review of procedures and processes, as well as contractor training and oversite so that this situation does not repeat in a way that harms habitat and community relations.

Section 2:

Recent vegetative management by USACE contractors in the Elysian Valley section has included removal of low story native reeds and rushes adjacent to the toe. I understand that Federal guidelines dictate removal of plants near the toe, but this practice should be carefully examined because it may be harmful rather than helpful for the flood control mission.

When plants near the toe are removed, scouring occurs that threatens to undermine the toe. I speculate that the steepness of the river here causes up and down hydraulic effects in large rain events that deeply scour sediments near the toe when all plant stabilization is removed, contributing to delamination and structural instability of the toe.

For the Glendale Narrows I urge that seek exemption from Federal guidelines that dictate removal of vegetation with 15’ of the toe based on the unique conditions of the reach. Native reeds and rushes should be left since their impact on flood is minimal and they provide habitat.

As well other stabilizing low-lying plants might be useful for this stabilization, see Section 3, below.

Section 3:

A constructive proposal to be considered:

Within the Glendale Narrows, I have located a stand of native Sandbar Willow (Salix exigua).

Based on my observations and that of indigenous biologist Matt Teutimez, I hypothesize that this low lying and “wispy” willow seems to compete well against the aggressive spread of Giant reed (Arundo donax).

With modest mass and height and possessing a rhizomic root structure, this plant has been employed in riparian restoration and bank stabilization projects across the country. Propagation from cuttings is a simple process that can stabilize soils adjacent to the toe, helping to solve issues described in Section 2. The low flow watercourse is remarkably consistent over time based on review of aerial photos. Propagation of sandbar willows may also assist in low flow watercourse stabilization post removal of invasives- stabilizing natural watercourse, locking out invasives and providing habitat.

I am in the process of designing a laboratory study of competition between this local Salix exigua

v. Arundo donax and Phragmites australis, to be hosted at California State University Los Angeles.

Please do not cut down the Salix exigua stand I have found in Elysian Valley. It is a precious resource for study and a source for propagation cuttings. I will follow up with a map of its location later.

Thank you for considering my comments and suggestions. Please do not hesitate to contact me if you have questions. I look forward to a constructive and ongoing dialog about how local communities, indigenous representatives and USACE can work together to the benefit of flood management and habitat objectives.

Steven J. Appleton

July 16, 2023

Atn: Kenneth Wong, CESPL-PD-RQ U.S. Army Corps of Engineers 915 Wilshire Boulevard Los Angeles, CA 90017

RE: Los Angeles River Glendale Narrows 10-Year Operations and Maintenance Plan Programmatic Environmental Assessment

The following are comments concerning the proposed US Army Corps of Engineers (USACE) Los Angeles River Glendale Narrows 10-Year Opera�ons and Maintenance Plan:

Please provide an addi�onal 90-day extension for public review and increase outreach efforts.

Despite living and working locally in related fields I found out only this last week about details of the proposed project and the deadline this weekend to provide comments. There are interested and impacted par�es that will not have opportunity to review scope and respond. At a minimum please provide direct communica�ons from USACE to local governments and ac�ve organiza�ons including the Urban Water Federal Partnership Stakeholder group, indigenous leaders and groups, and City and Neighborhood Councils within the project scope.

The proposed project is not in alignment with USACE plans and processes, including the Los Angeles River Ecosystem Restoration Project, the International Guidelines on Natural and Nature-Based Features for Flood Risk Management, and the Engineering With Nature Initiative.

With the advancing threats of climate change, equity concerns, and increasing impacts on natural areas there has never been more need for leading prac�ces that have been demonstrated by the USACE on other projects. In just the last decade the LA area has been par�cularly hard hit by habitat loss through development, drought, and fires unprecedented in human records. These impacts, large and diverse popula�ons, and the visibility of the region present the LA River as even more significant, not less, for realizing resilience through nature-based solu�ons. There is an impera�ve to move forward and present for the na�on and world the best that can be done to serve our communi�es.

A comprehensive regional assessment of timing relative to similar projects impacting populations in the region is critical for considerations. Impacts to vegetation at a minimum will require timely and proactive mitigation actions.

Vanishingly litle wetland and riparian cover remains across the region, which is essen�al for special status species and species of concern. In 1989 Faber et. al. es�mated in The ecology of riparian habitats of the southern California coastal region: A community profile that 90-95% of all historical riparian areas in Southern California had been lost. Beyond just being scarce, riparian areas are founda�onal corridors in semi-arid regions suppor�ng many more species across land cover types, more than any other habitat in a region recognized as a biodiversity hotspot for the impressive diversity of species and the threats that they face.

Recognizing these prevailing condi�ons, the project is proposed within a period too narrow for substan�al recovery of other large areas that have been cleared at Hahamongna on the Arroro Seco, Whi�er Narrows, the San Gabriel River, and poten�ally in the near-term also the Sepulveda Basin, represen�ng a majority of remaining natural cover along riparian corridors in the LA Basin. With extensive areas being cleared there is limited refugia for already declining popula�ons.

A protocol-level assessment was just conducted this 2023 nes�ng season in a so� botom reach of the San Gabriel River outside cleared areas and within areas CA Fish and Wildlife mapped as hos�ng specific special status avian species. None were observed. This is not an isolated condi�on making clear the shortsightedness of expecta�ons that land in some imagined somewhere else is s�ll suppor�ng popula�ons impacted by the extreme habitat loss and erosion of natural systems being substan�ally funded by taxpayer dollars. For any en�ty that cannot exempt themselves the proposed ac�on would be unlikely to be approved without extensive mi�ga�on, also acknowledging that mi�ga�on rarely if ever fully recovers original damage.

Respec�ully, Johnathan Perisho 1751 N New Hampshire Ave Los Angeles, CA 90027

July 16, 2023

U.S. Army Corps of Engineers 915 Wilshire Blvd., Los Angeles, CA 90017 Sent via email to: kenneth.wong@usace.army.mil

RE: Los Angeles River Glendale Narrows 10-Year Operations and Maintenance Plan Programmatic Environmental Assessment - Request for extension of public comment period, full environmental review, and prioritization of natural and nature-based solutions

Dear Kenneth Wong:

On behalf of the undersigned 11 groups and individuals, we respectfully submit the following in response to the Los Angeles River Glendale Narrows 10-year Operations and Maintenance Plan Programmatic Environmental Assessment (hereafter, proposed project or EA). The undersigned represent non-profit organizations, businesses, Los Angeles River-adjacent residents, concerned community members, local advocates, and key constituents, all of whom support natural and nature-based solutions for the Los Angeles River (L.A. River) that prioritize ecosystem function and protection of communities.

We have serious concerns about the proposed project, the first and most immediate of which is that:

1) There was inadequate public outreach and notification about the proposed project. We, therefore, request an extension in the public comment period for an additional 90 days.

Despite being intimately engaged on issues related to the L.A. River, many of us only found out about this proposed project and comment opportunity very recently near the end of the public comment period and not directly from the U.S. Army Corps of

Engineers (USACE) project proponent. The short public comment period and insufficient public outreach has resulted in many groups being unaware and scrambling to make last-minute comments on a large project with a long timescale and impacts likely to be major. The USACE must do better on public outreach, by extending the public comment period and sharing this opportunity with existing listservs (e.g., Urban Water Federal Partnership Stakeholder group), Indigenous leaders and groups, all Neighborhood Councils within the project’s scope, local multilingual community-based organizations, and more, providing the document in Spanish, reaching out individually to key constituents, partners, and community members, and hosting at least one virtual public meeting and one in-person public meeting during the comment period extension.

In addition to our request for an extension to the public comment period, we offer the following high-level comments:

2) The proposed project is contradictory to the USACE’s own planning processes by not addressing and including ecosystem function, restoration, and natural and nature-based approaches to flood risk management; the project is likely to have significant negative impacts on biology, hydrology, and water quality.

The proposed project is contradictory to the USACE’s own efforts and approaches being taken towards the L.A. River and flood management, including the Los Angeles River Ecosystem Restoration Project1, the International Guidelines on Natural and Nature- Based Features for Flood Risk Management2, and the Engineering With Nature (EWN) Initiative3. The Los Angeles River Ecosystem Restoration Project (or LARER project), approved in 2016 and jointly led by the City of L.A. and the USACE, purports to create, restore, and establish historic riparian and freshwater marsh habitat, and reintroduce ecological and physical processes to 11 miles of the L.A. River. The proposed project to remove significant sediment and native vegetation from the Glendale Narrows is in direct opposition to the LARER project and takes an outdated approach to flood risk management. We urge the USACE to be consistent in its approaches to the L.A. River and restoration, and to prioritize flood risk management approaches that are natural and nature-based and take an ecosystem restoration approach. Removal of sediment and thriving native vegetation from the river channel is antithetical to an ecosystem restoration approach and will very likely have negative impacts on ecosystem health, including protected species. Healthy functioning local waterways, including the L.A.

River, are critical for climate change resilience, public health and safety, biodiversity, and ecosystem services.

Notably, the L.A. River in the proposed project area supports a diverse set of species and is an area where members of the public and local communities participate in beneficial use activities that include bird watching, hiking, fishing, and kayaking. The L.A.

River must be treated as the living river it is, not solely as a flood channel.

1 https://www.spl.usace.army.mil/Missions/Civil-Works/Projects-Studies/Los-Angeles-River-Ecosystem-

Restoration/ 2 https://ewn.erdc.dren.mil/international-guidelines-on-natural-and-nature-based-features-for-flood-risk-management/ 3 https://ewn.erdc.dren.mil/ https://www.spl.usace.army.mil/Missions/Civil-Works/Projects-Studies/Los-Angeles-River-Ecosystem-Restoration/ https://www.spl.usace.army.mil/Missions/Civil-Works/Projects-Studies/Los-Angeles-River-Ecosystem-Restoration/ https://ewn.erdc.dren.mil/international-guidelines-on-natural-and-nature-based-features-for-flood-risk-management/ https://ewn.erdc.dren.mil/international-guidelines-on-natural-and-nature-based-features-for-flood-risk-management/ https://ewn.erdc.dren.mil/

We request that the USACE:

● Examine how this project aligns with the stated goals of the LARER project, the forward-thinking Engineering With Nature initiative, and the Guidelines on Natural and Nature-Based Features for Flood Risk Management.

● Take a watershed approach to flood risk management prioritizing ecosystem restoration.

● Explain how the proposed project will not significantly impair the objectives of the LARER project and how the proposed project will be consistent with the actions taken under the LARER project.

● Incorporate findings of the forthcoming USACE report on native and invasive vegetation in the project area, particularly in regards to impacts to native vegetation.

3) A full environmental analysis must be conducted with consideration of site-specific conditions, consistent flood maps, and further justification.

The USACE’s proposal to develop an EA, rather than a full Environmental Impact Statement (EIS), is improper. An EA would inherently be inadequate in its assessment of impacts and site-specific conditions. The EA is overly simplistic and lacking in details both in terms of impacts as well as in site conditions. It is not even clear to us if the USACE’s notice of the EA is the EA itself or just the notice for a forthcoming, more complete EA.

The proposed project in the Glendale Narrows encompasses a long section of the L.A.

River with diverse and changing conditions over space and time. These nuances must be accounted for and analyzed in detail given the high likelihood of significant environmental impacts from sediment and vegetation removal. For instance, the cross-sections shown in the EA are too simplistic and do not represent the entirety of the project area; cross-sections must be examined for specific reaches where impacts will occur. Further, given the extensive timeframe of the project, adaptive management must be built in to the project. Conditions will undoubtedly change over the 10-year time frame, necessitating review of conditions and impacts before work starts.

The project must also rectify inconsistent flood maps; currently, the flood maps presented by the Federal Emergency Management Agency (FEMA)4, UC Irvine5, and First Street Foundation6 are not consistent. Before flood risk management projects are undertaken, the inconsistencies between different maps and risks must be addressed and rectified in a publicly transparent manner, which would require an EIS. Finally, we request that additional and appropriate justification for the proposed project be included, because the notice on the USACE website provides no transparent or justified reasoning as to the necessity of sediment and vegetation removal for flood control or other purposes.

In summary, we have significant concerns about the proposed project as well as the process by which key constituents, nonprofit organizations, and community members have been engaged.

We ask for an immediate extension to the public comment period so that we can adequately review the project and expand upon our concerns, and we urge that the USACE reconsider the

4 https://msc.fema.gov/portal/home 5 https://www.nature.com/articles/s41893-022-00977-7.epdf 6 https://riskfactor.com/city/los-angeles-ca/644000_fsid/flood https://msc.fema.gov/portal/home https://www.nature.com/articles/s41893-022-00977-7.epdf https://riskfactor.com/city/los-angeles-ca/644000_fsid/flood proposed project entirely. To the extent the USACE moves forward with the proposed project, an EA is not appropriate and a full EIS must be prepared.

Thank you for your consideration. If you have any questions concerning these comments, please contact Katherine Pease by email at kpease@healthebay.org or by phone at (310) 451- 1500 x 141.

Melanie Winter, Founder & Director, The River Project

Katherine Pease, Director of Science & Policy, Heal the Bay

Anthea Raymond, California State Director, American Canoe Association; Cypress Park resident and property owner

Candice Dickens-Russell, President & CEO, Friends of the LA River

Benjamin Harris, Staff Attorney, LA Waterkeeper

Kelsey Jessup, Urban Conservation Program Director, The Nature Conservancy

Charles Miller, Chair, Los Angeles Chapter, Climate Reality Project mailto:kpease@healthebay.org

Steven Appleton, Water Institute for Science Policy and LA River Kayak Safari

Diana Weynand, Chair, San Fernando Valley Chapter, Climate Reality Project

Janet Schulman, Interim Executive Director, North East Trees

Daniel S. Cooper, Ph.D., Deputy Executive Officer, Resource Conservation District - Santa Monica Mountains.

July 14, 2023

915 Wilshire Blvd., Los Angeles, CA 90017

Reg.: Los Angeles River Glendale Narrows 10-Year Operations and Maintenance Plan

Dear Mr. Wong, The Greater Los Angeles County Vector Control District (GLACVCD) is a public health agency that is enabled and empowered by the California State Health and Safety Code to provide and enforce mosquito and vector control for 36 cities and unincorporated areas of Los Angeles County.

The Glendale Narrows segment of the Los Angeles River potentially impacted by U.S.

Army Corps of Engineers (Corps) proposed 10-year operations and maintenance plan is under GLACVCD’s jurisdiction. We are concerned that both the process of removing accumulated excess sediment and vegetation management as well as the resulting alterations to the streambed might result in the temporary and/or permanent creation of still water zones that will allow mosquito breeding.

We therefore insist, that no matter which one of proposed scenarios ends up being approved, that:

large areas of quiescent water are not even temporarily created during implementation; and final plans include a clearly defined and well stabilized low-flow channel, to prevent areas of stagnant water throughout the riverbed that will otherwise promote mosquito breeding habitat.

We request for more detailed plans, once developed, to be submitted for review to:

Mark Hall, Environmental Manager Greater Los Angeles County Vector Control District 12545 Florence Ave, Santa Fe Springs, CA 90670 mhall@GLAmosquito.org

With kind regards

Susanne Kluh General Manager

GREATER LOS ANGELES COUNTY

VECTOR CONTROL DISTRICT

12545 Florence Avenue, Santa Fe Springs, CA 90670 Office (562) 944-9656 Fax (562) 944-7976

Email: info@GLAmosquito.org Website: www.GLAmosquito.org

PRESIDENT GENERAL MANAGER

Scott T. Kwong, San Marino Susanne Kluh

VICE PRESIDENT

Marilyn Sanabria, Huntington Park

SECRETARY-TREASURER

Ali Saleh, Bell

ARTESIA

Melissa Ramoso

BELL GARDENS

Pedro Aceituno

BELLFLOWER

Sonny R. Santa Ines

BURBANK

Dr. Jeff D. Wassem

CARSON

Jim Dear

CERRITOS

Mark W. Bollman

COMMERCE

Leonard Mendoza

CUDAHY

Daisy Lomelí

DIAMOND BAR

Ruth M. Low

DOWNEY

Robert Kiefer

GARDENA

Paulette C. Francis

GLENDALE

VACANT

HAWAIIAN GARDENS

Luis Roa

LA CAÑADA FLINTRIDGE

Leonard Pieroni

LA HABRA HEIGHTS

Catherine Houwen

LAKEWOOD

Steve Croft

LA MIRADA

John Lewis

LONG BEACH

Emily Holman

LOS ANGELES CITY

Steven Appleton

LOS ANGELES COUNTY

Steven A. Goldsworthy

LYNWOOD

Rita Soto

MAYWOOD

Jessica Torres

MONTEBELLO

Avik Cordeiro

NORWALK

Margarita L. Rios

PARAMOUNT

Isabel Aguayo

PICO RIVERA

Gustavo V. Camacho

SAN FERNANDO

Sylvia Ballin

SANTA CLARITA

Heidi Heinrich

SANTA FE SPRINGS

William K. Rounds

SIGNAL HILL

Robert D. Copeland

SOUTH EL MONTE

Hector Delgado

SOUTH GATE

Denise Diaz

VERNON

Leticia Lopez

WHITTIER

Jessica Martinez

A CALIFORNIA GOVERNMENTAL AGENCY

PROMOTING COMMUNITY HEALTH, COMFORT AND WELFARE THROUGH EFFECTIVE AND RESPONSIVE VECTOR CONTROL SINCE 1952

Friday, July 14, 2023

Los Angeles River Glendale Narrows 10-Year Operations and Maintenance Plan Attn: Kenneth Wong, CESPL-PD-RQ 915 Wilshire Blvd., Los Angeles, CA 90017 Submission via email to: kenneth.wong@usace.army.mil

Dear Kenneth

North East Trees (NET) appreciates the opportunity to provide expert comment on the Los Angeles River at Glendale Narrows 10-Year Operations and Maintenance Plan as part of your Programmatic Environmental Assessment. As you know, NET has a long history with the River, including creating 25 nature parks and an extensive tree planting program along the Glendale Narrows. Currently, we lead a planning project for Sennett Creek and a maintenance and habitat restoration project at the Zev Yaroslavsky Greenway Trail. NET is a community-based, non-profit organization that helps heal environmental injustice through urban forestry, nature-based design-build, habitat restoration, and workforce development. Our projects benefit underserved communities of color in Los Angeles who are disproportionately harmed by environmental injustices such as diminished tree canopy, excessive pollution, and the resulting negative public health impacts. Our staff includes certified arborists and licensed landscape designers.

Given the substantial ecosystem values provided by the river’s in-channel vegetation, the only viable option of those proposed is the No Action Alternative, in which no sediment or vegetation is cleared except in smaller-scale site specific work in critical areas. The removal of native vegetation near bridges and edges would unnecessarily remove what is already precious and scarce habitat. If there is to be any large-scale sediment and vegetation removal, we advocate for an option that was not included in the document: removal of only non-native vegetation, leaving all sediment and all native flora undisturbed. In summary, we oppose the Fifty Percent and Full Removal alternatives. Trimming of native trees to a maximum height of 10 feet is problematic in terms of habitat quality, and we do not support this practice. Lastly, we note that the preservation of native vegetation “to the extent practicable” is a highly subjective judgment, and we would request that an independent professional be consulted to assess practicability whenever clearing is taking place.

This stretch of river provides crucial habitat for migratory and local wildlife, counteracts the urban heat island effect, sequesters carbon, and provides much-needed public open space for the one million Angelenos who live within one mile of the river. We thank you for the opportunity to advocate for its protection.

Best, Janet Schulman Interim Executive Director

North East Trees | Los Angeles River Center | 570 W Ave 26 Ste. 200 | Los Angeles, CA 90065 | www.northeasttrees.org |

(323) 441-8634 | NET is a 501(c)(3) non-profit organization registered in California. Gifts to NET are tax-deductible to the extent of the law. Our tax ID is 95-4320174.

July 14, 2023

Attn: Kenneth Wong United States Army Corps of Engineering

Dear Mr. Wong -

The Frogtown Association of Business (FTAB) is a community-based organization that represents the interests of small businesses in the riverfront community of Elysian Valley. This organization was formed in 2017 by long term community members. For us, the LA River is a critical, (and much loved), component of the neighborhood we selected to establish our base of operations.

Many of our businesses front on the river path, and in some cases, our clientele rely on the path for access to the business.

We are writing to comment on the US Army Corp of Engineers 10-year sediment removal project in the Glendale Narrows:

(1) None of us received the project call for public comment until this week. Nor have we seen any public postings or any effort to communicate with key stakeholders. We urge that the comment period be extended by at least 120 days to allow full public participation.

(2) We are concerned that the schematic drawings presented are general and non-specific.

They do not provide enough information to understand the possible impacts. Without any further detail, of one thing we are clear---removing all plants and sediments in this area would be devastating to the natural environment and would have a negative impact on many businesses in the area.

In light of these and other concerns, we request an extension of 120 days for public comment and urge that USACE engage in a robust process of discussion and engagement with local communities, the business community and experts in hydrology and ecology.

Please feel free to contact Dr. Katelyn Lehman at 650-279-5857 if you have any questions. In addition, we can be helpful in extending your outreach to our membership and others in the community.

Sincerely -

Other Digital Signatories -

Allen Anderson Tracy Stone Vijay Sehgal Co-Founder, FtAB Co-Founder, FtAB Co-Founder, FtAB

Cyndi Hubach Kate Banford Chris Gonen Co-Founder, FtAB Vice-Chair, FtAB Vice-Chair, FtAB

Steve Appleton Vice-Chair, FtAB

Response to Public Comments

Mr. Brett Kushner (Atwater Village Neighborhood Council)

By letter dated July 13, 2023, Mr. Brett Kushner, representing the Atwater Village Neighborhood Council (“Council”), generally expressed support for Alternative 2. The Council expressed concern about delamination of the LAR channel near Los Feliz Bridge and asked the damage to be repaired. Likewise, the Council requested that storm drains be upgraded to match needed flood protection levels and solutions for people living in storm drains. The Council also requested that high-flood risk areas be identified and addressed first. The Council asked the USACE to be mindful of recreation activities on the left embankment and projects that would connect the left bank to the right bank. Last, it was noted that the legend on the map accompanying the public notice was unclear. An updated map was requested.

Response to Comments:

1. Delamination: The USACE is aware of delamination of the engineered structure.

The delamination is deterioration of a thin layer of concrete overlay that protects the underlying steel reinforced concrete structure. According to USACE field personnel, the underlying steel reinforced concrete structure remains sound and in good condition. Thus, the delamination of the concrete overlay would have no bearing on the performance and safety of the engineered structure. Furthermore, repair of engineered structures is also outside the scope of the Proposed Action.

2. Storm drain repairs and upgrades: With the exception of hinged storm drain covers, maintenance and upgrades of storm drains are the responsibility of cities that discharge into the LAR. Storm drains from unincorporated area are the responsibility of the County of Los Angeles.

3. High flood risk areas: As discussed in the EA, channel capacities of the lower reaches (Reach 4D to Reach 6C) are most compromised. The Preferred Alternative would start work from these lower reaches and proceed upstream.

4. Recreation on the left embankment: As indicated in the EA, there are no recreational facilities on the left embankment as compared to the right embankment where there is a bicycle trail. However, the USACE is aware that the left embankment may periodically be used for recreation. Pursuant to environmental commitment Rec-1, the USACE would continue to coordinate with interested residents and stakeholders through coordination venues listed in Section 1.1 throughout the 10-year lifespan of the operations and maintenance plan to discuss additional ways to avoid or minimize impacts to recreation.

5. Map: An updated map is included in the Final EA.

Mr. Steve Appleton

Mr. Appleton, an owner of a parcel in the LAR downstream of Taylor Yard, states that removal of native vegetation should not be undertaken without notice to the public and the landowner. Mr. Appleton requested that sediment removal activities not result in impoundment of water which results in vector control issues. Mr. Appleton states that USACE O&M staff are responsive and willing to listen to concerned members of the community and asked for contractor training and oversight.

USACE guidelines requiring vegetation removal from the toes of levees should be reevaluated as removing reeds and rushes could cause scouring that could undermine the toe and destabilize the engineered structure. Mr. Appleton recommends use of native Sandbar Willows to stabilize soils and asked to not remove this species from the Elysian Valley.

Response to Comments:

1. Public Notices: .

Pursuant to environmental commitment Rec-1, the USACE would continue to coordinate with interested residents and stakeholders through coordination venues listed in Section 1.1 throughout the 10-year lifespan of the operations and maintenance plan which would serve to inform of upcoming sediment removal activities.

2. Water impoundment and vector control: Removal of excess sediment and establishment of a Vegetation Free Zone (VFZ) should help in removing blockages that impound water especially in Reach 6. However, the continual process of sandbar formation coupled with vegetation growth in the Glendale Narrows may periodically result in flow blockages. USACE maintenance goal is to ensure positive drainage through the Glendale Narrows.

3. USACE guideline for vegetation removal: Engineering Pamphlet 1110-2-18, the USACE national standards for levee vegetation, does not allow for vegetation within the VFZ except for approved grasses. For the levees through Glendale Narrows, the VFZ extends to the access road, though the exact location would vary depending on the segment discussed (see Figure 2 in the EA). Thus, if vegetation were to be allowed in the VFZ, it would grow atop an engineered structure. However, adjacent to the VFZ, a Vegetation Management Zone (VMZ) would be established. As shown in Figure 2, the VMZ would extend from the edge of the toe road to 15-ft. riverward. Within the VMZ, vegetation that can flex such as willow scrubs and freshwater marsh vegetation would be allowed to grow. Based on the above, request for a variance is not warranted.

Mr. Jonathan Perisho, Project Manager, Watershed Conservation Authority

By letter dated July 16, 2023, Mr. Jonathan Perisho: (1) requested a 90-day extension for public review and increased outreach efforts; (2) stated that proposed project is not in alignment with USACE plans and processes, including the Los Angeles River Ecosystem Restoration Project, the International Guidelines on Natural and Nature- Based Features for Flood Risk Management, and the Engineering With Nature Initiative;

(3) requested consideration of regional losses of riparian ecosystems over concern that recovery of vegetation would not be sufficient to compensate for regional losses and suggested that extensive mitigation should be incorporated.

Response to comments:

1. 90-day public review period extension:

Pursuant to the regulations implementing the procedural provisions of the National Environmental Policy Act, the USACE issued a public notice advising the public that the USACE had initiated preparation of an EA and was soliciting comments from the public, Federal, state, and local agencies, and other interested parties in order to consider and evaluate the impacts of the proposed activity. The USACE made available the public notice for a 30-day review and comment period. Upon availability of the notice, the USACE directly reached out to stakeholders such as Friends of the Los Angeles River and the River Project to raise awareness and increase circulation. Furthermore, as noted in Section

1.1 of the Environmental Assessment, USACE briefed a number of stakeholders on this project in December 2021 and 2022 through the Los Angeles River Flood Risk Awareness Project. Based on the above efforts, an additional 90-day public review was deemed to be unwarranted.

2. Compliance with USACE planning guidelines and projects:

The proposed action does not involve construction of a new Civil Works project which can be designed and built with concepts discussed in the International Guidelines on Natural and Nature-Based Features for Flood Risk Management, and the Engineering with Nature Initiative. Rather, it is maintenance of an existing Civil Works flood risk management structure constructed in the early 20th century prior to the evolution of the concept of incorporating natural features into the design and construction of flood risk management projects. Accordingly, the LAR channel through Glendale Narrows was designed to be free of vegetation to convey the design flows.

Allowance for a robust riparian corridor while maintaining design flood levels would require structural modifications to the levee. As stated in Section 2.4 of the EA, structural modifications were considered but were not carried forward for analysis. First, operational and maintenance funds cannot be used for activities that would result in substantial modification of authorized structures.

Furthermore, raising the levee height would increase the design capacity of the LAR channel through Glendale Narrows beyond that authorized by Congress.

Changes to the design capacity would require separate Congressional authorization and appropriations. Raising the levee height may require structures to be built atop the bicycle/pedestrian trail on the right levee (facing downstream) thereby permanently prohibiting the use of the trail and disrupting the trail connectivity at Glendale Narrows. Furthermore, the forthcoming LAR Ecosystem Restoration (LARER) Project will result in substantial structural modifications to the LAR channel throughout Glendale Narrows. Structural modifications for the purpose of restoring capacity may need to be dismantled when the LARER project is implemented.

The request to incorporate ecosystem restoration and nature-based elements into flood risk management projects has already been realized in the LARER Project. The project aims to restore and reconnect of riparian strand, freshwater marsh, and aquatic habitat communities while maintaining existing levels of flood risk management. This strategy includes removal of non-native vegetation from the flood control channel. The LARER project also plans to incorporate existing native vegetation into the proposed ecosystem restoration measures. In accordance with these measures, the Preferred Alternative would selectively remove non-native vegetation from areas between the VMZs and outside the nine bridge crossing approaches while avoiding native trees to the extent practicable. Thus, the Preferred Alternative is in accord with the LARER Project.

3. Regional loss of riparian habitat:

Mr. Perisho’s comments on declining riparian ecosystem within the larger region are noted. However, USACE’s responsibility is maintaining the LAR for the intended purpose and proper functioning as authorized by Congress. As discussed in the EA, the USACE recognizes the importance of retaining native vegetation to the extent practicable. The Preferred Alternative would balance maintenance needs while preserving and enhancing native vegetation. Last, as further discussed in the EA and the 404(b)(1) analysis, compensatory mitigation is not warranted since the native vegetation remaining in the channel would be enhanced and areas throughout the channel including the VMZ and bridge crossing approaches affected by sediment removal and vegetation management activities would be allowed to revegetate with wetland vegetation that can flex and bend during storm flows such as native understory vegetation (e.g., mulefat scrubs, willow scrubs, etc.) or emergent freshwater marsh vegetation (e.g., cattails, bulrush, etc.).

Consortium of stakeholders (The River Project, Heal the Bay, American Canoe Association, Friends of the Los Angeles River, Los Angeles Waterkeeper, The Nature Conservancy, Climate Reality Project)

A consortium of stakeholders by letter dated July 16, 2023 (1) requested extension of the comment period for 90 days citing inadequate public outreach and notification; (2) stated that the Proposed Action contradicts USACE’s planning process by not addressing ecosystem function, restoration and natural and nature-based approaches to flood risk management; (3) requested preparation of an Environmental Impact Statement.

Response to comments:

(1) 90-day public review period extension:

Pursuant to the regulations implementing the procedural provisions of the National Environmental Policy Act, the USACE issued a public notice advising the public that the USACE had initiated preparation of an EA and was soliciting comments from the public, Federal, state, and local agencies, and other interested parties in order to consider and evaluate the impacts of the proposed activity. The USACE made available the public notice for a 30-day review and comment period. Upon availability of the notice, the USACE directly reached out to stakeholders such as Friends of the Los Angeles River and the River Project to raise awareness and increase circulation. Request from Friends of the Los Angeles River for the channel capacity analysis was promptly provided.

Furthermore, as noted in Section 1.1 of the Environmental Assessment, USACE briefed several stakeholders on this project in December 2021 and 2022 through the Los Angeles River Flood Risk Awareness Project. Based on the above efforts, an additional 90-day public review was deemed to be unwarranted.

(2) Compliance with USACE planning guidelines and projects:

The proposed action does not involve construction of a new Civil Works project which can be designed and built with concepts discussed in the International Guidelines on Natural and Nature-Based Features for Flood Risk Management, and the Engineering with Nature Initiative. Rather, it is maintenance of an existing Civil Works flood risk management structure constructed in the early 20th century prior to the evolution of the concept of incorporating natural features into the design and construction of flood risk management projects.