ASC, Topanga Watershed Committee Oppose Permit for Berm Removal

The following are excepts from Aug. 5 letter from Topanga Association For a Scenic Community and Topanga Watershed Committee letter to the California Coastal Commission opposing California Department of Parks and Recreation’s Resource Conservation District-backed plan for a berm removal in lower Topanga State Park. It has, of necessity, been edited for space, but can be found in its entirety online at 2007/8/W14e-8-2007.pdf, together with the Coastal Commission’s 56-page staff report and recommendations in favor of the project.

The Topanga Association for a Scenic Community (TASC) and the Topanga Creek Watershed Committee have joined together in opposing a Coastal Commission permit for the proposed Rodeo Grounds Berm Removal Project. This extensive excavation proposal for Lower Topanga State Park raises significant concerns, including health and safety hazards, and was not intended to be undertaken until a general plan for this vast 1,659-acre addition to Topanga State Park was completed. Indeed, this project is specifically rejected in the Interim Management Plan for Lower Topanga.

No project of anything close to this scale was authorized in the Interim Plan. To ignore prohibitions against a project of this size is to knowingly make a travesty of the public-input process and to demonstrate bad faith on the part of several cooperating state agencies. It would bypass the spirit of prudent planning, in favor of chasing funding wherever it may lead; deliberately cut the public out of the process, and betray State Parks’ prior commitments.

In the Interim Plan’s executive summary, the plan itself is described as “full public disclosure of the Department’s proposed actions.” It goes on to assure the public that only “a number of small projects” and “data recovery to assist in subsequent planning efforts” would be undertaken.

Under no circumstances could the proposed berm removal be considered a “small project.” The primary goal of the Interim Plan is “stabilizing the environment.” Nowhere does restoration of the streambed or lagoon, or any phase of it, occur as an action item. In fact, removal of the berm is among alternatives considered, and subsequently rejected in the final plan.

What we see here are the parochial interests of grant-paid agency staffers (however well-intentioned) driving the process and skewing broader public priorities to fit their particular specialties. Leadership at State Parks and here at the Coastal Commission should not abdicate their roles in protecting the public’s right to participate in a comprehensive future plan for Lower Topanga, one that balances resource protection with public access, public safety, protection of historical resources, visitor services and even the creative reuse of some existing structures, which give the area a unique character.

Loss of the berm road eliminates an existing trail into the park, and could make a broad area of property much more hazardous during heavy rains, when flooding often occurs. Currently, there is no trail-use plan for the area and access into the property is essentially unrestricted. One entrance leads directly into this area. A general plan could coordinate a public-use plan to accommodate restoration work.

There are also numerous hazards that the current proposal itself presents that should have been addressed in an EIR. Unearthing 19,000 cubic yards of fill dirt, two-thirds of it identified as hazardous material, represents a danger to humans, air quality, the stream, and coastal waters – particularly if there is rain during the project. Since the park does not provide controlled access, there is no way to ensure people will be exposed to these airborne contaminants, including lead dust.

Caltrans called it “a very extensive earth haul” and offered cautions about the dangers of trucks piling up at the intersection of Topanga Canyon Boulevard and PCH. (The intersection is also a public school bus stop and an MTA bus stop.) The project calls for 1,000 trucks making a wide circuit through sensitive habitat areas, establishing a continuous road where none currently exists. This will mean 2,000 separate truck turns into and out of the Lower Topanga property at a blind curve.

Wildlife surveys involving birds apparently have not been completed and only generic bird lists are offered in the proposal. There is no mention of Nighthawks, which are present there, and, with their preference for perching on the dirt roads, would be especially impacted by truck traffic and herbicide use. This close relative to the Whip- poor-will is beginning to show up on lists of birds in decline. Audubon lists them as significantly declining in Arizona, and the Corneil Lab of Ornithology says populations are decreasing dramatically in some areas. This is one place in Topanga where they have been observed regularly. It would be a shame to allow protection of relatively few steelhead to facilitate the decline of other species.

We are also concerned about the status of previous State Parks commitments regarding mature tree removals and herbicide use. These commitments, made at a hearing before the Santa Monica Bay Restoration Commission, include confining removal of non-native mature trees to the berm area itself and not the surrounding 10 acres. This would save about 100 trees out of 136 trees originally to be cut down, and would better comply with restrictions in the Interim Plan. Similarly, it is our recollection that herbicides would not be used on this project. Months after that hearing, we were informed by RCD staff that the application for funding had been pulled. Its resurrection has come as a surprise.

Controversy over the difference between damaging invasive species such as arundo donax and merely atypical plants and tree species should be addressed in a general planning forum. Issues of aesthetics, as well as unacknowledged environmental impacts of wholesale eradication, are reasonable public concerns and were appropriately deferred in the Interim Plan for a more full consideration in a general plan.

If this project goes forward, the public role in park planning becomes nothing but a perfunctory sham. We are told this plan is State Parks’ top priority now, but that it will be summer 2008 before a public process is begun. These kinds of delays should not be rewarded by allowing a massive project like this to go forward with no public involvement.

Habitat protection and preservation will certainly be common goals in a general plan, but the methods, timing and overall scale of restoration strategies are reasonable subjects for public discussion. To date, there has been no State Parks public planning forum for consideration of this proposal.

We urge you to reject this irresponsible piecemeal project that far exceeds the work authorized in the Lower Topanga Interim Plan. Don’t let our resource protection agencies take on the failings we’ve seen in public works departments and the Army Corps of Engineers, where the bias is always in favor of doing projects. If they do so, much money will be wasted, their popularity and goodwill will quickly erode – and important future resource-protection efforts will be sacrificed as a result. Many local residents and commuters, unprepared for this project, are likely to be shocked by what they see if it should go forward. It would look like a massive grading operation; with disappearing tall trees that have defined the viewshed of Lower Topanga for many years. Lower Topanga is too complex and too promising a park to rush ahead with no overall plan. Let the people have a voice.


Roger Pugliese, Chair, Topanga Association for a Scenic Community (TASC)

Ben Allanoff, Acting Chair, Topanga Creek Watershed Committee