Channelizing Aliso Creek
See also the Save Aliso Creek Website
Nov. 28, 2017 Letter to Eduardo T. De Mesa, Planning Division, US Army Corps of Engineers, Los Angesles District:
The Aliso Creek Mainstem Ecosystem Restoration Project Feasibility Report lists as a key planning consideration “avoiding increase in manmade structures with visible construction elements (such as concrete) that would not be esthetically consistent with the natural setting of the Wilderness Park” (p. 6). Nevertheless, it doubles the number of manmade structures earlier proposed, in addition to grading five miles of the canyon, removing all of the vegetation, displacing or destroying wildlife, armoring the creek banks, raising and altering the course of the creek, and dumping 300,000 cubic yards of dirt in the park.
In the letter we prepared for the scoping session in 2009 (which is included without comment as an appendix in the report), we asked for consideration of less destructive alternatives, quoting a 2007 technical review of the concept by Geosyntec and a 2009 review prepared for the City of Laguna Beach by Phillip Williams and Associates that recommended such alternatives. The majority of the public comments on the proposal also asked for less invasive alternatives. Even the County’s original concept for the project (the Aliso Creek Concept Plan, February 2006), despite depending on the construction of several dozen drop structures, envisioned “salvaging native vegetation such as willows and shrubs that are currently growing adjacent to the channel” where possible and investigating “opportunities to incorporate desirable stands of existing vegetation when developing the final alignment” (p. 28). According to the Feasibility Report (p. 3–46), the U.S. Fish and Wildlife Service’s 2015 proposal would “leave riparian areas along the creek relatively undisturbed,” but the proposal is dismissed as “possibly not cost-effective” (p. 11, Table ES-2) and the recommended alternatives of others are overlooked altogether.
It has been clear from the beginning that the “restoration” proposal is primarily about protecting the sewer pipes along the creek. We believe that a wilderness park is no place for sewer lines. The park’s resource management plan calls for “protecting and preserving the native habitat in the park for the benefit of its natural resources and providing outdoor education and low-impact recreation consistent with resource protection goals” and assessing proposed projects for their potential impacts to park resources. Certainly this means that removing the sewer pipes, rather than undertaking heroic measures to protect them, should be considered.
A project of this magnitude appears to commit the County to continuing to allow the dumping of millions of gallons a day of treated sewage into the ocean for the foreseeable future. In an era in which water is increasingly scarce, energy is costly, and open space is precious, our public agencies should not be perpetuating unsustainable practices. Increasing concern about the health of the ocean and its wildlife and the conservation of energy and water is producing new, integrated approaches to the handling of sewage. For example, when the South Orange County Wastewater Authority (SOCWA) received approval last year to replace its sludge force main with a new one in the same location, it was recognized that the “environmentally superior alternative” would have been processing the sludge on site. Twenty-first century approaches are increasingly becoming available, and their costs can often be managed with federal or state grants or public-private partnerships. The state’s Water Resources Board has set a goal of increasing the use of recycled water over 2002 levels by at least one million acre feet per year by 2020 and at least two million acre feet a year by 2030, and it is developing public health standards for the potable reuse of recycled wastewater. SOCWA is talking about increasing its own production of recycled water in the next five to ten years, and the time may not be far off when the neighboring agencies that join Laguna Beach in dumping their secondary-treated sewage into the ocean will no longer need to do so.
There is an opportunity here to take a step in the direction of enabling our wilderness park to be wilder. It would be tragic to gut and urbanize it for the sake of protecting the pipes that move sewage through it, the more so when the pipes themselves and the technology they reflect may soon be obsolete and alternatives are available. We believe that this plan should be abandoned and replaced with one that uses minimally invasive and natural methods to protect the utilities until they can be removed and the creek comes to its new equilibrium. What the report dismisses as “routine temporary emergency protective actions” (p. 4) and “band-aid solutions” (p. 16, Table ES-4) should be sufficient to allow the utility to catch up with the times.
The argument for no action or at least a different kind of action seems the stronger for the judgment of even the Army Corps’s own experts (pp. 3–48, 5-7, 5–43) that the creek is reaching a new equilibrium on its own. The comment letter you will be receiving from the City of Laguna Beach is expected to reaffirm this and point out that the removal of four million pounds of invasive arundo from a twenty-mile stretch of the creek is facilitating the rapid reestablishment of native riparian vegetation. We welcome the evidence that, with help from this $6 million multiagency effort in the years since the data for this report were gathered, the creek is repairing itself. We wonder if further acquaintance with the results of this effort, which are given only brief mention (p. 5-50), might have modified the report’s conclusions.
Any eventual comprehensive plan for Aliso Canyon, which we hope would consider the input of all stakeholders, should include discussion of its likely effects on the Laguna Ocean Foundation’s just- completed plan for restoring the Aliso Creek estuary.
Johanna Felder, President, Village Laguna
Village Laguna General Meeting, Oct. 23, 2017
Derek Ostensen spoke about the status of the creek and the current version of the US Army Corp of Engineers Superproject. Village Laguna has opposed this project in the past, and the new version.
Derek provided a summary of the current situation.
See our October newsletter for a good article on the project.
In 2009, a report was commissioned by the City of Laguna Beach to define the City's objectives for Aliso Creek and to evaluate the Superproject and Army Corps Feasibility Study with respect to the City's objectives. The report (memorandum) was written by Nick Garrity and Andrew Collison of PWA.
Village Laguna’s June 4, 2016, letter to the Coastal Commission Re: 5-15-1670-Al(SOCWA) :
As stakeholders in SOCWA's Aliso Canyon sludge pipeline replacement project and participants in the EIR process three years ago, we had expected to receive notice of the permit hearing. Instead, we learned of it by chance only this week, and therefore this letter will be reaching you rather late. We hope that you will nevertheless be able to give our issues your consideration and vote to reject this replacement project.
The resource management plan of the Aliso and Wood Canyons Wilderness Park stresses “preserving the park’s natural resources and providing recreational opportunities and public access with minimal impact on those resources.” It doesn't mention conveying sewage. A wilderness park is obviously no place for a sewer, and we would like to see all of the pipes removed from it eventually. This is the first opportunity we have had since the park was created to remove any of the existing sewer pipes from the canyon, and we are hoping that you will take advantage of this opportunity by rejecting SOCWA’s proposal.
Even if the location weren’t a wilderness park, the pipeline alignment is known to be highly vulnerable to erosion. As the staff report for the project makes clear, locating a new pipeline in the same place as the existing one depends on the eventual ability to protect it with something like the SUPER Project first proposed several years ago, with its 26 dams, channelization of the creek, and massive grading. Indeed, the bank stabilization plan proposed here, invasive as it is, is admittedly adequate only for ordinary storms. The “potential, future federal project” mentioned by staff as eventually providing permanent creek stabilization is, as far as we know, unfunded and has yet to receive public review, and if it is like the original in its environmental impact, it is likely to be controversial.
Moreover, increasing public concern about protecting ocean water quality, conserving energy and water, and reducing the production of greenhouse gases all call for new, integrated approaches to the handling of sewage. These approaches are increasingly becoming available, and their costs can often be managed with federal or state grants or by public-private partnerships. Simply replacing a 30+-year-old pipeline in kind and in place is a step in the wrong direction.
The EIR for the project identified two alternatives to the pipeline as “environmentally superior:” solids handling at the coastal treatment plant and trucking. Treatment of solids at the plant would generate electricity, and it would save water because it would no longer be necessary to add water to the sludge to move it through a pipe. Trucking would, according to the EIR, save energy and reduce the production of greenhouse gases, and its additional impacts on air quality would remain below the South County Air Quality Management District’s thresholds.
We suggest that trucking be adopted as a temporary measure while a comprehensive plan is developed for treating sewage sustainably and eventually moving all of the sewage infrastructure out of the wilderness park. If this became the objective, it might be the first step toward a self-contained system, with more recycling, that would make it unnecessary to go on dumping treated sewage into the ocean.
We hope that you’ll agree with us that this problem calls for a thoughtful twenty-first-century solution and encourage the applicant to pursue one.
Sincerely, Ginger Osborne, Acting President, Village Laguna
In 1999 the U.S Army Corps of Engineers conducted a Watershed Feasibility Study on the Aliso Creek Watershed and identified a number of water resource issues including erosion, habitat damage, and exposed sewer lines, coupled with high levels of bacteria from urban runoff. Since then Corps of Engineers and the county have been conducting a study on how to deal with these problems. The first version of a solution, known as the SUPER Project (for Stabilization, Utility Protection, and Environmental Restoration), has long been on hold for lack of funding but has recently resurfaced in the form of the Aliso Creek Ecosystem Restoration Feasibility Study.
Village Laguna opposed the SUPER Project because of its massive grading and channelization of the creek, which runs through a wilderness park. We participated in the scoping for this study in 2009, arguing that destroying the existing riparian vegetation, grading the canyon floor, and placing concrete and rock in the creek would be devastating to the wilderness park and inconsistent with Orange County’s General Plan.
Five years later, the study has received new funding and is expected to be complete by the end of next year. Unfortunately, the long-awaited alternatives turn out to be simply minor variations on the original. All of them have dams (now called not “drop structures” but “pools and riffles”) and armoring of the banks of the creek. The “ecological restoration” of the creek ecosystem will come only after the canyon has been graded and the creek has been equipped with concrete structures (16 now, rather than the original project’s 26) designed to keep it in its (new) place.
The study is expected to be distributed for public comment in March 2015, and Village Laguna will be reiterating its concerns about the approach. Problems with the SUPER Project approach and suggestions for better alternatives can also be found at the Laguna Greenbelt.
Village Laguna’s contribution to the 2009 scoping session for the Aliso Creek Ecosystem Restoration Feasibility Study reads as follows:
The site of the study is Aliso and Wood Canyons Wilderness Park, a 4,000-acre natural park with steep hillsides, deep canyons, landscapes ranging from oak woodlands to grasslands and coastal sage scrub, and some thirty miles of trails. Dedicated to Orange County in 1979, it is designated in the County’s General Plan as a wilderness park, ‘a regional park in which the land retains its primeval character with minimal improvements and which is managed and protected to preserve natural processes.’ A deed restriction placed on it in 2001 limits it to county park uses in perpetuity.
The wilderness park is part of the Laguna Greenbelt, some 20,000 acres of protected open space surrounding the city of Laguna Beach. It is bordered on the north by residential and commercial development associated with the cities of Aliso Viejo, Laguna Niguel, and Laguna Woods. At the time the park was established (as mitigation for the development of Aliso Viejo), the upstream portions of Aliso Creek were beginning to be channelized to make way for development, and county planners hoped to preserve the rest of the creek in its natural state.
Planning for the park had begun even earlier. In December 1973 the University of California, Irvine, Extension held a conference entitled ‘The Aliso Creek: Potentials, Problems, and Public Policy’ coordinated by a former county planning commissioner and with an afternoon session led by a member of the county’s planning staff. Beginning in 1974, some 40 separate land parcels were assembled to create the park. The initial planning was funded by the California Coastal Conservancy, and later work was undertaken by the county’s Department of Harbors, Beaches, and Parks, often with funding from competitive state and federal grants. A proposed six-lane highway down the canyon as removed from the county’s Master Plan of Arterial Highways specifically to preserve Aliso Creek in its natural configuration. Over the years the canyon’s original riparian vegetation has gradually reestablished itself after more than a century of grazing. Although invasive species may be spotted in the riparian zone, the vast majority of plants are typical native riparian species, including cottonwoods, sycamores, willows, and mulefat. The county is pursuing funding for removal of the invasives, and we hope to see this work undertaken without waiting for any ultimate plan for the creek.
The Aliso Creek watershed inland of the park is now heavily developed, and recent years have seen a substantial increase in runoff as a result of this development that increased the flow of the creek, exacerbating seasonal flooding, and poured urban pollutants into it. Much of this development was made dependent on a commitment not to increase runoff into the creek, but the facilities for fulfilling this commitment have not been established.
At the same time as being the heart of the wilderness park, Aliso Canyon has become the conduit for treated wastewater from the treatment plants of the surrounding communities to the ocean outfall at Aliso Beach. The original idea, when the Aliso Wastewater Management Agency was founded in 1974, was that the inland cities would recycle their wastewater. The outfall constructed along the creek was expected to be used only in winter, when the supply of reclaimed water would exceed the demand for it. Although recycling is under way in the various inland water districts, the demand for outfall capacity has increased over the years. The existence of sewer pipes in the ground along the banks of the creek and the desire to install more of them have created a perceived need to lock the creek in place so that these pipes will not be threatened by erosion.
The project that Orange County calls the SUPER Project—whose acronym stands for Stabilization + Utility Protection + Environmental Restoration—is primarily an attempt to prevent the creek from encroaching on these pipes. It involves (1) the construction of a buried riprap wall 3 miles long beside the maintenance road east of the creek, (2) twenty-four 2-foot grouted-rock drop structures sunk into bedrock, each with a 30-foot-long basin below it that will be protected on both banks with stone, (3) two 6-foot drop structures with 150 feet of concrete revetment downstream of them along both banks, and (4) realignment significant filling of the channel. According to the County’s Aliso Creek Concept Report (February 2006), ‘The actual channel will not be intact in much of the project reach’ (p. 27). Grading is expected to be so extensive—involving some 70 acres of the canyon floor and moving 1 million cubic yards of earth—that there will be little opportunity to preserve desirable stands of existing vegetation (p. 28).
The objectives of the Aliso Creek Mainstem Ecosystem Restoration study bear a close resemblance to those of the SUPER Project, though the study makes no mention of protecting utilities and lacks the project’s water-quality component. As does that project, it involves grade controls and the raising of the floodplain, and one Corps supporter at a recent meeting declared that restoring a creek in a developed area sometimes requires concrete. Further, the techniques for restoration of vegetation described by David Derrick of your Vicksburg office all seem to involve the import of tons of rock. All this and the fact that the SUPER Project closely follows the recommendations of an earlier Corps of Engineers study for Aliso Creek persuade us that our concerns about damage to the creek and the wilderness park remain relevant in the new context.
Destroying the existing riparian vegetation, grading the canyon floor, and placing concrete and rock in the creek would be devastating to the wilderness park and are inconsistent with the County’s General Plan.
The County’s 2008 draft resource management plan for the park, produced with broad public input, is described as a blueprint for ‘protecting and preserving the native habitat in the park for the benefit of its natural resources and providing outdoor education and low-impact recreation consistent with resource protection goals.’ It proposes improving the quality of the water in the creek through such methods as manufactured wetlands and portable filters. It also calls for assessing proposed projects for their potential impacts to park resources.
The technical review of the concept plan by an outside consulting firm (Aliso Creek Concept Plan Report, Technical Review, prepared by Geosyntec in January 2007) stresses the importance of addressing the causes of creek instability and water-quality degradation and the potential for limited mitigation measures to have unintended consequences (p. 16). It indicates that the two-year storm event for which the channel is to be designed may or may not be appropriate (p. 10) and points to ‘indications that past efforts at peak-flow ‘shaving’ for a series of storm events (two-year and up) have not successfully protected the creek and have actually accelerated stream erosion’ (p. 16). The review recommends consideration of ‘alternatives that may result in improvements in design, cost savings, and/or improved habitat,’ among them the use of (1) biotechnical streambank stabilization methods, (2) methods that could lengthen flowpaths and reduce the required amount of grade control, (3) tiered levels of protection, and (4) creek enhancement measures promoting a return closer to natural hydrologic wetting patterns and biodiversity (p. 11). It also recommends the development of upstream detention and retention facilities to ‘reduce pollutant loadings throughout the creek, mitigate dry weather flows, and reduce required capacity of treatment downstream’ (p. ES-3). ‘Without an integrated, strategic approach,’ it concludes, ‘SUPER Project benefits could be limited in longevity and multi-benefits, as pollutant and hydrologic loading could stress, and potentially reimpact, the restored creek segments’ (p. ES-3).
The Concept Report itself (p. 40) identifies five sites—two in the park and three on public land owned by cities—on which detention, infiltration, or wet basins could be constructed. An additional site that has recently attracted attention is the huge parking lot of the federal building on Alicia Parkway locally known as the Ziggurat, which is now for sale.
The Aliso Creek Stabilization Project Review prepared by Phillip Williams and Associates for the City of Laguna Beach (May 29, 2009) suggests that, contrary to the assessment of the earlier studies, the relevant section of the creek (from Alicia Parkway to the sewage treatment plant) may be close to or at equilibrium and starting to form a new floodplain. Accordingly, it suggests that the channel could be stabilized by introducing as few as three 2-foot and two 6-foot grade control structures or, alternatively, by stabilizing the base of the ACWHEP structure and allowing another 6 feet of incision downstream. The latter alternative would allow the self-formation of an equilibrium system that would be ‘more likely to be resilient to large flood events than a system that is kept out of equilibrium using hardscape, as well as likely to function [more naturally] and appear more natural’ (p. 23). The PWA review advises the City to have fairly modest expectations about using upstream stormwater control to reduce erosion downstream but to take advantage of opportunities to ensure that future development upstream does not make matters worse and to improve the situation incrementally through low-impact development and stormwater detention. In further contrast to the Concept Report, in which the effects on sand supply to the beach are considered indeterminate, the PWA review considers the sand discharged from the creek ‘very important to the system’ of maintenance of our beaches and not something that should be ‘locked in place’ to stabilize the creek (p. 25).
The proposed new wastewater management regulations (Revised Tentative Order R9-2009-0002)—the MS4 permit—under review by the San Diego Regional Water Quality Control Board includes stricter regulations of discharges into the creek that can perhaps be expected to reduce the excess flow that is so important a part of the problem. It would prohibit dry-weather discharges into the creek, thus helping to return it to something more like the intermittent stream that historically it was, and require controls on stormwater discharges through the careful planning of new development and retrofitting of existing development with detention basins.
The current water shortage and new state laws requiring water efficiency in landscaping in response to that shortage are likely to serve as additional incentives for capturing and reusing much of the water that now ends up in the creek.
The various reports of the creek stabilization proposals agree that past efforts to rein in the creek with concrete and rock have been a failure and have actually contributed to its erosion. The drop structure known as the Aliso Creek Wildlife Habitat Enhancement Project (ACWHEP) is an eyesore in addition to a testament to this failure and ought to be demolished. Elsewhere in the country, we understand, the results of such efforts are being dismantled in favor of natural solutions. We hope that the feasibility study will take our concerns about this approach into account and that a noninvasive solution to Aliso Creek’s problems will emerge from it.
Problems with the SUPER Project approach and suggestions for better alternatives can also be found at Laguna Concerns