The County of Los Angeles is seeking public comment on the LA River Master Plan 2020. Submissions close on Thursday May 13, 2021.
This is a different process to comments on the Program Environmental Impact Report (PEIR). Those comments are due on the same day, but they’re a separate thing. You can read more here.
Your comments need to be sent to:
County of Los Angeles Department of Public Works
Subject line: “2020 LA River Master Plan Comments”
For instant activism. you can use this handy template developed by Friends of the LA River and a coalition of other advocacy groups.
For More about the Plan, go to the Master Plan 2020 website
As ever, you’re welcome to adapt or reuse anything from my letter. The important thing is that you send a letter, by Thursday May 13. If you have feedback on this letter, please do reach out by email. I’m at firstname.lastname@example.org.
County of Los Angeles Department of Public Works
13 May 2021
2020 LA River Master Plan Comments
I am writing to comment on the County’s draft LA River Master Plan. I am an independent scholar and the founder/curator of Los Angeles River X. I have over a decade of international research and community engagement expertise in river landscapes and their complex interrelationships with surrounding communities, particularly the Los Angeles River. On that basis, I make the following comments.
The County is the only agency with jurisdiction to take a genuinely whole-river, whole-watershed approach. The draft Master Plan fails to do this, and missing this opportunity is unacceptable. The confined geographic reach of the plan – just a mile to either side of the mainstem – signals that the County is continuing to take an infrastructural not an environmental view. This Plan conceptualizes the river as many things, but rarely actually as a river. This begins in the vision statement, and metastasizes across the entire document. The River and the City deserve better than this.
No robust evaluation of the preceding Master Plan
It is surely a basic principle of planning that a robust evaluation of the existing 1996 Plan should have been conducted. I have seen very little evidence of this in the documentation nor in public meetings. I ask that the team systematically documents the achievement or otherwise of each recommendation of the 1996 Plan and analyzes reasons for successes and failures. It is only through a programmatic evaluative approach that there can be genuine improvement in the visioning and management of the river. The elephant in the room is that the success or otherwise of the 1996 Master Plan remains unevaluated and this is an unstable footing on which to rest a new plan.
Comments on the 9 Goals
Goal 1: Reduce flood risk and improve resiliency
I take issue with the premise that concrete removal is not an option because ‘it is not feasible to remove the concrete from the LA River without causing significant negative impacts to communities and local culture’ (p. 23). This explanation uses an all or nothing argument, which is flawed. I agree, obviously, that a ‘holistic 51-mile restoration strategy is not realistic, even on a generational timeline’ if restoration is defined as removal of all channelization infrastructure for the entire 51 miles . This goes without saying. However, a Plan that prioritized ecosystem services could selectively remove and reshape concrete to maintain or even improve flood protection whilst also undoing some of the extremes of channelization, in areas, not everywhere. The dismissal of these possibilities, and in fact a suggestion that the County intends more channelization, is very concerning.
I am concerned that reducing peak flows to the river (p. 149) contains no mention of stormwater flow reduction (rain gardens, water retention, infiltration basins, urban acupuncture and the like, at various scales) but rather proposes ‘capacity increasing measures as appropriate, such as modifying the channel, deepening the channel, raising levees, building bypass channels or tunnels, removing invasive plants, or removing sediment from the channel’. This sounds more like 1938-style flood control thinking, rather than 2020.
It is startling that studying climate change impacts in the LA Basin and how they impact hydrology and sea level rise is a future action in the plan (p. 149), not a foundational underpinning of the Draft Plan. How can the river and the city possibly be well-served by a 25-year plan that isn’t built on robust climate science?
I commend the actions around increasing public awareness of flooding (p. 150), but systemic solutions are also crucial, such as not permitting dense developments inside of high-risk flooding areas.
Goal 2: Provide equitable, inclusive, and safe parks, open space, and trails
The Master Plan presents an overly-developed, hyper-mediated, and human-centric idea of what open space means. This concerns me greatly, and I would like to see this tempered in the final version of the Plan.
The cadence of pavilions proposed for the river undermines the opportunity for immersive and authentic nature connection. The idea of building a pavilion every 0.4 – 0.6 miles and restrooms every mile on both riverbanks is excessive. Adding wayfinding and interpretive signage at access points and every half-mile threatens to overwhelm the visual landscape and diminish opportunities for self-directed exploration and nature immersion which are integral to people’s biophilic relationships with place. The goal should be to create authentic nature spaces, not a highly manicured and regulated theme park-like river.
While I heartily agree that ‘clean-up of brownfield and toxic sites along the river for use as parkland and habitat areas’ (p. 156) is an important action, I am concerned that the extent of commitment to doing so is that it will be ‘encouraged’. River-adjacent communities have long lived with (and tragically died from) the environmental burdens of these toxic sites. Those communities tend to be low income, and communities of color, and they are heavily burdened by multiple layers of disadvantage and exploitation. Encouraging clean-up is weak and insufficient.
The goal to ‘encourage compatibility of the river and adjacent land uses’ reads like a recipe for gentrification and displacement. While certainly, ‘adjacent open spaces, restaurants, or retail that connect with the river could encourage patrons to use the river trail, and users of the river trail could increase patronage of those adjacent uses’ I disagree with the Plan’s assertion of mutual benefit. Or more specifically, I ask that the final draft more specifically identify who the intended beneficiaries are. I cannot imagine that long-term residents, many of whom are BIPOC or low-income, would be using or benefitting from the restaurants, retail spaces, increased traffic and crowding from visitors to their neighborhoods along the river.
I strongly object to platform parks. Whereas municipalities across the world are daylighting creeks and rivers to restore them, you are proposing to do the very opposite, capping the river in concrete platforms and constructing parkland on top which would do little if anything to improve air, water, or soil quality. This would be an unacceptable misstep in the river’s revitalization.
This section of the Plan sounds decidedly touristic and not for locals (many of whom know the river well already). It seems pro-commercialization, and threatens opportunities for free river enjoyment, for informal street vending, and for exploring nature rather than being casketed into a highly curated river experience.
Goal 3: Support healthy, connected ecosystems
I am very concerned that the action ‘collaborate with academic institutions and non-governmental organizations to collect data on ecosystem function within the LA River watershed and along the LA River corridor’ (p. 168) is an action of the Plan and not something that has already happened to fundamentally underpin the Master Plan. If ecosystem function data collection is an afterthought, it is little wonder that this draft Plan pays so little attention to ecology. This needs to be rectified in the final version. I echo this same concern for ‘collaborate with scientific research teams to increase the knowledge available about wildlife along and in the LA River and to create species profiles for different sectional conditions along the river’ and ‘consider findings of the LA River Ecosystem Restoration Project in determining habitat opportunities’ (p. 168). These all should have been built into an underpinning data bank informing the Master Plan. That it wasn’t suggests that the County’s priorities are elsewhere than on increasing or even protecting habitat and ecosystem function along the river corridor.
There are various Actions within this goal that would be great for the river, but they are worded weakly, and there is nothing in the Plan that builds confidence that they will be given priority over commercialized, gentrifying and destructive river developments. Examples include ‘Encourage cities along the river to adopt sustainability strategies,’ ‘Create a connective network of habitat patches and corridors to facilitate the movement of wildlife and support a diverse ecological community,’ ‘Where natural soils are degraded, remediate soils to support healthy ecosystems and the development of soil systems that can improve soil moisture retention and plant health,’ and ‘Support opportunities to acquire land in the corridor for projects that increase habitat and ecosystem function along the river.’ I strongly support these Actions but without any commitments or prioritization in the Master Plan I worry that they will not be realized. Please ensure the final version treats these fundamentally important matters with higher priority.
Goal 4: Enhance opportunities for equitable access to the river corridor
Goal Four is excessively human-centric, a reflection of the Master Plan’s vision statement which – unfortunately – is entirely centered on human enjoyment of the river. I am a strong advocate for people interacting with the river, accessing the river, and learning from the river. However, human enjoyment of the river as a destination cannot be the driving force of the Master Plan. Rather, if the Master Plan prioritizes environmental justice, restoration, and ecosystem values, the river will be a healthy and thriving place which will in turn attract people to explore and learn from it. The current draft of the Master Plan places excessive emphasis on people visiting and benefiting from the river, and far too little on meaningful restoration or future proofing. This needs to be addressed.
Goal 5: Embrace and enhance opportunities for arts and culture
The Plan notes that ‘the corridor has potential to be a major cultural destination that is also locally rooted in equitable access to cultural infrastructure, architecture, and landscapes’. I argue that it already is: SELA Arts Festival, Meeting of Styles, Hopscotch opera, Projected Visions, Frogtown Artwalk, River Catz, the Great Wall of Los Angeles, the Saber and MTA graffiti pieces (now abated), the river’s starring role in film and television, just to name a few. As curator of LA River X, I see on a daily basis how the river inspires and fuels artists and culture-makers across the city and beyond. The Plan shows a lack of appreciation for the existing arts and culture profile of the river.
The Plan writes only in past tense about the river’s role in global graffiti culture, and gives little hope that this would be protected or nurtured in any way in the next 25 years.
One of the precious qualities of the river is that there is spaciousness that allows informal exhibitions and performances – performances, installations, land art – to be offered by artists. This is likely to be severely hindered by the highly controlled character of the Master Plan. That control would be a tremendous cultural loss for the city.
I would also ask that the legal implications of Action 5.1.6 – ‘Require that all permanent art within the LA County Flood Control District right-of-way be deeded to the LA County Flood Control District’ (p.184) – be explained.
Goal 6: Address potential adverse impacts to housing affordability and people experiencing homelessness
River-adjacent communities have long demanded community-driven restoration and park access to the LA River. Implementing major park construction in low and extremely-low income communities poses a threat that current residents will be displaced by new projects. The County must invest heavily in anti-displacement programs and policies, and implement them before any project construction is underway.
Goal 7: Foster opportunities for continued community engagement, development, and education
While I commend the intention to ‘develop educational materials for people of all ages to learn more about the past, present, and future of the river corridor; natural resource protection; and the wildlife and water of the LA River’ (p. 202) I would like to see a commitment that such materials will be pedagogically courageous. By this I mean they must include environmental justice, countercultural, gentrification, and antiracist themes, as well as addressing shortcomings and controversies in river management as well as successes. If they fail to do so, learners will have access to only whitewashed and selective perspectives, which is unacceptable.
To say that ‘there is still much to learn about and document from present day Tribal communities’ (p. 203) is true, but concerning because it’s too little, too late, to do this after the fact. This should have been integral to the Master Planning effort, yet the draft does not show robust engagement with all Native American communities in the watershed. Further, the goal to ‘foster and expand an ongoing conversation and collaboration with local Tribal governments and local Native American communities about advancing the LA River Master Plan’ (p. 203) suggests less of an interest in learning from and implementing traditional ecological knowledge practices, and more of a tokenistic engagement with Native communities to advance the goals of a Plan that was not authentically collaboratively developed with indigenous input. The Master Plan needs to demonstrate intentional engagement with indigenous peoples of the area, and include strategies for maintaining and strengthening this throughout the Plan’s life. Settler colonialism and relentless actions that seek to erase native people and culture must be countered in this Master Plan, and unfortunately that is not yet evident in the draft.
I would like to see goal 7.4.2 (p. 204) strengthened to include prioritizing, incentivizing and seeding BIPOC-owned businesses to be able to win service provider and concessionaire contracts. This could offset gentrification risks inherent in the Plan.
As happens often in this Draft Plan, goal 7 raises grave concerns about underpinning work that has not been undertaken in the master planning exercise. It is too little and too late to ‘Identify community vulnerabilities, such as displacement risk, flood risk, or climate vulnerability, and investigate potential impacts associated with river improvement projects.’ and to ‘Develop a strategy to address identified threats by projects to community and resident stability, particularly forces of economic displacement, flood risk, and climate risk’ (p. 205) after the Plan is approved. These should have been fundamental building blocks informing the Plan’s development.
Goal 8: Improve local water supply reliability
While many of the Actions in this Goal are beneficial ones, and it is one of the few places that a more whole-of-watershed approach is evident, my overarching concerns persist here about the Plan’s vague and prolific suit of Actions that are not prioritized or expressed in ways that gives confidence that they will indeed be actioned.
Goal 9: Promote healthy, safe, clean water
This goal needs further development. The statement that ‘while over 800 water quality improvement projects are planned, in development, or have been completed within the river’s watershed, additional efforts are needed to meet established water quality Targets’ (p. 215) uses obfuscating language and fails to evaluate successes or failings of 1996 Master Plan in this regard.
The major flaw in this section is that it only considers sub-watersheds within the LA River watershed that directly drain to the LA River, not its tributaries (p. 216). This profoundly disregards how watersheds work, neglects the connectivity of the system, and tempers the chances of any meaningful improvements in water quality.
I am concerned by the prospect of water being diverted from the LA River to ‘enhance habitat, support recreation, or supply water for municipal and industrial uses’ (p. 218). Without an ecological or justice framing of the Master Plan, this risks the removal of water for the benefit of industrial and commercial interests, damaging the river’s delicate, water dependent ecosystem and continuing the extractive, exploitative practices that have for decades plagued the Los Angeles River.
Conflicts of interest
I am concerned that some of the same consultants and firms who have developed the Master Plan are also actively engaged in and commercially benefiting from river development projects, such as the SELA Cultural Center. These overlaps, and any efforts that have been made to manage actual or perceived conflicts of interest, should be disclosed in the Plan to ensure transparency.
Complexity of the Document/Unhelpfulness of Public Meetings
The suite of Master Plan documents is cumbersome, lengthy and inaccessible. This has been compounded by the PEIR public comment period closing on the same date (both confusing and cumbersome for community members). The pandemic has been an additional compounding factor, as meetings, access to physical copies, or viewing large-scale maps, have not been possible. The online information and town hall sessions that were held by the County and its consultants were inadequate. Some meetings prohibited questions, only allowing comments. At others, not all questions were addressed and were only visible to the organizers not to other attendees, quashing opportunities for learning from fellow community members’ perspectives. Document complexity, coupled with poorly designed online meetings, places tremendous burdens on readers and locks people out of the public comment process.
I have also written several queries to the County Master Plan team, using both the email address and the web form, which have gone unanswered. This is very concerning as if it’s happened to me, I suspect it has happened to many others.
The problem with the expansive, let a thousand flowers bloom sensibility of the Master Plan is that it will not lead to strategically prioritized action by the County and other jurisdictions. Instead, it will incentivize private interests to develop along the river. Where there is money we will see momentum, likely bringing about gentrification and displacement. This would be a tragic loss for the river and the city.
We need guarantees that displacement, housing affordability and climate resilience will be meaningfully addressed, This needs to happen before projects are built. We need numeric goals set for addressing climate change issues like urban heat impacts, water quality, and flood control. We need prioritization, because some issues need more attention and resources and the draft Plan does nothing to focus attention on those matters.
Many river adjacent communities are already heavily burdened by environmental injustice and this Master Plan does little to remedy that legacy. Indeed, it risks making the situation much, much worse.
The current draft LA River Master Plan, if accepted as is, would cause significant adverse environmental effect. The Master Plan is also a missed opportunity for doing something truly remarkable for the environmental (and that includes human) remediation and safekeeping of our city. I request that the County substantially change the proposed Master Plan addressing community concerns before it proceeds any further.
Tilly Hinton, PhD