Guest Opinion | Tim Brick: Pasadena’s Arroyo Seco Project Has a Credibility Problem

The Arroyo Seco Water Reuse Project was originally conceived as a stream restoration and conservation project, but Pasadena officials have increasingly defended it as a near-unavoidable response to state mandates. The August 6 Pasadena Star-News article even framed the project as “Facing state pressure,” reporting that Pasadena and South Pasadena have been out of compliance with bacteria standards since 2023 and could face penalties of at least $10,000 per day. No penalties, however, have actually been levied.

That framing leaves out the most important fact in the record: the Los Angeles Regional Water Quality Control Board — the very regulator Pasadena invokes — has expressly said that the relevant water-quality mandates do not require this particular project and would not be achieved by it.

In a July 2, 2026 letter commenting on Pasadena’s Draft Environmental Impact Report (DEIR), Assistant Executive Officer Jenny Newman wrote that approval of the regional watershed management program “does not constitute approval of specific projects” or a mandate that they be implemented. The Board went further: “the Project is not required by the Total Maximum Daily Load or the Municipal Stormwater S4 Permit,” the two key elements of clean water enforcement. It also found that the current design would not help achieve TMDL compliance in wet weather and would provide only limited dry-weather compliance below the San Rafael diversion point.

That is not a minor technical clarification. It cuts directly against Pasadena’s public justification.

We all want clean water in the Arroyo, and Pasadena is entitled to propose a water-treatment project, but the city should not tell residents, neighboring cities and decision-makers that the state has effectively left it no choice when the state regulator itself says otherwise.

The Water Board’s letter also exposes a deeper problem: Pasadena has described the two project sites in ways that minimize what is actually there.

At San Rafael, near Pasadena’s southern boundary, Pasadena’s Draft EIR identifies San Rafael Creek as a “storm drain.” The Water Board says that is simply wrong. “San Rafael Creek is not a stormwater facility but a water of the state,” Newman wrote, directing Pasadena to correct the DEIR throughout.

That distinction matters. Pasadena’s project would divert all dry-weather flow and some wet-weather flow from the creek. According to the Board, removing that water would “effectively remove all beneficial uses in San Rafael Creek” and could adversely affect downstream waters, such as the Los Angeles River. The Board specifically rejected Pasadena’s assertion that no downstream habitat would be adversely affected, pointing to designated uses that include freshwater habitat, wildlife habitat, rare or threatened species, spawning and aquatic migration.

San Pascual is similarly mischaracterized. The project descriptions in the DEIR can leave the impression that Pasadena is simply adding a new “nature-based” wetland treatment system to disturbed land. The regulator describes something considerably different: an existing diversion already directs dry-weather flow into an existing stream and wetland, and the proposed project would remove that stream and wetland and replace them with a new engineered treatment wetland. “Water exiting the wetland would be directed to the Golf Course for irrigation.”

Indeed, the Water Board explicitly disagrees with the DEIR’s finding of “No Impacts,” citing both the diversion of San Rafael Creek and “the removal of the unnamed stream and wetland at the San Pascual site.”

Even more striking is what the regulator says about the basic strategy. The Water Board states that diversion projects intended to address upstream discharges should be undertaken only as a “last resort.” Pollution should first be addressed at the source.

The Board letter also says Pasadena has failed to adequately consider alternatives that would return some or all treated water to the Arroyo Seco stream. It warns that Clean Water Act Section 401 certification may be denied if the project fails to demonstrate that it is the Least Environmentally Damaging Practicable Alternative.

Then there are water rights. Because the project proposes to divert all dry-weather and some wet-weather flows, the Board says the DEIR must address Pasadena’s and South Pasadena’s rights to divert and use water from San Rafael Creek and the Arroyo Seco. South Pasadena claims that they have been using water for the golf course for years, but they have not been able to produce a water right or any of the required annual diversion reports.

This is hardly a regulatory green light. The Water Board’s stated goal under the federal Clean Water Act and California’s Porter-Cologne Act is not merely to hit a bacteria number. It is to protect water quality and the beneficial uses of waters of the state, including their physical and biological integrity.

Pasadena should stop hiding behind “state pressure.”

The honest policy question is not whether the state is forcing Pasadena to build this project. The state says it is not. The issue is whether Pasadena should proceed with a project that its own regulator says may unnecessarily dewater a creek, eliminate existing aquatic habitat, inadequately analyze cumulative effects, leave water-rights questions unanswered, and fail to demonstrate the least environmentally damaging alternative.

Pasadena’s project began seven years ago as a stream restoration project, but the Board’s letter shows that essential components of a nature-based approach have been lost. Our community deserves an open, honest debate—not mandates that don’t exist. Pasadena should choose transparency over pretense, confront what the regulator has said, and protect our natural resources for generations to come.

Tim Brick is the Executive Director of the Stewards of the Arroyo Seco.