Exhibit 2 CEQA IS_MND Responses to Comments (2026-04-30) — Glendale City Council, June 9, 2026

1 INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION -

RESPONSES TO COMMENTS
G
lendale-Los Angeles Garden River Bridge
The D
raft Initial Study/ Mitigated Negative Declaration was prepared pursuant to the California Environmental Quality Act Guidelines (CEQA Guidelines), Article 6 Negative Declaration Process, Sections 15070 to 15075. The public review period of the Draft Initial Study/ Mitigated Negative Declaration was from January 19 to February 17, 2026. The following comment letters were provided to the City of Glendale during the public review period:

Agency/ Entity/ Individual Date Received by City of Glendale California Department of Transportation (Caltrans) February 5, 2026 Francesca Smith February 16, 2026
The
following provides a summary of the comments contained in each of the letters received by the City of Glendale and responses to each of those.

C
altrans
C
altrans Comment
The Caltrans comment letter is included in Attachment A. The commenting agency indicates that the proposed project involves the construction of a bridge intended for the use by bicyclists and pedestrians, aimed at improving and promoting pedestrian access. As such, the project is not expected to result in an increase in vehicle miles traveled (VMT) or trigger the requirement for a VMT analysis. The project will support and enhance alternative means of transportation, designed to increase interjurisdictional pedestrian and bicycle access to LA River amenities, including the Glendale Narrows Riverwalk, Griffith Park, and nearby LA Zoo. Consequently, the impacts are anticipated to be less than significant.

A
ny transportation of heavy construction equipment and/or materials that require the use of oversized transport vehicles on State highways will need a Caltrans transportation permit. Any large-size truck trips should be limited to off -peak commute periods for the construction phase and operation phase. Construction truck loads should be covered with a tarpaulin cover . Storm water run-off is a sensitive issue for Los Angeles County. Please be mindful that projects should be designed to discharge clean run-off water.

C
ity of Glendale Response
The City of Glendale concurs that, as the proposed project would support and enhance alternative means of transportation designed to increase interjurisdictional pedestrian and bicycle access to the LA River amenities, it would not increase VMT or trigger VMT analysis.

D
uring construction, if oversized transport vehicles are needed on State highways, a Caltrans transportation permit would be applied for. Construction truck loads would be covered with a tarpaulin cover. The proposed project would be required to obtain coverage under the statewide National Pollutant Discharge Elimination System (NPDES) permit program which requires preparation of a project-specific Stormwater Pollution Prevention Plan (SWPPP) that outlines Best Management Practices (BMPs) to reduce stormwater and non-stormwater pollutant discharges.

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2 Francesca Smith

Francesca Smith Comment 1
Francesca Smith’s comment letter is included in Attachment B.

The comments contained in the letter from page 1 (starting 3 rd paragraph) through page 16 are
related to the Cultural Resources Assessment, Appendix C of the Initial Study Checklist/ Mitigated Negative Declaration. Responses to these comments are provided in Attachment C, prepared by BCR Consulting that prepared the Cultural Resources Assessment. The comments related to the Initial Study/ Mitigated Negative Declaration (IS/MND) in the latter part of the letter are summarized and responded to here.

The commenter indicates on page 17 she has unanswered questions related to the IS/MND project description and asks what kind of trees and other plantings exist in the baseline conditions; whether the proposed trees and planning materials will be compatible with the existing landscape, including in Griffith Park; asked how many of each tree are proposed to be planted; whether the planted trees will need irrigation; and who will be responsible for irrigation.

City of Glendale Response 1
The baseline conditions related to existing vegetation at the project site are described in Section E. Biological Resources of the Initial Study Checklist/Mitigated Negative Declaration (IS/MND), page 22, which states,“As the proposed Project site is within a concreted portion of the Channel, no riparian habitat or sensitive natural community, nor any sensitive natural communities identified by CDFW are supported or present within or in the immediate vicinity of proposed Project activities.” There are existing sycamore trees located in between Zoo Drive and the LA River, within the project footprint that require removal for project implementation, as outlined in the Project Description of the IS/MND, page 5, tree removal of approximately 18 western sycamore trees would be required to accommodate grading and Zoo Drive realignment. Only conceptual landscape plans have been developed to date; therefore, detailed construction landscape design has not been completed in order to be able to answer the commentors' questions. It is anticipated that permanent irrigation will be included, which would be the responsibility of the City of Glendale, with a financial contribution from the City of Los Angeles. The project description in the IS/MND contains a detailed and thorough description that meets and exceeds the requirements of the CEQA Guidelines Section 15071 (Contents of a Negative Declaration).

This comment does not provide new information or evidence related to the analysis completed in the IS/MND and does not reflect on the adequacy or content of the IS/MND. This comment is noted for the record, and no changes to the IS/MND are required.

Francesca Smith Comment 2
The commenter indicates on page 18 of the comment letter that the IS/MND indicates the bridge would be constructed of concrete whereas the “technical report states the bridge would be steel and concrete (page 1)”. The commenter also asks what the walking surface or deck material would be, whether there will be any jump protection; what will be the design, materials and finishes of such jump protection; what will be the design of the bridge pier base configuration; where proposed gates will be located; and what are the specifics on design, height, width, materials and finishes.

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3 The second part of the commenters' comment on page 18 , relates to the temporary and permanent impacts identified in the IS/MND , and whether the technical report (presumed to be the Cultural Resources Assessment) assesses the same impact areas.

City of Glendale Response 2

The proposed bridge type is a concrete box girder, which is a steel reinforced concrete structure (the steel is internal to the concrete). The final finishes and materials to be incorporated in the bridge design are not finalized. However, the final bridge design is expected to incorporate cast- in-place concrete for the bridge substructure and superstructure, textured and anti -slip concrete walking surfaces on the bridge, asphalt for the LA River Bike Path and Glendale Narrows Riverwalk, concrete with anti-graffiti coating or formliner for retaining walls, steel railings, and steel or aluminum canopy structures . Accordingly, the project description in the IS/MND contains a sufficiently detailed description based on what will be the reasonably foreseeable types of finishes and materials to be used in the final design. This description meets the requirements of the CEQA Guidelines Section 15071 (Contents of a Negative Declaration).

The total Project Work Area is approximately 7.3 acres and encompasses the area where construction activities will occur both within the LA River channel and outside and adjacent to the channel. This area is shown as Project Work Area Limits in the IS/MN D Figure 2 – Site Vicinity Map, Figure 3 – Glendale-Los Angeles City Boundaries, Figure 5 – Temporary and Permanent Impacts, and Figure 6 – Site Plan. Figure 3 – Glendale – Los Angeles City Boundaries has been revised to clarify and reflect the current Project Work Area Limits, consistent with the other figures, and the analysis throughout the IS/MND. Table 1 Comparison of Temporary and Permanent Impacts has also been revised to clarify and reflect the current Project Work Area Limits, consistent with the other figures, and the analysis throughout the IS/MND. The acreage of permanent impacts remains the same, at approximately 1.4 acres, while the temporary impact area, for access and staging was expanded by approximately 3 acres. The analysis throughout the IS/MND includes the 7.3- acre Project Work Area. These revisions clarify and correct the inconsistency of acreage shown in Figure 3 and in Table 1 with the remaining figures and analyses in the IS/MND. These clarifications are minor and do not trigger recirculation of the IS/MND, since these clarifications are not a substantial project revision; recirculation is not required where project revisions are added in response to written or verbal comments on the project’s effects which are not new avoidable significant effects. (CEQA Guidelines section 15073.5(c)) (Recirculation of Negative Declaration Prior to Adoption). The Cultural Resources Assessment, page 1, indicates “The area of ground disturbance on the channel floor has been calculated at approximately 8,500 square feet. Staging and access will all take place within the project site boundaries depicted in Figure 1.” The Cultural Resources Assessment evaluated the project’s potential impacts within the larger project site boundaries which extend outside of the Los Angeles River, as well as a focused look at the Los Angeles River channel, as that is the only historic resource in the project area that would be directly impacted by the project. As outlined on pages 10- 11 of the Cultural Resources Assessment, the Los Angeles River, of which the Glendale Narrows Segment and roughly coterminous Reach 3 (approximately 7.4 miles in length) constitute a portion, has been determined by the US Army Corps of Engineers as “presumed” historic district and is therefore also eligible for listing in the California Register and was considered a historic resource for the purposes of the analysis of potential impacts from the project. The 1.4 acre of permanent impacts identified in the IS/MND Table 1 and in Figure 5 – Temporary and Permanent Impacts (shown below) includes both impacts within the LA River channel from the bridge and bridge piers, as well as impacts outside the LA River channel, for bike path reconstruction, realignment of Zoo Drive and connection between Zoo Drive and the bridge (plaza, stairs, and ADA ramp). The proposed project will only have 0.03 acre (or 1,307 square feet) of permanent impacts for the EXHIBIT 2
4 bridge piers within the channel/on the channel floor, which is considered Waters of the US subject to US Army Corps of Engineers (USACE), Los Angeles District, jurisdiction. See page 22 of the IS/MND, and as shown in Appendix B Biological Resources Assessment, Figure 9 - USACE & RWQCB Jurisdictional Impacts Map.

This comment does not provide new information or evidence related to the analysis completed in the IS/MND and does not reflect on the adequacy or content of the IS/MND. This IS/MND has been revised to reflect (i) the final tribal cultural resources mitigation measures from the completed AB 52 consultation; (ii) corrections to typographical errors, (iii) revision to clarify information presented and correct internal inconsistencies, and (iv) to reflect an updated cultural resources report that was revised in response to comments received. Refinements made to this Initial Study Checklist do not change the environmental analysis and conclusions presented and do not warrant recirculation pursuant to CEQA Guidelines Section 15073.5 (Recirculation of Negative Declaration Prior to Adoption).

Francesca Smith Comment 3
On page 19 of the comment letter, the commenter asks what the length and width of Zoo Drive that is proposed to be realigned; what is the maximum dept of disturbance;, how would such realignment impact Griffith Park; how many and what species of trees between Zoo Drive and the LA River bike path would be removed ; where would the tree replacements be planted; would those replacement trees be irrigated and for how long. The commenter indicates that if a raised crosswalk is proposed across Zoo Drive, it should be depicted on plans, and the length and width of the proposed raised crosswalk should be shown.

City of Glendale Response 3
The realignment of Zoo Drive is shown on Figure 6 – Site Plan of the IS/MND and its length is approximately 700-feet with varying width , and a maximum depth of approximately 3 feet. The location of the raised crosswalk is shown on Figure 4 – Site Plan Render and on Figure 6 – Site Plan of the IS/MND and is anticipated to be approximately 32-feet wide and 24 -feet long. As outlined in the Project Description (page 5), tree removal would be required to accommodate grading and Zoo Drive realignment, and it is anticipated that approximately 18 western sycamore trees would be removed. S ome of these trees are under the jurisdiction of the City of LA’s Recreation and Parks Department (LARAP) and others under City of LA’s Bureau of Street Services (LABSS). Section 46.01 of the City of LA Municipal Code (LAMC) includes western sycamore trees as a protected tree species; therefore, the proposed tree removals within LABSS jurisdiction would require a Tree Removal Permit from the LABSS Urban Forestry Division.

Removal of protected trees requires replacement at a 4:1 ratio with the same species of trees as each species removed. The location of the replacement trees will be subject to the conditions of the future Tree Removal Permit.

Francesca Smith Comment 4
The commenter indicates on page 20 that the IS/MND identified an anticipated construction start date of Fall 2025 and that it is now winter 2026 and the environmental review has not been completed. The commenter indicates that the project’s website indicates construction will start in 2030.

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5 City of Glendale Response 4
The commenter is correct, that the current anticipated construction start has been updated in the project description of the IS/MND.

This comment does not provide new information or evidence related to the analysis completed in the IS/MND and does not reflect on the adequacy or content of the IS/MND. This Initial Study/Mitigated Negative Declaration (IS/MND) has been revised to reflect (i) final tribal cultural resources mitigation measures from completed AB 52 consultation, (ii) corrections to typographical errors, (iii) revision to clarify information presented and correct inconsistencies, and (iv) to reflect an updated cultural resources report that was revised in response to comments received. Refinements made to this Initial Study Checklist do not change the environmental analysis and conclusions presented and do not warrant recirculation pursuant to CEQA Guidelines Section 15073.5 (Recirculation of Negative Declaration Prior to Adoption).

Francesca Smith Comment 5
The commenter indicates on page 20 that the approach work, bike path work, and abutment work should be fully described, including the length, width, maximum depth, backfill, location of drains and location of any exported soil or other material. The commenter also indicates on page 20 that the design of piers should be fully described, including lengths, widths, depths, appearance, color and finish of concrete, and the location of any exported soil or other materials. The commenter asks if the plans will be reviewed for conformance with the Secretary of the Interior’s Standards for Rehabilitation by a qualified Historic Architect or Architectural Historian.

City of Glendale Response 5
Only conceptual plans have been developed to date. The detailed information that the commenter is asking questions about to completely describe the improvements are not made public until the release of the Notice Inviting Bids for the construction contract with the complete set of contract drawings, specifications, etc. The final finishes and materials to be incorporated in the bridge design are not finalized. However, the final bridge design is expected to incorporate cast-in-place concrete for the bridge substructure and superstructure, textured and anti -slip concrete walking surfaces on the bridge, asphalt for the LA River Bike Path and Glendale Narrows Riverwalk, concrete with anti -graffiti coating or formliner for retaining walls, steel railings, and steel or aluminum canopy structures.

As outlined in Attachment C - BCR Consulting Response to Comments Letter (page 1), the author of the Cultural Resources Assessment exceeds the Secretary of the Interior Professional Qualification Standards for Archaeology, Architectural History, and History and has successfully assessed and evaluated dozens of similar resources for projects subject to CEQA and Section 106 of the National Historic Preservation Act (NHPA). Appendix A of the Cultural Resources Assessment has been added to the report to include resumes of everyone that worked on the report, emphasizing qualifications. The findings of the Cultural Resources Assessment (page 11- 12), the LA River, determined the LA River to be eligible for National Register listing and as such is a historical resource pursuant to CEQA. Based on the small percentage of the LA River segment that will be subject to direct impacts, the proposed project would not result in a substantial adverse change to the LA River as an historical resource and, the plans will be reviewed for conformance with the Secretary of the Interior’s Standards for Rehabilitation by a qualified Historic Architect or Architectural Historian.

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6 This comment does not provide new information or evidence related to the analysis completed in the IS/MND and does not reflect on the adequacy or content of the IS/MND. This comment is noted for the record, and no changes to the IS/MND are required.

Francesca Smith Comment 6
On page 21- 22, the commenter asks that the project description describe the duration of the construction activities with hours as well as proposed temporary and permanent materials with heights above the bridge deck and channel, and that the proposed drainage for the bridge be described in more detail, materials, lengths, finishes, etc. The commenter also asks what other types of trees and plantings existing in the baseline condition and recommends the analysis use the ICF Jones & Stokes-prepared “Landscape Elements of Griffith Park” prepared in 2008.

City of Glendale Response 6
The IS/MND project description (page 6) indicates the project construction activities would conform to the City of Glendale’s Municipal Code, which prohibits construction from 7:00 pm to 7:00 am every night and from 7:00 pm on Saturday to 7:00 am on Monday. If and to the extent construction permits issued by the City of Los Angeles specify different times for construction activities on the City of Los Angeles portion of the Project, those construction activities would conform with those permitting requirements. Therefore, construction activities would be limited to 7:00 am to 7:00 pm Monday to Friday in Glendale and would conform with Los Angeles’ construction activity limits in the City of LA. Additionally, the IS/MND project description (page 5) indicates that construction is anticipated to last approximately 2.5 years. Only conceptual plans have been developed to date, and complete details about temporary and permanent heights, drainage, materials, etc. will be finalized during the subsequent permitting and final design phase of the Project.

As outlined in Response 1 above, there are existing sycamore trees located in between Zoo Drive and the LA River, within the Project footprint that require removal for Project implementation, as outlined in the Project Description of the IS/MND ( page 5) tree removal of approximately 18 western sycamore trees would be required to accommodate grading and Zoo Drive realignment.

The e LA Department of City Planning Recommendation Report 1 for Historic-Cultural Monument
Application for the Griffith Park project outlines the Character -Defining Features/Contributing Elements. One of the Character -Defining Features/Contributing Elements (#8) is a Sycamore Grove – “this grove of sycamore trees is on the western side of North Zoo Dr. and appears to be original to the park.” (emphasis added). In addition, the LA City Council Determination Letter for Historic-Cultural Monument Application for the Griffith Park 2 includes a Griffith Park Historic Resources Map which shows Historically Sensitive Resources and Areas, #8 Sycamore Grove, located south of the proposed Project site, south of the 5 and 134 freeways. The 18 western sycamore trees that would be required to be removed to accommodate grading and Zoo Drive realignment are located on the north side of North Zoo Drive, therefore, based on the LA Department of City Planning Recommendation Report and the LA City Council Determination Letter referenced above, the proposed Project would not affect Character-Defining Features/Contributing Elements of Griffith Park , including #8 Sycamore Grove and assessing compatibility with existing landscape at Griffith Park is not warranted. The Landscape Elements of Griffith Park (ICF Jones & Stokes, 2008 available at City of Los Angeles , Department of City Planning) describes component features of the Griffith Park landscape, which include entry programs, roads, the wilderness itself, picnic areas, and trails. The proposed Garden River Bridge is not located in or near either of the entries to the park or in the wilderness area of the park and

1 https://planning.lacity.gov/StaffRpt/CHC/10-30-08/CHC-2008-2724.pdf 2 https://plncts.lacity.org/pdiscaseinfo/Search/casenumber/CHC-2008-2724-HCM EXHIBIT 2
7 would not impact them. The proposed Project would not affect picnic areas or trails within the park. Character defining features of roads include the following:
• Alignments that correspond to natural features in the landscape • Gentle curves
• Roads take advantage of viewsheds and vistas
• Roads "girdle”" the wilderness area
• Certain roads have original Macadam-type surface
• Low, rounded curbs made of asphalt
• Roads no wider than three lanes
Tree specimens in medians and roadside not commonly seen in the wilderness area. The section of North Zoo Drive that would be affected by the proposed Project is not in or around the wilderness area that corresponds with the natural features of the landscape or take advantage of the viewsheds and vistas and does not have the original paving. The proposed Project would not increase the number of lanes. As outlined above the sycamore trees that will be removed along the north side of North Zoo Drive are not part of the #8 Sycamore Grove identified in the LA Department of City Planning Recommendation Report for Historic-Cultural Monument Application for the Griffith Park. As outlined in the IS/MND project description, sycamore trees removed that fall under the jurisdiction of the City of LA’s Bureau of Street Service (LABSS) require a tree removal permit and replacement at a 4:1 ratio with the same species of those removed. Therefore, the proposed Project would not adversely impact the character defining features described in the Landscape Elements of Griffith Park report (ICF Jones & Stokes, 2008).

Francesca Smith Comment 7
The commenter asks, on page 22-23, to describe the proposed work more fully, including demolition and grading, construction equipment, sizes and locations of timber mats, location of parking for personnel, temporary staging area, access ramps and additional staging areas.

City of Glendale Response 7
As outlined in City of Glendale Response 2, the total Project Work Area is approximately 7.3 acres and encompasses the area where construction activities will occur both within the LA River channel and outside and adjacent to the channel. This area is shown as Project Work Area Limits in the IS/MND Figure 2 – Site Vicinity Map, Figure 3 – Glendale-Los Angeles City Boundaries, Figure 5 – Temporary and Permanent Impacts, and Figure 6 – Site Plan. Figure 3 – Glendale – Los Angeles City Boundaries has been revised to reflect the current Project Work Area Limits, consistent with the other figures, and the analysis throughout the IS/MND.

Demolition activities are anticipated to occur along the LA River Bike Path, Zoo Drive, the Glendale Narrows Riverwalk, and portions of the LA River to facilitate construction of the proposed bridge and approaches. The LA River Bike Path will be graded (raised) approximately 6 feet to meet the bridge deck elevations. On the Glendale side, at the Glendale Narrows Riverwalk, minimal grading (less than 1 foot) is anticipated since the proposed bridge deck will be roughly at the elevation of the bike path. Two piers supporting the bridge are located within the LA River, and will require localized excavations – approximately 130-feet long by 8-feet wide and EXHIBIT 2
8 6-feet deep – to construct the foundations. This portion of the LA River has a concrete invert slab and timber mats are therefore not anticipated. Construction equipment will include concrete trucks, cast-in-drilled-hole concrete pile drilling rigs, mobile cranes, and excavators. The staging area is anticipated to be located along Zoo Drive, between Zoo Drive and the Ferraro Athletic Fields. Construction personnel would park in the staging area or along Zoo Drive. Construction equipment is anticipated to access the LA River via the sloped area between the LA River Bike Path and the invert slab of the LA River.

Francesca Smith Comment 8
The commenter indicates on page 23 that the analysis and the conclusion in the technical report (Cultural Resources Assessment) lack sufficient detail to prove that no impacts would occur. The commenter indicates on page 24 that weak identification of historical resources is a problem with the technical report, and that preparation of an Environmental Impact Report (EIR) may be necessary.

City of Glendale Response 8
The Cultural Resources Assessment does not conclude that “no impacts would occur,” as purported by the commenter. Rather, as outlined in Response 5 above, the findings of the Cultural Resources Assessment (page 11 -12), the LA River has been determined eligible for National Register listing and as such is a historical resource pursuant to CEQA. Based on the small percentage of the segment that will be subject to direct impacts, the proposed project would not result in a substantial adverse change to a historical resource, and plans will be reviewed for conformance with the Secretary of the Interior’s Standards for Rehabilitation by a qualified Historic Architect or Architectural Historian.

Therefore, the proposed project would not result in significant adverse impacts to a historical resource, and an EIR is not required pursuant to CEQA.

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Attachment A
Caltrans Comment Letter dated February 5, 2026
EXHIBIT 2

“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 7
100 SOUTH MAIN STREET, SUITE 100 | LOS ANGELES, CA 90012 PHONE (213) 897-0362 | FAX (213) 897-0360 TTY 711
www.dot.ca.gov

February 5, 2026

Dennis Joe, Principal Planner
Community Development Department
Development Services Division
City of Glendale
633 East Broadway, Room 103
Glendale, CA 91206

RE: Glendale - Los Angeles Garden River Bridge
Project
SCH # 2026010518
Vic. LA-134/PM R6.065, LA-5/PM 27.76
GTS # LA-2026-05003-MND

Dear Dennis Joe:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above-referenced project. The Project proposes the construction of a three- span, curvilinear, landscaped bridge across the LA River between the Cities of Los Angeles and Glendale for use by pedestrians and bicyclists .

It would feature extensive landscaping on the approaches , as well as on the bridge itself, and is thus named the "Garden River Bridge” . A number of raised and in-ground planting beds would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, and scenic views of the LA River. The intent of this multi- community resource is to increase access to Glendale Narrows Riverwalk and Griffith Park; to improve connections; and to increase the safety of paths used for pedestrians and cyclists. Dedicated access across the LA River at this key location would improve public safety and accessibility to important community resources by creating a connection between Glendale and Los Angeles across the LA River for pedestrians and cyclists.

The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. Senate Bill 743 (2013) has codified into CEQA law and mandated that CEQA review of transportation impacts of proposed development be modified by using Vehicle Miles Traveled (VMT) as the primary metric in identifying transportation impacts for all future development projects. You may reference the Governor’s Office of Planning and Research (OPR) for more information:

https://opr.ca.gov/ceqa/#guidelines-updates
EXHIBIT 2
Dennis Joe, Principal Planner
February 5, 2026

Page 2 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment”

As a reminder, VMT is the standard transportation analysis metric in CEQA for land use projects after July 1, 2020, which is the statewide implementation date.

The construction phase of the proposed project is expected to generate approximately 76 two-way construction trips per day, with 4 AM peak hour trips and 34 PM peak hour trips during the most intense phase. To mitigate potential off -site impacts, we concur with recommendation that employee and truck arrivals in the morning should avoid or minimize activity during the 7 -9 AM peak period, and employee and truck departures in the afternoon should avoid or minimize activity during the 4-6 PM peak period.

The proposed project involves the construction of a bridge intended for use by bicyclists and pedestrians, aimed at improving and promoting pedestrian access. Only maintenance vehicles, which do not contribute to Vehicle Miles Traveled (VMT), will be allowed on the bridge. As such, the project is not expected to result in an increase in VMT or trigger the requirement for a VMT analysis. The project will support and enhance alternative means of transportation, designed to increase interjurisdictional pedes trian and bicycle access to LA River amenities, including the Glendale Narrows Riverwalk, Griffith Park, and the nearby LA Zoo. Consequently, the impacts are anticipated to be less than significant.

Any transportation of heavy construction equipment and/or materials that require the use of oversized transport vehicles on State highways will need a Caltrans transportation permit. Any large-size truck trips should be limited to off-peak commute periods for the construction phase and operation phase. Construction truck loads should be covered with a tarpaulin cover.

Storm water run -off is a sensitive issue for Los Angeles County. Please be mindful that projects should be designed to discharge clean run-off water.

If you have any questions, please feel free to contact Mr. Alan Lin, the project coordinator at (213) 269-1124 and refer to GTS # LA-2026-05003-MND.

Sincerely,

Anthony Higgins
Acting LDR Branch Chief

email: State Clearinghouse
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Attachment B
Francesca Smith Comment Letter dated February 16, 2026
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1 FRANCESCA SMITH
February 16, 2026
Mr. Dennis Joe, Principal Planner
City of Glendale, Community Development Department
Planning Division
633 East Broadway, Room 103
Glendale, CA 91206
via e-mail

RE: Comments on Glendale-Los Angeles Garden River Bridge Mitigated Negative Declaration

Dear Mr. Joe:

I am grateful for the opportunity to provide comments on the “Glendale-Los Angeles Garden River Bridge Mitigated Negative Declaration” (MND, January 2026) and its cultural resources technical report. My review of the MND and the “Cultural Resources Assessment for the Garden River Bridge Project” (technical report or tech report) dated March 28, 2025 prepared by BCR Consulting, LLC. reveals numerous fatal ﬂaws and shortcomings.

Among the issues in this case is the Lead Agency using a Mitigated Negative declaration when all potentially significant impacts from the proposed project have not been identified, avoided or mitigated to a less than significant level by project revisions or other requirements imposed on the project. Preparation of a MND by a lead agency is based on the premise that the construction and implementation of the proposed project would not cause a significant effect on the environment. The project’s expected impacts to least one other known historic resource, Griffith Park have not been analyzed. The proposed project impacts to the Los Angeles River were not adequately analyzed either. Other potential built environment resources, including electrical transmission towers and electrical transmission lines in the Area of Potential Effects/Project Area Limits were not evaluated for historic significance or analyzed, if warranted, for impacts that could be caused by the proposed project.

Another important complication is the use of a preliminary archaeological investigation prepared by archaeologists as the project technical report to address the identification of built environment resources with a wholly inadequate impacts analysis. The preparers of the technical report are unfortunately, not qualified to evaluate or analyze impacts to built environment historic resources. Archaeologists are trained to examine human history by excavating below ground and analyzing physical material, such as ruins, artifacts, and landscapes. Conversely, architectural historians evaluate design, construction methods, and cultural significance of existing usually “above ground” built environment resources, using written records and professional judgment to identify significant properties and to analyze expected effects of proposed projects.

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2 Phase 1 Cultural Resources Assessment
The technical report is described in the Management Summary on page ii as a Phase 1 Cultural Resources Assessment. A Phase I report is term-of-art which is limited to archaeological investigations. That report type is deﬁned
Phase I investigation consists of a combination of background research and fieldwork designed to identify resources and define site boundaries within a given project area or area of potential effect[s] (APE1). Phase I fieldwork consists of several methods including pedestrian survey, excavation of limited shovel test probes, or remote sensing. The use of specific field methods and techniques is dependent upon the type of ground cover present, the topographic setting, and the amount of observed disturbance in a given area (National Park Service. Cultural & Natural Resources, Cultural Resources “Cultural Resource Identification & Evaluation” at https://www.nps.gov/dscw/cr-identification-evaluation.htm accessed on January 21, 2016).

Archaeologists and architectural historians are entirely separate disciplines and are not interchangeable. The Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation clearly define minimum “Professional Qualifications Standards” for History, Archeology [sic] and for Architectural History. I meet and exceed the qualifications standards for booth Architectural History and History. Let me know if anyone would like to review my qualifications. Page 7 of the Phase I, the “Personnel” section enumerates the qualifications of the technical report preparers. The iterated qualifications are ambiguous for the Project Manager, Principal Investigator and author of “the technical report and [California] Department of Park and Recreation (DPR) 523 forms for the current study” as well as for the Archaeological Crew Chief. The qualifications of the Consulting Staff Historian who assisted in preparation of the DPR form are not provided. Technical studies for the built environment are prepared by professionals who meet the Secretary of the Interior’s Professional Qualifications Standards for History, Architectural History or Historic Architecture, not by Archaeologists with the services of a Historian.

Identification of Historical Resources
Another related and significant error in the tech report is burying and not even addressing what the historical resources are in the project’s Area of Potential Effects (APE). The “Direct APE” on page 2 of the technical report and the Project Area Limits (PAL see Figures 1 and 2) are not defined. The following page contains “project work area limits” (Figure 1 on page 3) but neglects to identify where much of the work and ground-disturbing activities would be (see Outstanding Questions on pages 17-22). Worse yet, neither the referenced project Direct APE nor the PAL is defined in the document.

1 Area of Potential Eﬀects (APE): A term used and deﬁned in National Historic Preservation Act Section 106 regulations as the geographic area or areas within which an undertaking may cause changes in the character or use of cultural resources, if any resources exist there. This area always includes the actual site of an undertaking, but may also include other areas where the undertaking will cause changes in land use, traﬃc paĴerns, or other aspects that could aﬀect cultural resources, including visual, atmospheric, or audible changes (see “Deﬁnitions” at National Park Service. Home; Information; Deﬁnitions- A at hĴps://www.nps.gov/dscw/deﬁnitionsdc_a.htm#ape accessed on January 21, 2026).

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3 Figure 1: Project
Area Limits, Exhibit
C: “Detailed Project
Exhibit” in technical
report. Visible CAD
comment is
“proposed ADA
ramp.”

Figure 2: Project
Work Area Limits,
Figure 6 in MND.

The indirect APE or PAL for the project must be defined and surveyed as well. It should, at minimum, include all project-related potential staging and staff parking areas unless additional supplemental environmental review would be prepared after those staging and parking areas were identified.

An APE or PAL boundary must cover areas of direct physical impact (e.g., demolition, construction and implementation) as well as indirect impacts (e.g., noise, vibration, staging and parking areas, future related changes, alterations to setting and visual intrusions). There is no defined or delineated subterranean or vertical APE or PAL defined either, for a project that would include significant construction activities and result in permanent changes both beneath and far above finished grade.

EXHIBIT 2
4 The technical report’s Significance Evaluation section is entirely superfluous and seems to struggle to make a finding regarding the Los Angeles River’s California Register eligibility.

There should be no question: the Los Angeles River Channel was determined eligible for the National Register in 2019. Because the linear resource was determined eligible (not “found” nor does it “appear to be eligible”), therefore the Los Angeles River Channel is automatically listed in the California Register in 2019. See Attachment A.

Without explanation, the technical report largely overlooks another historic resource, Griffith Park. Griffith Park was determined eligible for the National Register in 1994. It is also listed in the California Register and is Los Angeles Historic-Cultural Monument #942. The proposed project would be built largely within the identified boundaries of Griffith Park, including the 1897 survey boundaries of the historic property (in gray) and historical resource boundary in yellow dashed line (Figure 3 below).

Figure 3: Excerpted, annotated Griffith Park Historic Resources Map with proposed project area circled in red.

See 1897 Park Survey Boundary in gray. Source: https://friendsofgriffithpark.org/wp-content/uploads/2015/11/ GPboundarymap.pdf accessed on January 24, 2025.

PROPOSED

PROJECT
EXHIBIT 2
5 No longer extant historical resources in the
proposed project area include
Griﬃth Park Aviation Park/Aerodrome (1912-
1939), National Guard Airport (1939-1946),
Glendale Grand Central Airport, locally
designated in 1977 (historic maps show runways
on the north side of the river until at least 1962);

Roger Young Village (1946-1954, south side of Los
Angeles River);
Grayson Steam-Electric Generating Station;
Grayson Power Plant Boiler Building after 1941
(determined National Register-eligible; listed in
California Register 2019; rescinded 2021; found
eligible for National and California Registers 2021;
demolished 2023, see Figures 4 (at left) and 5
(below).

Figure 4: Excerpt from 1953 USGS Burbank,
California quad map showing approximate
project area in red.

A Works Progress Administration
Map prepared with the Federal
Writers Project depicts the Griffith
Park in the late 1930s.

The proposed project area
contained far different uses than
are mentioned in the technical
report, including a Japanese
Cherry Grove, a Pecan Grove and
a National Guard Airport (Figure
4). None of those tree types are
proposed to be used for the
proposed project (see pages 9 and
17 of this letter under item [1]).

Figure 5: Excerpted Works Progress Administration map of “Griffith Park, Los Angeles City” prepared with the Federal Writers Project between in 1937. Library of Congress. HALS.

HALS NO. CA-105 at https://tile.loc.gov/storage-
services/master/pnp/habshaer/ca/ca4100/ca4161/data/ca4161da ta.pdf.

Another serious oversight is that Los Angeles Department of Water & Power 230kV electrical transmission lines with towers are extant in the proposed project APE or PAL (see Figure 6 and Photographs 3-6 in Appendix E of tech report). There are five separate lines, including the line on the south bank of the Los Angeles River. Those transmission lines and towers are not mentioned, evaluated for historic significance or analyzed for impacts that would be caused by the proposed project in the technical report (see Figure 6 on page 6).

A revised, corrected or addendum technical report prepared by both qualified archaeologists and built environment professionals must address this issue as well as other identified oversights in the March 2025 document. It should change the technical report’s conclusions and could well affect the type of environmental document used to clear the project.

EXHIBIT 2
6 Figure 6: Annotated, excerpted
graphic map of project APE or
PAL (in red dashed lines) with
electrical transmission lines
overlaid in dashed black lines.

Base map is Open Street Map
Historic Aerials.com at
https://www.historicaerials.com/v
iewer accessed on January 27,
2026.

Interestingly, also without explanation, the technical report does contain a California Department of Parks & Recreation (DPR) series 523 update for the Los Angeles River Glendale Narrows. The unnecessary recordation is not an “intensive” evaluation (as cited in *P10. in Figure 7) and was prepared for the Glendale Narrows segment of the Los Angeles River.

As described and defined in the California Office of Historic Preservation-prepared Instructions for Recording Historical Resources “Appendix 6: Types of Survey Activities” Intensive surveys go beyond the systematic identification and description of historical resources to encompass the evaluation of those properties within a historic context.

Thus, in addition to the five categories of information needed for a reconnaissance report,2 the report documenting an intensive survey should also contain: 6. An evaluation of heritage resources identified during the survey as determined within a historic context using the National Register criteria (or CEQA criteria if appropriate). 7. Evidence that the evaluation was conducted or confirmed by an appropriately qualified professional (emphasis added 1995).

Because the preparers did not follow Instructions for Recording Historical Resources “Appendix 6:

Types of Survey Activities” by not evaluating the Los Angeles River for National or California Register eligibility and worse, overlooked the previous determination of eligibility for the Los Angeles River, the DPR form survey type is not “Intensive” as claimed, and worse yet, is unfortunately useless to the environmental clearance document.

2 1. Purpose of survey, 2. Deﬁnition of survey area, 3. Research design, 4. Methods, 5. Summary of results (California Oﬃce of Historic Preservation. Instructions for Recording Historical Resources “ Appendix 6:

Types of Survey Areas” 1995).

EXHIBIT 2
7 Figure 6: DPR series
form 523A prepared
for the Phase 1. The
recorded resource
name is “Glendale
Narrows Segment of
the Los Angeles
River.”
In the header, under
Other Listings, the
from is blank.

In the location Map it
refers to a 1972 USGS
quad map that was
updated in 1994.

As mentioned, the DPR 523 forms dated January 15, 2022 prepared for the Phase 1 did not take into account or even reference the US Army Corps of Engineers’ 2019 determination of eligibility for the Los Angeles River Channel. The California Oﬃce of Historic Preservation Built Environment Resource Directory for Los Angeles County shows that the Los Angeles River Channel was determined eligible for listing in the National Register of Historic Places in 2011. That segment of the river is therefore also listed in the California Register (Status Code 2S2, see hĴps://ohp.parks.ca.gov/ ?page_id=30338 accessed on February 1, 2026).

Status Code 2S2 means “Individual property determined eligible for [the National Register] NR by a consensus through Section 106 process. Listed in the [California Register] CR.” (California Register Status Codes, February 8, 2023).

EXHIBIT 2
8 In 2019, the US Army Corps of Engineers (COE)
Determined the Los Angeles River Channel… eligible for the National Register of Historic Places (NRHP) under criterion A at the local level of signiﬁcance for its signiﬁcant association with the development of a comprehensive ﬂood risk management program in the county and development of the metropolitan area. Further, the COE had determined the Channel is eligible under NRHP criterion C as the ﬁrst implementation of a fully concrete lined waterway engineered to address unique challenges in the locale and for its role as a prototype for ﬂood control channels in the region. The COE points out that the Channel maintains integrity of workmanship, materials, seĴing, feeling and association. The period of signiﬁcance is 1936-1960. The SHPO concurs. (emphasis added leĴer from California SHPO Julianne Polanco to COE re “Section 106 consultation for Los Angeles Channel[,] and Reach 2A repairs…” dated September 20, 2019, see AĴachment A).

For the record, both the Los Angeles River Channel and Griﬃth Park each retain the integrity of their original locations as well. A copy of the quoted Los Angeles River Channel determination of eligibility leĴer is AĴachment A.

Despite the referenced DPR forms prepared for the Phase 1 which provide no professional judgments regarding the established historic property and historical resource, the report nonetheless concludes that “the Los Angeles River Channel (including the Glendale Narrows/Reach 3 Segment) is eligible for California Register listing. As such it is recommended a historical resource under CEQA” (emphasis added, page 11).

This means that the technical report preparers and their reviewers were not aware that the 2019 determination of National Register eligibility for the Los Angeles River meant that the linear resource is also listed in the California Register. The Los Angeles River is therefore both a historic property for the purposes of Section 106 and a historical resource as deﬁned in CEQA.

In the History section on page 4, the American Period inexplicably ends in the late 19th century when the population of the City of Los Angeles was approximately 50,000 persons (1890). The head count roughly doubled to 102,000 by 1900, and entirely overlooks the boom years after the ﬁrst and second World Wars. The City of Glendale was notably not established until 1906. No context for Griﬃth Park’s establishment or for the occurrence of electrical transmission in the area is in the technical report.

Project Description
The Project Description for the Initial Study for this project is extremely vague. The Project Description section in an Initial Study is considered a “road map” providing information that characterizes a proposed project’s goals and objectives. Project descriptions must be the same in all supporting documents for a given project. They are intended to describe the project providing suﬃcient detail to set forth the baseline of information for use as a foundation in analyzing the speciﬁc components elsewhere in the document. The project description should describe the project’s related activities (e.g. construction and implementation), identify and discuss any jurisdictional issues relating to project commencement including acquisition of applicable permits, project duration, the proposed project’s speciﬁc location and a listing of related environmental review and consultation requirements mandated by federal, state or local EXHIBIT 2
9 laws, regulations or policies (CCR Title 14, Section 15124). A project description must also include site, regional and vicinity maps to provide reviewers a sense of geographical location respecting the project site and its surroundings. It is noted that the Project Descriptions in the Initial Study, the MND and the technical report are entirely diﬀerent:

Cultural Resources Assessment for the Garden River Bridge Project/ Phase I Cultural Resources Assessment of the Garden River Bridge Project The project site is located in a non-sectioned portion of Township 1 North, Range 13 West, San Bernardino Baseline and Meridian, in the Cities of Los Angeles and Glendale. It is depicted on the United States Geological Survey (USGS) Burbank, California (1994) 7.5-minute topographic quadrangle... A detailed project exhibit is provided as Appendix C. The project site consists of areas in which impacts from a proposed project to potential historical resources could occur. The project includes construction of an approximately 350-foot long three-span curvilinear pedestrian/ bicycle bridge structure that spans the Los Angeles River with canopied seating areas. The bridge will be constructed using steel and concrete. It will be supported by two piers located in the river. Safety railings, trash cans, interpretive signs, pedestrian safety lighting, and other features will also be installed. The maximum height of the bents which will support the bridge from the ﬂoor of the channel will be 23 feet and six inches. The area of ground disturbance on the channel ﬂoor has been calculated at approximately 8,500 square feet.

Page 1 ends

On pages 3 and 4 of the MND, a far more comprehensive project description is provided, which would greatly have informed the technical report’s brief and insufficient analysis of impacts:

The City of Glendale as lead agency in cooperation with the City of LA, as responsible agency, proposes the construction of a three-span, curvilinear, landscaped bridge for use by pedestrians and bicyclists; see Figure 4 [not in this letter] for a visual of the proposed landscaping arrangement for the bridge, including locations of planting beds and tree canopies. [1]3 Tree species proposed to be part of the bridge’s landscape palette include western sycamore, valley oak, coast live oak, and tipu tree. Additional species included in the proposed planting mixes for the bridge include toyon, California sagebrush, California buckwheat, and star jasmine. The intent of this multi-community resource is to increase access to Glendale Narrows Riverwalk, and Griffith Park; to improve connections; and to increase the safety of paths used for pedestrians and cyclists. Dedicated access across the LA River at this key location would improve public safety and accessibility to important community resources by creating a connection between the Cities of Glendale and LA across the LA River for pedestrians and cyclists. [2] The proposed bridge would be concrete with two supporting piers in the LA River. [3] It would feature extensive landscaping on the approaches, as well as on the bridge itself, and is thus named the “Garden River Bridge.”[4] A number of raised planting beds on the bridge would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, dispersed gathering spaces, and scenic views of the LA River. The proposed bridge would operate on the same schedule as the LA River Bike Path, which is generally open from 6am to 9pm. [5] Any gating for the bridge would be located at the proposed access ramp and stairs off of Zoo Drive.

The LA River is a U.S. Army Corps of Engineers (USACE) flood risk management facility, in which USACE holds primary authority over any proposed changes. In addition to USACE, several other stakeholder entities are within the proposed Project footprint. The City of LA owns, operates, and maintains the south side of the LA River, located within the southern portion of the proposed Project area; also within this area, Southern California Edison (SCE) holds a fifteen-foot easement along Zoo Drive and overhead facilities on Los Angeles Department of Water and Power (LADWP) poles. On the north bank of the LA River, parcels within the northern portion of

3 Red numerals in brackets are used to create the sequence of activities that should have been analyzed in preparing the project’s impacts analysis.

EXHIBIT 2
10 the proposed Project limits are owned by the City, the City of LA, and the Los Angeles County Flood Control District (LACFCD). Furthermore, easements that cross the proposed Project area on the northern side are held by the City for utility purposes ( e.g., poles, sewers and related structures), and for the existing Riverwalk pedestrian/bike trail. [6] Table 1 below shows overall temporary and permanent impacts from the proposed Project.

Table 1 Comparison of Temporary and Permanent Impacts
Area of Impact Temporary Impacts Permanent Impacts
Total Project Area 2.94 acres 1.4 acres
[7] The Proposed Project would include overall temporary impacts of approximately 2.94 acres and approximately 1.4 acres of permanent impacts. Temporary impacts would include water diversion activities, excavation activities, and areas of access and staging. Permanent impacts would include the bridge, Riverwalk bike path reconstruction adjacent to the bridge, a new connection from the bridge to Zoo Drive, and the re-alignment of Zoo Drive… [8] The re-alignment of Zoo Drive would be to permit the construction of stairs and a ramp leading up to the LA River Bike Path and the proposed bridge. Trees between Zoo Drive and the LA River Bike Path would be removed and a new curb would be installed as part of proposed street improvements. [9] Additionally, a sidewalk would be installed to facilitate access from the bridge to the John Ferraro Athletic Fields to the south via a new raised crosswalk across Zoo Drive. These activities associated with the re-alignment of Zoo Drive would not result in the loss of parking as parking along this segment of Zoo Drive is not currently permitted, nor would realignment activities create parking along Zoo Drive.
[10] Construction is anticipated to begin in the Fall of 2025 and would last approximately 2.5 years, ending in the Spring of 2028. The proposed Project would occur in six (6) phases and shown and summarized below.
• Phase 0: Mobilization – The initial phase of the proposed Project would include requests for information, preparing and reviewing submittals, and procuring materials. • Phase 1: North Abutment and Approaches – [11] Approach work, bike path work, and abutment work.
• Phase 2: Bridge Substructure – [12] Construct piers within the LA River. • Phase 3: South Abutment and Approaches – [13] Construct the south abutment and connections to Zoo Drive; realign Zoo Drive.
• Phae 4 [sic]: Bridge Superstructure – [14] Construct the bridge superstructure using falsework within the LA River.
• Phase 5: Architectural Elements/Landscaping – [15] Construct the architectural elements (e.g., canopies, landscaping, etc.) on the bridge and approaches. [16] The bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. The abutments would be supported by deep foundations consisting of cast-in- drilled-hole concrete piles; the abutments would not be supported by the channel walls. [17] To address drainage from the bridge deck, pipes would be hung inside of the bridge and tie into existing drainage pipes or water treatment features on both sides of the LA River channel. [18] Activities associated with the realignment of Zoo Drive would include the removal of trees along the LA River Bike Path along Zoo Drive, within the southern portion of the proposed Project’s footprint in the City of LA. The tree removal would be required to accommodate grading and Zoo Drive realignment, and it is anticipated approximately 18 western sycamore trees would be removed, some of which fall under the jurisdiction of the City of LA’s Recreation and Parks Department (LARAP) and others under City of LA’s Bureau of Street Services (LABSS). Section 46.01 of the City of LA Municipal Code (LAMC) includes western sycamore trees as a protected tree species; therefore, the proposed tree removals within LABSS jurisdiction would require a Tree Removal Permit from the LABSS Urban Forestry Division. Removal of protected trees requires replacement at a 4:1 ratio with the same species of each species removed…
[19] The demolition and excavation phases of the proposed Project are expected to generate the most construction traffic and require the most equipment. In-river construction would occur EXHIBIT 2
11 during the dry season (April through October) when flood flows are very unlikely, per USACE requirements. [20] The construction equipment used during different portions of the proposed Project would include work trucks, concrete trucks, cast-in-drilled-hole concrete pile drilling rigs, mobile cranes, and excavators. [21] The construction contractor would be required to lay down timber mats to protect the LA River bottom to prevent potential impacts to the LA River bottom during construction. [22] While variable, an average of 15 people would be on site daily for the duration of construction activities. [23] Construction access to the proposed Project site would be provided from Zoo Drive on the City of LA side of the proposed Project and from Flower Street on the Glendale side of the Project, with intermittent temporary lane closures and or reduced access. [24] Due to the lack of suitable access ramps within close proximity to the proposed Project site, the construction contractor may construct a temporary ramp from Zoo Drive down the sloped levee into the channel bottom. The temporary construction staging area would be located in the City of LA and City of Glendale at the southern and northern areas of the proposed Project; [25] specifically, one of the staging areas would be on the north side of Zoo Drive within the shoulder of the road. Additional staging would occur within the LA River northern bank and southern bank during construction of the bridge’s piers (MND pages 3-5).

While the referenced project description provides a large amount of specificity that is not addressed in the technical report, its incorporation and analysis with additional information that the Project Design Team could have provided would have greatly informed the analysis of impacts in the technical report.

Conclusions
In the “Recommendations” section, the technical report concluded without adequate explanation:

The Los Angeles River has been determined eligible for National Register listing and as such is a historical resource under CEQA. However, the proposed project will impact a tiny portion (approximately .06 percent) of the Glendale Narrows/Reach 3 segment of the Los Angeles River. Based on the small percentage of the segment that will be subject to direct impacts, BCR Consulting recommends that the proposed project will not result in a signiﬁcant adverse eﬀect to a historical resource under CEQA. Furthermore, the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. Although the integrity of seĴing would be minimally impacted by the installation of the bridge, the seĴing of the Glendale Narrows/Reach 3 segment has already been impacted by development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges that are visible from the proposed project site and were constructed after the period of signiﬁcance [identiﬁed as 1936-1960 in SHPO leĴer]. As such, the proposed project will not introduce any elements to the seĴing that are not already present, and the proposed project will not alter the ability of the Glendale Narrows/Reach 3 to contribute to a larger district. Based on these results, BCR Consulting recommends that the project as proposed will not result in signiﬁcant impacts to a historical resource (under CEQA). No mitigations are recommended for the current undertaking. No archaeological resources were identiﬁed during this assessment (emphases added, pages 11 and 12).

The assertion that proposed project would not cause a “signiﬁcant adverse eﬀect” to the Los Angeles River or to its Reach 3 was made without any demonstrable evidence or reasoning. The threshold for an impact on historical resource is not an “adverse eﬀect;” the correct language in CEQA is substantial adverse change which can cause a signiﬁcant eﬀect on the environment.

EXHIBIT 2
12 In California Code of Regulations in Title 14, Section 15064.5 “Determining the Signiﬁcance of Impacts to Archaeological and Historical Resources, the law deﬁnes and clariﬁes:
(b) A project with an eﬀect that may cause a substantial adverse change in the signiﬁcance of an historical resource is a project that may have a signiﬁcant eﬀect on the environment. (1) Substantial adverse change in the signiﬁcance of an historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the signiﬁcance of an historical resource would be materially impaired.
(2) The signiﬁcance of an historical resource is materially impaired when a project:
(A) Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical signiﬁcance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources;
(B) Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the Public Resources Code or its identiﬁcation in an historical resources survey meeting the requirements of section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the eﬀects of the project establishes by a preponderance of evidence that the resource is not historically or culturally signiﬁcant; or
(C) Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical signiﬁcance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA . (3) Generally, a project that follows the Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer, shall be considered as mitigated to a level of less than a signiﬁcant impact on the historical resource (emphasis added).

If the preparers of the technical report were qualiﬁed to identify and analyze impacts to built environment historic resources, partially by incorporating and applying the MND’s far more thorough Project Description, they would likely also have presented questions to the PDT, considered the responses and applied the appropriate CEQA impacts thresholds, they may well have arrived at a diﬀerent conclusion. This presents a substantial obstacle for the MND which unfortunately relies on the technical report’s inadequate identiﬁcation eﬀorts as well as its ﬂimsy conclusion.

The California State Historic Preservation Oﬃcer concluded in 2019 that for Section 106 [or CEQA] compliance on future undertakings [or projects] on the Los Angeles River Channel, the COE [or lead agency] will need to identify character-deﬁning features within the segment under consideration and assess whether the work will alter any of those features such that the segment will no longer be able to convey its signiﬁcance” (Julianne Polanco, California SHPO, leĴer to COE re “Section 106 consultation for Los Angeles Channel[,] and Reach 2A repairs…” dated September 20, 2019). That clear direction must be followed for the proposed project and any future projects in the Los Angeles River (see AĴachment A).

EXHIBIT 2
13 If, as described on pages ii and 11, “the proposed Project would only impact a very small portion (approximately 0.6 percent) of the Glendale Narrows/Reach 3 section of the LA River, which, due to the small percentage subject to direct impacts, would not result in a signiﬁcant adverse eﬀect to a historical resource under CEQA.” That surprisingly brief analysis begs an important question that is not answered. What size is the Glendale Narrows/Reach 3 section of the Los Angeles River? How large is the entire Los Angeles River? Is it 100 acres or 1,000 acres in size? Is the consultant considering only the “temporary impact area” of nearly three acres (2.94) or the “permanent impact area” of 1.4 acres described in the MND? Strangely, as cited in the technical report on page 1, only 8,500 SF of the Los Angeles River channel ﬂoor would be “temporarily” used. It should be noted that 8,500 SF is just 0.1951331 of an acre, it is not 1.4 “direct impact acres” and certainly not the estimated “2.94 indirect impact acres” that are estimated and described in the MND. Why were these ﬁgures not cross-checked? Merely checking to see if numbers merely match is absolutely not an appropriate built environment impacts analysis under CEQA. My understanding of the project is that two bridge piers would be permanently located within the Los Angeles River channel, which is certainly not a temporary impact and is, far more importantly, not even analyzed.

The technical report asserts “the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls” (emphasis added). Would the new feature being built higher than the historical resource be preferable to the abutments being built lower than the levee walls? The description regarding “not ‘touching’ the levee walls” is in the MND project description. It is a physical description, not an analysis of historical resources impacts. No explanation for the statement or what it really means is provided.

According to The Secretary of the Interior’s Standards For the Treatment of Historic Properties With Guidelines For Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings In Guidelines For Rehabilitating Historic Buildings under New Exterior Additions and Related New Construction, under Rehabilitation as a treatment:

New additions should be designed and constructed so that the character-deﬁning features of the historic… [resource]4, its site, and seĴing are not negatively impacted.

Generally, a new addition should be subordinate to the historic… [resource]. A new addition [like a bridge] should be compatible, but diﬀerentiated enough so that it is not confused as historic or original to the … [resource]. The same guidance applies to new construction so that it does not negatively impact the historic character of the … [resource] or its site” (emphasis added, Anne E. Grimmer, 2017. page 79).

There are no detailed plans, no sections or elevations provided in the analysis for the proposed bridge abutments or for the new bridge Abutment types can vary from gravity walls to complex integrated systems, and gravity abutments, cantilever abutments, stub abutments, spill-through (or open) abutments, and integral abutments, all of which are designed to support the ends of a bridge, retain earth when necessary and to transfer loads, with selections depending on soils (where applicable), overall cost and a proposed bridge’s height. The insuﬃcient explanation in

4 In this quote, the word building is replaced by resource, because the Los Angeles River is a linear resource, not a building. It does not change the meaning, because the Standards are intended to be used for all types of historic properties.

EXHIBIT 2
14 the tech report’s conclusion does not describe how much higher than the Los Angeles River levee walls are from grade, from the ﬂat part of the river, nor does it specify what type or size the thinly described bridge abutments are proposed to be. Worse yet, the idea that the abutments not “touching” the abutment walls alleviates the prospect of impacts to the historical resource is preposterous and demonstrates an essential issue with the preparers’ understanding of how to analyze impacts that may be caused by a given project to built environment historic resources.

The applicable thresholds are material impairment that would cause substantial adverse change. How high above grade would the proposed abutments be at the bases? How high above grade would the abutments be at the tops? Show a detailed plan and elevations. Would the design conform to the Secretary of the Interior’s Standards for Rehabilitation? Describe how.

How much soil is proposed to be excavated? To what depth would that soil be removed? If applicable, where would that soil be deposited? When will that analysis be prepared? These are usually important questions that are answered and analyzed in an archaeological technical report.

According to the CEQA Guidelines Section 15064.5(b), a project with an eﬀect that may cause a substantial adverse change in the signiﬁcance of a historic resource may have a signiﬁcant eﬀect on the environment. A substantial adverse change means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings, resulting in material impairment of the historic resource (CEQA Guidelines Section 15064.5[b][1]).

The technical report further confuses immediate seĴing within and near the historical resource’s boundaries with its larger surrounding seĴing. SeĴing is deﬁned by the National Park Service as the physical environment of a historic property or a historical resource. Because location refers to the speciﬁc place where a resource was built or an event occurred, seĴing refers to the character of the place in which the property played its historical role. It involves how, not just where, the property is situated and its relationship to surrounding features and open space.

SeĴing can reﬂect the fundamental physical conditions under which a resource was built and the functions it was intended to serve. In addition, the way in which a resource is positioned in its environment can reﬂect the original designer or engineers’ concepts of nature and aesthetic preferences.

The technical report concludes that “Although the integrity of seĴing would be minimally impacted [not explained] by the installation of the bridge, the seĴing of the Glendale Narrows/Reach 3 segment has already been impacted by development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges that are visible from the proposed project site and were constructed after the period of signiﬁcance.” The period of Signiﬁcance in the SHPO leĴer is 1936-1960 (AĴachment A). The preparers do not seem to have performed adequate research to justify that claim. The reader does not know how high the new bridge would be, how thick or deep the deck and girders or whatever its supporting elements would be, what its overall appearance would be and because of that, has no compelling reason to believe the conclusion.

The seĴing of the Los Angeles River and of any historical resource is both close-in (within and nearby the Los Angeles River Channel) as well as the linear property’s larger surroundings that EXHIBIT 2
15 establish its larger atmosphere. On page 9 of the technical report, it states “The project site and surrounding area have been subject to severe disturbances related to reconﬁguration of Flower Street, construction of the channel, construction of the modern bike path and walkway, modern refuse dumping, the installation of transmission towers and streetlights, and by repeated ﬂooding.” While those described activities may equate to “severe disturbances” to the archaeologists who prepared the technical report, to a qualiﬁed architectural historian, the project area’s larger seĴing was described. The channelized Los Angeles River and Griﬃth Park are each historic resources. The electrical transmission lines and towers may wel1936 l be historically signiﬁcant as well. What was described was the environmental baseline, the time and conditions used as the point of comparison that would normally be used for determining the signiﬁcance of a given project’s environmental eﬀects.

On the north side of the river, the project area has been industrial since the turn of the early 20th century. The proposed project area, called “Flower Street District Annex” was not part of the City of Glendale until May of 1923 (Los Angeles, County of. “City of Glendale Annexations.” At hĴps://pw.lacounty.gov/sur/nas/SMPM_ AnnexationCityPDFs/Glendale.pdf accessed on February 2, 2023). Just three years later, San Fernando Road, roughly a block north of the proposed project became US Highway 6 in 1926. About a decade after that, US Highway 6 became US Highway 99, known as “the Mother Road, in 1934 (California, State of. State Highway Map. 1934). As Highway 99, the road was populated by scaĴered gas stations and primarily industrial uses in the project area, much like it still is.

Review of various sources shows that development of what is now State Route 134 freeway was ﬁrst considered in 1934, before the Los Angeles River was channelized, and before the identiﬁed 1936 period of signiﬁcance commenced (see AĴachment A) . The subject property section of the Los Angeles River was channelized in 1939, according to the technical report (page 10). In 1946, 750 Quonset huts were relocated to Griﬃth Park where the former National Guard Airport had been in the park. The area surrounding the Los Angeles River, like most of Los Angeles, was constantly changing.

In 1947, during the same decade that the river was channelized, the Regional Planning Commission established a “Master Plan of Metropolitan Los Angeles Freeways.” That Master Plan was adopted on August 4, 1947 and included part of the Ventura Freeway running east-to- west in Glendale in the approximate location of present-day State Route 134 (SR 134). In 1952, Grand Central Airport ceased operations because its limited landing strips could not accommodate large planes. The Interstate 5 bridge over the Los Angeles River was built in 1957.

Walt Disney recognized the potential in Grand Central’s location and large footprint. He purchased part of the property in 1961, the year that the identiﬁed period of signiﬁcance closed (AĴachment A). Between 1962 and ’65 the Colorado Street extension in Glendale, south of the proposed project area was a brief alternate stub route of the present-day Interstate 134. In 1963, the California Streets and Highways Code established Route 134 as being “from Route 101 near Riverside Drive easterly to Route 210 via the vicinity of Glendale” (California, State of. Streets and Highways Code - Division 1. State Highways, Chapter 2. The State Highway System, Article 3. The State Highway Routes. At
hĴps://leginfo.legislature.ca.gov/faces/codes_displaySection .xhtml?lawCode=SHC&sectionNum=434 last accessed on February 13, 2026). San Fernando EXHIBIT 2
16 Road was re-signed as State Route 163 in the 1960s. In 1969, State Route 134 was rerouted oﬀ of Colorado Street in downtown Glendale north on to State Route 2 Verdugo Road to the “new” segment of the Ventura Freeway. By 1967, SR 134 reached Concord Drive in Glendale. Map review reveals that I-134 was completed in Glendale in 1971.

Sanborn Fire Insurance Co. Maps of Glendale, CA updated to October 1950 reveal that the larger seĴing of the Los Angeles River, particularly on the north (Glendale) side of the project area was much like it is now, developed by Glendale Central Aircraft Co., Grand Central Airport (built in 1930) runways and Cal-Aero Technical Institute (Sheet 222H, see also Figure 3 of this leĴer).

Sheet 0B in Figure 7 below reveals that Victory Truck Boulevard ran along the north bank of the Los Angeles River. The Grayson Steam-Electric Generating Station Boiler Building was completed after 1941 with various additions in the late 1940s through the 1970s.

Figure 8: Excerpted, annotated Sheet 0B from
Sanborn Fire Insurance Co. Maps of Glendale, CA,
dated October 1950.

Note that the regional airport was on the north
side of the Los Angeles River (in yellow) and that
the project area is circled in red. Flower Street
was not shown on the map, so it was added in
gray dashed lines. The Grayson Steam-Electric
Power Plant was located at approximately 1
o’clock, northeast of the proposed project. It was
demolished in 2023.

What this brief timeline reveals, is that the larger seĴing of the Los Angeles River in this area has been characterized by industrial and institutional uses since Glendale was established.

Furthermore, the environmental seĴing has been subject to nearly constant change from approximately the 1920s until between the 1940s, when the river was channelized and present day.

Absent any information regarding the proposed height of the abutments, bridge deck, railings, canopies and all other vertical features, it is impossible to make the conclusions in the technical report. The technical report describes the proposed bridge as concrete and steel materials, however the MND describes only steel, with no ﬁnishes speciﬁed. There is no agreement among these documents regarding the proposed project’s materials, and even less information regarding the designs. sizes or shapes of the bridge piers, the bridge deck, anti-scour features, connected deck items including railings, planting beds, trashcans, canopies, trees and other plants and the gates on the “Los Angeles” side. The PAL map in Figure 1 of this leĴer notes a “proposed plaza and stair area” that is not described in the tech report. It also depicts a lengthy ADA ramp conﬁgured in a loop on the southeast side of the proposed bridge.

Eﬀects to the seĴings of properties eligible under Criteria A and 1, C and 3 like the Los Angeles River and Griﬃth Park must not only allow historic resources to retain their essential physical features, but those features must be clearly visible enough to suﬃciently convey their signiﬁcance. This means that even if a historical resource is physically intact, its integrity may become questionable if its signiﬁcant features would be concealed beneath new features, under EXHIBIT 2
17 modern added construction like the proposed bridge. Will the new bridge be a truss, an arch, have open or closed spandrels, metal built-up girders, metal rigid frame, suspension, cantilever or another type of bridge not listed? Most bridge types have diﬀerent features, which can result in very diﬀerent appearances and impacts to historic resources. Without this information, including renderings and elevations, no conclusions can be made regarding physical (direct), atmospheric, visual or future expected impacts.

There are numerous outstanding issues described in the MND project description were not analyzed and must be addressed in a revised or addendum technical report that would be prepared by qualiﬁed built environment professionals.

Outstanding Questions for Analysis of Built Environment Impacts Detained review of the MND project description reveals some of those unanswered questions.

Statements below from the MND have responses that must be addressed immediately following the text:
[1] Tree species to be part of the bridge’s landscape palette include western sycamore, valley oak, coast live oak, and tipu tree. Additional species included in the proposed planting mixes for the bridge include toyon, California sagebrush, California buckwheat, and star jasmine...

Response (or R): What types of trees and other plantings exist in the baseline conditions? Griffith Park’s landscaping is among the historical resource’s most important features. The park’s more than 4,200-acre area contains natural features, with acres of undeveloped, open space and numerous designed landscapes. It is strongly recommended that the future revised built environment analysis use the ICF Jones & Stokes-prepared “Landscape Elements of Griffith Park” in prepared in 2008. The report identified and illustrated the character-defining features of the natural and designed landscape components of Griffith Park with related context for their establishment and development. Character-defining features in the project section of the Los Angeles River must be identified in the revised technical report to ensure than none are destroyed or altered such that the significance of the larger resource would be impaired. That assessment will be a crucial component of the future impacts analysis.

The Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes prepared by the National Park Service as part of their Cultural Landscape Guidance Documents for Cultural Resource Stewardship and Partnerships in 1996, applies directly to this project, and directs:

Guidance for the Rehabilitation treatment begins with recommendations to identify those landscape features and materials that are important to the landscape's historic character and therefore must be retained. Therefore, guidance on identifying, retaining and preserving character-defining features is always given first. An overall evaluation of the existing conditions should always be made at this phase. The character of a cultural landscape is defined by its spatial organization and land patterns; features such as topography, vegetation, circulation and materials (emphasis added, 1996).

Will the proposed trees and planting materials be compatible with the existing landscape? Would Japanese Cherry or Walnut trees be planted, as historically existed in Griffith Park in the project area in 1937 (see Figure 5 on page 5)? How many of each tree are proposed to be removed or planted? What size boxes or specimens would be planted? Will the trees require supplemental irrigation? For how long a duration? Whose responsibility would that be? EXHIBIT 2
18 [2] The proposed bridge would be concrete with two supporting piers in the LA River.

R: The technical report states that the bridge would be steel and concrete (page 1). The MND describes it as being concrete. Would the bridge materials be both steel and concrete? What would the walking surface or deck material of the bridge and abutments be? What are the proposed railings’ materials, colors and finishes? Would the railings have jump protection designed as part of the project? If so, would the jump protection be physical barriers like high- tensile stainless steel mesh, inward-curved fencing or under-deck netting? What are the proposed designs, materials and finishes for the piers and their bases? What color(s) would the concrete and/or steel be? What would the finishes be? Would the concrete match the existing Los Angeles River concrete? Would that concrete matching be undertaken before or after cleaning the concrete using the gentlest means possible in keeping with the Standards for Rehabilitation? Who would perform those reviews? It certainly sounds like additional mitigation would be necessary. Why was none of this coordinated? Would the bridge pier base configurations, in plan, be circular, rectangular, oblong or chamfered? Would they have tapered (sharp) or rounded (oval) noses? Are the shapes depicted in the few figures containing renderings? How high and long would the pier bases be? What shapes and designs would be the bridge piers and pier caps be? These issues must be addressed in a revised or addendum built environment technical report. [3] It would feature extensive landscaping on the approaches, as well as on the bridge itself, and is thus named the “Garden River Bridge.”
R: See responses regarding item 1.
[4] A number of raised planting beds on the bridge would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, dispersed gathering spaces, and scenic views of the LA River. The proposed bridge would operate on the same schedule as the LA River Bike Path, which is generally open from 6am to 9pm.

R: See responses regarding items 1 and 2.
[5] Any gating for the bridge would be located at the proposed access ramp and stairs off of Zoo Drive.

R: Show exactly where the proposed gates are proposed, with proposed posts and gate heights, their widths, proposed materials and finishes for analysis in the future technical report that would address impacts to built environment resources.
[6] Table 1 below shows overall temporary and permanent impacts from the proposed Project.

Table 1 Comparison of Temporary and Permanent Impacts
Area of Impact Temporary Impacts Permanent Impacts
Total Project Area 2.94 acres 1.4 acres
R: Was the archaeologist consultant considering only the “temporary impact area” of nearly three acres (2.94) or the “permanent impact area” of 1.4 acres in Table 1 above? Would that include the large timber mats to protect the river and the two proposed construction ramps (see page 22)?
As described in the technical report on page 1, only 8,500 SF of the Los Angeles River “on the channel floor” would be temporarily used. That leaves the rest of the project being built using floating sky-hooks. 8,500 SF is just 0.1951331 of an acre, not 1.4 direct impact acres and certainly not the estimated 2.94 indirect impact acres estimated in the MND.

EXHIBIT 2
19 This highlights the vast difference in the technical report preparers and the generalists’ thought processes and fundamental understanding of the proposed project.

The actual impacts of the proposed project must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report. These outstanding questions should have been identified and corrected by city staff reviewers, Ruth Villalobos & Associates, Inc. and BCR Consulting?
[7] The Proposed Project would include overall temporary impacts of approximately 2.94 acres and approximately 1.4 acres of permanent impacts. Temporary impacts would include water diversion activities, excavation activities, and areas of access and staging. Permanent impacts would include the bridge, Riverwalk bike path reconstruction adjacent to the bridge, a new connection from the bridge to Zoo Drive, and the re-alignment of Zoo Drive; see Figure… R: See response to item 6. All of the described “temporary impact” areas must be included in the proposed project’s revised APE or PAL.
[8] The re-alignment of Zoo Drive would be to permit the construction of stairs and a ramp leading up to the LA River Bike Path and the proposed bridge. Trees between Zoo Drive and the LA River Bike Path would be removed and a new curb would be installed as part of proposed street improvements.

R: How many lineal feet and what width of Zoo Drive is proposed to be realigned? What would be that component’s maximum depth of disturbance and how would that realignment impact Griffith Park? The technical report does not address “stairs and a ramp,” although both are noted in the Project Area Limits map in Figure 1 of this letter and in the MND.

Once those project components have been designed, including materials and railings, with depths of disturbances considered, the expected impacts of those features must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report.

How many and what species of trees “between Zoo Drive and the LA River Bike Path would be removed” for the proposed project. Where would the replacements be planted and what species would the replacement trees be? What is the basis for the identification of the new trees? What box sizes would the new trees be? How would they be irrigated and for how long? What and where would the proposed new curb be? What is there now? How long and tall would it be? Once those project components have been designed, including materials, finishes and railings, the expected impacts of those features must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report. [9] Athletic Fields to the south via a new raised crosswalk across Zoo Drive. These activities associated with the re-alignment of Zoo Drive would not result in the loss of parking as parking along this segment of Zoo Drive is not currently permitted, nor would realignment activities create parking along Zoo Drive.

R: If a raised crosswalk is proposed “across Zoo Drive,” it should be depicted on plans and elevations in any future built environment technical report. How long and wide would the raised crosswalk be? What would the proposed materials be? How deep would the proposed ground disturbance be (if any is necessary)? How high would the proposed raised crosswalk be at the highest points from finished grade? Where would the required ramps be? How many lineal feet long and how wide would the proposed ramps be? EXHIBIT 2
20 Once those project components have been designed, including materials, finishes and other features, the expected impacts of those features must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report. [10] Construction is anticipated to begin in the Fall of 2025 and would last approximately 2.5 years, ending in the Spring of 2028. The proposed Project would occur in six (6) phases… and shown and summarized below…
R: The undated MND incredulously states for the proposed project that “Construction is anticipated to begin in the Fall of 2025 and would last approximately 2.5 years, ending in the Spring of 2028” (emphasis added, page 9). It is now winter of 2026 and environmental review for the proposed project has not been completed.

The project website states that construction will commence in June 2030 (see Glendale-Los Angeles Garden River Bridge Project (Glendale Narrows Riverwalk, Phase III). All such references must be coordinated in future recirculated documents. • Phase 1: North Abutment and Approaches – [11] Approach work, bike path work, and abutment work.

R: Fully describe the proposed approach work (including its length, width, maximum depth of disturbance, including necessary backfill and locations of drains), bike path work (same), and type of abutment work (including its type, length, width, maximum depth of disturbance, including necessary backfill and locations of drains, including the expected maximum depth and widths of disturbance). If soil or other material would be removed, provide that figure and provide the location where the soil would be taken.
• Phase 2: Bridge Substructure – [12] Construct piers permanently in within [sic] the LA River.

R: Fully describe the proposed pier types, their caps or headers, their lengths, widths, maximum depths of disturbance, any columns or shafts, their types, styles and shapes of footings and or piles. If the proposed CIDH piles would be “wet,” would they be placed under slurry? Would temporary casing used to control groundwater? Are inspection pipes proposed (where and how many)? How large would the inspection pipes be (height below grade, circumference and diameter for the wet method? What is the proposed appearance of the piers and anti-scour bases? How tall, with the bridge piers, abutments, deck, railings and other features be above the levee walls? Will plans be reviewed for conformance with The Secretary of the Interior’s Standards for Rehabilitation at 30, 60 and 90 percent completion by a qualified Historic Architect or Architectural Historian? It may well be too late according to the current schedule. Will the concrete be matched to the color and finish of the existing Los Angeles River in the project area? Would that original concrete be cleaned using the “gentlest means possible” before matching? (see SOIS Standards for Rehabilitation). If soil or concrete would be removed, provide the location where that material would be deposited. • Phase 3: South Abutment and Approaches – [13] Construct the south abutment and connections to Zoo Drive; realign Zoo Drive.

R: Same responses as items 9 and 11. Show how and where Zoo Drive would be realigned, including dimensions, materials and depths of disturbance. • Phae 4 [sic]: Bridge Superstructure – [14] Construct the bridge superstructure using falsework within the LA River.

EXHIBIT 2
21 R: Describe the proposed work more fully. How long is it expected to take, how many members of construction team in river, debris removal methods, proposed hours of construction, etc. • Phase 5: Architectural Elements/Landscaping – [15] Construct the architectural elements (e.g., canopies, landscaping, etc.) on the bridge and approaches.

R: Describe the expected duration of the construction activity with construction hours (e.g., 7:00 AM to 5PM), as well as identifying proposed temporary and permanent materials with their heights above the bridge deck and the concrete bottom as well as the channel of the Los Angeles River.
[16] The bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. The abutments would be supported by deep foundations consisting of cast-in-drilled-hole concrete piles; the abutments would not be supported by the channel walls.

R: See responses to items 11 and 12.
[17] To address drainage from the bridge deck, pipes would be hung inside of the bridge and tie into existing drainage pipes or water treatment features on both sides of the LA River channel.

R: Describe the proposed work more fully. Show on a plan where and how the pipes are proposed. Describe proposed materials, estimate the number of pipes, their maximum diameters, lengths, finishes and whether they would be in chases, concealed beneath the deck or clearly visible.
[18] Activities associated with the realignment of Zoo Drive would include the removal of trees along the LA River Bike Path along Zoo Drive, within the southern portion of the proposed Project’s footprint in the City of LA. The tree removal would be required to accommodate grading and Zoo Drive realignment, and it is anticipated approximately 18 western sycamore trees would be removed, some of which fall under the jurisdiction of the City of LA’s Recreation and Parks Department (LARAP) and others under City of LA’s Bureau of Street Services (LABSS). Section 46.01 of the City of LA Municipal Code (LAMC) includes western sycamore trees as a protected tree species; therefore, the proposed tree removals within LABSS jurisdiction would require a Tree Removal Permit from the LABSS Urban Forestry Division.

Removal of protected trees requires replacement at a 4:1 ratio with the same species of each species removed…
R: What other types of trees and other plantings exist in the baseline conditions? Griffith Park’s landscaping is among the historical resource’s most important features. The park’s more than 4,200-acre land area contains natural features, with acres of undeveloped, open space and numerous designed landscapes. It is strongly recommended that the future revised built environment analysis use the ICF Jones & Stokes-prepared “Landscape Elements of Griffith Park” in prepared in 2008. The report identified and illustrated the character-defining features of the natural and designed landscape components of Griffith Park with related context for their establishment and development. Character-defining features in the project section of the Los Angeles River must be identified in the revised technical report to ensure than none are destroyed or altered such that the significance of the larger resource would be impaired. That assessment will be a crucial component of the impacts analysis.

Apply The Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes which directs:

EXHIBIT 2
22 Guidance for the Rehabilitation treatment begins with recommendations to identify those landscape features and materials that are important to the landscape's historic character and therefore must be retained. Therefore, guidance on identifying, retaining and preserving character-defining features is always given first. An overall evaluation of the existing conditions should always be made at this phase. The character of a cultural landscape is defined by its spatial organization and land patterns; features such as topography, vegetation, circulation and materials (emphasis added, 1996).

Will the proposed trees and planting materials be compatible with the existing landscape? Will the replacement trees require supplemental irrigation? For how long a duration? Whose responsibility would that be?
[19] The demolition and excavation phases of the proposed Project are expected to generate the most construction traffic and require the most equipment. In-river construction would occur during the dry season (April through October) when flood flows are very unlikely, per USACE requirements.

R: Describe the proposed work more fully. Is any demolition proposed to any character- defining features of the identified historic resources. What are those character-defining features? If so, why?
Show on a plan exactly where the proposed demolition and grading would occur, and how much material in cubic yards would be proposed to be removed. How many trucks are expected per day? Identify haul routes and the duration of the activities [20] The construction equipment used during different portions of the where Project would include work trucks, concrete trucks, cast-in-drilled-hole concrete pile drilling rigs, mobile cranes, and excavators.

R: Describe the proposed work more fully. Include more complete information and consider the full heights of the vehicles and equipment in the revised description of the vertical and subterranean APE or PAL in the supplemental technical report. [21] The construction contractor would be required to lay down timber mats to protect the LA River bottom to prevent potential impacts to the LA River bottom during construction.

R: Describe the proposed work more fully including the sizes and location of the timber mats on plans. Include more complete information and consider the duration of their use. [22] While variable, an average of 15 people would be on site daily for the duration of construction activities.

R: Describe that use of personnel more fully. Where would that parking be located? Where would construction trailers be placed? Show all potential locations on plans and include those areas in the revised Area of Potential Effects or Project Area Limits map. Describe how any parking limits would be enforced?
[23] Construction access to the proposed Project site would be provided from Zoo Drive on the City of LA side of the proposed Project and from Flower Street on the Glendale side of the Project, with intermittent temporary lane closures and or reduced access .

R: Show all potential access locations on plans and include those areas with the intermittent temporary lane closures and reduced access in the revised APE or PAL map. [24] Due to the lack of suitable access ramps within close proximity to the proposed Project site, the construction contractor may construct a temporary ramp from Zoo Drive down the sloped levee into the EXHIBIT 2
23 channel bottom. The temporary construction staging area would be located in the City of LA and City of Glendale at the southern and northern areas of the proposed Project; R: Show all potential access ramps, including their lengths, widths and materials on plans and include those areas in the revised APE or PAL map.
[25] specifically, one of the staging areas would be on the north side of Zoo Drive within the shoulder of the road. Additional staging would occur within the LA River northern bank and southern bank during construction of the bridge’s piers (emphasis added, MND pages 3-5).

R: Show all potential and additional staging areas on plans and include all staging areas in the revised APE or PAL map.

Closing
The MND states:
the results of the Cultural Resources Assessment conclude that the proposed Project would only impact a very small portion (approximately 0.6 percent) of the Glendale Narrows/Reach 3 section of the LA River, which, due to the small percentage subject to direct impacts, would not result in a signiﬁcant adverse eﬀect to a historical resource under CEQA. Additionally, the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls.

While the integrity of the seĴing would be minimally impacted by the installation of the bridge, the seĴing of the Glendale Narrows/Reach 3 segment has already been impacted by subsequent development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges over the LA River, which are visible from the proposed Project site and were constructed after the period of signiﬁcance. Thus, the proposed Project would not introduce elements (e.g., bridges over the LA River) to the seĴing not already present, nor would the proposes project alter the ability of the Glendale Narrows/Reach 3 to contribute to a larger district (page 25).

That analysis and the conclusion in the technical report lack suﬃcient detail as described in this leĴer to prove the that no impacts would occur. The character-deﬁning features of the Los Angles River and Griﬃth Park were not identiﬁed or analyzed for project-related impacts. We do not know whether the ﬁve electrical transmission lines and their four towers are historically signiﬁcant or whether these resources would be impacted, if they are historic resources, by the proposed project. The delineation and deﬁnition of the APE or PAL must include all additional areas where the project could cause impacts (including parking, construction trailers, etc.) and must be supplemented and reconsidered.

The Project Design Team and specialists preparing each of the project technical reports must share, collaborate and work from the same baselines and identical project information. Clearly, they did not collaborate adequately for this project, which leaves the cultural resources technical report relying on and using old and mistaken information.

More importantly, if no impacts are expected to occur as a result of the proposed project as described in the technical report, then why are these areas deﬁned in the MND as “impact areas?” The consultant does not explain the diﬀerence between indirect and direct impacts.

EXHIBIT 2
24 This list of unanswered questions, along with the weak identiﬁcation of historical resources are each crucial problems with the technical report and necessitate preparation of a revised Built Environment technical report, which may cause revisions to the umbrella clearance document.

If these questions are revisited by qualiﬁed professionals in the proper ﬁelds, preparation of an Environmental Impact Report may be necessary. In this leĴer I have provided “substantial evidence” which includes “facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts.” Inaccurate information and unsubstantiated opinion are not substantial evidence (Public Resources Code Section 21082.2 (c); CEQA Guidelines Section 15384). Based on this review, the technical report must be revised by qualiﬁed built environment professionals, taking these comments and other related comments into account.

I sincerely appreciate the opportunity to comment on this important project. Please ensure that this leĴer is included in the proposed project’s Administrative Record. Kindly add me to the mailing and e-mail lists for any future, related environmental review documents.

Sincerely,
Francesca Smith
Francesca Smith

aĴachment

cc: Suzie Abajian, PhD, City Clerk
Historic Preservation Commission
Daniel Hernandez, Director, Public Works

EXHIBIT 2

Attachment C
BCR Consulting Response to Comments Letter dated March
28, 2026
EXHIBIT 2

1 March 28, 2026

Dennis Joe
Principal Planner
City of Glendale
633 East Broadway, Room 103
Glendale, California 91206

Subject: Response to Comments on Glendale- Los Angeles Garden River Bridge Mitigated Negative Declaration

Dear Mr. Joe:

BCR Consulting LLC (BCR Consulting) is presenting the following response to Comments on Glendale-Los Angeles Garden River Bridge Mitigated Negative Declaration submitted by Francesca Smith on February 18, 2026. Responses focus on Ms. Smith’s comments to the Cultural Resources River Bridge dated March 28, 2025.

Comment A: Phase I Cultural Resources Assessment (page 2) The reviewer states that a Phase I report is a “ term of art ” limited to archaeological investigations. She then quotes the National Park Service (NPS) definition of a Phase I study. It is not clear why she uses the NPS definition as the NPS is a federal agency that is not involved in the current study. Also, as a federal agency NPS projects would follow federal statutes, not the California Environmental Quality Act (CEQA) under which the subject study has been completed. (Admittedly, the NPS was influential in developing cultural resource rules and these have influenced CEQA, but again, NPS and its regulations do not apply to the current project .) Different agencies use different terms for cultural resources assessments /inventories, evaluations , and data recovery reports -some use "Phases", others use "Classes", and there are many agencies that accept building or built environment evaluations as part of a Phase I survey. "Phase I" can also refer to environmental remediation projects. So "Phase" can be confusing and we usually don't use it. But use of the term does not indicate a shortcoming, or that report is only used for archaeology. Even so, since the term has caused confusion for this reviewer, all references to “Phase I” have been deleted.

Comment B: Phase I Cultural Resources Assessment (page 2) The reviewer explains the difference between archaeologists and architectural historians and questions the author’s qualifications . Since qualifications are not in the report (which she states) she cannot know what they are. The author exceeds the Secretary of the Interior Professional Qualification Standards for Archaeology, Architectural History, and History and has successfully assessed and evaluated dozens of similar resources for projects being completed pursuant to CEQA and to Section 106 of the National Historic Preservation Act (NHPA). Appendix A has been added to the report to include resumes of everyone that worked on the report, emphasizing qualifications.

Comment C: Identification of Historical Resources (pages 2-4) Under "Identification of Historical Resources" the reviewer states that the Area of Potential Effect (APE), Direct APE, and Project Area Limits (PAL) are not defined. APE and Direct EXHIBIT 2
2 APE are federal terms that are defined under Section 106 of the NHPA, which she states in the footnote on page 2 of her comment letter . As stated above, this report was not completed pursuant to Section 106 of the NHPA, and as such this statute and its rules and terms do not apply here. Use of t hese terms in a CEQA context would be misleading and is not recommended. The reviewer notes that the term “Direct APE” (a federal term usually reserved for specific Programmatic Agreements) was used in a callout in Figure 1 (page 2).

Given the references to CEQA in the report (there are 19), it seems implausible that the reviewer would think the report was intended to meet an unstated regulation (i.e. Section 106 of the NHPA ), but it appears to have caused confusion. We regret the errant use of “Direct APE” in Figure 1 and have replaced it with “Project Location”, which is appropriate for CEQA.

The reviewer references Figures 1 and 2, and claims that “project work area limits” is in Figure 1 on page 3. Since this term is not used in the cultural resources report and the figures do not match with the figures in the report, the reviewer has apparently switched to a critique of the Initial Study/Mitigated Negative Declaration (IS/MND). She also uses the abbreviation “PAL” and states that the PAL is not defined in the document. "Project Area Limits" is a specific term most widely used in cultural resource management by the California Department of Transportation ( Caltrans). Although this can be a useful term in a general planning context, it can cause confusion in a cultural resources context as it is a narrowly defined Caltrans term. As with incorrect use of federal terms, the use of “Project Area Limits” or “PAL” in this context would be misleading and is not recommended. Since the term has caused confusion, it may be better to replace “Project Area Limits” in the IS/MND with “Project Work Area Limits”, if appropriate. No change has been made to the cultural report in reference to this comment.

The reviewer goes on to state that staging and parking areas should be identified and that indirect impacts (noise, vibration, staging, and alterations to setting, etc.) should be addressed (page 3 of the comment letter). We received information that staging and parking would all be confined within the project site (depicted in our Figure 1). Since this did not change the project area, we did not think it needed to be mentioned but a sentence has been added to the report address that on page 1 of Cultural Resources Assessment.

Potential for impacts to the setting are addressed on page 11 of the Cultural Resources Assessment. Specifically, the previous development of Interstate 5 and State Route 134 freeway bridges, the reconfiguration of Flower S treet, construction of a modern bike path and walkways, and installation of transmission towers and streetlights, have completely altered the visual setting from when the channel was constructed. Furthermore, the area is highly urbanized and there is lots of noise and vibration, so I don't believe these impacts will be significant. Finally, we do not recommend adjustments to a project boundary to depict construction workers parking on a street with legal street parking, any more than it should be changed to include the streets that they drive on during their commutes.

On page 4 the reviewer states that the evaluation is superfluous and struggles to make a finding regarding eligibility. This is not accurate. We exhausted all available resources and references and made a clear recommendation for eligibility, which the reviewer apparently agrees with. She states that "Because the linear resource is determined eligible (not "found" nor does it "appear to be eligible"), therefore the Los Angeles River Channel is automatically listed in the California Register." Under CEQA there is no regulatory difference between eligibility and listing, so this is not a consequential comment. We would be happy to cite other reports (even if they were not filed at the South Central Coastal Information Center, as EXHIBIT 2
3 required) to support eligibility, but the things mentioned here would not change our recommendations. Besides, we do state that the L.A. River was determined eligible by the U.S. Army Corps of Engineers (page 10 of the Cultural Resources Assessment ), citing Thompson et al. 2022. The 2019 study by the Army Corps has been referenced in several other documents, and we requested it from the Army Corps of Engineers . We never received it and were told that it was not going to be made available. Furthermore, neither the reviewer nor SHPO (in the concurrence letter cited on page 8) cite the report directly so we do not even have direct evidence that this report exists . And finally, CEQA requires that “if the survey is five or more years old at the time of its nomination for inclusion in the California Register, the survey is updated to identify historical resources that have become eligible or ineligible due to changed circumstances…” (Public Resources Code §5024.1). As such, the 2022 citation is preferred over the 2019 study.

Regarding the project site's connection with Griffith Park, we do not think it is relevant. When we did our research, we used the map from the 1994 National Register Eligibility evaluation, and the project is clearly outside of the park boundaries, separated by Interstate 5 and State Route 134. The reviewer does provide a figure with lots of different boundaries that show the project within an approximate 1897 park survey boundary, and an approximate City of Los Angeles Park Boundary, but it also shows that the project site is outside of boundaries that depict historically sensitive resource areas, and other things (page 4 of the comments).

She also mentions “N o longer extant resources in the proposed project area” (page 5 comments). As the reviewer does not explain why she mentions these resources, and they no longer exist, this is not addressed.

She goes on to cite another "serious oversight" that transmission lines are within the project APE or PAL (page 5 of the comments). As indicated above, the terms "APE" and "PAL" are not relevant to this project, but we can still consider potential for indirect impacts. There are transmission lines that go overhead, but these have not been evaluated in the project area so eligibility was not indicated in our research and the towers are outside the impact area so direct impacts will not be a factor (which is why we have not recorded them). The project will not impact the alignments directly , and indirect impacts to transmission alignments are not likely to be consequential. Transmission alignments are made to withstand significant indirect impacts (like vibration and noise) and they occupy extensive linear alignments within all kinds of settings. And (as indicated above), the visual setting of this neighborhood has changed many times over the years and the proposed project would represent another change that is not substantially different from the previous changes. I think most reviewers understand this context, which is why it has not previously come up during any of the previous comments. No change to the report is necessary to address this comment.

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and that it is recorded without explanation. Page 7 of the report explains that the project site is occupied by the Glendale Narrows/Reach 3 segment of the Los Angeles River. Citations are provided that substantiate terms. No response to this comment is warranted.

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Historical Resources by not evaluating the Los Angeles River for National or California Register Eligibility. Again, it is not clear why she cites National Register eligibility since this is a CEQA report for which federal rules d o not apply. Furthermore, California Register eligibility evaluation is provided clearly on pages 10 and 11 of the assessment, including the statement that “the Los Angeles River Channel (including the Glendale Narrows/Reach 3 EXHIBIT 2
4 Segment) is eligible for California Register Listing” (page 10). No change to the report is necessary based on this comment. Page 6 of the comments indicates that the evaluation is not intensive because it lacks evaluation within a historic context. Context is provided on page 4-7 of the Cultural Resources Assessment, and evaluation is provided on pages 10-

11. No change to the report is necessary based on this comment.

The bottom of Page 7 and page 8 before “Project Description” contain several repetitions, rewording, and emphasis of previous comments. No change to the report is necessary based on this comment.

Comment C: Project Description (page 8)

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to the cultural resources assessment is necessary based on this comment. Page 9 indicates that the Project Description in the IS/MND and the technical report (which presumably means the Cultural Resources Assessment) are entirely different. Unless the Project Description in the Cultural Resources Assessment is inaccurate (not indicated), there is no need to provide the level of detail from the IS/MND Project Description. No change has been made to address this comment.

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points out that “significant adverse effect” is not correct and that “substantial adverse change which can cause a significant effect on the environment” is the correct CEQA verbiage. Elsewhere she prefers federal language so this is a confusing comment.

Nevertheless, the CEQA language is correct and the verbiage has been corrected as indicated on page ii of the assessment Management Summary and page 11 under Recommendations. The reviewer incorrectly assumes that the preparers are unqualified on page 12; this comment has already been addressed. She also cites CCR Title 14 Section 15064.5 “Determining the Significance of Impacts to Archaeological and Historical Resources” which explain when a historical resource’s significance is materially impaired. It is not clear why she cites this; the statute has been applied to the analysis and cited in the assessment. On page 12 of the comment letter, the reviewer claims to cite a California State Historic Preservation Officer concurrence letter to state that character -defining features within any projects at the Los Angeles River must be identified to assess whether project impacts will affect significance. As indicated above, we requested the report referenced (but not cited) and we have not received it. Therefore, it cannot be cited in our report.

Furthermore, the study may be outdated by CEQA standards due to age (as indicated above), and our reference to the 2022 citation is adequate. However, since we do not have a description of character-defining features, we have addressed all of the features that could be impacted by the project under Recommendations on page 12 of the Cultural Resources Assessment. Since all features have been addressed, no change is necessary to address this comment.

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River segment and how these things were calculated. The cultural resources report states that the segment in question is 7.4 miles long, and that impacts will occur within approximately .06 percent of the resource. The size of the segment was calculated using square feet of the 7.4 mile segment at a maximum width of 354 feet (approximately 13,831,488), minus the maximum square feet of area that the proposed project overlaps with the channel (97,800). The math gives us approximately .07 percent, but this is an overestimation because not all of the channel area that is intersected by the bridge will be EXHIBIT 2
5 impacted. We have therefore rounded down to .06 percent (the actual impacts are certainly smaller) of a resource that is virtually unvaried within its 7.4 miles. This calculation and reasoning are inexact but are designed to overstate impacts, as stated. The method was developed by the U.S. Bureau of Reclamation for an eligible river channel and this method has been used and approved for numerous similar projects in southern California. It has never been challenged in my experience. No changes to the report are made based on this comment.

Comments on page 13 question why the assessment states that bridge abutments would not touch levee walls (page 12 of the assessment, under Recommendations). This statement clearly demonstrates that installations will not impact features (including character-defining features) of the resource. She goes on to cite the U.S. Secretary of the Interior standards for rehabilitations, emphasizing that “a new addition should be subordinate to the historic.” We have demonstrated that a tiny (.06 percent -probably less) of the resource will be impacted. This demonstrates consistency with this comment. This was all apparently clear to the many previous reviewers and no changes to the report are necessary based on this comment.

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where it would be deposited, and the reviewer asks when that analysis would be prepared. It is not clear what she means by “analysis”. Due to the high level of disturbance and the complete lack of archaeological sites recorded in the area (zero within a mile), answering these soil questions would not constitute archaeological analysis. There are no indications of archaeological sensitivity, but given the level of disturbance, discovery of buried cultural resources is possible. Therefore, we have recommended robust measures to address potential archaeological discoveries on pages 12 and 13 of the assessment, under Recommendations. No change to the assessment is necessary based on this comment.

On page 14 of the comment letter, the reviewer states that the assessment confuses immediate setting within and near the resource’s boundaries with its larger surrounding setting, and goes on to provide a federal definition of setting (but does not provide a citation). Again, it is not clear why she is presenting federal verbiage for a CEQA report. She goes on to re -state that the “channelized Los Angeles River and Griffith Park are each historic resources. The electrical transmission lines and towers may wel…l… be historically significant as well.” The status of the L.A. River and Griffith Park are not in question, and the reason for this statement are not clear. Potential for indirect impacts to transmission alignments and Griffith Park have been addressed above and do not merit another response.

On pages 15 and 16 of the comment letter, the reviewer presents additional neighborhood details which she summarizes to state that the “area surrounding the Los Angeles River, like most of Los Angeles, was constantly changing” (page 15 and restated on page 16). We have not reviewed the additional neighborhood details provided, but if they are accurate the cultural resources report is in agreement with this statement. Page 7 of the assessment states that “the historic setting has been affected by the modern construction of athletic fields to the south, construction of Interstates 5 and 134 to the south, paved bicycle and walking paths, and the reconfiguration of Flower Street.” The additional details provided in the comments emphasize this statement. It’s not clear if the reviewer would like this information added to the report, but since it agrees with the report, we do not believe any EXHIBIT 2
6 change to this effect would be substantive. No change has been made to address this information.

The last paragraph on page 16 of the comment letter states that effects to eligible properties must allow resources to retain essential physical features and that they must be sufficiently visible to convey significance. The reviewer goes on to ask for new information that would help address the visibility issue. As indicated above, the assessment has demonstrated that all features that are present in the .06 percent of the resource that could potentially be partially obscured are visible within 99.94 percent of the resource. The U.S. Bureau of Reclamation (a federal agency) and many local agencies (for CEQA) accept that this level of impact would not constitute “a significant adverse effect”, or “ a substantial adverse change which can cause a significant effect on the environment”. No change has been made to address this comment.

From page 17 to 24, t he reviewer provides comments to the IS/MND, which was not prepared by BCR Consulting. We have not addressed these comments but will be available to answer related questions, and to make sure the cultural resources assessment remains consistent with this document.

Please contact me by phone at 909/525- 7078 or e -mail at [email protected] with any further questions.

Sincerely,

BCR Consulting LLC

David Brunzell, Principal

EXHIBIT 2

Glendale City CouncilJune 9, 2026

Glendale City Council
June 9, 2026