Creek trail litter anticipated six years ago

Stanley Roberts of KRON brings his camera to the South Bay, where he finds evidence of People Behaving Badly as they litter the San Tomas Aquino Trail adjacent to Levi’s Stadium in the city of Santa Clara, CA.

This trail litter was anticipated six years ago during the environmental review process.

The Santa Clara Valley Water District, which manages and monitors water quality in this and other South Bay creeks and rivers, submitted public comment to the city of Santa Clara warning that trail litter is inevitable at large public venues. The Water District asked the city to monitor trash in and around the creek and to create “pre-established mitigation measures.”

Selections from 49ers Stadium Final EIR

The city of Santa Clara Bicycle Advisory Commitee (BAC) also expressed concern about trail litter.

Selections from 49ers Stadium Final EIR

The city’s response was underwhelming.

Selections from 49ers Stadium Final EIR

This same Final Environmental Impact Review, incidentally, also made no mention of trail closures.

Selections from 49ers Stadium Final EIR


  1. Excellent. I was the one that tipped off Stanley to check out the mess out there. I also filed illegal dumping complaints with the SCV Water District and they forced at least one largely ineffective cleanup.

    To date I can see none of the trash mitigation measures that were promised in the EIR have been done. The use of fine mesh fencing on pedestrian bridges to prevent trash blowing into the creek is not there. Monitoring of trash before and after events is not being done. And mitigating trash, when present, is not being done.

    I see open bags and bins of loose trash just piled up behind concession stands and that trash just blows away during the week. There are stadium signage, flyers, food and beverage containers, etc. scattered all along the creek.

    This is a major environmental issue and the city as the public agency in charge of this project needs to step in and enforce the CEQA regulations that were promised in the EIR:
    If the city is not going to own up to their responsibility, then it may be time for legal action:
    “Public agencies are entrusted with compliance with CEQA and its provisions are enforced, as necessary, by the public through litigation and the threat thereof.”

    I made a recommendation to the city and water district that the stadium adopt the entire stretch of creek from Mission down to 237 and thus be responsible for keeping it clean. As it is, some poor volunteers are stuck with that task and I know if I were one of them, I would be awful pissed at how the stadium operations are trashing my creek!

    From the EIR:

    Comment NN-1: This letter is in response to the Draft Environmental Impact Report for the 49ers Santa Clara Stadium Project. The report claims there will be a less than significant impact to the immediately adjacent San Tomas Aquino Creek or San Francisco Bay from increased pollution runoff or trash. Proposed post-construction BMP’s include sweeping, maintaining vegetative swales,
    litter control, stenciling storm water catch basins to discourage illegal dumping, and installing trash racks. However, I don’t believe this DEIR is taking into account the trash that will be discarded 1) on surface streets as people are driving to the stadium including over the Tasman Drive bridge crossing
    the creek and 2) by people walking over the creek on the two newly proposed pedestrian bridges. A pilot study done in San Mateo County to identify trash sources found littering at parks and dumping from bridges were the most likely sources of trash to the creek at the study site (“Pilot Study to Identify Trash Sources and Management Measures” park trash pilot study
    2005 report.pdf).

    How will littering directly into the creek be prevented and how will impacts to the creek be assessed after stadium events?

    Response NN-1: The proposed stadium and all parking areas will have sufficient numbers of trash receptacles to accommodate the volume of trash and recyclables estimated to be generated during stadium events. In addition, parking areas will be cleaned after each event. For these reasons, the City believes that operation of the stadium will not result in a significant increase in debris in San Tomas Aquino Creek.

    Comment NN-2: Firstly, the pedestrian bridges should be enclosed by fencing with small enough mesh to discourage all trash from being discarded over the bridge, including cigarette butts.

    Secondly, trash receptacles should be installed at both ends of each pedestrian bridge and positive signage should be posted encouraging people to use the receptacles in order to keep the creek clean for fish and wildlife. Thirdly, monitoring of the stream at the pedestrian bridges and the Tasman Drive bridge crossing using the Regional Water Quality Control Board’s or the Santa Clara Valley Urban Runoff Program’s ‘Urban Rapid Trash Assessment’ protocols should be done both the day before and the day after events to document trash accumulation information. This should be done several times before and after different event types. If trash is increased after an event, predetermined
    mitigation measures should be implemented.

    Response NN-2: This comment is noted.”

    Interestingly this section states no impact on the creek trail because I suspect all along they were thinking it would be closed during events. There is no mention of trash receptacles along the 3/4 mile stretch of trail (which I don’t think there are any). Also no mention of wind blown trash and for anyone who has been down there any afternoon, that is a significant factor.

  2. Made a presentation to the city council about this issue earlier this week. Not sure it had any effect as the regulations do not permit any discussion on the topic until it is agendized, which I asked for.

    I started a thread on a local NextDoor forum:

    Someone posted a reply from the SC city manager’s office and they are blaming the water district’s weed trimming as the cause of the trash problem. In so many words, had the water district not cut down all the tall weeds hiding the trash, it would not be visible. And their mowers chopped the trash into smaller pieces making pick up harder.

    OMG, what a cop out, blame the water district for doing their job! Perhaps this was the “pre-determined mitigation measure” promised in the EIR, hide the trash under the weeds!

    And they did admit in the reply that “some trash does reach the channel embankment”. So once a piece of litter makes its way off the paved surface, it is not the stadium’s problem any more. And this from the city that promised “the City believes that operation of the stadium will not result in a significant increase in debris in San Tomas Aquino Creek.”

    I’m guessing “a significant increase in debris” would equate to not being able to see the creek for all the trash. So anything less is not significant?

    Keep America Beautiful did a study on littering and found that the presence of existing litter has a high correlation to the likelyhood of new litter:

    “The second statistically significant predictor of littering behavior was the
    presence of litter in the site. Locations with more litter were associated with a
    higher littering rate. The statistical analyses showed that the presence of existing
    litter (both counted and rated by the observers on a scale from 0‐10) was predictive of littering behavior (γ = .02, p< .001 for the objective counts)."

    First predictor was number of trash receptacles preset. According to reports I've heard, there are a lot of red Levis Stadium trash bins out there, but many are all lined up next to the portable toilets. So the stadium is expecting patrons to detour down off the trail to the toilet area or else carry any trash with them 3/4 mile up to Agnews Rd. And when something like an empty drink cup is discarded, is it likely to be set neatly down on the paved trail for later pickup or tossed off down the embankment? So the stadium sends out a crew to pick up trash on the trail surface, but anything off to the side is left.

    And then the city has the gall to ask for volunteers to help clean up the trash generated from activity of this private company. Why can't the stadium clean up their own mess like they promised in the EIR? They could at least sponsor the clean up and treat volunteers to refreshments or something at the stadium, but instead the city is trying to recruit volunteers to help.

    And clean up the creek once a year for trash that accumulates on a weekly basis? Lest we forget what happens to that creek when it rains, water is up high on the banks and that trash gets washed into the bay. I guess it'll take Levis Stadium branded trash washing up on Redwood Shores or Shoreline Park in Mt. View to get some attention focused on this.

  3. Thanks for doing this. One of the ideas I’ve thrown out there about the trail closures was getting news media involved. I’ve also noticed that on the CEQA website there is contact information, and I’m debating getting in touch with them to question/discuss the legal status of the trail closures wrt the approved EIR, as the situation has changed since approval with the leasing of the GA parking lot and operation of the concession stands in it (prompting the SCPD to close the trails).

  4. Thanks Pete and yes, I think media attention is the way to go. What is up with those concession stands anyway? That is where they pile the loose trash after events and that blows away in the wind to litter the creek. I saw more out there last night.

    Then on top of that, this LEED-Gold certified stadium with 300+KW of solar panels has to put diesel generators out front to power those stands? They have power out there with the light poles, how about putting a few plugs and run those stands w/o polluting the air. Same with the multiple portable diesel powered light stands they have. Did they not plan for adequate lighting along with adequate litter control and closing the trail? Apparently not much coordination among those involved int he project. I can see putting in a generator or two for a temporary setup, but this is every event and seems to be part of the plan.

    Last night there was a ton of heavy copper cabling running all over the place and nobody around. A copper thief could have a heyday there, drive into the GA parking lot and load it up.

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