Dear Ballona Supporters,
Patricia’s Letter to the Water Board is dense with informationbut even if you only understand part of this information,you will be the better for it. JeanetteLearn about our local aquifers.1. Who’s wasting 650,000 gallons of freshwater daily and much more!2. Where our aquifers are!3. Why our wetlands are so un-naturally dry!SEE Grassroots Coalition - Patricia McPherson’s Waterboard Letter:
"Ballona Wetlands Ecological Reserve--Protecting & Restoring Ballona's Freshwater"
Hello Mr. Kang, Waterboard personnel,Ballona Wetlands overlies freshwater aquifers. The degradation of the freshwater aquifers of Ballona Wetlands has occurred through manmade over drafting of its freshwaters and by allowing the saltwater intrusion caused by the creation of Marina del Rey and the breeches into the Ballona Channel levees allowing saltwater flow into the manmade canals. Despite this degradation, the freshwater shed flow into Ballona Wetlands provided for freshwater levels to be at or near the surface in 1990. (1990 Environmental Impact Report) The upper freshwater aquifers are classified by the Los Angeles Regional Water Quality Control Board (LARWQCB) as Potential Drinking Water andthe lower, Silverado Aquifer is a major drinking water source for the Los Angeles Basin.LARWQCB currently permits a maximum of 651,500 gallons per day of Ballona’s groundwaters to be either thrown away into the ocean and/or the sanitary sewer as part of their CleanUp & Abatement Order 98-125 for decontamination of the historic industrial waste of the HowardHughes, McDonald-Douglas toxic legacy.Since, 2001, the LARWQCB has allowed for greater volumes of Ballona’s groundwaters and stormwaters to be pumped out, diverted and thrown away, resulting in 17 years of dewatering and drying out of the adjacent, unique coastal freshwater-- Ballona Wetlands. How much degradation to Ballona’s freshwater aquifers has occurred due to saltwater intrusion caused by the dewatering?Grassroots Coalition is requesting a proactive approach to ongoing control of dewatering activities at Playa Vista which will minimize the overall negative impacts to the natural features of Ballona Wetlands.The beneficial use, of the significant volumes of fresh water being pumped and diverted out from under Playa Vista, is being actively denied to Ballona Wetlands. Why?The GC CalEPA Complaints and the GC California Coastal Commission Complaint are requesting answers and action to restore Ballona’s freshwater to Ballona Wetlands Ecological Reserve.Department of Fish & Game and State Water Resources Control BoardOverall Goal Statement-To: Increase the abundance and diversity of California’s wetlands and riparian areas, and tosustain and enhance the delivery of ecosystem services.Executive Order 11990- Protection of Wetlands.Section 1. (a) Each agency shall provide leadership and shall take action to minimize the destruction, loss or degradation of wetlands, and to preserve and enhance the natural beneficial values of wetland in carrying out the agency’s responsibilities. Ballona’s oversight is inclusive of federal, state & local agencies that are able to work in concert to protect Ballona Wetlands Ecological Reserve.The diagram below, depicts the California Coastal Conservancy’s plan to further degrade the freshwater aquifers of Ballona by creating a salt marsh as similarly agreed upon in a 1990 Settlement Agreement with Playa Vista developers. The Ca. Coastal Conservancy does not address the freshwater aquifers of Ballona in restoration concepts and failed to alert the public to the drying out of Ballona via illegal drains that were recently capped after the California Coastal Commission cited the drainage as causing harm to the wetlands and a violation of the Coastal Act.LARWQCB dewatering volumes of a few years ago—950,000 gpd are depicted in blue overlay. The freshwaters of Ballona need to be returned and restored to Ballona Wetlands.The ongoing dewatering and diversion of Ballona’s ground and storm waters is the drying out of a wetland.The Artificial Drying of Ballona WetlandsViolating the Coastal Act, Playa Capital LLC inserted rainwater drainage devices, unpermitted by theCalifornia Coastal Commission. For approximately 20 years the Playa Vista mega developmentowners have been draining and throwing Ballona’s rainwater, into the ocean. And, since 2003, theCalifornia Department of Fish & Game (CDFW)has allowed the drainage to continue.A recently won Settlement Agreement by Grassroots Coalition against Playa Capital LLC and theCalifornia Dept of Fish & Wildlife(CDFW), included a California Coastal Commission(CCC) investigation,and CCC letters to both Playa Capital LLC & CDFW announcing the violations, seeking to end thedrainage. The Settlement Agreement provided for CDFW to apply for a Coastal DevelopmentPermit (CDP) to stop the drainage. CDFW applied for a CDP to cap the drains and the CoastalCommissioners approved an immediate (30 days) interim capping and required CDFW to alsoapply for a CDP to REMOVE THE DRAINS within 180 days.The decades long drainage of Ballona’s rainwaters has had no evaluation of its harm to the wetlands,no hydrology report of Ballona itself exists within the Draft Environmental Impact Report (DEIR) forBallona. The DEIR information was performed by the Ca.Coastal Conservancy’s contractors, whoare—in the main, Playa Vista’s long time contractors.Playa Vista Methane Mitigation DewateringThe City of LA, Dept. of Sanitation has allowed 17 years of pumping and dewateringunderneath the building sites of Playa Vista to ensure a lowered water table in order tokeep experimental oilfield gas mitigation systems free of clogging groundwater andsediments. In 2001-2 the Playa Vista site was discovered to be one of the largestoilfield gas leakage areas in the U.S. Experimental gas mitigation systems becamenew Methane Code requirements for Playa Vista called the PLAYA VISTA METHANEPREVENTION DETECTION AND MONITORING PROGRAM (PVMPDMP). And, a newCITYWIDE METHANE CODE was born based upon the PVMPDMP.https://www.ladbs.org/docs/default-source/publications/ordinances/methane-code---ordinance-no-175790.pdf?sfvrsn=10The City of LA Findings from the 2001 Task Force-‘found the occurrence of methane in soil gas to be correlated with the location of oil wells,oil fields, underground gas storage facilities, and landfills.’ pg.3“Known potential methane hazard areas are in the vicinity of gas sources such as landfills,oil wells, oil fields and underground gas storage facilities.” pg. 4(The LA City Council's approval of the city’s Chief Legislative Analyst’s Report (CLA) in 2001, disallowed residential development west of Lincoln Blvd. due to the potential hazards associated with SoCalGas oil/gas reservoir operations adjacent to Playa Vista. In 2003, the remaining portions of Ballona Wetlands, west of Lincoln Blvd. and north of Ballona Channel, were acquired via public bonds and by the state.)None of the cumulative dewatering of Ballona’s freshwater aquifersand stormwaters has been evaluated to consider protecting the historic freshwater that nurtures Ballona Wetlands.Based upon hearsay, the 1990 Settlement Agreement, (which ended a land use disputebetween the California Coastal Commission and the ‘Friends' of Ballona Wetlands),mislabeled the unique, freshwater aspects of Ballona Wetlands -- as saltwater wetlands.The Settlement Agreement’s parties divvying up Ballona land included the developers ofPlaya Vista, who promoted their designs upon Ballona to include a parcel (Area A) withinwhich they wanted to create a new marina, allowing intrusion of saltwater. The SettlementAgreement included the Playa Vista developers’ plans to dig out other parcels of Ballona,allowing for further degradation by saltwater intrusion. The parcels were to be intrinsicflood control areas for the development. The plan to dig out Ballona was born.The Friends of Ballona Wetlands Settlement Agreement managed to allow a catch basinportion of the development’s flood control to be placed west of Lincoln Blvd. with anoutlet to Ballona Channel that would throw away Ballona’s stormwater and water thatwas cleansed of contamination from the Howard Hughes historic toxic sites. (LARWQCBClean Up & Abatement Order 98-125) The Army Corps of Engineers and the CaliforniaCoastal Commission were both quick to provide permits, that were a part of the 1990Settlement Agreement, to Playa Vista developers prior to any Environmental ImpactReport being done onsite. ( 90-EV-463 Army Corps, Coastal Development Permit 5-91-463CA. Coastal Commission)WHAT DOES 651,000 GPD LOOK LIKE? IT IS SIGNIFICANT!__________________________________________Wetland impacts from groundwater withdrawals, March 2016 SnapshotsIn Minnesota-______________________"In general terms, long term dewatering has a greater potential to cause significant impact, compared to short term dewatering.”At Playa Vista, directly adjacent to Ballona, long term dewatering has been occurring forapproximately 20 years with no cumulative study to determine the water resource impactsand environmental consequences and/or mitigation potentials to restore the freshwater toBallona Wetlands Ecological Reserve—a freshwater dependent wetland."Natural groundwater flow plays an important role in sustaining many natural water dependentfeatures such as rivers, springs and wetlands. Groundwater control by pumping can potentiallyintercept groundwater which would normally reach these water-dependent features. If this occursthen river and spring flows may reduce or water levels fall in wetlands and ponds.”"ADEQUATE INVESTIGATION AND BASELINE MONITORINGIt is essential that the design is based on a thorough site investigation, including a desk study, toallow hydro-geological conditions and environmental receptors to be identified. It is also prudentto have extensive pre-construction monitoring of groundwater levels, spring flows, ground levels,etc to determine baseline conditions against which any impacts can be assessed.”-No studies have been done by either LARWQCB and/or the LA Dept. of Sanitation todetermine the effects upon Ballona Wetlands due to the voluminous, long term andongoing dewatering and drawdown of Ballona’s aquifers under Playa Vista.- In meetings, LARWQCB staff have stated that in areas under Playa Vista, as muchas 20 feet of lowering groundwater has occurred.-No baseline monitoring, assessment or comparisons with the hydrology studies donein 1990, have been done on Ballona pertaining to its hydrogeology in studies done forthe DEIR for Ballona’s restoration.-No mention of all the adjacent Playa Vista lowering of the groundwater table via multipledewatering devices and no mention of the drainage devices in Ballona itself was includedin the DEIR.__________________________Assessment of the Ecological Impacts of Ground Water Overdraft on Wetlands and Riparian Areas in the United Stateshttps://nepis.epa.gov/Exe/ZyNET.exe/20001V0G.txt?ZyActionD=ZyDocument&Client=EPA&Index=1995%20Thru%201999&Docs=&Query=&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&UseQField=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5CZYFILES%5CINDEX%20DATA%5C95THRU99%5CTXT%5C00000005%5C20001V0G.txt&User=ANONYMOUS&Password=anonymous&SortMethod=h%7C-&MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&Display=hpfr&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&MaximumPages=1&ZyEntry=14The following 2 links and copy, while going back into the 1960s—reveals what we already know today, WATER IS EXTREMELY VALUABLE AND NEEDS TO BE PROTECTED.https://books.google.com/books?id=ROMDAAAAMBAJ&pg=PA98&lpg=PA98&dq=what+does+650,000+gallons+of+water+per+day+look+like?&source=bl&ots=agvJHe5d6o&sig=VhU84RKXBr4wFUDygZcgsnsIwEQ&hl=en&sa=X&ved=0ahUKEwimrpHSkrraAhXL1IMKHTtBDYIQ6AEITDAD#v=onepage&q=what%20does%20650%2C000%20gallons%20of%20water%20per%20day%20look%20like%3F&f=falseWater Supply & Irrigation Papers of the USGShttps://books.google.com/books?id=kllNAAAAYAAJ&pg=PA17&lpg=PA17&dq=what+does+650,000+gallons+of+water+per+day+look+like?&source=bl&ots=cU9Zd7USty&sig=I2GANjVUgnYAi-otCciSAxifJFs&hl=en&sa=X&ved=0ahUKEwimrpHSkrraAhXL1IMKHTtBDYIQ6AEIUDAF#v=onepage&q=what%20does%20650%2C000%20gallons%20of%20water%20per%20day%20look%20like%3F&f=falseThe volumes of dewatering occurring under the buildings at Playa Vista, in order to lower the water table and disallow any groundwater and rainwater (which Playa Vista developers have classified as ‘NUISANCE WATER’) from infiltrating the gas mitigation systems, has only been partially determined. Methodology for measurement has been either lacking entirely and/or was not to industry standard. The Department ofnSanitation has however, simply allowed for the throw-away of these life-giving waters, without consideration to its beneficial uses for Ballona Wetlands.Grassroots Coalition is requesting the multiagency review and coordination take place to restore Ballona’s beneficial groundwaters and rainwater for use in Ballona Wetlands Ecological Reserve.THANK YOU FOR YOUR TIME in reading this letter and Grassroots Coalition looks forward to further meetings toward achieving the goal of restoring Ballona’s surface waters and recharging Ballona’s freshwater aquifers.Patricia McPherson, Grassroots CoalitionBallona Wetlands Aquifers-