RESPONSE TO CALIFORNIA COASTAL COMMISSION ...SUSTAINABILITY PRINCIPLES
August 9, 2023 Item 6 e.
Coastal Commissioners and Coastal Commission Staff,
Grassroots Coalition appreciates the California Coastal Commission's (CCC) initial steps to promote coastal sustainability in Greenhouse Gas Emissions (GHG) as well as Sea Level Rise (SLR)-INCLUDING PROTECTION OF COASTAL FRESHWATER RESOURCES PER THE CCC's adherence to the SUSTAINABLE GROUNDWATER MANAGEMENT ACT (SGMA) and its attendant GROUNDWATER DEPENDENT ECOSYSTEMS (GDE), and other sustainability factors for the coast.
Grassroots Coalition has previously supplied information to the CCC on these issues and again re-provides information alongside new information in order to help facilitate action on the part of the CCC to
protect the coastal Santa Monica Groundwater Basin and its Groundwater Dependent Ecosystem known as the Ballona Wetlands Ecological Reserve. The following issues presented include the need to protect the human built environment within the Santa Monica Groundwater Basin and inland.
https://saveballona.org/ website for Grassroots Coalition
The Playa Vista development site is well established as a known high pressure (20psi) oilfield gas emissions area which according to the City of Los Angeles' oil/gas experts-namely Exploration Technologies Inc. Victor Jones et al., is one of the largest oilfield gas leakage areas in the United States. As such, the City of Los Angeles created a new methane code that was and is, in part experimental and that but for this system operating properly and safely, the site was considered too dangerous to develop. The Ballona Wetlands underlies this development site and the Ballona Wetlands Ecological Reserve lies adjacent to this development site to the west and north, north west. At the time the methane mitigation was being developed--the Playa Vista Methane Prevention Detection and Monitoring Program (PVMPDMP) ORDINANCE, the site was thought to not have SoCalGas reservoir gases leaking to the surface. Contrary to this old belief, it is now known and established that SoCalGas reservoir gas leakage has been occurring for decades and gave rise to the shut down of the operations in the 2010 timeframe for about a year while containment was attempted.(Division of Oil & Gas Order (1008)
SoCalGas continues to operate in the Playa del Rey bluff top area as well as it operations continue throughout numerous wells located in the 'flats' of Ballona Wetlands Ecological Reserve and the SoCalGas reservoir gases are continually being retrieved by SoCalfrom their northerly migration within the Playa del Rey oilfield to the north, into the Venice, Marina del Rey area.
The following link provides information to the state status of attempts for closure of SoCalGas' underground gas storage operations. CCST Report, a legislatively ordered report on the safety of underground gas storage reservoir operations in California. SCG/Playa del Rey was considered to be dangerous due to its age and gas leakage problems.
The CCC maintains authority over the coast at Ballona via its Coastal Development Plan 5-91-463 which includes the Playa Vista -riparian corridor area that leads into the FRESHWATER MARSH, a Playa Vista catch-basin that is owned by the State Lands Commission and is overseen by Playa Vista and the California Department of Fish & Wildlife via their joint board membership of Playa Vista's Ballona Wetlands Conservancy. The following link provides the City of LA's former oil/gas expert's comments and concerns regarding the leaking Playa Vista/ State Lands Commission oilwell known as University City Syndicate which is located in the 'freshwater marsh'. This well needs to be abandoned properly.
Cal Gem, formerly known as the Division of Oil & Gas and Geothermal Resources (DOGGR) has already plotted University City Syndicate's location via a magnetometer and gps as seen in the DOGGR video clip.
NOTE: The state of California and the City of Los Angeles is pursuing a 3500' buffer zone for any new oilwell drilling. The SoCalGas 'replacement oil/gas wells' as cited in the now decertified CDFW-Final Environmental Impact Report are planned by SoCalGas to be new drillings of wells within that buffer zone. Most of the citations by SoCalGas place the replacement wells within a few hundred feet to less than half the 3500' buffer zone( sensitive receptor area) being sought by the city and state. SoCalGas should be working to abandon the SoCalGas operations entirely but for the need to forever monitor their operative field area for migrating gases. We hope that the CCC will work to disallow the replacement wells .
Data from SoCalGas has already established the known saltwater corrosion problems with numerous wells of this operation as well as corrosion and leakage issues from wells not formerly operated by SoCalGas but are within the underground storage area used by SoCalGas. Numerous wells are documented as having acted as gas migration conduits to the surface for SoCalGas reservoir gas and oilfield gases. Saltwater intrusion into the coastal area should be avoided due to the hazards posed by corroding, old and abandoned wells that can and have acted as leakage areas from the Playa del Rey oilfield within which SoCalGas injects and stores its gas.
PROTECTING BALLONA WETLANDS ECOLOGICAL RESERVE'S FRESHWATER DRIVEN ECOSYSTEMS.
Ballona's plentiful, natural freshwater - View our Slide Show below or download the Slide Presentation Ballona Wetlands Freshwater Playa Vista CDFW Drainage - 19 slides/pages in PDF of 11.1 megabytes.
Sea Level Rise is not an issue of concern for the Ballona Wetlands Ecological Reserve as it is protected via the coastal dune system and human built environment on its western edge. However, should CDFW be allowed to remove the levees of the Ballona Channel and dig out Ballona below sea level, repositioning the levees to the perimeter of Ballona Wetlands---then there would be great concern created due to saltwater intrusion for both its corrosive actions upon the hundreds of old, abandoned oil wells but also from the TMDL impaired saltwater and sediment of the ocean and Ballona Channel that has not been evaluated for its contamination consequences to the multiple underlying freshwater aquifers of Ballona Wetlands Ecological Reserve. Ballona Wetlands is acknowledged by the Department of Water Resources as a Groundwater Dependent Ecosystem and as such must be protected from saltwater intrusion into all of its underlying freshwater aquifers. The surface waters of Ballona derivd from rainfall, give rise to lakes of freshwater being formed each year.
As cited in the California Coastal Commission (CCC) Letter (4/11/14) to Playa Vista and CDFW draining Ballona is harmful to the ecosystem
- SaveBallona.org/2017-california-department-fish-wildlife-cdfw-betty-courtney-cites-harm-ballona-due-reduced-water-flow-playa-vista.html (CDFW Betty Courtney letter to Playa Vista).
Like the CDFW/Playa Vista unpermitted drains action that has harmed Ballona's hydrology and ecosystems for 20 years prior to them being ordered capped/sealed by the CCC after prevailing litigation by Grassroots Coalition against both CDFW and Playa Vista; the surface waters of Ballona are being drained away to the ocean via old agricultural drainage ditches that send the freshwater out through the southwestern levee of the Ballona Channel through unpermitted (no NPDES permits); CCC permits appear nonexistent) openings to the sea. The unevaluated volumes of wasted freshwater sent to sea need to have CCC protection for sustainability of the freshwater ecosystems of Ballona Wetlands. While the issues likely require multiagency collaboration in order to stop this waste of clean freshwater draining away from Ballona, this IS AN ISSUE OF SUSTAINABILITY AND AN ISSUE OF THE SUSTAINABLE GROUNDWATER MANAGEMENT ACT and its required enforcement for GROUNDWATER DEPENDENT ECOSYSTEMS.
The following PPT provides an historic background as to how BAllona Wetlands has been failed by multiple agencies in its protection.
FRESHWATER- the Surface/Groundwater interface needs to be protected.
Ballona Wetlands is a Sacred Site, as registered by John Tommy Rosas, Tongva Ancestral Territorial Tribal Nation (TATTN) and as carried forward by Chief Anthony Morales. (Sequence 1, 2 PPT)
NOTE: CEQA litigation by Grassroots Coalition et al has prevailed against the California Department of Fish & Wildlife (CDFW) and its certification of a Final Environmental Impact Report for Ballona Wetlands.
The court ordered all physical activities to cease by CDFW upon Ballona. A new Environmental Impact Report must be prepared. Therefore, Sequence 1,2 are disallowed at this time however, the PPT provides informational background for protecting Ballona's freshwater resources and stopping the wasteful drainage and throw-away of Ballona's abundant freshwater resources.
Please review the materials provided and we request to meet to review the issues of the Santa Monica Groundwater Basin and the protection of the GDE-Ballona Wetlands freshwater resources.
Patricia McPherson, Grassroots Coalition
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