Ballona Wetlands Aquifers At Risk: Playa Vista Throws Away Millions of Gallons of Freshwater Every Week

Grassroots Coalition's leader, Patricia McPherson, raises major alarm about Playa Vista's 30 year history of intentionally de-watering to protect their billion dollar development on Los Angeles' Westside. 

Hello Waterboard-State and Regional and Ca. Dept. of Water Resources, 
USING WATER WISELY —Executive Order B-37-16
The aquifers underlying Ballona Wetlands are classified as ‘potential drinking water’. Historically, the groundwater is at or near the surface. (EIR 1990 PLAYA VISTA)
“Water is the main requirement for a functional wetland. Any fill or alteration of wetland hydrology reduces a wetland’s ability to function.  If water is drained or removed, or isn’t present in the wetland for as long, then wetland function is degraded.  Therefore, wetland function is degraded by actions that disrupt water supply through direct fill and draining of a wetland and habitat within the reserve.” pg. 8 of 9, 4/11/14.  PDF attached below.

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(The PDF references California Coastal Commission identification of Coastal Act violations and unpermitted drainage sites in Ballona Wetlands Ecological Reserve.

                                An August Meeting of the CCCwill address an Application by the Ca. Dept. of Fish & Wildlife (CDFW) to stop the drainage from these sites.  The Application is a result of a Settlement Agreement between CDFW & Grassroots Coalition after CDFW & Playa Vista failed to act per CCC requests that are included within the CCC Letter.)
This is a request for review and analysis to determine potential harm to Ballona Wetlands Ecological Reserve from the diversion of all the waters east of Lincoln Blvd. that would ordinarily flow into the Ballona Wetlands and provide the life-giving waters to Ballona Wetlands.
The following image depicts a portion of Ballona Wetlands, in Los Angeles and is intended to convey a simplified image of one source of freshwaters that could be restored to Ballona Wetlands Ecological Reserve.  This source and other dewatering areas have been being pumped out and diverted away from Ballona Wetlands.  The 950,000 GPD comes from a 2008 document (attached) describing Playa Vista dewatering of groundwater that ordinarily would be supplying Ballona Wetlands.  The image only includes one portion of dewatering elements of Playa Vista.  Playa Vista has multiple dewatering elements.  
The bottom of page 2 (attached below) states, “ There are no other feasible reuse options for the groundwater other than for dust control purposes at the site.  Therefore, the majority of pumped and treated groundwater will be discharged to the storm drain.”
Playa Vista's reasoning that water reuse cleanup efforts are COST PROHIBITIVE is their only rational for throwing its groundwaters into the sanitary sewer system.
( Agreement attached- Groundwater Discharge Into City’s Sewer System)
REALITY:  THERE ARE EXTREMELY BENEFICIAL REUSE OPTIONS FOR GROUNDWATER;   NAMELY,  RETURN THESE WATERS TO BALLONA WETLANDS ECOLOGICAL RESERVE.  ‘Cost prohibitive’ citations by Playa Vista should be evaluated in context of causing unnecessary harm to the publicly acquired, 
Ballona Wetlands and the millions of dollars of public funds placed in jeopardy.
1.  The EIR, Phase 1 of Playa Vista cites that there should be no long term dewatering of the site.  The EIR and Vesting Tract Agreements speak to any groundwaters brought to the surface, will be cleansed and reused onsite to eg. recharge the underlying aquifers. This is not occurring.
2.  Best Management Practices provide for protection of the groundwater.  The groundwater of Playa Vista and Ballona Wetlands are classified as potential drinking water.
Ballona Wetlands Ecological Reserve is downgradient of freshwater that flows from east to west from the surrounding watershed. The EIR for Playa Vista, phase 1 reveals the groundwaters are at or near the surface.
3.  Over the years, since the development of Playa Vista and, since the acquisition by the public of much of the Ballona Wetlands, there has been a progressive theme cited by agencies with oversight of the public lands.  Namely, that Ballona Wetlands is drying out.  These agencies which include the California Coastal Conservancy, California Dept. of Fish & Wildlife(CDFW) and private businesses such as the Bay Foundation.   These entities profess oversight of the restoration of Ballona Wetlands but none have had hydrology studies performed for Ballona Wetlands itself. Instead, these entities have excluded any actual onsite hydrology studies, excluded any acknowledgement of the illegal drains and drainage happening within Ballona Wetlands and have excluded any review or analysis of upstream dewatering of Ballona-- by Playa Vista-- that is directly adjacent to and part of the historic Ballona Wetlands. Playa Vista needs to dewater due to toxic remediation and its need to lower the waters away from their methane gas mitigation systems.  Playa Vista must also be responsive to the overall problem of being located within a 100% liquefaction, floodplain area.  None of these problems however, means that the waters that are taken out, cannot be returned to Ballona Wetlands.
This is a request for review and analysis to determine potential harm to Ballona Wetlands from the diversion of all the waters east of Lincoln Blvd. that would ordinarily flow into the Ballona Wetlands and provide the life-giving waters to Ballona Wetlands.
Already, Playa Vista and the CDFW have been determined by the California Coastal Commission to be in violation of the Coastal Act for harm being done to Ballona Wetlands Ecological Reserve via the unpermitted drains and drainage directly within Ballona Wetlands.  
-When this illegal drainage is combined with all the Playa Vista constantly ongoing dewatering, what is the cumulative volume of water that is being deprived from reaching the Ballona Wetlands? 
The Ballona Wetlands is historically, a predominantly seasonal freshwater wetlands.  Its history does include its ancient saltwater influx from hundreds of years ago and historic but occasional saltwater influx when sand dune barriers were temporarily broken from storms. But now, Ballona’s unique and rare freshwater aspects are currently being destroyed due to the diversion and throw-away of its freshwaters to both the sanitary sewer and the Santa Monica Bay via the Ballona Channel.  The City of LA Dept of Sanitation is allowing, without any consideration of the negative environmental consequences, for Playa Vista to simply throw away this precious groundwater into the sanitary sewer.  The Waterboards are aiding this endeavor due to the lack of review of how diverting and taking  away a wetland’s groundwaters has deleterious environmental consequences.  We ask that the Waterboards investigate this matter and act to protect the historic groundwater flows into Ballona via any and all codes and other legal means available.
Best Management Practices should allow for Ballona’s freshwaters to be restored to Ballona Wetlands Ecological Reserve.  The public has paid millions of dollars for the restoration of Ballona Wetlands Ecological Reserve which should intrinsically include the return of its freshwaters to flow into Ballona Wetlands as occurred prior to the development of Playa Vista. 
Past meetings with LARWQCB staff has alerted Grassroots Coalition to their acknowledgement that the water table of Playa Vista has been lowered approximately 15-20 feet.
The historic water table of the area has thus been lowered and consequently the normal flow of groundwater and surface rainwater flowing into Ballona Wetlands has been removed.  
The California Coastal Commission has stated that if Ballona Wetlands is being harmed from the diversion and removal of the waters then, action can be taken to restore those
waters.  LARWQCB and Dept. of Water Resources have the ability to investigate and determine what are the actual volumes of water being diverted from Ballona Wetlands.
-There are no well completion permits for Playa Vista according to USACE documents that requested all such permits within a few mile radius of Ballona Wetlands.
Only a couple of well completion reports were provided to USACE and none were from Playa Vista.
The SPIDER MAPS included in this request letter, provide a visual for the numerous dewatering well locations at Playa Vista.
- The monitoring of dewatering volumes needs to be assessed in light of the difficulties of actual valid measuring dependent upon specific measuring device(s) that may or may not be being utilized by the Dept. of Sanitation and/or LARWQCB.
DWR Portion copied: 
Article 2. Definitions 13710. 
"Well" or "water well" as used in this chapter, means any artificial excavation constructed by any method for the purpose of extracting water from, or injecting water into, the underground. This definition shall not include:

(a) oil and gas wells, or geothermal wells constructed under the jurisdiction of the Department of Conservation, except those wells converted to use as water wells; or

(b) wells used for the purpose of (1)
dewatering excavation during construction, or
stabilizing hillsides or earth embankments.
Well Completion Reports
DWR is responsible for maintaining a file of well completion reports, which must be submitted whenever a driller constructs, alters, or destroys a well. This is a valuable resource and service to landowners who want to find out about subsurface geologic conditions on their property or to determine particular well construction details for their water wells. The information is also valuable to researchers trying to better understand the groundwater basin.
Other Well Forms for Well Drillers, Water Well Contractors, and Well OwnersTo protect the State's groundwater supplies, the Legislature authorized the establishment of well standards (Department of Water Resources Bulletins 74-81 and 74-90) and regulations pertaining to the construction, alteration, and destruction of wells. California Water Code Section 13750.5 requires that those responsible for the construction, alteration, or destruction of water wells, cathodic protection wells, groundwater monitoring wells, or geothermal heat exchange wells possess a C-57 Water Well Contractor's License. This license is issued by the Contractors State License Board. California Water Code Section 13751 requires that anyone who constructs, alters, or destroys a water well, cathodic protection well, groundwater monitoring well, or geothermal heat exchange well must file with the Department of Water Resources a report of completion within 60 days of the completion of the work.
The following Documents highlight significant volumes of dewatering taking place that need to have cumulative impact analysis.

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This next 2002 document discusses 25,000 GPD  and Playa Vista's need to have perpetual dewatering and the sending of that groundwater to the sanitary sewer.  While, through time there may be variation in groundwater dewatering, the focus of this review request is to raise awareness and promote action towards a cumulative dewatering analysis that includes what has been done since buildout of Playa Vista started and a bringing up to date the current volumes of dewatering that are occurring.

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Other dewatering that is being done at Playa Vista, includes the building sites themselves as continual dewatering is done to keep groundwater and any rainfall or sprinkler system waters from percolating down into the methane gas mitigation systems.  Included below are images (SPIDER MAPS) of building sites and dewatering locations. Please note the date of the map as 2000, hence prior to actual buildout of the sites and hence questimated/ not actual  dewatering.

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Thank you for review of this information.  Grassroots Coalition looks forward to a positive resolution of these issues that 
will benefit the public and the environment,
Patricia McPherson, Grassroots Coalition

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