CDFW's Nefarious Scheme to Destroy Ballona, a Rare Coastal Wetlands

California Department of Fish and Wildlife (CDFW) tries to get California Coastal Commission permit approval for cutting toxic, salt water channels into clean, healthy, freshwater habitat. CDFW tries to circumvent the CEQA lawsuits by illegally piecemealing a portion of their entire destructive plan: Sequence 1 and 2.

Three Presentations

  1. 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.
     
  2. CDFW scheme to undermine the California Clean Water Act - View our 13 page Slide Presentation below or download Contradiction to CDFW Sequence 1 and 2 - PDF of 12.1 megabytes.
     
  3. Our quest to have CDFW adhere to CEQA and do the required Ballona Wetland's Groundwater Dependent Ecosystem (GDE) evaluation - Read our letter to CDFW Angela Murvine (click here), lead administrator for CDFW's Sustainable Groundwater Management Act (SGMA), and available as a download in a 5 Page PDF of 2.1 megabytes.

Presentation 1:  Ballona's Plentiful, Natural Freshwater

Ballona Wetland's Freshwater Playa Vista CDFW Drainage - 19 slides


Slide 1
: Water Is Life - Protect Ballona's Aquifers
            Introduction  - Predominantly Freshwater Wetlands and Tongva Indigenous Sacred Site

01.Water_Is_Life-Protect_Ballonas_Aquifers-Introduction-Predominantly_Freshwater_Wetlands-Tongva_Indian_Sacred_Site.png


Slide 2
: Ballona Wetland's Plentiful Freshwater

Freshwater_Wetlands_Protected_by_Who_Question


Slide 3
: Protected by Who Question: Playa Vista Dewatering Needs

Protected_by_Who_Question-Playa_Vista_Dewatered_Needs


Slide 4
: Playa Vista Pumps Clean Freshwater into the Sanitary Sewer and the Ballona Channel.

Playa_Vista_Pumping_Freshwater_to_Sewer_Lower_Water_Table


Slide 5
: Restore Freshwater Flow Into Wetlands

Restore_Freshwater_Flow_Into_Wetlands


Slide 6
: Playa Vista Drainage System 2003: no consideration of Sea Level Rise in the Playa Vista EIR.

Playa_Vista_Drainage_System_2003_Ignores_Sea_Level_Rise


Slide 7
: LARWQCB Dewatering

LARWQCB_Dewatering


Slide 8
: Spider Maps: Locations of Permanent Methane Gas Dewater Systems

Spider_Maps-Locations_of_Permanent_Methane_Gas_Dewater_System


Slide 9
: Playa Vista Dewatering Purpose

Playa_Vista.Dewatering.Purpose


Slide 10
: Dewatering for Methane Gas System Mitigation

Dewatering.Methane.gas.mitigration


Slide 11
: Playa Vista Dewatering Daily of Clean Groundwater

Playa_Vista_dewatering_daily_of_clean_groundwater


Slide 12
: Dewatering Diverts Freshwater from Wetlands

Dewatering.diverts.freshwater.from.Wetlands


Slide 13
: Unpermitted Drains Installed by Playa Vista

unpermitted.drains.installed.by.Playa.Vista


Slide 14
: Unpermitted Draining of Ballona Wetlands

Unpermitted.draining.of.Ballona.Wetlands


Slide 15
: Land.Management Plan still not done by CDFW

Land.Management.Plan.still.not.done.by.CDFW


Slide 16
: Historical 1998 USACE 1135 Levee Project

USACE.1135.Levee.Project


Slide 17
: Historical EPA 1986 Report states Clean Water Act Applies to Ballona Wetlands

EPA.1986.Report.states.Clean.Water.Act.applies.to.Ballona.Wetlands


Slide 18
: Ponding Rainwater Pumped Out by Playa Vista

Ponding.Rainwater.pumped.out.by.Playa.Vista


Slide 19
: Rare Regional Habitat: Coastal Predominantly Seasonal Freshwater Wetlands

Rare.Regional.Habitat-Coastal.predominantly.seasonal.freshwater.wetlands

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Presentation 2:

CDFW Scheme to Undermine
the California Clean Water Act:
Contradiction to CDFW Sequence 1 and 2

 

View our 13 page Slide Presentation below or download Contradiction to CDFW Sequence 1 and 2 - PDF of 12.1 megabytes.

Slide 1: CDFW tries to illegally piecemeal a portion of their entire destructive plan.

01

Slide 2: CDFW is legally required to do the Groundwater Dependent Ecosystem (GDE) evaluation

02

Slide 3: CDFW's Sequence 1, 2 continue to fail to address the natural freshwater systems

03

Slide 4: Belding's Savannah Sparrow endangered habitat has been restored.

04

Slide 5: Historical 2014/4/8 endangered Belding's Savannah Sparrow habitat.

05

Slide 6: Passive regeneration in Four Months of native plant species after 2021 BWER fire.

06

Slide 7: Post 2021 Fire Passive Regeneration of Sedges and Pickleweed.

07

Slide 8: Regrowth of many native flora species.

08

Slide 9: "..tidal channels are not needed" - Margot Griswold Ph.D

09

Slide 10: Performing a required Land Management Plan of natural hydrology will show no need to create harmful saltwater channels.

10

Slide 11: John Tommy Rosas registers Ballona as a Sacred Site -.

11

Slide 12: Indigenous Tongva Tribal Nation not responded to by CDFW, CCC, and CSLC.
Comments from Chief Anthony Morales of the Gabrieleno Tongva San Gabriel Band Mission and John Tommy Rosas Tongva Ancestral Territorial Tribal Nation (TATTN).

12

Slide 13: Indigenous Chief Anthony Morales requesting required Land Management Plan (LMP) to adhere to SGMA per Ballona being a GDE, to protect the SA'ANGA Sacred Site.  Ballona's Freshwater Is Sacred.

13

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Presentation 3:

Our quest to have CDFW adhere to CEQA and do the
required Ballona Wetland's Groundwater Dependent Ecosystem (GDE) evaluation

Read our below letter to CDFW Angela Murvine, lead administrator for CDFW's Sustainable Groundwater Management Act (SGMA), and available as a download in a 5 Page PDF of 2.1 megabytes.

grassroots_coalition-logo.png

Good afternoon Ms. Murvine,

This email is sent to you as the Sustainable Groundwater Management Act/
Groundwater Dependent Ecosystem administrator for the California Department of
Fish & Wildlife. Please note/ include the email sent today, to you from Grassroots
Coalition that is additional response regarding the Santa Monica Basin and Ballona
Wetlands Ecological Reserve –a Groundwater Dependent Ecosystem. (sent at 2:10
pm Monday, Oct. 31, 2022)

mywaterquality.ca.gov/monitoring_council/environmental_flows_workgroup/docs/2019/cdfw_sgma_20190514.pdf,

Grassroots Coalition continues to attempt to bring CDFW into compliance
with the Sustainable Groundwater Management Act (SGMA) and
compliance with Groundwater Dependent Ecosystem evaluation for
protection of the Title 14, Section 630 FGC approved and Office of
Administrative Law registered, Terrestrial / Non-Marine Ecological
Reserve--Ballona Wetlands Ecological Reserve, located on the Los
Angeles coastline in the Santa Monica Basin--a medium priority
basin. The Department of Water Resources has acknowledged Ballona
Wetlands as a Groundwater Dependent Ecosystem (GDE).

letter.picture1.CDFW_.Non-Regulatory-Request-Action-Table.png

As cited above by the staff of the Fish & Game Commission (FGC) the
issues of protection Ballona Wetlands Ecological Reserve (BWER) under
SGMA as a GDE are a part of discussions with FGC staff and Grassroots
Coalition as to how to protect Ballona Wetlands, as legally required.

As noted in the comment by FGC staff, the geohydrological / GDE issues of
BWER should be included in the restoration objectives of Ballona
by CDFW. However, SGMA and GDE issues are not addressed in the
CDFW certified Final Environmental Impact Report (FEIR).
Neither the
Draft EIR nor the FEIR have geohydrological evaluation of Ballona
Wetlands Ecological Reserve itself.
There are two CDFW failed /
rejected by Army Corps of Engineers, flood control/ hydraulics studies for
the Ballona Channel (which is outside the the Ecological Reserve). Thus
far, there has been no address/ evaluation by CDFW of Ballona Wetlands
Ecological Reserve itself as a GDE. There has been no address or
evaluation by CDFW for the protection of the multiple underlying freshwater
aquifers that underlie both the adjacent Playa Vista development site (of
which CDFW claims to be a board member of the Playa Vista Ballona
Conservancy) and underlies all of Ballona Wetlands Ecological Reserve.

CDFW has acknowledged problems with freshwater diversion by Playa
Vista's ongoing dewatering and diversion away from Ballona, that has
harmed the hydrology and ecosystem(s) of Ballona.
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).

Ms. Courtney of CDFW, has since retired but the letter clearly announces
the harm to Ballona Wetlands due to Playa Vista's failure to allow
freshwater flow to Ballona.

"The reduced volume of water has compromised the success of the
mitigation project, limited the habitat function and value, and
decreased fish and wildlife diversity."
Betty Courtney CDFW

And, the California Coastal Commission has confirmed that CDFW violated
the Coastal Act via unpermitted drainage of Ballona Wetlands since
CDFW's acquisition of Ballona Wetlands in the 2003/4 timeframe.

Any take away of Ballona’s freshwater is harmful to Ballona Wetlands
Ecological Reserve. There is no excuse for throwing away this
precious, life-giving water.

As cited in the California Coastal Commission (CCC) Letter (4/11/14)
to Playa Vista and CDFW … draining Ballona is harmful to the
ecosystem:

“… a water supply of a reliable quantity and quality is needed thus
contributing to the habitat function of the larger Ballona Wetland
project instead of directing it away from habitat regs within the
Ballona Wetlands Ecological Reserve.”
(p. 3 of 9 4/11/14 CCC Letter to
Playa Capital LLC and to CDFW re: unpermitted drains)

“… a continuous detriment to wetland hydrology and habitat that
relies on water to function.”

“… degradation of wetland function through alteration of hydrology
means that the same plants may not grow and habitat value and
wildlife use of the wetland are reduced.” (p. 8 of 9 4/11/14 CCC Letter to
Playa Capital LLC and CDFW)

As discussed by Lisa Haage lead of CCC enforcement, referencing
that taking away water from a wetland is the exact opposite of what
one would allow in a wetland:

“We think that draining a wetland is about the most amazing violation
that you could have.”

“I mean, putting a drain in a wetland is exactly the opposite of
anything that you’d do in a wetland.”
(December 14, 2017 Dana Point CCC Meeting Item 10 C)

This CDFW unpermitted drainage has since been stopped via litigation
against CDFW, and the Ca. Coastal Commission ordered the capping of
the illegal drainage. The area now ponds again and the Title 14, Section
630 Purpose and Goal--targeted vegetation pickleweed has passively
regenerated throughout this previously drained area. The Endangered
Belding's Savannah Sparrow, targeted species, now has this habitat again
to forage and nest.

letter.picture2.FEIR_.Inconsistencies.Hydrology.Vegetation.Native.Pickleweed.freshwater.wetland.habitat.from_.capping.unpermitted.drains.2012.image_.compare.2020.image_.png

None of this activity has been accounted for in the FEIR or in any recent
activities proposed by CDFW for this and adjacent areas wherein CDFW is
now proposing to contaminate the freshwater aquifers with new manmade
channels to bring in toxic Ballona Channel, Santa Monica Bay seawater.
(LARegional Water Quality Control Board has listed the manmade Ballona
Channel and the manmade channel entrances for seawater into Ballona
Wetlands as IMPAIRED waterways/sediment. The land and groundwater
areas of Ballona outside these impaired waterways have been provided No
Further Action (NFAs) by LARWQCB as clean.)

At this time, there is exigency of CDFW's SGMA/GDE division to compel
adherence to SGMA and GDE protective measures of evaluation and of
protective measures for the freshwater natural resources of Ballona
Wetlands Ecological Reserve.

There is also ongoing pumping, dewatering of Playa Vista clean
groundwater that has not been evaluated per any Groundwater
Sustainability Plan which is simply sent to the City of LA's Sanitary Sewer
under Industrial Wastewater Permits. (Grassroots Coalition, in response to
the Draft Groundwater Sustainability Plan for the Santa Monica Basin has
4been responsive including adding the Playa Vista/ CDFW dewatering
information to DWR.)

Since, Ballona's acquisition by CDFW, there has been no protective
hydrological evaluation of the multiple drainage channels that Playa Vista
had created in the Ballona Wetlands Ecological Reserve that continue to
needlessly discharge seasonal rainwater ponding into the ocean via the
Ballona Channel discharge points. None of the pumping/dewatering/
diversions of Ballona's natural freshwater (both surface and groundwater)
by either Playa Vista (for dewatering to keep groundwater at least 1 foot
below oilfield gas intake pipes; the LARWQCB CLEAN UP & ABATEMENT
ORDER program; or CDFW drainage and diversion of Ballona's freshwater
to the sea, has been evaluated and/or addressed as required per SGMA
and GDE(s) protocol.

Currently, CDFW is attempting to excavate new channels to bring in
saltwater into the predominantly seasonal freshwater wetlands, into areas
that have not had tidal influence (Historical Ecology of Ballona Wetlands
Watershed, Dark, Longcore et al) The area under immediate threat, CDFW
is calling Sequence 1,2. At risk are the underlying freshwater aquifers that
are classified by the Los Angeles Regional Water Quality Control Board as
Drinking Water and Potential Drinking Water. At risk is the biodiversity of
Ballona Wetlands as a Groundwater Dependent Ecosystem.

The following PDF is a powerpoint presentation pertaining to Sequence 1,
2.

Grassroots Coalition respectfully requests your response to these very
timely and now urgent issues.

Patricia McPherson, Grassroots Coalition

Please note included powerpoints in the email cover letter for further
information.

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