Dear CDFW Director Bonham and Mr.(s) Burg, Brody, Pert and State Lands Commission personnel including Jennifer Lucchesi,
The Sierra Club Airport Marina Group is requesting responsive action to alleviate ongoing outgassing that is occurring over the Playa Vista oil well known as University City Syndicate, and to end the drainage of freshwater and outgassing ongoing at the unpermitted Drain (part of the Playa Vista/ CDFW Freshwater Marsh System) in the Ballona Wetlands & Ecological Reserve (BWER. We also support the actual language of the Coastal Development Permit Order which calls for the CDFW Application's removal of the unpermitted Drains to NOT be associated with the overall CDFW restoration plans for Ballona.
We are the regional group of the Sierra Club LA Chapter and are empowered with territorial jurisdiction of the Ballona Wetlands and the Ballona Wetlands Ecological Reserve (BWER).
We are raising critical issues brought to your attention in an April 27, 2020 email, “Subject: 2017 California Department of Fish & Wildlife, (CDFW) Betty Courtney Cites Harm to Ballona Due to Reduced Water Flow from Playa Vista | Grassroots Coalition.” The AM Group requests response to these issues of harm to BWER and requests that CDFW and State Lands Commission actively work to ensure that the freshwater of Ballona is RESTORED to the BWER.
In her email, Patricia McPherson, President of GC, highlights multiple points per the CDFW Coastal Development Permit regarding the Unpermitted Drains:
1. It is Grassroots Coalition’s understanding that the CDP Application was to provide for the re-moval of the Drains within six months and was NOT to be an Application for the abandonment
of the Drains.
The current application includes abandonment as an equal option. Also Condition #4, the removal within a year of action has been dismissed by CDFW, and instead ties the removal of the drains to CDFW’s plans to dig and dredge out Ballona.
The Coastal Commissioners voted unanimously and vigorously to disallow CDFW from applying
the Application for the removal of the drains to CDFW’s Plan for digging and dredging out Ballona Wetlands Ecological Reserve. CDFW has presented its Application in defiance of the orders of the California Coastal Commissioners. (See also Richard Burg’s email to Mandy Revell of Oct. 11, 2019) Furthermore, CDFW has acknowledged gross errors in their flood control design and specifications for their Plan, to which they have acknowledged it will likely take another two years before design corrections are made. The immediacies of the current drainage and outgassing are not being acknowledged or safely dealt with by CDFW.
2. During recent rains it has been documented that methane is being vented from at least one of the drains. This demonstrates that the drains are not properly capped. And, that with the breech of the drain, both outgassing and draining of water is taking place.
The specific concern of volatile gases utilizing the Main Drain and the risers as secondary collector zones of oilfield gas was raised by GC and dismissed by CDFW and its partner Playa Capital (and consultants) during the Coastal Commission hearings. It is well apparent that CDFW has failed to understand, acknowledge and prevent both drainage and outgassing as is demonstrated by the documented and current drainage and outgassing.
3. The ongoing outgassing over Playa Vista’s oil well - University City Syndicate has also been dismissed as a non-occurrence by CDFW vis a vis its Playa Vista/Brookfield leadership and consultants during Coastal Commission hearings. CDFW has failed to acknowledge, understand and alleviate the harmful oilfield outgassing within its jurisdiction within the Freshwater Marsh System. Ca. State Lands Commission has similarly failed to acknowledge, understand and alleviate the harm and ongoing dangers to the environment of the freshwater marsh system and BWER and to the public. The AM Group requests immediate acknowledgement and response from the State Lands Commission as to their participation in alleviating the ongoing threats.
The outgassing over University City Syndicate has since been reviewed by oil/gas experts including the City of LA’s former expert-Exploration Technologies Inc. and the need for re-abandonment of the well has been brought to the attention of Cal Gem.
4. Ongoing dewatering activities to which CDFW is allowing due to the current drainage via the breeched and failed capping of the unpermitted Drain and also due to the dewatering that CDFW allows via its ‘board membership’ of the Ballona Conservancy (a Playa Vista business) as it diverts freshwater out of the Freshwater Marsh System into the Main Drain and out to sea.
The Sierra Club Airport-Marina Group reiterates, and supports the Grassroots Coalition position and believes CDFW to be in violation of its permit conditions to cap the drains and to properly submit an application to remove the drains and associated unpermitted development within a year.
Along with Grassroots Coalition, Sierra Club Airport-Marina Group wishes to alert the CDFW & the State of California Lands Commission so that they may take immediate action to remedy the situation.
This situation threatens the public health, safety, and well-being of the 700,000 residents who live above and in close proximity to the BWER, as well as the endangered ecosystems that CDFW is mandated to protect and preserve.
Please respond to the Sierra Club Airport-Marina Group and please provide any/all questions or would like additional information.
Thank you for timely attention to this critical situation.
For Sierra Club Airport-Marina Group,
Chair, Conservation Committee, Sierra Club Airport-Marina Group