September 28, 2021
Good Morning Jennifer Wong and Lisette Gold,
Thank you Jennifer, for your email response message to Grassroots Coalition, confirming that you are the Department of Water Resources (DWR) SGMA Person of Contact (POC) for the basin. Thank you also for your explanation that it is not necessary to submit a copy of the Draft Groundwater Sustainability Plan (GSP) at this time, as it is a Draft, and therefore, we ostensibly needn't send our response comments for the Draft GSP to DWR at this time either. However, we send our comment response to you and the lead GSA, the City of Santa Monica and Lisette Gold due to our concerns regarding comments made in the Draft GSP as well as during GSA meetings by the GSA and its consulting company Dudek. As is cited in our response, we are greatly concerned that the GSA will not further its evaluation of the Groundwater Dependent Ecosystem(GDE), Ballona Wetlands Ecological Reserve. Our concerns are due to the GSA and Dudek expressing in both the Draft GSP and during GSA meetings that Dudek has already concluded its regulatory obligations under SGMA for evaluation of Ballona Wetlands Ecological Reserve as a GDE, including evaluation of CDFW Plan impacts upon the underlying freshwater aquifers. There is exigency to the performance of a prudent GDE study per SGMA requirements due to an approved plan of the California Department of Fish and Wildlife (CDFW) that would convert the Ballona Wetlands into a fully tidal saltwater bay. Thus far, neither the Draft GSP nor the CDFW Environmental Impact Report have performed a hydrology evaluation of Ballona Wetlands itself, or performed a Land Management Plan of and for the Ballona Wetlands natural resources, and/or gathered readily available hydrological data and information that contradict comments made in the Draft GSP pertaining to this southern region of the Santa Monica Subbasin.
Due to the above stated issues Grassroots Coalition requests the Department of Water Resources (DWR) to please review our response to the Draft GSP and hopefully step in to provide guidance and possibly technical support at this time in order to illicit a prudent GDE evaluation take place for Ballona Wetlands/ Ballona Wetlands Ecological Reserve and its underlying freshwater aquifers. The entire southern basin region is at issue, including potential impacts to the adjacent West Basin that have not been included while the GSA appears to state that these issues are concluded.
The Ballona Wetlands area includes public trust land and water under stewardship of the California State Lands Commission, and is managed by Playa Vista via its private business, the Ballona Conservancy. The Ballona Wetlands Ecological Reserve, is a Title 14, Section 630 Ecological Reserve with specific Purposes and Goals that are threatened by saltwater intrusion, and ongoing fresh groundwater and surface water diversion and wasteful discharge that has not been contemplated and/or addressed in the current Santa Monica Draft GSP. At stake, is the protection of the underlying freshwater aquifers, classified by the Los Angeles Regional Water Quality Control Board as Potential Drinking Water, which are currently being threatened with saltwater intrusion plans of CDFW, which are not addressed in the Draft GSP.
The Draft Plan does not satisfy the required conditions as outlined in § 355.4(a) of the GSP Regulations (23 CCR § 350 et seq.):
1. The Plan is incomplete, meaning it does not appear to include the information required by the Act and the GSP Regulations sufficient to warrant a thorough evaluation by the Department. (23 CCR § 355.4(a)(2).)
2. The Plan does not cover the entire Subbasin. (23 CCR § 355.4(a)(3).).
3. The Plan does not conform with Water Code §§ 10727.2 and 10727.4 in the Act, as we believe the Draft Plan does not substantially comply with the GSP Regulations, and therefor is not likely to achieve the sustainability goal for the Basin.
a. The sustainable management criteria and goal to stop seawater intrusion and maintaining protective groundwater levels are not sufficiently justified and explained.
b. The Plan relies on inaccurate information and has large, easily remedied data gaps that would provide information for prudent, adequate scientific assessment to quantify the groundwater conditions that are not currently dealt with in the Plan in order to provide an objective way to determine whether the Subbasin is being managed sustainably in accordance with SGMA.
c. The Plan demonstrates an inadequate understanding of where data gaps exist and does not demonstrate a commitment to eliminate those data gaps. In particular, increasing the monitoring network and retrieval of readily available data that would fulfill current data gaps for depletion of interconnected surface water is critical. Such data gathering and agency consultation, that has been lacking on the part of the GSA, is critical to obtaining a better understanding of the hydraulic connectivity of surface water and groundwater of the Ballona region. Addressing the proposed data gaps should also improve the ability to run more accurate model simulations.
d. The projects and management actions, as described in the Santa Monica Draft Plan, are currently unreasonable and are not commensurate with the level of understanding of the basin setting that would provide for planning to protect the Groundwater Dependent Ecosystem- Ballona Wetlands Ecological Reserve that the public paid over $140 million in specific bond allocations to protect and to ensure as a lasting public trust treasure. Additionally, the current Draft Plan does not provide data and/or information to increase storage potential of the Ballona, Bellflower and Silverado aquifers/aquitard or to prevent negative consequences of seawater intrusion upon the Public Trust lands and water. The Ballona public trust land and water are also registered as a Sacred Site by John Tommy Rosas, of Tongva Ancestral Territorial Tribal Nation (TATTN). The TATTN issues are also not addressed in the Draft GSP and need inclusion.
e. The use of conservation efforts such as discussed by the US Fish & Wildlife Service per performance of a prudent and adequate GDE study under SGMA at this time, appears feasible and reasonable to provide sufficient data and information likely to mitigate overdrafting via Playa Vista & CDFW as well as provide seawater intrusion protective response .
f. At this time, it does not appear that the Santa Monica Draft Plan addresses the potential of negative seawater intrusion upon the adjacent West Basin, which currently utilizes roughly 3/4 of its funding to inject freshwater to offset seawater intrusion into this drinking water basin. The CDFW Plan for saltwater intrusion into the Ballona Wetlands through an industrial scale removal of over 3 million cubic yards of soils to convert Ballona Wetlands into a saltwater bay has not been addressed in the Draft Plan.
g. The Plan does not provide a detailed explanation of how the varied interests of groundwater uses and users in the Subbasin were considered in developing the sustainable management criteria and how those interests, including their pumping, drainage and diversion of clean ground and surface water into the ocean and/or the Los Angeles Sanitation System will be or can be remedied in order to protect the GDE, Ballona Wetlands/Ballona Wetlands Ecological Reserve (all public trust land and water) and/or the multiple freshwater aquifers of this area.
Thank you for your attention to these matters of great public concern,
Patricia McPherson, Grassroots Coalition
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