2018 GC Letter Requests Restart of Cancelled 2005-2012 Ballona Wetlands Hydrological Study - 2012 Shelley Luce Cancelled without Santa Monica Bay Restoration Commission's Knowledge or Authority

GC Letter below, includes FinalHQ_LowerBallonaCreek.pdf 
The Ballona Reserve is a predominately FRESHWATER WETLAND.

The US Army Corps of Engineers​ (Corps) watershed & hydrology analysis of Ballona Wetlands was stopped, precluding inclusion of Ballona's fresh groundwaters and seasonal surface water as part of any restoration option. Thus, the US Army Corps of Engineers​' directive, that included "all reasonable alternatives", was also stopped.

Because a reasonable study was stopped by Shelley Luce, without consent of the Corps' local sponsor, the Santa Monica Bay Restoration Commission in 2012, the current Environmental Review only allows choices that will destroy all of Ballona's habitat, and its underlying freshwater aquifers to EXPERIMENTALLY CREATE saltwater embayments allowing saltwater intrusion, through massive, industrial scale bulldozing and digging out of Ballona (THE BALLONA BIG DIG)

The United States Army Corps of Engineers (USACE) never answered Congress. Thus, Congress has been taken out of the loop and still needs to be part of the decision making process for Ballona, including the reasoning process used to create alternatives. 

Below find a letter from our President, Patricia McPherson, to the California State Waterboard.

In the letter are excerpts from this 34 page PDF titled, "Lower Ballona Creek Watershed Ecosystem Restoration Los Angeles County, California 905(b) Reconnaissance Report", authored by U.S. Army Corps of Engineers, Los Angeles District on September 2002.  FinalHQ_LowerBallonaCreek.pdf (1.1 meg)

Hello Waterboard,

Grassroots Coalition provides the following document for inclusion in CALEPA Complaints 25061 & 23608.

GC brings this document to your attention. USACE was to perform watershed evaluations which would include hydrology analysis of the areas within this area of study.  Both the saltwater and freshwater aspects of Ballona were to be illuminated and inculcated into restoration options.  Ultimately, a Joint EIR/S beginning in 2005 occurred that was terminated in 2012.

No hydrology studies were performed. Playa Vista, which is highlighted in the descriptions of areas and transfers of property was an integral part of the study area. However, no examination of Playa Vista hydrology and its pumping and diversion of that historic water flow(s) and its draining away of rainwater was ever explored.  Instead, this 

Lower Ballona Creek Watershed
Ecosystem Restoration
Los Angeles County, California
905(b) Reconnaissance Report


U.S. Army Corps of Engineers,
Los Angeles District
September 2002




       a. This 905(b) Analysis was prepared in response to Section 216 of the Flood Control Act of 1970 which states:

“The Secretary of the Army, acting through the Chief of Engineers, is authorized to review the operation of projects the construction of which has been completed and which were constructed by the Corps of Engineers in the interest of navigation, flood control, water supply, and related purposes, when found advisable due the significantly changed physical or economic conditions, and to report thereon to Congress with recommendations on the advisability of modifying the structures or their operation, and for improving the quality of the environment in the overall public interest.”

supplemented by House Resolution on Public Works and Transportation dated September 28, 1994 which states:

"The Secretary of the Army is requested to review the report of the Chief of Engineers on Playa del Rey Inlet and Basin, Venice, California, published as House Document 389, Eighty-third Congress, Second Session, and other pertinent reports, to determine whether modifications of the recommendations contained therein are advisable at present time, in the interest of navigation, hurricane and storm damage reduction, environmental restoration, and other purposes at Marina del Rey Harbor, Los Angeles, California, with consideration given to disposal of contaminated sediments from the entrance channel required under the existing operation and maintenance program at Marina del Rey."

       b. Funds in the amount of $100,000 were appropriated in fiscal year 2002 to conduct the reconnaissance phase of the study, under the title, Lower Ballona Creek Watershed Restoration Study.


       The purpose of the reconnaissance phase study is to determine if there is a Federal (Corps) interest in participating in cost shared feasibility phase studies to evaluate water resource and ecosystem restoration opportunities within the lower Ballona Creek watershed. In response to the study authority, the reconnaissance study was initiated March 2002. The reconnaissance study has resulted in the finding that there is a Federal interest in continuing the study into the feasibility phase. The purpose of this Section 905(b) (WRDA) analysis is




       Because of the funding and time constraints of the reconnaissance phase, only limited and informal coordination has been conducted with State and Federal resource agencies, including the California Coastal Conservancy, California Department of Fish and Game, National Oceanographic and Atmospheric Administration and the Regional Water Quality Control Board. Generally, these agencies are supportive of other Corps of Engineers watershed studies in southern California. They recognize the merits of a regional approach to addressing water resource problems and opportunities and advocate the development of watershed management plans.



whole ‘iterative’ process the USACE had entered and that needed further congressional reporting and approvals, was ended without congressional approval and without its non-federal sponsor’s approval.

Instead, a private nonprofit, the Santa Monica Bay Restoration Foundation’s Director, without any state authority, single handedly told the USACE to stop the process.  Without checking credentials for such authority to end any studies—the USACE dropped the study(ies).

While the process problems noted above exist, the need for understanding the hydrology aspects of Ballona Wetlands/Playa Vista persist, in particular Ballona's freshwater aspects remain vitally important and Playa Vista’s pumping and dewatering of Ballona waters needs to be thoroughly examined.  The freshwaters of Ballona need to be returned and restored to Ballona.

Lower Ballona Creek Watershed Ecosystem Restoration Los Angeles County, California 905(b) Reconnaissance Report - Study Area

Example below of USACE acknowledgement of freshwater sources for Ballona.

Area B is bounded by Ballona Creek to the north, Lincoln Blvd to the east and the Westchester Bluffs to the west. It is currently an undeveloped parcel but for a few exceptions. There are approximately 142.6 acres of historic wetlands fed by freshwater sources including precipitation and local area runoff.

The above is just one reference to Ballona’s historic freshwaters.  The Poland et al report (1948-9); the Playa Vista 1990 EIR; subsequent studies by Travis Longcore PhD et al paid for with Ballona restoration bond funds….all demonstrate the vast freshwater component of Ballona’s freshwater sources.

Thank you for your assistance in review and investigation of these matters,

Patricia McPherson, Grassroots Coalition

Click on Grassroots Coalition LETTERS below for further information: