Grassroots Coalition Letter to State Lands Commission, Director Lucchesi, April 23, 2018 re: Ballona Freshwater & Methane Gas Leakage

Hello Ms. Lucchesi, 

In watching the April 19, 2018 SLC meeting on C-SPAN, your discussion of “getting to know the SLC properties” was of particular interest as the role play of SLC appears to be shifting as part of  new strategic planning that is a bit different than prior years where the properties were delegated out for stewardship and SLC was not as engaged in oversight.  Ballona Wetlands is leased, as you know, by CDFW.  
We-- Grassroots Coalition and the Sierra Club, Airport/Marina Group have been made aware of your recent visit to Ballona.  While, we were not participatory in that meeting, we appreciate your visit.  
Grassroots Coalition (GC), as you are also aware, has been sending various Public Record Act requests and supplying some information to SLC pertinent to Ballona.
SLC has, historically played a large role in oil/gas issues along the coast and it was gratifying to read about SLC’s role in the reabandonment/closure of the Becker Onshore well. While your visit, here at Ballona, was primarily focused with the Ballona Institute and wildlife related issues, GC would like you to be aware of issues that
have been ongoing with the habitat upon which the wildlife lives.  Namely, oil & gas issues and freshwater issues inclusive of groundwater and rainwater pertinent to Ballona’s survival as a freshwater dependent wetland and ecosystem.
To that end, GC is sending you a copy of correspondence-series of Letters-- that we are writing up as part of our collaborative work with the LA Regional Water Quality Control Board and the California Coastal Commission.  These issues, while we provided information to the DEIR/S in the SCOPING PHASE, they were not made part of the Draft Environmental Impact Report.
The DEIR contains no onsite hydrology evaluation of Ballona and contains no evaluation of potential harm to the freshwater systems- including multiple underlying aquifers, should the site be converted into a non-historically oriented salt water wetlands.  As you likely have seen presentations by Margot Griswold, a leading restoration ecologist, then you know that southern California has been systematically altered or ‘homogenized’ into saltwater habitats as Ms. Griswold characterizes the restoration projects in SoCal.  While, restoration attempts for historic saltwater wetlands are appreciated, it is the fewer, unique freshwater coastal wetlands, as is Ballona, that need the utmost protection and address to issues of freshwater dependent wetland ecosystems.
Hence, GC is providing our Letters discussing Ballona’s freshwaters and what has been happening to that freshwater. (Some letters were previously provided to you.)
GC’s background in oil/gas field issues is also extensive, having engaged SOCALGAS in litigation via the California Public Utilities Commission system for over 8 years.  The litigation resulted in a Settlement Agreement achieving precedent setting monitoring of oilfield gases of SCG operations however, there is much that SCG remains to do per the SA.  GC was instrumental in the creation of a new LA CITYWIDE METHANE CODE and the Playa Vista—METHANE PREVENTION DETECTION AND MONITORING PROGRAM that resulted from extensive oilfield gas monitoring studies done in Ballona Wetlands and the Playa Vista site.
Please note the following study ( CCST Report) performed as the result of a legislative request for it.  The Playa del Rey SoCaGas facility is singled out with the CCST Report stating,
“Our report questions, but does not answer, the impact of closing this site.  The State should commission a cost-benefit analysis including full consideration of risks associated 
with loss-of-containment from this facility." 
That —loss of containment is what GC has been pursuing for the past 20 plus years and to which we have extensive scientific analysis from experts in gas migration. Namely,Bernard Endres Phd, John Robertson, Petroleum Engineer and Mr. Chillingar Phd.  
RECENT HEIGHTENED gas leakage in land owned by SLC, is occurring in the freshwater marsh/aka Playa Vista’s flood control catch-basin.
The Playa Capital LLC abandoned well, University City Syndicate leaked shortly after its reabandonment.  DOGGR required the near surface leakage sealed and 
several bags of cement were used.  However, within a few months the well continued to leak and has been leaking since, with heightened  volumes of outgassing occurring recently.  There has been no address of the leakage.   This outgassing is occurring over the well head of University City Syndicate.
Oilfield gases in this area, are exposed via free outgassing but also there are dissolved gases which, during various drilling operations at Playa Vista and/or on the wetlands can and do cause geysering effects.  The State Lands Commission owns the freshwater marsh system, at least, west of Lincoln Blvd. which includes the Main Drain of the system out to the Ballona Channel.  The Main Drain has, attached to it, two illegal drainage wells put there by Playa Capital LLC approximately 20 years ago that drain off ponding rainwater.  The California Coastal Commission, after investigation, declared the wells unpermited by the CCC and, a Violation of the Coastal Act due to their harm to the wetlands via freshwater removal.  CDFW is now under a CCC requirement to have capped the wells and to apply for another coastal development permit to remove the drains.
Thank you for your time spent in reviewing this mail and Letters,
Patricia McPherson, Grassroots Coalition

Also see Letter to Mr. Kang and Water Board Personnel:
Patricia McPherson's Water Board Letter re: PROTECTING BALLONA AQUIFERS and Attachments 4.17.18