2/22/2018

Bureaucrats Want to Speed Up Sea Level Rise's Harm to the Ballona Wetlands: 

Why the "un-natural" levees along the creek are actually good for the Wetlands

re:
"California's Salt marshes will vanish in less than a century if seas keep rising..., study finds"
http://www.latimes.com/…/la-me-salt-marsh-climate-change-20…

http://advances.sciencemag.org/content/4/2/eaao3270.full

Dear Editor, LA Times

LA's 600 acre State-owned Ballona Wetlands currently sit safely protected behind the levees of Ballona Creek. Un-natural as they are, the levees keep the rising sea from drowning out the homes for thousands of rare animals. Our State's engineers say the levees are adequate to continue protecting the wetlands at least until the year 2100. The levees also keep polluted upstream urban drainage in the creek from pouring into the fragile homes for wildlife.

So why is the California State Wildlife department pursuing an alleged "restoration" plan, which they admit is mostly not a restoration at all, to demolish these already-paid-for wetland protectors and submerge Ballona under the sea? Why do they want to spend $182 million or more to bulldoze Ballona and scrape it bare for years? Ballona is a fragile and biodiverse ecosystem that is now and was historically full of wildflowers, butterfly habitat, lizard-hideaways, freshwater ponds and muddy salt marshes. Why do state bureaucrats want to turn Ballona into exclusively an arm of the ocean, a biological mono-culture which your article and the new study warn against?

Construction and engineering firms may benefit from this boondoggle. Not the public. Alternative proposals that would actually restore the wetlands and preserve its biodiversity at a fraction of the cost were summarily rejected by the state bureaucracy. Google the Ballona Wetlands Restoration Plan and read about the rejected Alternatives 10 and 11. There is still time to change the bureaucrats' minds.

Even the loudest two supporters of the state's bulldozing plan have rejected the bureaucrats' plans for the wetlands south of Ballona Creek. And the Coastal Commission, which is one of two state agencies that must approve any plan for it to happen, is similarly skeptical. So, behind the scenes, the state plan has big problems.

Rex Frankel
President and Legal Director
Ballona Ecosystem Education Project
http://saveallofballona.org

2/5/2018

Our Comment Letter on the 8000-Page Restoration Plan Report

https://drive.google.com/file/d/1_77mAmDMAkGdEAFurhc8sLzarePIcMMi/view

and the attachments:

2/5/1991 DFG letter:
https://drive.google.com/file/d/1sQd8ifVouLUpv-YrG7QX3nH3T6jB_Pi3/view

Bay Foundation and Heal The Bay stretch the limits of good science to claim Ballona is "trashed":
https://drive.google.com/file/d/11K7E7hS_ds_lqQEkBKnLnxk5sZQ60_Z1/view
https://drive.google.com/file/d/1CeFyb6LNyyz4qDKaEc4tsOEBuouRkthb/view

North Ballona is not all "fill":
https://drive.google.com/file/d/1IKFG5mnzFQ2teh553-sYYqz0bmXuIKXu/view

10 Archeological Sites ignored, to be bulldozed or buried?:
https://drive.google.com/file/d/0B5SGRAMv8RXuS3FMZl84V01CRU0/view

Photos of all the cute critters at risk from the bulldozing plan

WILDLIFE OF BALLONA
https://drive.google.com/file/d/18NcQrj_XZUnh4fhCGEvg64t68JHW5FXQ/view

1/22/2018

 A Big victory for fans of the Ballona Wetlands: 

the governing board of LA's revered parks creator, the Santa Monica Mountains Conservancy, unanimously rejected endorsing the industrial scale, 9-years of earthmoving, wildlife- wipeout fake restoration plan despite heavy lobbying by state bureaucrats eager to blow $180 million of our taxes on a project rejected by locals, the Sierra Club and the LA Audubon Society. Here's the audio: https://soundcloud.com/rex-frankel/smmc-meeting-01-22-2018

12/14/2017 Coastal Commission Hearing on Illegal "Drying" of the Ballona Wetlands

CA Coastal Commission Slaps Around Developer For Illegally Drying Up Our Wetlands

A 4 Minute video, 12/14/2017



photos and maps:
https://photos.app.goo.gl/ZCMg227x57HJzA3m2

11/8/2017 Public Hearing on Ballona Restoration Plan

OUR STATEMENT AT THE 11/8/2017 PUBLIC HEARING ON THE BALLONA WETLANDS RESTORATION PROJECT:


TO: the California Department of Fish and Wildlife and the US Army Corps of Engineers,


"Of all the alternatives, if #3 eliminated the dredging of Parcel A and featured historically accurate small creeks in it, there would be something I could endorse. Unfortunately, the current Alternatives 1, 2 and 3 are intolerable and are not restorations by any credible standard.

My message to you is this: YOUR PLAN SIMPLY SWITCHES THE LOCATIONS OF THE PARCEL B WETLANDS AND THE PARCEL A UPLANDS.

THIS SWITCHEROO IS A HUGE WASTE OF OUR MONEY.

RESTORE THE BALLONA WETLANDS...WHERE THEY ARE NOW.
RESTORE THE BALLONA UPLANDS...WHERE THEY ARE NOW.

YOU DON'T NEED TO DESTROY BALLONA IN ORDER TO SAVE IT


THERE ARE MANY LEGAL DEFICIENCIES IN THIS DRAFT EIR.

--YOUR PROJECT VIOLATES THE COASTAL ACT. Because it's not a restoration and that's all the Coastal Act allows.


--YOUR PROJECT VIOLATES THE U.S. CLEAN WATER ACT: because it floods the wetlands with polluted street runoff, with no plan to clean it up. It is illegal to degrade the water quality in federally delineated wetlands, which is what the Ballona Wetlands are.


--YOUR PROJECT ALSO VIOLATES CEQA, in that it fails to include or analyze an essential part of the project, which is the Clean Water Act-mandated street runoff cleanup plan that must be implemented before you can tear down the levees and flood the wetlands with water from Ballona Creek.
You have no plan to clean up 99% of the flow of Ballona Creek (which comes on rainy days), no EIR, and no analysis of its impacts or whether it will ever happen.
The only plan that exists is to clean up flows in the dry season, which is not when most of the pollution and trash flows down the creek. This plan will mostly dry up the creek in the dry season by pumping three quarters of creek flows to Hyperion which will dump it in the ocean. A WASTE. Then your own EIR says it will be too difficult to provide freshwater to the wetlands, so you dismiss all freshwater alternatives as “MECHANIZED” OR HIGH MAINTENANCE. But that problem of lack of freshwater is created by your partners in the Wetlands restoration project LA City's Sanitation Department which chairs the SMBRC, which created the Bay Foundation, and the LA County Flood Control District, BY THEIR “MECHANICALLY” DRYING OUT BALLONA CREEK during most of the year. (As stated in their Ballona Creek Bacteria TMDL Project DEIR released August 2017, CA State Clearinghouse number 2017021047)


So you dismiss reasonable alternatives by using a “straw man” argument.




YOU CAN FIX ALL THESE LEGAL VIOLATIONS THIS WAY:

give us a historically accurate project, thus it will fit the definition of “restoration” and comply with the Coastal Act.

Don't flood our wetlands with polluted cruddy Ballona Creek stormwater which may never be cleaned up. INSTEAD: Pipe the clean flows during the dry season from the new Ballona Creek dry season treatment plant in Culver City to restore the historical freshwater marshes of the Ballona Wetlands.

Because you won't be flooding the wetlands with pollution, you won't violate the US Clean Water Act. Because upstream polluted stormwater will not flow into the Ballona Wetlands, an upstream rainy season creek water cleanup plan is not an essential part of your project, thus, you will then not violate CEQA by deferring analysis of what is no longer an essential part of your project.
Finally, by leaving most of the land at Ballona where it is, (leaving the wetlands where they are now, leaving the uplands where they are now), you will avoid destroying thousand year old archeological sites or desecrating graves as the Playa Vista developer discovered. You will avoid evicting the wildlife while engineering firms and their friends “Heal Their Wallets” at our expense.


Please listen to the groups who saved over 600 acres when others were willing to let it be paved. This current plan is not “Bringing Back Ballona”. Let's actually restore Ballona, not turn it into something it never was."