Sunday, November 18, 2007

Major Gas Station-Groundwater Polluters of the Lower Ballona Valley

Natural Treatment by River and Wetlands Restoration, or

At Least 20 Hyperion-Style Treatment Plants Throughout the City

(Click on maps to enlarge)

The above map can be found in the City's Integrated Resources Plan, located on the web at
(large 8.4 megabyte file)

By Rex Frankel/March 31, 2007

The Regional Water Quality Control Board has set deadlines for complying with the Clean Water Act for trash, bacteria, and other pollutants in our urban waterways and beaches.

The trash deadlines are very short, a matter of 2-3 years.

The bacteria deadlines are much longer, as compliance is much more complicated, and were set this way:

for the Santa Monica Bay watersheds including Pacific Palisades, Santa Monica, Venice, Westchester, Playa Del Rey and El Segundo, the deadline for full compliance is July 2013 if the Cities choose to merely treat the water and dump it back into the creek or ocean; this is called the standard approach.

the deadline is July 2021 if the cities not only clean up the pollution, but reuse the water, or replenish groundwater aquifers, and/or create wetlands, wildlife habitat and parks as part of the project. This is called the “integrated approach”. If the City chooses this approach, by the interim deadline of July 2013, the City must reduce health code violations at beaches by 25%, and reduce violations by 100% by 2021.

For the Ballona Creek Watershed, including Mar Vista, Del Rey, Culver City, east Santa Monica, Brentwood, Inglewood, Hollywood and West L.A., the final compliance deadline is July 2017 if the standard approach is used, or July 2021 if the integrated approach is used.

Either way, the City needs to get moving as these approaches will take a long time to construct and finance.

For the rest of the City, the water board has not yet adopted cleanup timetables for bacteria in the L.A. River and Compton and Dominguez Creeks.

How Much Water to Capture:

The City’s engineers have determined that in order to comply, they must capture and manage 25% of the City’s total runoff. This is based on the determination by the Water Board that before L.A. was developed, natural sources of bacteria led to high pollution levels on an average of 17 days a year. This is based on a reference watershed, the Arroyo Sequit in west Malibu, which is largely undeveloped and yet bacterial water standards are violated 17 days a year there. Therefore, the City has decided to capture and manage the runoff from all “rain days” except the largest 17 days of flow per year. That’s how the 25% number was arrived at. Since “rain days” include the day of a storm and the next three days (each storm creates 4 days of heavy amounts of runoff), this means that rain days in L.A per year have ranged from 30 in 2003 to 104 in the El Nino of 1998.

As anyone who has seen our creeks flowing on a rainy day knows, this 25% is still an enormous amount of water.

Current City Proposals to Comply with the TMDLS, (called Implementation Plans):
For the Santa Monica Bay watersheds, the Cities of L.A., Santa Monica and El Segundo made this “Integrated” proposal to the Water Board last year:

1. Storage and Reuse sites: use parks, government facilities and schools to capture clean rainfall in cisterns so that it can be reused on-site for landscape irrigation.
Potentially there are 62 acres of vacant urban sites available for this use, too, although 27 acres of this is at LAX Northside. The other acreage is not specified but the only site that comes to mind is at Playa Vista.

2. Divert dry weather runoff to the Hyperion treatment plant or to Santa Monica’s new urban runoff treatment plant. Most of these diversions have been constructed.

If #1 doesn’t work, the Cities proposed these additional “Standard Treatment” projects as a fallback:

3. Three Treatment Plants: at Temescal Canyon Park at Pulga Canyon (the ex-Oxy oil site); South Beach Park in Santa Monica; and LAX Northside (which could be either a treatment plant or a subsurface constructed wetland, which is effectively a gravel filter).

4. Operational Storage Sites: underground storage tanks under all existing beach parking lots would be needed to hold all the water so the treatment plants have more time to treat it; this allows treatment plants to be smaller.

5. Three potential subsurface flow constructed wetlands/gravel filters:
-Will Rogers State Historic Park, using 17 acres of native planted areas out of a total of 34 native planted areas in the park;
-Santa Inez Canyon Park, using 23 acres of native planted areas out of a total of 45 native planted areas in the park;
-El Segundo at Grand Ave and Illinois Street, using 1 acre of native planted areas out of a total of 2 native planted areas in the park;

The Cities’ proposed Implementation Plans proposed to only construct the projects in #1 above, which are projects in 25 parks and government sites, by the interim compliance deadline of July 2013, at which 25% of violations must be eliminated. These sites include 5 parks and street parkways in Venice, 2 parks in Westchester and Playa del Rey, 5 parks in Brentwood and the Palisades, 9 park and civic buildings in Santa Monica and 4 detention basins and the golf course in El Segundo. The problem with this plan is that these 25 projects would only capture around 2% of the Cities’ target runoff goal.

Proposals #3 and 5 could also curtail existing public use of these parks, or could be sited under a landslide (Pulga Canyon)

Based on this huge shortfall, the Water Board rejected this Implementation Plan in April 2006 and directed the cities to present a revised plan by January 2007, to allow the Water Board staff time to analyze it in time for the planned hearing in June 2007. So far, I have not seen nor heard of any revised plan being submitted.

For the 130 square mile Ballona Creek Watershed, City engineers have proposed some similar “integrated” facilities like in the Santa Monica Bay watersheds Plan:

-1. source reduction at schools and parks
-2. redirect dry season runoff to Hyperion sewage plant or to the existing North Outfall Treatment Facility in Culver City
-3. a possible Centinela Creek diversion to a constructed wetlands facility
-4. in-stream treatment by restoration or daylighting (uncovering a buried stream) for dry weather flows

However, because this approach doesn’t add up to managing enough runoff, the cities also proposed these “standard treatment” projects:

-including integrated projects #1 and 2, and eliminating a Centinela Creek treatment wetland and other creek restoration and in-stream cleanup projects; and
-building 3 wet weather treat and discharge (not reuse) plants at a cost of over $900 million in
the upper watershed, probably near La Brea and Venice Blvds., at the lower end of Westwood Creek/Sepulveda channel, and at the confluence of Centinela Creek and Ballona Creeks

Problems with the Cities’ Proposals:
In Neither of the 2 watershed Implementation Plans, or in the L.A. City IRP, is there any consideration of river restoration and removal of concrete or of a citywide network of greenways and treatment wetlands, except for mention in passing. No actual study that makes it possible to compare the merits of the natural treatment and restoration approach to either the source reduction or treatment plant approaches was done. This appears to violate the California Environmental Quality Act, which requires that project approval studies must consider a “reasonable range” of alternatives to the proposed project that could reduce the significant environmental impacts of the proposal. Natural river restoration and treatment wetlands have been documented as an effective and less expensive way to solve our water pollution problems, costing half as much as the “standard” methods. (See L.A. County Public Works Department study summary at this link:

To read the full final version of the study, click here: Adopted IRWMP, December 13, 2006

Why Go Natural? Alternate Natural Treatment Case Studies:
Natural treatment of water pollution is not some gleam in the eye of environmentalists. It is, in fact, being done right now in communities only a few miles from the Ballona Creek area. We have several examples of natural runoff capture and treatment methods available for us to evaluate their potential, showing that treatment plants are not the only possible pollution solution.

The Sun Valley Watershed project in the East San Fernando Valley ( has been launched in an area that does not have any storm drains and therefore, has severe flooding problems. The retrofit project includes construction of cisterns and infiltration basins, and in many cases using existing gravel pits to hold the stormwater. These pits will also serve as parkland on the upper terraces, while habitat and water storage will be in the lower elevations. The project’s goal is for no rainfall/runoff to run into the L.A. River. This means that any street pollution will be captured and kept from our rivers and beaches.

The South Bay Cities including Manhattan, Hermosa, & Redondo Beaches and Torrance have an equal level of concreting of the landscape as the rest of Los Angeles, in that there is very little open space left. But this region has dramatically less wet weather beach water violations than Ballona and the Santa Monica region. (See study of pollution problems at this link, especially on page 3-15. The study concludes
“In general, dry weather exceedances have been more problematic in Jurisdictional
Groups 5 and 6 (the South Bay Cities) than wet weather exceedances.”

The reason can be seen in the many open and unpaved water catch basins throughout the South Bay, which are in fact remnants of a system of vernal pool wetlands that once covered large areas of the sand dune system that the South Bay was built upon. Rainfall is now funneled from developed areas into “sumps” featuring wetland vegetation, as these natural basins are called, whereupon any overflow is carried by a storm drain to the ocean. Because the problematic dry season flows are very small compared to storm flows, they can easily be, and, in fact, are being diverted into the L.A. County sewage treatment plant in Carson. Therefore, the cleanup of the remaining water pollution problems in the South Bay is being accomplished much more easily than in the Ballona Watershed, because much of the natural drainage system was never paved over in the first place.


In the Ballona and Santa Monica Bay watershed of the City of Los Angeles, these natural treatment methods have a great potential to provide parks and habitat and they require very little maintenance compared to the “standard treatment” methods. Ultimately the taxpayers need to know the pros and cons of all three methods of compliance; until now, these choices have been made by City Engineers in relative isolation from the general public that will foot the bill.
Are L.A. officials mis-spending Bay Cleanup Funds?

From, January 15, 2007

Water bond projects flow slowly
Some L.A. officials and activists say public should be seeing more tangible results from the $500 million measure.

Staff Writer

More than two years after Los Angeles voters approved a $500 million water bond, only one project has been completed, others remain mired in bureaucracy and some environmentalists have begun to question city priorities.

Passed overwhelmingly in November 2004, Measure O raised property taxes to fund projects designed to keep trash and pollutants out of the Los Angeles River and Santa Monica Bay

In return, voters were promised solid engineering solutions to the city's water pollution and innovative projects to create parks and green space while cleaning up tainted urban runoff.

Since the measure has passed, the City Council has approved $70 million for 10 projects and recommended $28 million for four others.

But only one project has been completed and just a few others have broken ground, frustrating some city leaders who want voters to see the impact of their dollars faster.

"For people like me and (Councilwoman) Janice (Hahn), as well, we have portions of our districts that have really been mired in serious runoff contamination problems and needing more green space," said Councilwoman Jan Perry, who helped initiate the bond measure. "We have a real sense of urgency to get things proposed, funded and built because it takes so long to get public-funded projects built."

But some environmentalists on a Citizens Oversight Committee that reviews each bond project expressed satisfaction with the projects so far, but complained there is no master plan for spending or measuring projects' effectiveness.

And that has heightened concerns as the panel prepares to weigh two lake restorations that could suck up $200 million -- or 40 percent of the bond.

"The lack of a plan has been a real problem. They should have been working on a plan the day after the election," said Mark Gold, who is executive director of Heal the Bay and sits on the oversight committee.

Deputy Mayor Nancy Sutley has proposed an overhaul of the process, including the passage of a master plan and selection criteria to guide funding.

"We want to be sure the money we're spending is really going toward improving water quality," Sutley said. "In anything like this, it's OK once you've been through the first round to take a deep breath and see what parts worked and what parts didn't." But even as the city wrestles with spending the water bond money, there already is growing concern that it will soon run out if not managed carefully or leveraged with state funds.

While a half-billion dollars sounds like a lot of cash, the estimated cost of cleaning the city's dirty water and polluted bay is $8 billion. Shahram Kharaghani, the city's stormwater program manager who is responsible for implementing the bond measure, said the measure helped the city meet some water-quality regulations. But Kharaghani said he'll need $100 million more to comply with trash and bacteria pollution limits.

And to meet upcoming water quality regulations, Los Angeles will need another bond or two -- which could be hard to persuade voters to approve if money from the first water bond isn't spent well.

"When we spend this money it's literally a drop in the bucket," said Francine Diamond, a member of the oversight committee.

"We're very serious about making sure the money is well spent. We want to be able to say to the voters (the city) did a good job and we're ready for another water bond." But the bond itself may be making that difficult.

Previous bonds raised taxes to build fire stations, libraries and animal shelters -- straightforward projects the city has handled hundreds of times. But Measure O had a more intangible mandate: Clean the water.

Los Angeles is crisscrossed with 7,300 miles of paved streets, littered with trash, stained with motor oil and fouled with pet waste, fertilizers and toxic chemicals. Rain and irrigation wash the muck into concrete drainage channels that carry it into the river and ocean. Under a 1999 settlement between the U.S. Environmental Protection Agency and environmental groups, Los Angeles has 13 years to meet more than 60 water quality regulations on trash, bacteria, metals, salts and other pollutants. The measure was designed to raise money to meet those regulations -- and the owner of a $350,000 home will pay about $34 annually over 20 years to fund it. But the ballot measure was deliberately vague because many of the water regulations aren't even written yet.

And it took a year just to appoint the administrative oversight, citizen's oversight committee and create basic project-selection standards to administer the bond money.

"This is uncharted territory. We took a real leap of faith as a municipality," said Council President Eric Garcetti, who helped draft the measure.

"Part of the risk of being first is you have to learn the technology.

"Now that we have some of the lessons from that, we should be able to spend the money a little more quickly and with less guesswork."

City leaders also wanted the bond measure to address community desires. So in 2005, the city asked environmental groups, neighborhood councils, city departments and governmental agencies for project ideas. They submitted 52 ideas that were whittled down to 22.

But from the beginning, there was uncertainty about what would qualify as a water project. And then community groups and nonprofits were expected to prepare detailed, technical proposals -- for free -- and hand them over to the city agencies for implementation.

Eventually, the city hired a consultant, CH2M Hill, to help groups develop concept reports -- at a cost of roughly $30,000 a piece -- with technical water quality analysis.

Stephanie Pincetl with UCLA's Institute of the Environment recently critiqued the first phase of the water bond measure and found a lack of order and unclear guidelines risk "increasing disillusionment with city government" and could hurt future water bonds.

"We don't want to use this money helter skelter, because this project seemed good and that project seemed good, but they didn't have the cumulative effect we need."


Tuesday, November 21, 2006

Dear Friends,

Our campaign to save the rest of the open spaces in the Los Angeles
area got a big boost with the publication of a huge, extremely
favorable story by Judith Lewis in the November 9th edition of the L.A.
Weekly. To read it, click on this link:

The article explains how our beaches and rivers which have serious
water pollution problems can be cleaned up while at the same time
unpaving some of our concrete-covered metropolis, creating more parks
and wildlife habitat and linking together the parks we have.
The article explains how the project to clean up the Bay is mandated
under Federal law and thus presents a great opportunity to restore
natural rivers and wetlands which can help clean up this polluted water
that now runs down our streets, gutters and storm drains straight into
the ocean.

Longtime Ballona advocates were interviewed for the story and we are
very pleased with the result! (We are featured starting in the middle
of the article.)

Also, with the passage by the voters of Proposition 84 last week, more
money is available to buy and preserve parks. The last park bond
approved by voters in 2002 led to public acquisition of 600 acres of the
Ballona Wetlands and the 3000 acre Ahmanson Ranch, two long-fought-over
nearby open spaces.

more on river restoration from Judith Lewis' blog:
Prop 84: Dig up the culverts!

by Judith Lewis, L.A. Weekly

California voters on Tuesday approved Proposition 84, a $5.4 billion
bond measure for clean water and coastal protection that I would have
pushed hard for were I not playing journalist these days. And I was
worried about it-- 84 had been polling inauspiciously.

Coincidentally, the story I wrote about Jessica Hall and her search for
L.A.ís buried streams is on the cover this week. Money from 84 could go
to some of the projects discussed in this story: It’s been earmarked
for projects that prevent toxic runoff from entering the ocean--which
in many ways means returning natural waterways to as close to their
natural state as possible. Nature already did what infrastructure
continually fails to do. I began researching this story thinking that
Hall’s ambitions were sort of far off and visionary, but over the six
months I spent figuring it out, daylighting streams began to seem like
an utterly sensible way to fix our urban water problems. I’m hoping
people get that from the story.

L.A.'s Water Board voted unanimously (9/14/06) to enforce Clean Beaches laws; Polluters not happy...

Restored Creeks Can Revitalize Our Cities



Includes sidewalks and dining areas on walkways elevated above the creekside on stilts; a big difference from the concreted-over and the vertical-concrete-walled creeks in Los Angeles

Politics vs promises in quest for cleaner Bay

Monday, September 11, 2006
L.A. Weekly's Judith Lewis exposes the politics behind cleaning up Santa Monica Bay and how the promise of Proposition O and Cleaning up the Bay is being compromised by politicians' pork-barrel pet projects.

An excerpt from the voter information pamphlet describing Proposition O:

Development, and purchase, of land to create water-cleansing landscapes and parkways along and surrounding the Los Angeles River and Ballona Creek to reduce storm water pollution and bacteria that wash into these waterways, through natural filtration and treatment. These parkways provide multiple benefits such as controlling storm water runoff and flooding through increasing percolation areas and by creating open space for habitat preservation and recreation."
River Restoration is least expensive Santa Monica Bay Cleanup plan; L.A. City plans hearings on their plan for water pollution

Thursday, August 10, 2006

This is Scenario three, which creates connected parks and wetlands throughout L.A. County to help clean up our beaches and rivers.


A great study has just come out of the L.A County Public Works Department (August 2, 2006) that analyzes three scenarios
for cleaning up the County's polluted runoff that now fouls our beaches.

The results are: natural river restoration is the least expensive and has the most benefits!

Scenario three is strictly river restoration with treatment wetlands and parks along the rivers, a plan
which we support, and which could include the remaining 200 acres of unpaved private land at the
Playa Vista development site in the Ballona Creek floodplain.

Scenario one is similar to the plan L.A. City has been pushing as part of their TMDL and integrated resources
plan with small mechanized runoff treatment plants throughout the city and minimal land purchases.

Scenario two is a hybrid of #1 and river restoration concepts with large basins and treatment wetlands
scattered throughout the county, but not along the major waterways, and would require a lot of land

The results are that scenario 1 costs $47 billion and has $7.5 billion in benefits; scenario 2 costs $53
billion and has $8.1 billion in benefits.

Scenario 3, however, only costs $27 billion and has $12.5 billion in benefits. The experts have now
spoken: river restoration and natural treatment of urban runoff is not only the best plan, it's also
least expensive.

The full report is available at,%202006%20Workshop%20Materials/IRWMP%20Workshop%20Presentation.pdf

To See the three plans:

And to learn more, go to and click on the "Documents" tab at the top of the page.
L.A. City Releases Final Report on Sewage, Greywater and Storm Runoff Plan

August 8, 2006

The Final Environmental Impact Report for L.A. City's Integrated Resources Plan was released in early September. It can be read at the City's website,
Public hearings have not been scheduled yet, but could take place as early as October. Here's the City's news release from August, which mis-stated when public hearings will be held:

To: Neighborhood Council Leaders
From: Department of Neighborhood Empowerment

Subject: Joint DWP & Public Works Board meeting Notification of an Upcoming Joint Department of Public Works and LADWP Board meeting to consider adopting an Integrated Resources Plan and related Environmental Impact Report for wastewater, recycled water, and stormwater management. As a result of a joint effort between the Bureau of Sanitation of the Department of Public Works and LADWP, an Integrated Resources Plan (IRP) and Environmental Impact Report (EIR) was developed which:

· integrates planning for the three interdependent water systems of wastewater, recycled water and stormwater;
· reviews the City's water and wastewater needs for the next 20 years; and
· identifies necessary infrastructure improvements and policy recommendations.

The IRP and EIR were developed after an intensive 4-year process was undertaken that was built upon stakeholder preferences. During the process 21 initial alternatives were narrowed down to 4 alternatives that were carried through the environmental review process. These alternatives will meet a 20 percent projected increase in wastewater flow while maximizing the beneficial use of recycled water and urban runoff. This will optimize the use of our existing facilities and water resources, reduce pollution and Los Angeles' dependence on water imports. The Draft EIR for the IRP was issued for public review in November 2005. Thereview period ended on March 2006. This is an advance notice on the near completion of the Final Environmental Impact report (FEIR) for the Integrated Resources Plan (IRP). It is anticipated the FEIR along with the IRP recommendations will be forwarded to Council for certification after consideration by the Board of Public Works and the DWP Board of Commissioners (Boards). The consideration by the Boards will be at a joint meeting around the second half of September 2006 with Council action scheduled around the middle of October 2006. A copy of the Draft IRP recommendations, a copy of the FEIR and the IRP plan will be posted on the website before the joint meeting of the Boards. If you have any questions or would like to provide some feedback, please contact Mr. Adel H. Hagekhalil of the Bureau of Sanitation at (323) 342-6225 or Mr. Bill Van Waggoner of LADWP at (213) 367-1138.
Please also see for more information


Marina Freeway wetlands threatened by highway bridge construction

Read our lawsuit brief