Monday, September 29, 2014

comments on L.A. City and County urban runoff cleanup plans (ie., wetland pollution plans)

Get Your Comments in Today by 5 pm (September 29th) on Plan to Clean up L.A.'s Beaches: hint, the devil is in the details, which so far do not exist

Comments are due today to

sorry for the lateness, but I'm "swamped".

Just copy and paste if you agree.

the project planners' websites are here:




September 29, 2014, 1:30 pm

From Rex Frankel, director, Ballona Ecosystem Education Project,

I understand why no one but myself attended the NOP hearing on September 9th in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects’ impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible.

Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches.

In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree.

Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion-style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere.

In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for.

Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is “piecemealing”, by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan.

The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around.

Please put me on the notification list for all actions relating to this project. Thank you.