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."
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