Updated: Nov 20, 2022
August 3, 2020
August 3, 2020
TO: Richard Brody
California Department of Fish and Wildlife
c/o ESA (jas)
550 Kearny St. Suite 800
San Francisco, CA 94108
E-mail and USPS: BWERcomments@wildlife.ca.gov
U.S. Army Corps of Engineers,
Attn: Dan Swenson CESPL-RGN-L
915 Wilshire Blvd.
Los Angeles, CA 90017
Email and USPS E-mail: Daniel.email@example.com
RE: DRRA Position Statement on the Ballona Wetlands Restoration Project
It is the position of the Del Rey Residents Association that:
No restoration project be approved at this time
These issues are detailed in Comment Letter 09, dated Feb. 5, 2018, and restated and summarized below in this letter.
The Del Rey Residents Association represents residents living adjacent to Ballona Creek and the Ballona Wetands Ecological Reserve. Ballona Creek bisects the Del Rey community (about 33,000 residents), and Area C of the Ballona Wetlands is entirely in Del Rey. The members of our Association are extremely concerned about the proposed impact of the Ballona Wetlands Restoration Project as described in the Final Environmental Impact Report (EIR).
We previously submitted Comment Letter O9, dated February 5, 2018, in response to California Fish and Wildlife’s Draft EIR detailing our concerns with the proposed Project and asking for information regarding potential significant impact to our community and the mitigation measures that would be implemented to address them (see attached O9 letter and response).
We have now had the opportunity to review the Agency’s responses to our submission in the Final Environmental Impact Report (EIR) and find the responses completely inadequate. Some were unhelpful (e.g., response 09-4), some were basically just acknowledged (e.g., response 09-22), and some were “will be considered.”
For a project of this size and scope, the potential impact could have irrevocable and incalculable consequences for us.
We must have answers to our questions and concerns in order to assess whether the Project proponents will be able to mitigate the Project’s potentially significant impact to our community.
ALL of our comments must be completely addressed prior to ANY approvals or formal decisions. There should be no monies spent, contracted for, or otherwise committed, until our concerns are fully responded to and resolved. Based on the information provided in the Final EIR, the DRRA supports only the “do nothing” alternative.
We recognize some resolutions may be outside the scope of the Department of Fish and Wildlife. By way of copies of this communication, we are asking our elected officials to make sure our concerns are addressed and resolved prior to the determination of a selected alternative.
A. Our concerns in our February 2018 Comment Letter were not fully addressed and continue to exist. We request that all of our previous comments be revisited, considered seriously and adequately answered.
B. Subsequent to February 2018 our concerns have only expanded and now include additional critical questions that must be answered:
1. Risk of Flooding
One of the primary goals of the Project is “to reduce flood risk to the surrounding communities and infrastructure for up to the 100-year flood event” (see DEIR 1.1). We, as local residents, face serious potential harm from inadequate flood control along Ballona Creek and in the Ballona Reserve.
Over the course of the EIR/EIS process, multiple flood conveyance rates have been used as a baseline for this Project, including 46,000 cfs (from the original design in the 1940s) and 68,000 cfs (in 1979). For perspective, the lower rate is less than half of the 99,000 cfs in the LA River during the flood of 1938.
The flood control standard must not be reduced from the current 68,000 cfs. Moreover, the risk should be re-evaluated based on current and potential future Ballona Wetlands Restoration Project Final Environmental Impact Report State Clearinghouse No. 2012071090 Del Rey Residents Association Page 3 of 4 conditions to determine if an increased (and safer) conveyance rate is required. Any reduced flood conveyance rate, the proposed earthen levees, global warming and related sea-level rise, and lack of identified on-going additional maintenance, are extremely concerning to all of us. These concerns must be addressed prior to finalizing the Project design and issuing contracts.
2. Closing the Gas Fields
The gas storage area has been identified as a public safety concern. An increasing closed. Yet, per response O8-16: ‘‘...none of the restoration alternatives has been revised to include it.” Closing the gas fields must be a prerequisite to commencement of any project and to issuing contracts. Further, the Gas Company must be held responsible for the entire cost of closing the gas storage field; closing costs must not be part of the Project costs as this would be a burden to the public.
Local environmental advocacy groups are raising alarms about the quality of the water currently going into the aquifer. This Project must include a means to remedy this problem and ensure that water quality standards are met or exceeded.
4. Restoration Alternatives
The Final Environmental Impact Report does not include a fresh water alternative that is consistent with restoration to our collective historical wetland’s status (see Comment O9-07). This must be included as an option.
This letter was approved by our Land Use Committee on July 28, 2020, and by our Board of Directors at their monthly meeting on August 3, 2020.
DEL REY RESIDENTS ASSOCIATION
By Maureen Madison,
President Del Rey Residents Association
CC. Autumn Burke Ben Allen Diane Feinstein Doug Barish Eric Garcetti Ballona Wetlands Restoration Project Final Environmental Impact Report State Clearinghouse No. 2012071090 Del Rey Residents Association Page 4 of 4 Frank Wu Gavin Newsom Janice Hahn Kamala Harris Karen Bass Mark Ridley-Thomas Matt Wersinger Mike Bonin Sydney Kamlager-Dove Ted Lieu Del Rey Residents Association board of directors Del Rey Residents Association land use committee Council District 11, Planning Deputy Len Nguyen Council District 11, Del Rey Deputy Nick Sundback Attachment (PDF file): Comment Letter 09 of February 5, 2018 with CDFW’s Responses