Patricia McPherson's Water Board Letter re: PROTECTING BALLONA AQUIFERS and Attachments 4.17.18


Hello Mr. Kang, and Waterboards, Agencies, County Supervisors, Legislative Persons, City of Los Angeles, Coastal Commission Commissioners and Staff,  

Grassroots Coalition requests adherence to Senator Pavley’s SB 1168, which requires the reasonable and beneficial use of water, for its application in use for
BALLONA WETLANDS ECOLOGICAL RESERVE. Grassroots Coalition is also requesting adherence and enforcement of all local, state and federal protective
laws including but not limited to the Porter-Cologne Act and the Clean Water Act and recent underground gas reservoir/oilfiled gas leakage including SB4, Water Code 10783.
Section 3, Part 2.74 “Sustainable Groundwater Management Act” discusses the legislation intent as providing protection to the ‘greatest extent possible’. 
Information on the amount of groundwater extraction, natural and artificial recharge, and groundwater evaluations are critical for effective management of groundwater.
10728  Groundwater Planning
(a) Groundwater elevation data   (An overall review and evaluation of Ballona’s groundwater elevation data is needed which includes the Playa Vista site and its impacts upon the
groundwater elevation.)
10727.4.  In addition to the requirements of Section 10727-2, a groundwater sustainability plan shall include, where appropriate and in collaboration with the appropriate local agencies, all of the following:
(A few  among many Pertinent Parts are listed below)
(a) Control of saline water intrusion.
b) Wellhead protection areas and recharge areas.   
(Per Water Code 13751 and 13752 Well Completion Reports-Playa Vista has no known well completion reports for all of the long-term dewatering wells at occupied development sites that are being used to lower the aquifer levels to keep the gas mitigation intake systems free of water.  GC requests agency collaboration in determination of the cumulative dewatering ongoing at Playa Vista and its cumulative impacts upon the aquifers from the Playa Vista pre- development  to the present.)
(c) Migration of contaminated groundwater.
(Inclusive but not limited to Playa del Rey, SoCalGas oilfield/reservoir gas migration)
(e) Replenishment of groundwater extractions.
(i) Impacts on groundwater dependent ecosystems
 Ballona Wetlands is a unique, coastal, predominantly freshwater wetland, that after a decades long battle between the developers and the public to save it as habitat, was acquired by the public, via the Wildlife Conservation Board (WCB) in 2003-4.  The WCB, in tandem with the California Fish & Game Commission assigned the strongest protective standard available by designating Ballona Wetlands as an Ecological Reserve.  Ballona Wetlands Ecological Reserve is a water dependent ecosystem and as such is allocated the greatest  resource  protection to its historical habitat and its sustaining freshwaters under current laws.
Currently, the DEIR for Ballona’s restoration contains no discussion of the freshwater aquifers of Ballona and there are no hydrology studies contained in the DEIR that provide evaluation of the aquifers and impacts upon them from and by-- either Playa Vista groundwater/surface dewatering and diversion and/or any potential of any further saltwater intrusion contamination.  The breeches to the Ballona Channel in the past by the Army Corps had no 408 Permits for the breeching and no studies were done to evaluate the harm to the freshwater aquifers.  (FOIA requested info by GC)