Inconsistencies and Missed Opportunities in the Current CDFW Plan for the Ballona Wetlands Ecological Reserve
By Margot Griswold, Ph.D, | Photos by Jonathan Coffin
October 30, 2021
Western Tanager, Vol. 88 No. 2, Nov.-Dec. 2021
I want to acknowledge that the land which encompasses the Ballona Wetlands Ecological Reserve (BWER) is part of the unceded territory of the Tongva/Gabrielino people. The Tongva call this land Pwinukipar (‘it is filled with water’).
And indeed, the historic wetlands of over 2,000 acres were filled seasonally with freshwater from the Ballona Creek watershed, especially in years of heavy rainfall (Dark et al. 2010). Historically, the Ballona Wetlands were only open to tidal influence from the Pacific Ocean in years of heavy rainfall when the double dune system at the beach was breached from the flood waters. And importantly, there is no record of cord grass (Spartina foliosa) within the Ballona Wetlands which is a plant species that is usually found in tidal wetlands. Areas of brackish water near the Pacific Ocean at the westerly end of the historic wetlands supported salt marsh vegetation. Based on the shape of the land and movement of sand, the opening to the Pacific Ocean was closed relatively quickly (Jacobs et al. 2011). Such sand movement can be seen at estuaries in Orange and San Diego Counties where openings have been engineered to create full tidal wetlands. These estuaries must be constantly dredged to keep the estuaries open to the ocean.
All of this history matters, because the current plans for the Ballona Wetlands under the management of the California Department of Fish and Wildlife run counter to this historical ecology. Ballona Wetlands is of central importance to Los Angeles Audubon as a birding location and the site of our long-standing and highly successful elementary school education program. We have trained hundreds of docents and educated thousands of schoolchildren about this land and its natural functioning. In this column, I review the plans for this important place, how they conflict with its ecology and are infeasible in the face of sea level rise, and a possible path forward.
Most of the remaining Ballona Wetlands were designated as a State Ecological Reserve in 2005. The Reserve is the largest remaining coastal wetland in Los Angeles. It is sandwiched generally between Marina del Rey to the north, Playa Vista to the east, bluffs to the south, and a double dune system to the west, separating it from the Pacific Ocean. The BWER is bisected by the Ballona Flood Control Channel, which carries rainwater and dry season urban flow from the upper Ballona Creek Watershed through the urban core to the ocean. BWER is owned by the California Department of Fish and Wildlife (CDFW), which is the land manager.
The language of the official State designation of the BWER is helpful to understand some of the issues surrounding the ongoing effort to rehabilitate the wetlands. The language in the California Code of Regulations for the designation of the Ballona Wetlands as an Ecological Reserve is revealing:
“Ballona Wetlands consisting of 553 acres in Los Angeles County is proposed for designation as an ecological reserve for the protection and enhancement of coastal salt marsh and freshwater marsh habitats, and associated species, including the state listed endangered Belding’s savannah sparrow. The area is also an important wildlife movement corridor to other public lands in the vicinity of the wetlands.
The reasons for listing this property in Title 14 are to regulate public use and provide the best available protection for the species and habitats the property was acquired to protect.” Section 630, Title 14, California Code of Regulations, relating to Ballona Wetlands Ecological Reserve, 2005.
State law requires that an Ecological Reserve have Land Management Plan prepared by CDFW (Fish and Game Code Section 1019). As of this writing, no Land Management Plan for BWER has been prepared.
So BWER has gone 16 years without a Land Management Plan, and it shows. Most importantly, a Land Management Plan would set goals, which in this case, would be those already articulated in its designation, “the protection of salt marsh and freshwater marsh habitats and the associated species ….” The plan would describe the natural resources of a site and usually would develop detailed maps and analyses of soils, common and rare vegetation communities, year-round and migratory wildlife, and in the case of a wetland, detailed hydrologic information, including surface water and groundwater resources. The results of these studies would be combined with historic and current conditions to determine how the resources within the site can be managed within a local and regional context. Generally, the trajectory of a site can be determined in the context of stressors, including, in the case of BWER, urban development and groundwater pumping, public access, climate change and sea level rise. From the detailed information gathered, an LMP outlines the management methods and timing to achieve the goals outlined. An outcome of a LMP may be a recommendation to development a habitat restoration plan.
Short Eared Owl over Ballona | Photo by Jonathan Coffin
At Ballona, CDFW has approached the management process backwards. Instead of preparing a Land Management Plan, they skipped ahead to a ‘restoration plan’, planning for which was relatively closed to the public, in that there was no meaningful consideration of the public’s comments on the process or the plan. The ‘restoration’ plan that was developed for BWER, as presented in the Final Environmental Impact Report (EIR) ignores the language in the designation of the Ecological Reserve and the resources that it commits to protect.
White-tailed Kite at Ballona | Photo by Jonathan Coffin
The proposed ‘restoration’ plan is not by any definition a ‘restoration’, but rather it is a ‘creation’ plan that requires removing 3.2 million cubic yards of soil. This soil removal would open the wetlands to daily ocean tides of Santa Monica Bay, thereby laying the wetlands open to sea level rise and the loss of the habitat and the very species that the Ecological Reserve designation is meant to protect. But you do not have to take my word for it.
Belding’s Savannah Sparrow on Pickleweed Habitat at Ballona Wetlands
The impacts from sea level rise are shown in the Final EIR (ESA 2020, Figures 2-36 through 2-40) and plainly show the loss of habitats that are exceedingly rare in Southern California coastal wetlands (as I described in Western Tanager, 2020 Volume 87 No. 2 Nov-Dec):
•Salt panne/salt flat habitat, beloved by migrating birds, will be lost in the first 10 years of the proposed project, 2030.
•Mid-marsh habitat and high marsh (mainly Salicornia virginica as well as Juamea carnosa and Distichlis spicata) will start to disappear in 2030 and by 2100 will be such a narrow band, that experts indicate it will not be viable breeding habitat for the State-listed Endangered Belding’s Savannah Sparrow.
•Loss of low, mid and high marsh will start in 2030 and by 2100 result in the loss of most, if not all, existing species using this habitat either as breeding or foraging, including the White-tailed Kite, a State Fully-Protected Species, among other wildlife species, namely small mammals that feed the many other raptors, as well as snakes and coyotes.
Female Northern Harrier at Ballona Pickleweed Marsh Habitat
These impacts show that the current plan for BWER completely ignores the designation of the Ballona Wetlands as an Ecological Reserve, and its purpose to protect and enhance “coastal salt marsh and freshwater marsh habitats, and associated species, including the state listed endangered Belding’s savannah sparrow” (14 CCR 630).
Impacts to these species and habitats from sea level rise would be far less without the project (see Appendix B7, Figures 6–10, of the FEIR, ESA 2020). With proper management of BWER, there would likely be negligible impacts from sea level rise with the ‘No Project” alternative as compared to the proposed project.
If the proposed project is not based on the purpose of the 2005 designation of the wetlands as an Ecological Reserve, nor on a specific Land Management Plan, what is the basis for the proposed ‘restoration’ project? To be implemented, the Ballona Wetlands would have to be officially re-designated from a non-marine ecological reserve (14 CCR 630) to a marine ecological reserve (14 CCR 632). The analysis of sea level rise alone shows that there will be nothing but open water, mud flats and engineered flood control levees by 2100 under that scenario.
Opposition to the proposed plan for BWER is much more than a disagreement over saltwater versus freshwater. The fact is that a reasonable alternative to enhance and rehabilitate the existing habitats and consider the wetland’s trajectory as a mainly seasonal freshwater/brackish water wetlands for over the last 150 years, was rejected without adequate analysis because it would ‘require management’ (per CDFW Director C. Bonham, 10/14/21, Fish & Game Commission meeting). All land requires some management, and without a more detailed analysis of predominately seasonal freshwater marsh alternative presented for full public review, CDFW’s reasoning is questionable, and its environmental analysis is lacking.
Figure 1. Loss of marsh habitat from sea level rise with the current CDFW plan – Map colors: greens are low, mid, and high marsh; red is mudflat; blue is open water.
Furthermore, the current proposed plan results in outcomes that are inconsistent with Governor Newsom’s goals for the State.
The proposed plan will:
•Make the wetlands less resilient to sea-level rise, losing existing rare coastal habitats almost from the outset. It is the only project on the Pacific coast that proposes to lower a coastal wetland and open it to full tidal influence and existing sea level, to protect the wetland from future sea level rise.
•There will be a loss of existing species diversity both in terms of the soil ecosystem and the above the ground ecosystem, from the start of the project, including the loss of increasingly rare regional coastal wetland habitats.
•The removal of 3.2 million cubic yards of soil will result in the loss of carbon currently sequestered in the soil (which was not considered in the Final EIR) as well as loss through the massive operations to move that much soil which is acknowledged as an impact in the Final EIR. It is unlikely that the project, as described, can replace the carbon loss through sequestration.
How could such an approach have been developed by a resource protection agency?
It seems that the main motivation for the massive removal of soil, below the historic marsh surface is based on an idea that fill was placed on Area A of the wetlands in the 1960s. The claims that Area A of the BWER received fill from the material dredged from the creation of Marina Del Rey in the early 1960s, however, are not born out by historical records, which describe the use of the dredge material from the marina to significantly enhance beaches north and south of Marina Del Rey, as well as to build up areas of Marina Del Rey itself, because it was built on a wetland and needed soil! This information is found in U.S. House of Representatives Document 389 from 1954, 83rd Congress. Other compelling records include reports from a wetland assessment for the US EPA (Huffman 1986) and the Phase I Playa Vista Archeology Report (1994) that indicate no surface disturbance of soil on Area A except along the Ballona Flood Control Channel where soil was disposed from building the levees. Nor do historical photos support the claims. The claims of fill in Area A are much repeated, but I have never seen documentation for the fill.
The elevation of Area A is 14-feet above sea level, which leads some people to think it was filled. However, as documented by Dr. David Jacobs of UCLA, coastal wetlands behind dune systems, such as at Ballona, are often the result of freshwater perched at elevations above sea level (URSUS 2021).
The facts remain that the areas of the Ballona Wetlands were designated as a State Ecological Reserve with specific language as to the protection of coastal salt marsh and freshwater marsh habitats and the species associated with these habitats. No Land Management Plan has been prepared for BWER since it was designated in 2005, even though some 15 million dollars have been spent through the California Coastal Conservancy to prepare a ‘restoration’ plan that is neither a ‘restoration’ nor a plan that protects the resources designated in California code to be protected at Ballona Wetlands Ecological Reserve.
Current science must be considered to base management decisions for BWER, and consensus must be reached to find the most ecologically efficient plan to increase the functional integrity of the existing wetlands and maintain the public trust.
Let’s discuss openly the science and the opportunities for management to truly restore, enhance and rehabilitate BWER. We suggest an open forum, led by an unbiased, trained facilitator. There is science to be discussed and consensus to be reached. Otherwise, the beat will continue with loss of public access and habitat through lack of management of BWER.
True public input and consensus has been missing from the process. It can be done with some planning and open discussion. We look forward to participating in the process of developing the missing Land Management Plan for BWER, as a starting point.
Literature Cited
California Department of Fish and Wildlife, 2005. Section 630, Title 14, California Code Regulations. Concerning designation of Ballona Wetlands as an Ecological Reserve.
Dark, S., E. D. Stein, D. Bram, J. Osuna, J. Monteferante, T. Longcore, R. Grossinger, and E. Beller. 2011. Historical Ecology of the Ballona Creek Watershed. Southern California Coastal Water Research Project, Technical Publication No. 671, Costa Mesa, California.
ESA, 2020. Final Environmental Impact Report (FEIR). Ballona Wetlands Restoration Project. Prepared for the California Department of Fish and Wildlife.
Huffman, T. 1986. USEPA, Region IX, Determination of the Presence of Aquatic and Wetland Habitats Subject to Federal Regulatory Jurisdiction Within the Ballona Creek Land Tract. Prepared for the US Environmental Protection Agency.
Jacobs, D., E. D. Stein, and T. Longcore. 2010. Classification of California Estuaries Based on Natural Closure Patterns: Templates for Restoration and Management. Southern California Coastal Water Research Project, Technical Publication No. 619a, Costa Mesa, California.
Jacobs, David E. 2021. URSUS Environmental Symposium: The Ballona Wetlands and the Future of Southern California Coastal Conservation. April 13, 2021.
Playa Vista Phase 1, City of Los Angeles, 1994. Figure 50 Maps showing 1990 Cultural Resources Survey, in relation to surface disturbance conditions, Volume 23, Phase 1 Project Environmental Impact Report.
San Francisco Estuary Institute. 2014. Northern San Diego County Lagoons Historical Ecology Investigation Regional Patterns, Local Diversity, And Landscape Trajectories.
U.S. Congress, 1954. House Document 389. 83rd Congress. Complete 47 pages MDR House Document No. 389 SMB - Public Law 389 5:11:1954.
Zedler, J. B. 1996. Coastal mitigation in southern California: the need for a regional restoration strategy. Ecological Applications 6:84-93.
Margot Griswold, Ph.D., is a restoration ecologist with over 27 years of experience in habitat restoration. Soils, landscape position, and hydrology, coupled with existing and historic vegetation guide her work in restoration. She participated in consensus planning for plant and wildlife habitat within the Habitat Work Group of the Owens Lake Dust Control Project, Inyo County, California. She is past president of the Society for Ecological Restoration California and the Los Angeles Audubon Society.
Jonathan Coffin is a naturalist and photographer of exceptional talent. He has dedicated decades to photographing the biodiversity of the Ballona Wetlands and verifying his discoveries with other scientists. He can be found day or night documenting the wildlife (plants and animals) from the edges of the Ballona Wetlands Ecological Reserve.