Sea Level Rise and the Ballona Wetlands
The proposed Ballona Wetlands Restoration Project fails to protect critical marsh habitat and marsh-dependent species from the impacts of sea level rise. High and mid-marsh habitat would immediately begin to convert to low marsh habitat, which cannot support the endangered Belding’s Savannah Sparrow. Over time, the low marsh would convert to mudflat and sub-tidal habitat, which are important in their own rights, but which cannot support other marsh-dependent species like Wandering Skipper butterflies or the South Coast Marsh Vole.
The project must be reworked to correct this unacceptable shortcoming, and the project team has belatedly begun to acknowledge this reality, albeit indirectly. To distract from the shortcomings of the current project design, project proponents have taken to drawing a comparison between what would happen if the project is implemented as designed as opposed to what would happen if we “do nothing”, which they assert, without evidence, would be even worse. This is a false choice, and also not grounded in fact.
We do not have to choose between a $182 million plan that would extirpate endangered and sensitive species from the ecological reserve and “doing nothing”. There are other alternatives that the project team simply refused to analyze, but which they now acknowledge have merit. This includes the practice of using sediment to slowly raise elevations of the existing marsh habitat over time to keep pace with sea level rise. We requested that this practice be analyze in our comments to the draft EIR. In response, the project team claimed, falsely, that this analysis was already in the EIR. It isn’t. But it is being acknowledged now as a way to avoid the loss of virtually all coastal marsh from the reserve by 2100, as illustrated in the habitat project maps in the EIR. Other techniques could include the use of pumps, or allowing enough salt water into the marsh to maintain salinity with fresh water inputs.
Additionally, the environmental analysis simply doesn’t support the contention that “doing nothing” would be worse than implementing the project, even though both scenarios have unacceptable outcomes. The EIR states that: “Management of tide gates in West Area B to provide some acclimation to sea level rise would be possible temporarily; however, between 2070 and 2100, the tide gates would be permanently closed to prevent flooding from sea-level rise, and the existing tidal wetland habitats in West, South, and Southeast Area B would be cut off from the estuary.” (pg 37) In other words, sometime in the next 49 to 79 years, sea levels could be too high to keep the tide gates open. Although some project proponents have argued that this would cause the existing marsh to become “stagnant ponds” there is no evidence in the EIR to support this contention. The issue would be how to maintain sufficient water and salinity levels to continue supporting the existing marsh habitat and resident marsh species. As noted, there are several potential solutions to this problem, which is roughly five to eight decades away.
In contrast, however, the EIR shows that implementing the project would immediately begin converting existing mid-marsh habitat that currently supports breeding Belding’s Savannah Sparrow to primarily low marsh by 2030. Low marsh habitat will not support the current population of Belding’s Sparrow. By 2050, that same area would be converted mostly to mudflat and by 2070, there will be a drastic decline in coastal marsh across the reserve. Thus, the impacts of implementing the project as designed would be far more immediate than the impacts of leaving the levees in place, even without the alternative approaches discussed above.
Sediment Augmentation
While the project team is now openly acknowledging the merits of analyzing the use of sediment to raise marsh elevations, the California Environmental Quality Act requires that this analysis be in the EIR so that the public and responsible agencies can review it and comment on it. That is a problem because the state decided to certify an EIR that clearly doesn’t include this analysis. This isn’t just important on a procedural level. It is important because thin-layer sediment augmentation is a complex and relatively new method for protecting wetlands against sea level rise. Before such a method can be implemented, the project team will need to rethink its entire “cut and fill” calculations (i.e. the plan for excavating, repositioning, and/or hauling away of soil).
Regardless of what any member of the public might want a restored wetlands to look like, we need to be realistic about how we get there. The only path forward for any restoration plan at this point is to decertify the existing, deficient EIR, fix the deficiencies, and recirculate it for review and comment. This is going to happen. The only question is how much additional time and money the project team will squander before they decide to do this voluntarily, or are ordered to do so by the Courts.