Dear Wetlands Advocates,

In an ideal world, the Coastal Conservancy board members would have had the time to read through past funding approvals and other records prior to last Thursday's meeting and realize that the state's proposed restoration project has been spinning in circles since 2004. We knew that was unlikely. However your many emails to the Conservancy facilitated important and much needed discussion. Multiple board members acknowledged stakeholder concerns about accountability, public engagement and, most notably, the lack of ecologically and culturally-sensitive access to all but a small corner of the ecological reserve. The Coastal Conservancy spent over $500,000 over ten years ago to facilitate access to Area A of the reserve (west of Lincoln, north of Ballona Creek), but then locked the public out when they determined that the promise of future access would help garner support for their larger project proposal.

You can watch board member Joseph Alioto's request for increased access to the Director of CA Fish and Wildlife here. The Director subsequently expressed openness to allowing access concurrent with the ongoing planning process [link] . Positive change is within reach! However, it will take more work to finally get the gates unlocked for well-managed nature education and stewardship activities.

With regard to the allocation of the last of $25 million in Proposition 12 funds, we are reviewing our administrative and legal options to prevent the squandering of that remaining funding. This money is needed for near term care of the reserve and to analyze other restoration options. Every bit of work that this new round of money will fund has already been funded several times before. For instance, $500,000 has been set aside to engage the community in designing an equitable access plan for the future. But that work was supposed to be completed with the $750K allocated in December 2004 [link - "If approved, the planning studies would include analysis of opportunities to enhance the California Coastal Trail and create new public access opportunities at this site." - page 4] Likewise, money was previously allocated to address sea level rise, flood control, permitting and other issues. That money was mismanaged, plain and simple, and there is no reason to believe this round will be any different.

Unfortunately, quite a bit of misinformation was conveyed to the Board during the meeting, and members of the public had only one minute each to try to address numerous complex issues. A quick summary of the most important issues is below:

The Project Doesn't Protect Against Sea Level Rise

Proponents of the project are no longer disputing that the current project design would result in the loss of virtually all coastal marsh from the reserve, which would convert to mudflat and sub-tidal habitat as sea levels rise. Even by 2030, sea levels are expected to rise enough to convert the high and mid marsh that provides habitat to Belding's Savannah Sparrow into low marsh, which is not as conducive for the sparrow. The extirpation of multiple marsh-dependent species from the ecological reserve is clearly not an acceptable outcome for a $182 million restoration project. To distract from this dire outcome, proponents have taken to making a false comparison between the impacts of the proposed project and "doing nothing" which, they argue without any compelling evidence, would be even worse. Unfortunately, the board members seemed to accept this false choice rather than recognizing the need for an option that doesn't surrender critical habitat and species to rising seas.

Even on this issue, however, we have made tremendous progress. Project proponents are now finally acknowledging the need to analyze the use of sediment to slowly raise marsh elevations to keep pace with sea level rise. We asked for this analysis in our 2018 comments to the draft environmental impact report and were told, falsely, that such analysis had been conducted. Thin-layer sediment augmentation is a promising, but complex and relatively new approach to mitigating against sea level rise. By law, analysis of this option needed to be in the draft environmental analysis where it could be reviewed by the public and responsible agencies. Because of this remarkable omission, the environmental analysis will almost certainly need to be revised and recirculated for review and comment. This is another reason why spending every last penny of the remaining Prop 12 funds now is reckless.

Sediment augmentation will not only need to be analyzed as a potential mitigation measure, but also as an alternative to removing the levees. There is no question that the project could be made far less risky, far less expensive, far less disruptive to existing habitat, and would generate far less greenhouse gas emissions if construction activity can be reduced to a more reasonable level. By not analyzing any such smaller-scale alternative, the project team violated a basic tenet of the California Environmental Quality Act, which calls for a reasonable range of feasible alternatives. All three action alternatives that were analyzed require massive movement of soil, and the "no project" alternative was designed to be as punitive as possible. These is a need for an action alternative to be analyzed that better balances the level of construction activity with the need to protect existing habitat.

Flood Control

During the meeting, a Conservancy staff person claimed that the Corp of Engineers only "uncovered" a document showing a new flood control standard of 68,000 cubic feet per second "years into the project." In reality, agency staff and project consultants failed to adequately research the issue. A few simple Google searches would have turned up information that would have alerted the Conservancy and their consultants not to spend millions of dollars on technical engineering designs based on a lower and older standard of 46,000 cfs. For instance, the City of Los Angeles Planning Department signed off on another project based on a much higher channel capacity and a Corp standard of 69,800 cfs.

Conservancy staff also asserted that 46,000 cfs represents the existing flood capacity of the channel, suggesting that their design, if implemented, would not lower existing capacity. That assertion seems suspect given that multiple records (example) reference a channel capacity enlargement in the late 1950s and early 60s. We are looking into this apparent discrepancy.

Public Access

As noted above, there was encouraging discussion on this issue during the meeting. However, a false narrative was perpetuated that a handful of local stakeholders are interested in access only for their own use. The agency staff and others who have made these claims now they are false. Our organization, for instance, has invested thousands of dollars in bringing hundreds of elementary school students from underserved communities to the wetlands on field trips. That is who the increased access is for, and those opposing that access are doing so for self-serving political purposes.

These are just a few of the issues in a long list. We will keep using factual documentation to chip away at the wall of misinformation being used to block responsible management of this ecological reserve. Thank you as always for your support.