Report below is part of the public record, contained in the FINAL EIR which is posted on the website of the California Department of Fish & Wildlife. Here is the link:

Land Protection Partners Report dated February 2,2018 entitled “Review of Biological Impacts Assessment in Draft Ballona Wetlands Restoration Project Environmental Impact Statement/Environmental Impact Report, State Clearinghouse No. 2012071090


Land Protection Partners P.O. Box 24020, Los Angeles, CA 90024-0020 Telephone: (310) 247-9719

Review of Biological Impacts Assessment in Draft Ballona Wetlands Restoration Project  Environmental Impact Statement Environmental Impact Report, State Clearinghouse No. 2012071090

Travis Longcore, Ph.D. Catherine Rich, J.D., M.A.

February 2, 2018

Table of Contents

1 Introduction ……………………………………………………………………………………………………… 1

2 Overall Comments ……………………………………………………………………………………………….. 1

2.1 Project Is Not a Restoration …………………………………………………………………………..1

2.1.1 Importance for Assessing Functions and Values …………………………………………..4

2.1.2 Importance for Regulatory Permitting …….. …………………………………………………. 5

2.2 Project Purpose to Provide Recreation Is Too Broadly Construed ………………………….. 5

2.3 Project Purpose to Protect Public Infrastructure Is Inappropriate for Land Use ………… 6

2.4 Range of Alternatives Is InappropnatelyNarrowed in Project Development Process … 7

2.4.1 Project Objectives Are Unreason~bly Narrowly Defined ……………………………….. 8

2.4.2 Dismissed Alternatives Appear Intentionally Misrepresented …………………………. 8

2.5 Restoration’Lacks Target Species ………………………………………………………………… 9

2.6 No Basis to Create One Wetland Type at Expense of Another …………………………….. 10

2.7 Deferral of Habitat Restoration Plan ……………………………………………………………….. 10

3 Baseline Conditions …………………………………………………………………………………………… 12

3.1 Sensitive Vegetation …………………………………………………………………………………. …. 12

3.2 Sensitive Wildlife Species …………………………………………………………………………….. 13

3.2.1 Invertebrates ………………………………………………………………………………………… 14

3.2.2 Reptiles …………………………………………………………………………………………. ….. 23

3.2.3 Birds ……. ……………………….. .. ……………………………………………………. …………… 25

3.2.4 Small Mammals ……………………………………………………………………………………. 28

4 Impact Analysis ………………… …………………… …………………………………………………………. 28

4.1 Impacts from Trail System ……………………………………………………………………………. 28

4.2 Absence of Post-Restoration Vegetation Maps …………………………………………………. 29

4.3 Impacts to Endangered Species …………………………. ………………………………………….. 30

4.3.1 EI Segundo Blue Butterfly ……………………………………………………………………… 30

4.3.2 California Least Tern …………………………………………………………………………….. 31

4.3.3 California Gnatcatcher …………………………………………………………….. ……………. 32

4.3.4 Least Bell’s Vireo …………………………………………………………………………………. 33

4.4 Impacts to Special-Status Plants ………………….. ………………………………………………… 34

4.4.1 Lewis’ Evening.:.primrose ……………………………………………………………………….. 34

4.4.2 Woolly Seabite ………………………………… ………………………………………………….. 34

4.5 Impacts to Special’:Status Invertebrates …………………………………………………………… 35

4.6 Impacts to Special-Status Reptiles ………………………………………………………………….. 35

4.6.1 Silvery Legless ‘Lizard …………………………………………………………………………….. 35

4.6.2 San B~rnardino Ring-necked Snake …………………………………………………………. 36

4.7 Impacts to Special-Status Birds …………………………………………………………………….. 37

4.7.1 Belding’s Savannah Sparrow ………………………………………………………………….. 37

4.7.2 California Gnatcatcher ……………………………………………. … , ……………….. …….. …. 38

4.7.3 California Horned Lark ………………………………………………………………………….. 38

4.7.4 Burrowing Owl. …………………………………………………………….. …………………….. 38

4.7.5 Nesting Raptors …………………………………………………… .. …………………………….. 39

4.7.6 Additional Special-Status Upland Bird Species …………………………………………. .40

4.7.7 Special-Status Shorebirds ………………………………………………………………………. 42

4.7.8 Special-Status Marsh Birds …………………………… ……………………………………….. 43

4.8 Special-Status Mammals …………………………………………… …………………………………. 43

4.9 Night Lighting ………………………………………… ………………… ……………………………… .. 44

4.10 Noise ………………………………………………….. ………… ………………………………………. …. 45

5 About the Authors ………. ……………….. ………. …………………………………………………………… 46

6 Literature Cited …….. …. ……………….. ……………………………….. …… ………. ……….. ……………. 46


1 Introduction

The remnants of the Ballona Wetlands are mostly owned by the California Department of Fish and Wildlife (CDFW) as the Ballona Wetlands Ecological Reserve, with a portion owned by the State Lands Commission. Planning for restoration of the natural resources on this public property has been led by a private nonprofit, The Bay Foundation, operating as an agent of the Santa Monica Bay Restoration Commission. The results of that planning process have now been analyzed in the Draft Ballona Wetlands Restoration Project Environmental Impact Statement/Environmental Impact Report (Draft EISIEIR), issued in September 2017. The combined document serves as compliance under the National Environmental Policy Act (NEPA), with the U.S. Army Corps of Engineers (USACE) as Lead Agency, and the California Environmental Quality Act (CEQA), with the California Department ofFish and Wildlife as Lead Agency.

We have reviewed the Draft EISIEIR and its appendices and provide the comments here on behalf of The Urban Wildlands Group and Los Angeles Audubon Society. We have based our comments on the documents presented by the project proponents, published scientific literature, other scientific information available to us, and our expert opinion as supported by the best available scientific evidence.

In this review, we consider the analysis for Alternative 1, even though the Draft EISIEIR does not clearly identify it as the preferred project. It is evident that Alternatives 2 and 3 would have fewer impacts because their footprints are smaller, but the analytical flaws that we identify for Alternative 1 apply for the most part to the analyses of Alternatives 2 and 3 as well. We also limit our analysis to biological resources with a particular focus on birds, notwithstanding important issues arising from discussion of hydrology, groundwater, and flooding risk.

This review is organized with a series of thematic critiques at the outset, starting with the fundamental problem that the designed wetland system does not represent a “restoration” that creates conditions similar to those present historically. We then provide additional information pertaining to and analyzing baseline conditions for biological resources, drawing attention to incorrect assumptions about the presence andlor distribution of sensitive species and vegetation types. The remainder of the report addresses the analysis of impacts on biological resources and documents that the Draft EIS/EIR lacks crucial information to support the absurd conclusion that the proposed project would be a long-term benefit to all sensitive biological resources on the site.  To the contrary, although some species will benefit, others will be harmed significantly.

2 Overall Comments

2.1 Project Is Not a Restoration (emphasis added.)

The fundamental premise behind many of the assumptions in the project description and analysis of impacts is that the earthworks and planting proposed for the Ballona Wetlands Ecological Reserve represent a restoration of conditions that were present historically. The project is defined as “Restoration of the Ballona Reserve” (p. 1-7) and the project’s basic purpose under NEPA is “ecological restoration” (p. 1-2). The Draft EISIEIR further describes project activities as “restoring, enhancing, and establishing native coastal wetland and upland habitats within the Ballona Reserve” (p. 1-8). Although this sentence includes “enhancing” and “establishing” as activities, they are presented in conjunction with “native” habitats, implying that those are the habitats that belong (e.g., were present in the past).

The idea that the project is intended to be a restoration is stated in plain language, and the word restoration is defined in the Draft EISIEIR: “Restoration” means the manipulation of the physical, chemical, or biological characteristics of a site with the goal of returning natural or historic functions to a former or degraded resource; restoration may be divided into two categories: re-establishment and rehabilitation (33 C.F.R. §332.2).

Here, and elsewhere, the language of the EISIEIR leans on the idea of returning the site to a prior condition, often with an emphasis on function. For example, the text describes a goal of “realigning” Ballona Creek into the form of a meander, implying that such a form existed in the past and that the project is returning the site to those conditions (p. 1-10). Similarly, the Draft EISIEIR suggests that the project will “reconnect” Ballona Creek to its floodplain, implying that the creek formerly ran in a channel through the Ballona Wetlands (p. 1-10), and that the project will “return” daily tidal action to the site, suggesting that prior to disturbance the site was subject to daily tidal action.

All of the language about restoration and use of terms such as return, realign, and reconnect are important, because they are used to imply superiority by virtue of being natural and historically present. The entire restoration design is built on the idea that certain habitats must be restored and others can be obliterated because those being restored are natural and those that are to be obliterated are not. Sadly, however, the conditions to which the project proponents seek to restore are not natural.

Unfortunately, for various fiscal and regulatory reasons, coastal wetland restoration in southern California has been defmed as establishment of full-tidal wetlands that are jettied open to the ocean and remain open year-round. Research over the past seven years has shown that this type of wetland is not the natural state for nearly all southern California coastal estuaries, which naturally are closed from tidal action in full or in part for some to most of the year (Jacobs et al. 2011).

In addition to being demonstrated for Ballona (Dark et al. 2011), seasonal closure is also the case for the lagoons of northern San Diego County (Beller et al. 2014) and Ventura County (Beller et al. 2011). The only exception is San Diego Bay.

To be clear, the project description should be corrected to eliminate the word “restoration.” (emphasis added.)

The proposed project does not represent “the return of an ecosystem to a close approximation of its condition prior to disturbance,” which is the widely accepted definition of “restoration”  (emphasis added.) (National Research Council 1992).

Wetlands similar to those designed for the site have not been present in the system for over 2,000 years (Palacios-Fest et al. 2006, Dark et al. 2011) and would be, in fact, out of equilibriuim with the hydro geomorphological forces present in the current day watershed (Jacobs et al. 2011).

The site will not be “restored” by introducing permanent tidal flows and maximizing estuarine conditions and minimizing water residence time. Rather, in its historical condition prior to being jettied open to the ocean in the late 1800s, the Ballona Wetlands were only open to the ocean periodically in response to winter rains. As summarized by Dark et al. (2011)

Approximately half of the aggregate Ballona Lagoon area consisted of a freshwater and tidally affected saltmarsh and brackish habitats that transitioned into a more alkaline/freshwater system about 1.5 miles (2.4 km) inland. Historical habitat of the Ballona Lagoon coastal complex consisted of substantial amounts of brackish to salt marsh/tidal marsh habitat (29%), followed by salt flat/tidal flat (10%). Open water made up less than 3 percent ofthe lagoon and one of the more salient features of the complex was a long but narrow strip of open water referred to by some as a “lake” at what we call today Del ReylBallona Lagoon (Sheridan 1887). This strip of open water periodically emptied into the ocean at the documented location of seasonal tidal access (figure 22).

We found no evidence that the lagoon remained perennially open, but rather the textual sources indicate that access to the ocean depended on hydraulic forces during any given year (LAT 1887, Sheridan 1887, Hansen and Jackson 1889, Solano 1893). The migration of the Los Angeles River away from the lagoon transitioned the system into a lower energy system where only on rare occasions was there enough freshwater flow from Ballona Creek to break through the buildup of sediment along the coast. As a result, gradual build up of sediment around the terminus of the previous estuary formed dunes and created this “trapped” lake-like feature. The coastal dunes, which occupied four percent of the Ballona Lagoon coastal complex, played a significant role in the formation of the lake and the limited tidal access (see Jacobs et al. 2011).

The Draft EIS/EIR does get around to acknowledging the historical fact of the frequent and prolonged closure of tidal flows to the wetlands (p. 2-231), but relies on the idea that daily tidal flows are the natural and desirable condition throughout the Draft EISIEIR despite this conflict with historical fact. As a result, it wastes the opportunity of designing a restoration that would benefit numerous extant special-status species associated with historical conditions and could aid in recovery of more such special-status species through passive recolonization and active reintroduction.

Ballona Creek as it exits through the Ballona Wetlands is an entirely artificial feature. There was no Ballona Creek extending across the project site before it was constructed as a flood control channel (Dark et a1. 2011). Ballona Creek existed as a recognizable riparian feature that drained water between the large inland freshwater wetland complex on the east side of the Baldwin Hill  to the inland terminus of the large brackish to saltwater wetland complex at the coast. The creek did not extend through the wetlands and out to the ocean; it lost its identity as a channel around the middle of Area C. Therefore, the creation of a meandering channel across the project site for Ballona Creek would not be a “restoration.” The historical system did not have a large main channel; that channel was created as flood control infrastructure. Changing the shape of an unnatural channel does not “restore” it. The whole idea of a meander is that it is caused by the natural erosion and deposition patterns in a floodplain in the lower reaches of a watershed. The proposed “meander-shaped channel” is solely an artistic device on the part of the designers; no meander was present historically and the meander cannot even meander like a natural channel.

A restoration would allow for natural processes such as erosion and deposition to take place and not require that the “natural” feature be armored in place and immovable.  Similarly, moving the tidal channels on the project site will not “restore” the wetlands. To the contrary, this element of the project would introduce permanent tidal flows to areas that did not historically have such flows. The Draft EIS/EIR should be accurate in the use of the term “restoration” and not extend it to the creation of novel wetland systems that, because they would not be supported by the existing or proposed hydrology, would require significant maintenance (i.e., dredging) and would destroy existing biodiversity.

• Beach

• Dune

• Sail Flat

• Tidal Flat

• Brackish to Salt Marsh

• Full Tidal Mmsh

• Alkali Flat

• Alkali Meadow

• Wet Meadow

• Valley Freshwater Marsh

• Perennial Freshwater Pond

• Vemal Pool

• Willow Thicket

• Open Water

Figure 1. Historical habitats of the Ballona Wetlands (Dark et al. 2011). Note that Ballona Creek did not extend across the marsh plain to the ocean.  Furthermore, the designers of the project afforded no consideration to restoring the historic vegetation type of Area C. This area was alkali meadow, which is a habitat type that is rarer than estuarine salt marsh in the Los Angeles basin and would historically have supported several rare and endangered plant species such as Salt Marsh Bird’s-Beak (Stein et al. 2007, Stein et al. 2010, Dark et al. 2011). Faced with the opportunity to salvage and restore some of this unique habitat type, the project proponents propose to bury this site under piles of marina dredge spoils removed from Area A.

It is the complete opposite of restoration to turn an alkali meadow site on a marsh plain into a series of hills covered with an unspecified mix of scrub species.  Zedler (1996) warned about the need to assess the regional distribution of historical habitat types in restoration planning and to avoid a trend of restoring more deepwater habitat (which is now over-represented in southern California as a result of previous mitigation-driven projects) at the expense of now-rare historic habitat types, which include brackish marsh and especially salt flats (Beller et al. 2014).

2.1.1 Importance for Assessing Functions and Values

The failure of project proponents to recognize the historical habitat conditions leads to inappropriate metrics for assessing the functions and values of the current conditions and planned constructed wetlands. If one makes the assumption that a wetland’s natural condition is to have daily tidal flows when its natural state is to be seasonally tidal or brackish, then it willscore inappropriately low on metrics for wetlands that have daily tidal flows.

The Draft EIS/EIR compares wetlands at the project site with fully tidal wetlands (p. 3.4-62), when they are not, and were not historically. The choice of reference type for the rapid wetland assessment protocols strongly influences the resulting score. Use of the “estuarine” protocol for areas that are not estuarine in nature can only be seen as intending to obtain a low score to justify restoration actions. But it is sort of like saying that a vernal pool is not a good lake. It is true, but a bad comparison. In this instance, an estuarine reference type makes for a bad comparison being used to justify adverse impacts on resources.

2.1.2 Importance for Regulatory Permitting

That the proposed project is not a restoration – it creates new wetland conditions but does not restore conditions prior to disturbance in terms of vegetation type, function, or values – is particularly relevant because the project proposes to fill wetlands, converting them to uplands.

Filling wetlands is allowed only for specific purposes under Coastal Act (Section 30233(a)):

(a) The diking, filling, or dredging of open coastal waters, wetlands, estuaries, and lakes shall be permitted in accordance with other applicable provisions of this division, where there is no feasible less environmentally damaging alternative, and where feasible mitigation measures have been provided to minimize adverse environmental effects, and shall be limited to the following: … (6) Restoration purposes. ‘”

That is, the proposed project would be dumping marina dredge spoils on existing jurisdictional wetlands under the guise that the project is a restoration. Doing so depends on the project meeting the Coastal Commission’s standards for what constitutes a restoration. Such a determination should take into account the existing scientific information that the proposed project does not meet the generally accepted definition of restoration. It also means that the project must demonstrate that filling of wetlands cannot be avoided through a less environmentally damaging alternative. In this design, many of the wetlands to be filled are only being filled because it is convenient to dump dredge spoils from other portions of the site on them.

A less damaging alternative would be to dispose of all of the marina dredge spoils off site so that the issue of sequentially impacting wetlands with the dumping of spoils can be ended once and for all. The current proposal is like The Cat in the Hat Comes Back; the dredge spoils are the pink mess, and the project proponents are playing the role of the alphabet cats, trying to clean up the mess but only spreading it around.

2.2 Project Purpose to Provide Recreation Is Too Broadly Construed

The project objective for public access needs to be very carefully considered. To be consistent with the overall project and land use, recreation should be passive and compatible with protection of sensitive habitats. The degree of visitor-serving infrastructure is inconsistent with the primary purpose of an ecological reserve in California. The California Code of Regulations makes clear that the primary purpose of ecological reserves is for conservation of biodiversity, with visitor-serving uses optional and only upon Fish and Game Commission determination that such use is compatible:

All ecological reserves are maintained for the primary purpose of developing a statewide program for protection of rare, threatened, or endangered native plants, wildlife, aquatic organisms, and specialized terrestrial or aquatic habitat types. Visitor uses are dependent upon the provisions of applicable laws and upon a determination by the commission that opening an area to such visitor use is compatible with the purposes of the property.

Visitor use is subject to the regulations below, in sections 550 and 550.5 of these regulations, as well as any other commission regulations that may apply (14 CCR 630).

The Fish and Game Code reinforces the biological focus of ecological reserves:

The Legislature hereby declares that the policy of the state is to protect threatened or endangered native plants, wildlife, or aquatic organisms or specialized habitat types, both terrestrial and nonmarine aquatic, or large heterogeneous natural gene pools for the future use of mankind through the establishment of ecological reserves (Fish and Game Code Section 1580).

It is therefore unnerving that the Draft EISIEIR describes a project that attempts to maximize visitor infrastructure through a system of bicycle trails, walking trails, boardwalks, entry plazas, and even public art (p. 2-90). All of this infrastructure is presented without any serious analysis of impacts on biological resources.

The trail system for the proposed project should be limited to the perimeter of each of the land units rather than constructing mUltiple trails, including trails that cut through new or existing habitats. Any trails extending into habitat areas for wildlife viewing should be spurs and not loops to minimize disturbance to wildlife. As discussed in more detail below, the public trail system envisioned constitutes a large area (on the order of 12 acres) that fragments habitat, thereby introducing disturbance that will degrade the proposed restored habitats, and takes away from the area of those habitats. The reduction in habitat area resulting from the trail system is not disclosed.

It is furthermore difficult to evaluate the impacts of disturbance from the trail system because the project description is not consistent throughout the document on the location and nature of the trails. A different trail system is mapped in Figure 2-1 (Alternative 1, Phase 2: Proposed Habitats) from that shown in Figure 2-23 (Alternative 1: Public Access Plan Detail). The impacts of the two systems would be different, both because of their physical locations and the amount of traffic by different users that would be expected from their configurations.

A large trail system is not needed to achieve the passive nature education uses that are appropriate for an ecological reserve. It should not be, and statutorily is not, the responsibility of an ecological reserve to provide extensive recreational opportunities.

2.3 Project Purpose to Protect Public Infrastructure Is Inappropriate for Land Use

The property is an ecological reserve, established to protect native biodiversity. Yet one of the project purposes is to provide flood control for a 100-year flood event (p. 1-2). The proposed design of the project uses land set aside for biodiversity conservation to construct flood protection levees and berms.

The existing Ballona Creek Flood Control Channel provides adequate flood risk management.  By breaking open the channel and creating a large meandering creek (which has no historical precedent), the project designers create a need to provide flood risk management elsewhere.

Rather than elevating the infrastructure that they need to protect (e.g., by raising Culver Boulevard), they instead propose to construct at least 36 acres of levees on the ecological reserve. This levee system is not an optimum land use within an ecological reserve because the planting options on levees are highly constrained and their morphology is utterly and obviously unnatural within a coastal marsh plain. The design also includes levees to be constructed in the middle of existing brackish marsh habitats that would not need to be impacted except for the decision to remove the flood control channel.

A better option to protect Culver Boulevard that would not take up valuable land within the ecological reserve or leave it as a valley between raised levees would be to raise this road. The Draft EISIEIR dismisses this option as too expensive. The preparers err, however, in comparing the expense with the cost per acre of wetland restoration projects only, rather than the cost of wetland restoration coupled with flood risk management as is proposed in this project. In fact, in the future, funding will be available to prepare for coastal sea level rise for key infrastructure such as Culver Boulevard and the cost would be reasonable within that context. Instead, we have project designers causing the need to construct flood risk management infrastructure by proposing to remove the existing channel and then allocating valuable land that could be used for species conservation instead to piles of dirt.

The inclusion of flood risk reduction in the purpose of the project is also done incompletely. If the project is needed to improve flood safety, then the description of the No Project alternative should include a description of the current flood risk and what actions would need to be taken in the absence of the project to address those risks. If no additional actions would be needed in the No Project alternative to reduce flood risk, then it is inappropriate for the proposed project to include flood risk management as a project element and objective. Instead, increased flood risk must be seen as a significant adverse impact of the proposed project that must be mitigated. The levee system should be considered to be a mitigation for increased flood risk caused by the wetland creation project, not an element of the project.

2.4 Range of Alternatives Is Inappropriately Narrowed in Project Development Process

The Draft EIS/EIR contains a long and reasonably transparent discussion of alternatives brought forward to analysis in the document. The alternatives screening process appears, however, to be designed to give the appearance of being rational while having the function of excluding restoration options not favored by the project proponents.

The alternatives are unreasonably limited in two main ways. First, the project objectives are written in a manner that mandates certain hydrological functions. Second, the dismissed alternatives appear to be intentionally misrepresented to make them easier to exclude.

2.4.1 Project Objectives Are Unreasonably Narrowly Defined

The project objectives are written too narrowly, in that they specify a means to achieve an objective rather than the objective itself. For example, the objectives specify certain ways by which water quality goals must be achieved such as mandating that the project should: “establish natural processes and functions … that support estuarine and associated habitats through measures such as improving tidal circulation into the wetlands to enlarge the amount of area that is tidally inundated, increasing tidal prism and excursion, lowering residence time of water, ensuring a more natural salinity gradient, and creating dynamic hydrologic interactions between the Ballona Creek channel, wetlands within the Ballona Reserve, and the Santa Monica Bay” (p. 1-3-1-4).

This project objective enshrines an incorrect notion of the historic function of wetlands at Ballona. By specifying these functional criteria, the preparers of the Draft EISIEIR guarantee that no alternative that attempts to restore and enhance wetlands representing the historic types could make it through the screening process and be considered.

The U.S. Fish and Wildlife Service (USFWS) appears to have raised this issue while they were still acting as a Cooperating Agency in the development of the Draft EISIEIR. They argued that the project purpose should not be to maximize tidal influence, but rather to provide tidal influence that is “appropriate and practical” to the site (USFWS letter to USACE, October 23, 2015). Had the project proponents taken the advice of this federal agency, a more reasonable range of alternatives employing different approaches to increase wetland values on the project site could have been brought forward for analysis; such alternatives might have significantly reduced environmental impacts compared with the proposed project.

2.4.2 Dismissed Alternatives Appear Intentionally Misrepresented

The Draft EIS/EIR gives the appearance of carefully considering a range of alternatives before dismissing them, but the details indicate a clear preference to eliminate any proposals that were not close variants of the proposed project. Some of the reasons for eliminating alternatives are silly at best. For example, one of the reasons Alternative 5 was eliminated was that it was deemed to be not reasonable because heavy equipment would be needed to remove pampas grass and the alternative was intended to represent a light touch restoration effort. First of all, pampas grass can be removed by hand. Second, it would not be unreasonable to assume that appropriate equipment might be used to remove invasive vegetation, even in a light touch restoration. The idea that vegetation could not be managed with small-scale equipment appears to be used simply as a pretext to exclude the alternative.

Other alternatives are eliminated because they assume that no changes to infrastructure could be made in the future, intentionally misrepresenting those proposals. Alternative lOis excluded because it calls for using fresh water to restore wetlands and proposing to restore more brackish marsh. The preparers of the Draft EISIEIR dismiss it because, “In contrast to historic conditions, the Ballona Creek channel was designed to have a permanent opening between Ballona Creek and the ocean and, as a result, the historic water regime is no longer available to make large amounts of freshwater and brackish marsh self-sustaining” (p. 2-231). This is a ridiculous argument. Just because Ballona Channel exits to the ocean does not mean that fresh water is not available to sustain freshwater and brackish wetlands on the project site.

Alternatives that would require pumps and management of tide gates are eliminated because it would take time and money to manage such gates. Yet, such management would be far less expensive than the extensive monitoring and levee management obligations associated with the proposed project.

Raising Culver Boulevard is excluded from consideration on the basis of cost. This exclusion is because the Draft EISIEIR imagines that the only source of funding for such a project would be from the restoration project itself and compares the cost of a project that raises roads as part of a restoration to the cost per acre of a “tidal habitat restoration project” (p. 2-3). Elsewhere, the screening standard is phrased as: “Would the alternative be practicable in terms of cost for a tidal habitat restoration project?” (p. 2-9). Comparing the cost of a combined restoration/flood risk management project with the cost of projects only restoring wetlands is a fatally flawed approach, because flood risk management is one of the stated purposes of the project. Instead, the cost must be compared with combined coastal wetland restoration/flood risk management projects. From that perspective, raising Culver Boulevard is not exorbitantly expensive and would be part of an appropriate coastal resiliency strategy.

2.5 Restoration Lacks Target Species

The Draft EIS/EIR defmes a project need as providing coastal aquatic resources to increase “available breeding and foraging habitat for wildlife” (p. 1-2). The project does not, however, define the target species for which benefits are sought. The argument appears to be that by establishing a generic function and structure (tidal flushing within a gently sloping basin) all species will benefit. Not all species can benefit. It is useful, and indeed essential, to decide at the outset of a project which species will be the targets so that design can be adjusted to ensure benefits accrue to those species.

Quoting Miller and Hobbs (2007), “Identifying a focal or target species or group of species must necessarily be the first step in habitat restoration; their requirements will thereafter serve to guide the process.” Wildlife species are not tied to generic vegetation types, but respond to particular attributes within the landscape that may have little to do with vegetation.

The need to clearly specify target species for the proposed project is compounded by the poor record of restorations without target species at recreating natural services and function.

Comprehensive worldwide comparison of constructed and native wetlands shows that constructed (i.e., “restored”) wetlands do not provide the same ecosystem services as natural wetlands, even after long periods of slow recovery (Moreno-Mateos et al. 2012). As for uplands, recent research compared rodent, snake, and raptor densities in California annual grasslands before and after restoration to perennial grasslands. Reduction in abundance of non-native rodents through restoration resulted in a decreased abundance of native snakes and raptors, leading to this conclusion (Wolf et al. 2017): Our results reveal that while grassland restoration may promote persistence of native plant communities, restoration may not be beneficial to some higher trophic levels, and in fact may reduce habitat value for some native predators in grasslands invaded by Mediterranean plant species. Changes in vegetation structure can strongly impact wildlife species composition, suggesting a more nuanced approach is required for the restoration of desired wildlife communities. Thus, species-specific goals should be carefully considered to ensure improved alignment of restoration methods with expected restoration outcomes (Wolf et al. 2017).

It is therefore important that key target species be identified and their specific habitat needs be designed into any restoration project and especially relative to wetlands and grasslands at Ballona. Without an explicit focus on appropriate target species that are locally or globally rare, the proposed project will have the result of decreasing native biodiversity and homogenizing the biological diversity by increasing the extent of habitat types that are already over-represented relative to the historical condition (e.g., open water).

2.6 No Basis to Create One Wetland Type at Expense of Another

It is only the preferences of the project proponents that prioritizes estuarine habitat in the proposed project. No regulation or law specifies that this should be the focus of the project, andresearch has shown that full tidal estuarine conditions are unnatural at this site (Dark et a1. 2011, Jacobs et a1. 2011). It would be equally valid and more beneficial to concentrate on other even rarer habitat types, such as alkali meadow (Area C), and seasonal wetlands and brackish marsh (Area B).

The only rationale to fill seasonal wetlands or to construct levees on extremely rare salt pan habitat is that it would be difficult to dispose of marina dredge spoils off site. These are choices on the part of the project designers to favor one habitat type over another and to ignore the historical conditions in favor of creating even more subtidal and open-water conditions.

Within this context, the design of the wetlands in Area A deserves to be reconsidered. Not only does the design remove dredge spoils to then fill other wetlands, the grading would cut down below the original marsh plain to create conditions that are lower in elevation than before the construction of the marina. There is no need to create the proposed tidal channels and the excessive excavation serves only to make the created wetlands less resilient to sea level rise. If the project is to prepare for higher sea level, there is no reason to excavate down below original elevations, which were in the mid-to-high intertidal (Jacobs et al. 2011).

2.7 Deferral of Habitat Restoration Plan

Remarkably, the Draft EISIEIR does not contain a final vegetation map for the project alternatives. Rather, it contains this description: Habitat types that would be rehabilitated, re-established or enhanced within the Ballona Reserve include subtidal, intertidal, tidal wetland, brackish marsh, salt pan, dune, annual grassland, transitional, upland scrub, and riparian scrub. Restored habitat distribution and acreages vary by alternative (p. 2-17).

It is unclear why annual grassland is included in this list, since no native habitats are dominated by annual grasses in this region (the exception might the Los Angeles Coastal Prairie, but it was dominated by forbs; Mattoni and Longcore 1997). More troubling is the inclusion of “upland scrub,” which is not a known habitat type. Furthermore, the distribution of the different vegetation types that might be included in the term ”upland scrub” is not shown in any maps of the project alternatives.

The reason for this vague description is that the final distribution of vegetation types has not been established (p. B5-12). This is rather astonishing for a restoration project and reveals that the project really is about creating the tidal wetlands desired by the proponents and not at all about the uplands. The project description in this regard is incomplete and the Draft EIS/EIR should be recirculated when these details have been worked out. One wonders why the project proponents have rushed to release the Draft EISIEIR without having this most basic element of a restoration project: a map of vegetation types to be created.

The reason the upland vegetation types are not included is that the two Lead Agencies do not appear to have been able to come to agreement on the vegetation that will be allowed and maintained on the extensive levee network proposed for the project. The levees must have a ”vegetation free zone” along the levee core in which only perennial upland grasses can be planted. This zone extends 15 feet beyond the toe of the levee core (p. B5-12). Then another zone of vegetation management with limited vegetation would extend another 15 feet. So a cross-section ofa levee would consist of30 feet oflimited vegetation (small shrubs) and 30 feet of grass in addition to grass over the entire width of the levee core.

The total length of the two largest levees is 14,300 ft. Ifwe assume from the cross-sections provided in the Draft EISIEIR that the levee core is at least 50 ft across then the area restricted to perennial grass cover will be ~26 acres with an additional ~10 acres of limited vegetation cover, which means that there will be a minimum of ~36 acres for which rodents must be excluded and vegetation type is dictated by USACE regulations. These calculations do not include the additional levees and berms on the south side of Culver Boulevard, around the salt pan, or in the existing marsh in the southeastern portion of Area B.

Despite the significant restrictions on planting design and management imposed by the responsibility of levee ownership, the Draft EISIEJR makes the assumption that upland habitats will be enhanced for all sensitive species that use uplands. Such an assumption strains credulity when a map of the vegetation types is not provided and the vegetation composition is so severely constrained by the construction of the extensive levee system.

Ironically, the Draft EISIEIR states that a restoration plan will be developed as a project design feature (p. 2-22). The project is described as a restoration, so it should not have the restoration plan be something developed in the future as a mitigating feature. A conceptual restoration plan is in the appendices, but lacks adequate detail as discussed below.

What is known of the final restoration plan is unsatisfactory. The project designers do not even commit to using locally sourced native plants, but rather propose that they would include species not found in the region because they are easier to grow (p. B5-21). Use of species not native to the site is completely inappropriate, and certainly does not qualify as restoration (Longcore et al. 2000).

The creation of different wetland features in the proposed project is also speculative. The text suggests that salt pans can be created in the high marsh by grading depressions to capture water and using adaptive management to “encourage” the salt pans to form. This technique is unproven. Although it is good that the project designers recognize that salt pans are important and rare habitats, the pans need to be large, flat areas that slowly accumulate salt from freshwater runoff and pond shallow water in the winter to serve their historical function as bird habitats (Beller et al. 2014). The size allows birds to have roosts with a view of any approaching predators and shallow ponding of different depths under flood conditions gives habitat to the maximum range of migratory bird species (e.g., waders of different sizes, dabblers, divers).

3 Baseline Conditions

The vegetation mapping in the Draft EIS/EIR collapses a number of different habitat types into the composite category “invasive monoculture” (see Figure 3.4-2). This category is not an appropriate mapping unit for the purpose of impact analysis because it conflates different vegetation types that benefit different species. For example, one of the vegetation types included in “invasive monoculture” is Brassica nigra stands (see Appendix D2). Wild mustard is not always a monoculture even if it is mapped as such, and this vegetation type can be used as foraging habitat by threatened California Gnatcatchers (Campbell et al. 1998, Atwood and Bontrager 2001), while other vegetation types are also lumped into “invasive monoculture” (e.g., Carpobrotus edulis stand). The “invasive monoculture” category needs to be divided out by life form (grass, herbaceous, shrub, tree) and the term should be avoided in most instances because invasive species are almost never found in monocultures, with limited exceptions such as Ice Plant Mats that can be classified separately. Finally, “invasive monoculture” is not a recognized vegetation classification by CDFW.

The Draft EIS/EIR describes an area in the southeast of Area B as a “stabilized dune” (p. 3.4-11).  Although it has little impact on the analysis, the proper understanding of this feature is as a sandy alluvial fan associated with erosion of the Ballona Bluffs, not as an Aeolian dune feature.

Description of baseline conditions also draws into question the appropriate mapping of areas of the wetlands that have been subject to drainage from illegal infrastructure for over 20 years. The illegal drains are located north and south of Culver Boulevard near the underground outflow from Ballona Freshwater Marsh to Ballona Creek. With the Coastal Commission now ordering those drains to be capped, seasonal wetlands in East Area B should be remapped so that the full extent of the impacts of the project on seasonal wetlands can be assessed. The capping of the illegal drains to restore natural hydrology has been separated from the wetlands project by the California Coastal Commission (December 14, 2017 meeting, Item lOc, Application 5-17-0253) and therefore the proper baseline would be the condition of the site before this ongoing illegal activity.

3.1 Sensitive Vegetation

The map of sensitive habitat types (Figure 3.4-3) does not fully describe the extent of sensitive vegetation types. Specifically, Coastal Sage Scrub on site is not identified as a CDFW specialstatus vegetation community (p. 3.4-18). The scrub habitat in the upland zone is variously called upland scrub, which is not a formal classification, and Coastal Sage Scrub (p. 2-45). The 12 dominant species in these areas are described as coyote bush (Baccharis pilularis), big saltbush (Atriplex len tiform is) , and California sagebrush (Artemisia californica), along with lemonade berry (Rhus integrifolia) and seacliffbuckwheat (Eriogonum parvifolium) (p. 2-132). Of the 52.3 acres of Coastal Sage Scrub on site, 48.8 acres will be impacted by the proposed project.

Saltbush Scrub (10.5 acres) and “Coastal Scrub” (41.7 acres) are described in the biological resources section of the document (p. 3.4-11). Because of their combined area, presumably these two vegetation types make up the category called Coastal Sage Scrub elsewhere in the document.

The problem is that the description of sensitive vegetation in the main text of the Draft EISIEIR does not include the 52.3 acres of Coastal Sage Scrub, even though underlying biological reports do acknowledge that it is a sensitive vegetation type (e.g., Table D5-8).

The failure to list Coastal Sage Scrub as a sensitive vegetation type illustrates an overall lack of consistency in the mapping and classification of upland vegetation in the Draft EISIEIR as a whole. It is important that the analysis of impacts not be based on vegetation classifications that are not generally recognized (e.g., upland scrub, nontidal saltmarsh, stablilized dune) and instead use the California Natural Diversity Database categories or vegetation alliances (Sawyer et al. 2009). In this respect the Draft EISIEIR does not even follow CDFW’s own guidelines for the description of natural communities (Department of Fish and Game 2009) in the habitat maps.

For example, the wetland and upland habitats on the map should be remapped (Table 1).

Table 1. Habitat crosswalk for assessment of impacts on biological resources.

Draft EISIEIR_ Category.____ Natural Communities

Coastal Brackish Marsh Coastal Brackish Marsh

Muted Tidal Marsh Southern Coastal Salt Marsh

Non-tidal Salt Marsh Coastal Brackish Marsh

Disturbed Non-tidal Marsh Coastal Brackish Marsh (disturbed)

Saltbrush Scrub Remap to Venturan Coastal Sage Scrub,

WillowlMulefat Thicket

Stabilized Dune

Coastal Scrub

Eucalyptus Grove

Annual Grassland

Invasive Monoculture

3.2 Sensitive Wildlife Species

Coastal Salt Marsh, or Alkali Sink

Remap to Southern Willow Scrub, Southern

Riparian Scrub

Southern Dune Scrub

Venturan Coastal Sage Scrub (not Riversidian

Coastal Sage Scrub; see Westman 1981)

Eucalyptus Grove

Annual Bromus Grassland

Remap to Upland Mustard Stands, Ice Plant Mats, and other categories

To add further documentation to the description of sensitive wildlife, we have compiled photographs of sensitive species in each of the major project areas (A, B, and C) from photographs that have been taken by Jonathan Coffm and archived under the user name stonebird on the image-sharing website Flickr. With Mr. Coffin’s permission and assistance, we present a series of maps with documentation of these distributions, some of which extend beyond the described ranges in the Draft EISIEIR. In the interest of full documentation, we have included more than one image of some of the sensitive species, even when limited to the same management area.

The maps and photographs in Figure 2 through Figure 11 provide documented, verifiable information about the distribution of plant and animal species in different subsets of the project site that should be used to augment the information provided in the Draft EISIEIR. Mr. Coffin and other local naturalists have spent far more time (thousands of hours) observing nature in the Ballona Wetlands than the effort described in the surveys conducted for this Draft EISIEIR. The difference in time alone, and the spread of the survey effort throughout the whole year, means that Mr. Coffin will have observed more species and be more familiar with their distributions than the preparers of the Draft EIS/EIR.

3.2.1 Invertebrates

The Draft EISIEIR makes unsupported assumptions about the probability of presence and distribution of special-status invertebrates (see Table 3.4-4).

Wandering Skipper is assumed to be present only in Area B West and Southeast (Figure 3.4-7). It should be assumed that Wandering Skipper is found at any location where saltgrass is present.  We have presented photographic evidence of the species in Area A (Figure 3).

Belkin’s Dune Tabanid Fly is described as only having a “low potential” to occur. This species was found in the dune habitat at the western end of Area Bin 1981 (Nagano et al. 1981) and earlier (Middlekauff and Lane 1980) and no significant disturbance has occurred since then to support a conclusion that it would be absent now. To the contrary, significant removal of invasive species and propagation of native vegetation has taken place. The species has a narrowly limited range that includes only the El Segundo Dunes and the Silver Strand in San Diego and should be a target species for restoration.

Dorothy’S El Segundo Dune Weevil is evaluated as having only a ”moderate potential” to be present. This species was present in the past (Nagano et al. 1981), however, and no disturbance has occurred that would have extirpated it from the site. Local entomological experts havelocated this species on site as recently as 2016 (Jeremiah N. George, Ph.D., August 2016, pers. comm.; observation submitted to the California Natural Diversity Database (CNDDB], which is maintained by CDFW), so the surveyors involved in the preparation of the Draft EISIEIR must have lacked the experience or appropriate technique to find this species.

Figure 2. Part 1 of sensitive species documented in Area A with photographs (J. Coffin): Burrowing Owl, Northern Harrier, Cooper’s Hawk, White-tailed Kite (juvenile), Loggerhead Shrike. Data compiled and mapped in 2014 by B. MacDonald.

Figure 3. Part 2 of sensitive species documented in Area A with photographs (J. Coffin): Wandering Skipper, Monarch Butterfly, Snowy Egret, Belding’s Savannah Sparrow, Yellow-headed Blackbird, Black-crowned Night-Heron. Data compiled and mapped in 2014 by B. MacDonald.

Figure 4. Part 1 of sensitive species documented in Area B North with photographs (J. Coffin): Vaux’s Swift, White-tailed Kite, Short-eared Owl, American Peregrine Falcon, Northern Harrier Guvenile), Merlin, Yellow-headed Blackbird, Loggerhead Shrike. Data compiled and mapped in 2014 by B. MacDonald.

Figure 5. Part 2 of sensitive species documented in Area B North with photographs (J. Coffm): Long-billed Curlew, California Brown Pelican, White-faced Ibis, Elegant Tern, Belding’s Savannah Sparrow, Great Blue Heron, Great Egret. Data compiled and mapped in 2014 by B. MacDonald.

Figure 6. Part 3 of sensitive species documented in Area B North with photographs (J. Coffin): White-tailed Kite, Northern Harrier, American Peregrine Falcon, Burrowing Owl, Yellow-breasted Chat, Loggerhead Shrike. Data compiled and mapped in 2014 by B. MacDonald.

Figure 7. Part 4 of sensitive species documented in Area B North with photographs (J. Coffin): Black Oystercatcher, California Brown Pelican, White-faced Ibis, California Least Tern, Elegant Tern (juvenile), Double-crested Cormorant, Redhead, Brant. Data compiled and mapped in 2014 by B. MacDonald.

Figure 8. Part 1 of sensitive species documented in Area B South with photographs (J. Coffm): Belding’s Savannah Sparrow, Least Bell’s Vireo, Yellow-breasted Chat, Clark’s Marsh Wren, Wandering Skipper, Monarch Butterfly, Vaux’s Swift, Yellow-headed Blackbird. Data compiled and mapped in 2014 by B. MacDonald.

Figure 9. Part 2 of sensitive species documented in Area B South with photographs (J. Coffm): Short-eared Owl, White-tailed Kite (inc. juvenile), South Coast Marsh Vole, Cooper’s Hawk, Northern Harrier. Data compiled and mapped in 2014 by B. MacDonald

Figure 10. Part 1 of sensitive species documented in Area C with photographs (J. Coffm): Monarch Butterfly, Burrowing Owl, Lewis’ Evening-primrose, California Horned Lark, California Gnatcatcher. Data compiled and mapped in 2014 by B. MacDonald.

Figure 11. Part 2 of sensitive species documented in Area C with photographs (J. Coffin): California Brown Pelican, Osprey, White-tailed Kite, Loggerhead Shrike, Yellow-headed Blackbird, Great Egret, Great Blue Heron. Data compiled and mapped in 2014 by B. MacDonald.

Globose Dune Beetle is assumed to be absent. It was observed on site in 2016 by an entomologist (Jeremiah N. George, Ph.D., August 2016, pers. comm.; observation submitted to CNDDB) and failure to locate it speaks to the inadequacy of the survey efforts involved in preparation of the Draft EISIEIR.

Western S-banded Tiger Beetle (Cicindela trifasciata sigmoidea) is listed as having only a “low potential” to occur (p. 3.4-26). This species, along with the other two tiger beetle species recorded at the site in the 1980s (Western Tiger Beetle, Cicindela oregona, and Wetsalts Tiger Beetle, Cicindela haemorrhagica) represent a significant contribution to the biodiversity of this wetland system (Nagano 1982). C. t. sigmoidea was present in the 1980s and 1990s and it should still be present. Each of these three species was found along Ballona Creek and C. t. sigmoidea was found in the salt pan and mud flats of Area B (Nagano et al. 1981, Nagano 1982).

It would be startling if these species were no longer present.

The map for presence of El Segundo Blue Butterfly distinguishes between occupied and nonoccupied stands of Eriogonum parvifolium (Figure 3.4-5). Having worked extensively with this species, it must be assumed that all of the plants are occupied, given the published (Arnold 1983) and observed dispersal distances (> 1,200 ft; T. Longcore, pers. obs.), far exceeding the distance between plants at the Ballona dune. To do otherwise is naYve.

3.2.2 Reptiles

It should be emphasized that Southern Pacific Rattlesnake is present within the project site  (Figure 12; Appendix D). Observations reported on iNaturalist have been verified by Greg Pauly, Ph.D., the herpetology curator at the Los Angeles County Natural History Museum. This population is important to recognize, because its elimination would result in a significant contraction in the range of the species regionally, which would be a significant impact under CEQA. It is the only population between the Santa Monica Mountains and the Palos Verdes Peninsula on the coastal plain. Recent efforts to detect Southern Pacific Rattlesnake in the public lands of the Baldwin Hills were unsuccessful (Pauly et al. 2016). Snakes are easily killed by earthmoving equipment and restoration activities (Hinds 2017), so a specific and enforceable plan would be needed to protect the Ballona population.

3.2.3 Birds

The treatment of presence of birds at the site should be updated with reference to the Los Angeles County Breeding Bird Atlas (Allen et al. 2016). The project site was covered by surveyors for the Atlas in 1995-1999 and the results are reported for two Atlas “blocks” that cover the western and eastern portions of the site (Figure 13). These blocks contain more than simply the project site and so not all breeding records in these blocks indicate breeding at the site itself. However, they do indicate species of birds that either were breeding on the site or were breeding in the vicinity of the site and for which the site could be an important foraging area to support that breeding activity. Presence of breeding species is indicated as possible, probable, or confirmed for each Atlas block (Allen et al. 2016).

The Draft EIS/EIR states that the only raptor species breeding at the project site is Cooper’s Hawk (p. 3.4-57). During the Atlas period, however, Red-shouldered Hawk, Red-tailed Hawk, and White-tailed Kite were possible or confirmed breeders in the two blocks including the project site (Table 2). The breeding of White-tailed Kite at the project site is further supported by recent photographs of juvenile White-tailed Kite across the project site (Area A, Figure 2; Area B, Figure 9) and adults across all areas (A, B, and C).

Santa Monica


1 Segundo

Manhattan Beach


Lakewood/Long Beach

Figure 12. Distribution of Southern Pacific Rattlesnake in the region. Data from research-grade observations on iNaturalist (bUps:/ /www.inaturalist.orgltaxa/30713-Crotalusore2anus-heUeri). The grayed-out blue circular marks in Santa Monica are obscured locations and do not represent actual observation sites.

Figure 13. Location of western and eastern survey blocks encompassing project site from Los Angeles County Breeding Bird Atlas (Allen et al. 2016).

The Draft EISIEIR treats nesting raptors and other sensitive bird species separately. For sensitive bird species (not raptors), the Draft EIS/EIR lists four nesting on site: California Towhee, Loggerhead Shrike, Tree Swallow, and Western Meadowlark. These are confirmed by the Los Angeles County Breeding Bird Atlas (although Tree Swallow colonized after the Atlas period), and records suggest breeding by both Blue Grosbeak and Black-headed Grosbeak in the project vicinity (Table 2).

Table 2. Presence of sensitive bird species and raptors breeding in vicinity of project site (Allen et al. 2016).

Species Western Block Eastern Block

Black-headed Grosbeak Possible

Blue Grosbeak Possible Confirmed

California Towhee Possible Confirmed

Loggerhead Shrike Confirmed Probable

Western Meadowlark Confirmed Probable

White-tailed Kite Possible

Red-shouldered Hawk Possible Possible

Red-tailed Hawk Possible Confirmed

3.2.4 Small Mammals

The surveys most recently conducted for small mammals should not be interpreted as showing the absence of any species. It is possible, and in fact likely, that failure to detect some species during the surveys had as much to do with survey protocols as with presence of the species.

For example, it is highly unlikely that Southern California Salt Marsh Shrew (Sorex ornatus salicornicus) is absent from the site. The specimen that resulted in the scientific description of this unique subspecies was collected at Ballona (Owen and Hoffinann 1983). The subspecies was present in the 1980s (Friesen et al. 1981) and in later surveys. However, to capture shrews in Sherman traps it is necessary to have extra-sensitive traps because shrews weigh less than other small mammal target species (Friesen et al. 1981). In the 1980s surveys on the project site, especially sensitive live traps (“Museum Specials”) were set in particular areas where shrews were previously collected (Friesen et al. 1981). The more recent surveys by Johnston et al. did not involve use of specialized traps for shrews and probably were done without awareness of the collecting localities so their failure to capture shrews is to be expected. The conclusion that

Southern California Salt Marsh Shrew is only of “moderate potential” to occur should be revised (p. 3.4-29). If they are not present, their loss represents a significant degradation of the biodiversity on the project site.

4 Impact Analysis

4.1 Impacts from Trail System

The Draft EISIEIR does not currently but should consider the impacts on native wildlife from trail use facilitated by development of an extensive trail system (e.g., Boyle and Samson 1985, Steven et al. 2011). The current evaluation does not consider the impacts of the spatial design of the trail system or the potential adverse consequences of their use.

The Draft EISIEIR does not calculate the amount of the ecological reserve that is taken up with the trail system itself. The analysis of impacts on sensitive species does not subtract the trail area from its vegetation type totals, even though some of the trails will be 18 ft across and their influence from disturbance will extend outward hundreds of feet. This is a major flaw in the analysis in the Draft EISIEIR, because most sensitive species by definition need significant setbacks (hundreds of feet) from disturbance such as trails.

The Draft EIS/EIR describes development of 19,000 ft of pedestrian and Class I bicycle paths (18 ft wide; p. 2-100), which would have a footprint of 7.85 acres. An additional 29,000 ft of pedestrian trails of 6 ft width would cover 4.00 acres. The 2,000 ft of boardwalks of 10ft width over marsh would reduce that habitat area by 0.5 acres. In sum, the resulting trail system would cover an area of over 12 acres that is improperly counted as wildlife habitat in the impact analysis.

The Draft EISIEIR does not account for the fragmentation caused by the configuration of the trail network. It also fails to map the distance that detrimental impacts caused by different trail users (e.g., pedestrians, cyclists, pedestrians with dogs) would extend outward from the trails. The spatial extent and size of trails guarantee extensive use and concomitant disturbance of wildlife in the ecological reserve by visitors and their pets. Movement along trails, especially rapid movement and with pets, disturbs wildlife that can see and hear the activity. Rather than hugging the edges of the property and minimizing the visibility of the trails from sensitive habitat, trails are designed in a way that maximizes visitor access at the expense of sensitive wildlife.

The primary purpose of an ecological reserve is to conserve biological diversity, and the intense fragmentation that would be caused by the trail network would diminish what should be the core value of the project. The trail system has a compounding negative impact of being raised on levees around the open wetland areas. This will make activities on the levees more prominent and be disturbing to prey species. Part of the reason that birds roost in open areas like salt pans is that they can see predators from a great distance. The berm and trail system would bring activity that would be perceived as dangerous closer to prey species, decreasing the value of the habitat for those species.

Trail presence significantly depresses breeding density of sensitive open-land species such as Western Meadowlark. For example, density of breeding Western Meadowlark was depressed by about 25% at 100 m from a recreational trail, and >50% at 50 m (Miller et al. 1998). Across many wetland species, it is recommended that a buffer of 50-250 m be provided from disturbance such as trails (Carney and Sydeman 1999).

Both dogs and cats are allowed in State wildlife areas if on a leash (14 CCR Section 550(m)).

The Draft EIS/EIR assumes that humans and pets will have no impact if kept to the developed trail system (p. 3.4-87). This is false; the mere presence of pedestrians and dogs can disturb and adversely impact shorebirds (Lafferty 2001), grassland birds (Miller et a1. 2001), and forest birds (Thompson 2015). Passive recreation can have a large adverse environmental impact (Klein et al. 1995) and this is not properly addressed in the Draft EISIEIR.

The Draft ElSIEIR contains a mitigation measure to reduce the impacts of disturbance on nesting birds and raptors, but this measure would only extend through the construction phase of the project. The Draft EISIEIR contains no analysis of or mitigation measures for the permanent impacts on birds associated with the project (e.g., greatly increased maintenance activities and recreational use).

Furthermore, the inclusion of such an extensive trail network will work against restoration efforts because invasive species introductions are greater closer to trails (Benninger-Truax et a1. 1992).

4.2 Absence of Post-Restoration Vegetation Maps

The impacts analysis makes magically optimistic assumptions that all of the species that are currently found on the site will have their habitat needs fulfilled and enhanced (i.e., long-term beneficial impacts) by the end of the project. This analysis is not supported by adequate information and it cannot be true because of the different habitat needs of the many sensitive species on the project site.

There will be winners and losers in terms of species diversity, but those winners and losers cannot be identified because the Draft ElSIEIR does not provide postrestoration vegetation maps, instead providing maps that show large areas of “Upland” without vegetation types.

The reason for the absence of post-restoration vegetation maps is that the planting design for the levees has not yet been approved: [U]pland habitats would be subject to regular maintenance. Actual acreage of upland habitats dedicated to maintenance will be quantified after perimeter levee design has received approval. Maintenance in uplands is intended to meet multiple objectives, such as providing wildlife habitat, flood protection, and fuel modification. Please see Appendix B5 for additional details on activities and methods of maintenance to be conducted in these habitats (p. 2-45).

Flood control levees are subject to very particular requirements, including no-root zones, limited perennial vegetation, and a need to eliminate rodent burrows (U.S. Army Corps of Engineers 2014). It is unknown at this time what vegetation will be permitted on the extensive levees to be constructed around the project site, meaning that all of the assumptions about long-term beneficial effects on scrubland and grassland species are unsupported. Furthermore, by claiming broad benefits from restoration of uplands without providing a map of vegetation distributions, the preparers of the Draft EISIEIR inappropriately shield themselves from questions about whether the uplands can be all things to all species. That is, can the requisite habitat elements for each species for which upland mitigation is claimed actually be fit within the area left over after converting a large area to wetlands, having vegetation type constrained on the levees, removing the area taken up by trails and other visitor-serving infrastructure, and accounting for disturbance from recreational activity? The Draft EISIEIR does not even provide the most basic information, a post-project vegetation map, that could be used to answer that question.

4.3 Impacts to Endangered Species

4.3.1 El Segundo Blue Butterfly

Comparison of the map of final habitat types and the map of foodplant for El Segundo Blue Butterfly suggests that some of the habitat area for this species will be lost. The constructed levee extends up to and over several E. parvifolum patches. The final footprint of construction extends considerably into the area mapped as E1 Segundo Blue Butterfly habitat (Figure 3.4-5).

Furthermore, the area of some of these patches is depicted as undifferentiated “upland” andtherefore should be considered a permanent impact. Construction of the levee in that location will likely result in take from construction activities in addition to loss of existing habitat.

Figure 14. Comparison of fmal proposed habitats for Alternative 1 (left) with extent of EI Segundo Blue Butterfly habitat (purple outline; right).

The project management plan acknowledges that pesticides will be used to control mosquitoes, midges, and/or black flies at the project site (p. 3.4-139; see details in Appendix BS). The plan describes the use of Bacillus thuringiensis (Bt) as a control agent. Bt is a known pathogen of lycaenid butterflies (Tanada and Kaya 1993, Mattoni et a1. 2003), and lycaenid larvae exposed to Bt experience mortality in a dose-dependent relationship (Herms et al. 1997). Assessment of the impacts of the proposed project on EI Segundo Blue Butterfly (a lycaenid) therefore should consider non-target impacts of vector control activities.

The project design includes a levee immediately adjacent to occupied habitat and a culvert that drains under that levee (Figure 14; purple line). The risk of accidental or intentional flooding of EI Segundo Blue Butterfly habitat throughout the life of the project should be assessed, because inundation of habitat would constitute a significant adverse impact; the pupae of the butterfly live in the soil underneath host plants for most of the year (Mattoni 1992) and are consequently vulnerable to flooding.

4.3.2 California Least Tern

The impact analysis for California Least Tern makes the unsupportable assertion that the project site is not used by this species: This species is not expected to breed or forage on the Project site considering the habitat conditions onsite and the lack of recent observations of this species. This species unsuccessfully attempted to breed in Area Bin 2014, so potential impacts to nesting could occur if this species attempts to nest onsite again (p. 3.4-80).

The juxtaposition of the two sentences in this rather paltry analysis is striking. The salt pan is a potential breeding site where breeding has been attempted in the recent past, yet the Draft EISIEIR claims that the species is not expected to breed or forage. In addition to being observed roosting in the project site at the salt pan and at a freshwater pond in Area B (see many eBird reports), the species forages in Ballona Creek, which is part of the project site and would be significantly impacted during project construction.

4.3.3 California Gnatcatcher

The impact analysis for California Gnatcatcher is problematic for a number of reasons. The text reads as follows:

This species is not expected to breed or forage on the Project site considering the habitat conditions onsite and the lack of recent observations ofthis species. However, since focused surveys for this species have not been conducted at the Ballona Reserve since 2011, although unlikely, potential impacts to nesting could occur if this species is confirmed present onsite. However, with implementation of Project Design Features and mitigation measures, Alternative 1 may affect, but is not likely to adversely affect coastal California gnatcatcher or its habitat (p. 3.4-80).

First, the Draft EISIEIR asserts that foraging is not expected even though foraging has been reported on the project site multiple times and as recently as April, October, and November of 2016 (observations easily accessible and verifiable on eBird).

Second, the analysis is based on the unverified assumption that the area that would be used for foraging is limited to coastal scrub, when California Gnatcatcher uses many other vegetation types for foraging, including disturbed habitat (Campbell et al. 1998, Atwood and Bontrager 2001). In fact, the species has been observed in Areas A, B, and C. Any conclusion that the post-implementation project would provide more habitat is premature, however, because the acreages of those habitats has yet to be determined.

Third, the analysis presumes that foraging habitat has little value and provides no consideration of how the site might be used in a network of habitat patches allowing for the dispersal of this species across the landscape. The observations ofthe species reported on eBird suggest dispersal patterns that include the Ballona Wetlands as an intermediate location linking the El Segundo Dunes to the Baldwin Hills (Figure 15).

Fourth, the Draft EISIEIR does not disclose that California Gnatcatcher has recently (2013) colonized the nearby El Segundo Dunes as a breeding species, suggesting the possibility of breeding at Ballona as well.

It should be noted that the habitat for this threatened species in Area C would not be impacted for any restoration purpose; rather, the habitat in Area C would be destroyed solely for the convenience of dumping excavated material from Area A.

Figure 15. Past 10 years of California Gnatcatcher observations in and around project site (from

4.3.4 Least Bell’s Vireo

The analysis of impacts to this species is as follows: This species is known to breed and forage in Southeast Area B. Potential impacts to nesting could occur if this species attempts to nest onsite again. However, with implementation of Project Design Features and mitigation measures, occupied habitat for this species would be avoided (p. 3.4-80).

The Draft EIS/EIR acknowledges loss of 0.1 acre of habitat (p. 3.4-101) but then claims that the total habitat area will be increased by 2.9 acres at the end of the proposed project. This apparently would be achieved by creation of riparian habitat along a new drainage feature between two piles of dredge spoils in Area C North, because no additional willow habitats are proposed in Area B Southeast. The new willow habitat in Area C North is unlikely to be useful for the species because it is designed with a public access trail immediately adjacent to it. This location is also isolated from the block of habitat provided by the Ballona Freshwater Marsh and Centinela Creek. It is unclear if this is an appropriate location for this habitat or if the appropriate hydrology will be present to support it.  No additional water source is evident that would provide the hydrological conditions necessary to support a riparian forest at this location.

Least Bell’s Vireo relies on songs to attract mates and defend territories. Studies of road noise from Europe include similar small songbirds that use acoustical communication. Noise impacts on birds are not fully considered in the Draft EISIEIR. The threshold levels for two European warbler species (Phylloscopus sibilatrix and Phylloscopus trochilus) are 26 dB (A) and 39 dB(A), with decrease factors pfO.61 and 0.38, meaning breeding density was diminished to ~40-60% of undisturbed levels (Reijnen et al. 1995).

From the published literature, therefore, a conservative threshold based on similar species for Least Bell’s Vireo would be 40 dB(A) or below. The Draft EISIEIR should include performance criteria for noise impacts in potential Least Bell’s Vireo habitat, as well as assess the impacts of noise on areas of non-riparian vegetation that may be used by Least Bell’s Vireos. Other habitats, such as coastal sage scrub and chaparral, are documented as foraging habitats for the species (Kus and Miner 1989).

4.4 Impacts to Special-Status Plants

The approach to mitigation of special-status plants in the Draft EISIEIR is to count the number of plants and then commit to mitigating that number on a 1: 1 basis. Such an approach will not ensure that significant adverse impacts are mitigated to a less than significant level. For shortlived plants, the question is not the number of individual plants, since this number will change with conditions on an annual basis, but rather the area of habitat that is providing the appropriate soil, topography, aspect, and competitive conditions for that sensitive species to thrive. It is trivial, and insufficient, to plant and maintain a certain number of a special-status annual plant for a number of years through seeding, but quite another to establish habitat so that the species reproduces and is self-sustaining in perpetuity. It is furthermore inappropriate that the Draft EISIEIR does not provide a map of locations where special-status species will be restored so the prospects for success in doing so can be assessed.

4.4.1 Lewis’ Evening-primrose

The proposed project would grade or dump dredge spoils on 96% of the individuals of Lewis’ Evening-primrose that were surveyed on the project site (p. 3.4-85). The Draft EISIEIR commits to a replacement number of plants but not an equal area of habitat or assurance that thepopulation would be viable in perpetuity. Furthermore, the Draft EISIEIR does not explore the possibility of avoiding impacts to this species. Avoidance is always the preferred mitigation.

The only reason for impacts in Area C where the main population of this species is found is that this location has been chosen as the dumping ground for dredge spoils from Area A. Off-site disposal of dredged materials would avoid impacts to sensitive species and habitat in Area C.

4.4.2 Woolly Seabite

Mitigation for Woolly Seabite is also proposed at the individual level instead of for the area occupied. Although the marsh habitat for this species is likely to be provided in the proposed project, a map should be included in the Draft EISIEIR that shows where this species will be restored and how conditions for it will be maintained.

4.5 Impacts to Special-Status Invertebrates

The Draft EISIEIR lacks information and detail to support its conclusion that the impacts on salt marsh invertebrates (e.g., Wandering Skipper, Western S-banded Tiger Beetle, Western Tiger Beetle, and Wetsalts Tiger Beetle) would be less than significant. As discussed above, the Draft EISIEIR makes flawed assumptions about the distribution of these species and the analysis of impacts is nonexistent.

Saltgrass is the foodplant for Wandering Skipper. A map of post-restoration Saltgrass distribution is needed to compare against current distributions for Wandering Skipper. It is likely that the loss of habitat exceeds the 13.5 acres acknowledged because of the greater distribution of Wandering Skipper than assumed in the Draft EISIEIR. Notwithstanding the larger distribution than that disclosed, any project alternative that removes a significant proportion of the existing Saltgrass habitat risks extirpating the species from the site through direct impacts and fragmentation.

The sensitive nature of tiger beetles must be considered, and their presence on the rocks of Ballona Creek (Nagano et al. 1981, Nagano 1982) should be addressed in more detail. How will these species be protected during construction? Lacking a focused survey for tiger beetles by credential experts, these species should be assumed present and made target species for design of any restoration proposal.

It is furthermore not logical that a loss of 2.4 acres of Southern Dune Scrub would not have a significant adverse impact on dune-associated special-status invertebrates. To the contrary, this acreage would be a significant loss, both of a special-status vegetation type and of the special status invertebrates associated with that habitat. The resulting impact after mitigation would still be significant.

4.6 Impacts to Special-Status Reptiles

4.6.1 Silvery Legless Lizard

The Draft EIS/EIR draws the conclusion that impacts to special-status reptiles would not be significant after mitigation, but does not provide data to support that claim. The general argument is that the loss of 2.4 acres of sandy soils appropriate for Silvery Legless Lizard would be offset by increased quality of habitat elsewhere that would increase density. This is not a good metric of impacts or mitigation. The question is whether the distribution of this species would be decreased after implementation of the proposed project, which it would.

The Draft EIS/EIR does not provide evidence of differing densities of legless lizards in different areas of the project site, which is, admittedly, a difficult thing to do (Kuhnz et al. 2005). The highest density of legless lizards ever measured was at a development site at Moss Landing in Central California. It took 1,572 person-hours to clear 0.2 hectare oflizards (with “clearing” defined as searching for 40 hours without locating a lizard) (Kuhnz et al. 2005). Without such an effort, the preparers of the Draft EISIEIR do not have adequate information to make statements about lizard density. Furthermore, the survey approaches in the Draft EISIEIR are inadequate to determine presence, as shown by the Moss Landing study:

These results provide evidence that coverboard surveys and pitfall trap arrays do not accurately detennine the presence (or absence when used for habitat management decisions) of this species, and we suggest that these methods be avoided when surveying for California Legless Lizards as a predevelopment or predisturbance mitigation. In situations where it is essential to know whether legless lizards are present, a full depletion survey should be conducted in a discrete area within the habitat (Kuhnz et aI. 2005).

The Draft EISIEIR also proposes to relocate legless lizards. This would be a very timeconsuming endeavor for the area they describe (potentially >7,500 person-hours for 1 hectare l2.4 acres). Furthermore, relocating into existing habitat would not provide a conservation benefit, because existing habitat presumably already supports the species at its carrying capacity. The Draft EISIEIR is based on the assumption that it can increase carrying capacity or create new habitat, but provides no evidence to show that is feasible and can be implemented and measured.

Finally, assumptions about the density of legless lizards at the project site may well be wrong; the highest density of legless lizards ever recorded at a site was at a location with 50% cover of invasive plant species (Kuhnz et al. 2005) rather than a site with predominantly native plant cover.

To draw a conclusion about a beneficial effect, the Draft EISIEIR would need to account for the decrease in dune habitat, deal with the survey issues, and map where lower quality habitat will be improved. As it is, these benefits are speculative and insufficiently supported.

4.6.2 San Bernardino Ring-necked Snake

The Draft EISIEIR concludes that the proposed project will have a less than significant impact on San Bernardino Ring-necked Snake (p. 3.4-97). It is unclear how this would be possible, given that 56 acres of upland habitats would be converted to salt marsh.

The Draft EISIEIR contemplates enhancing 200 acres of “invasive monoculture,” arguing that this would benefit this species and offset the loss of over 50 acres of habitat. The Draft EISIEIR contains no information about density of the species and, importantly, does not map the pre- or postrestoration distribution of essential habitat features for the species. Ring-necked Snakes hide under rocks and logs and in moist soil (Pauly et aL 2016).

Such conditions are not necessarily tied to vegetation type. The Draft EISIEIR argues that 8.1 acres of levees would be potentially suitable habitat in the post-project condition, but does not list any specific design features that would be incorporated to support that assumption. The levees are elevated and dry and cannot include rocks and logs. In fact, the guidelines that must be followed specify that vegetation must be controlled on levees “to limit those habitat characteristics that encourage the creation of animal burrows” (U.S. Army Corps of Engineers 2014). The amount of habitat promised upon project completion has not been mapped, nor has any evidence been shown to conclude that the 200 acres of uplands will be better habitat for San Bernardino Ring-necked Snake following the project. It is not possible to conclude, therefore, that reducing the available upland habitat for a sensitive upland species by 50 acres, reducing it further by exclusion of vegetation and desirable physical features on levees, and reducing it even further through an extensive trail network where visitors are prone to kill snakes that they find (see description of hikers killing snakes in the nearby Baldwin Hills; Pauly et al. 2016) could possibly result in a net benefit for the species.

4.7 Impacts to Special-Status Birds

4.7.1 Belding’s Savannah Sparrow

Belding’s Savannah Sparrow should be a target species for any wetland enhancement at Ballona. Indeed, the species, a specialist of the upper marsh zone that naturally predominated the historical landscape, has long been the focus of conservation efforts for this site (Dock and Schreiber 1981, Corey and Massey 1990). It should be noted at the outset that this species does not require full tidal flushing to create habitat and in fact the muted tidal regime in place in Area B maintains a significant amount of habitat and the population of sparrows has been increasing there.

During the two phases of the proposed project, 7.9 acres of occupied habitat and 20.2 acres of potentially suitable habitat would be destroyed. A typical coastal wetland mitigation ratio for habitat destruction of salt pan or salt marsh is 4: 1 (e.g., San Diego Municipal Code, Land Development Code, Biology Guidelines, 2012). The proposed project would permanently impact 28.1 acres of potential or occupied Belding’s Savannah Sparrow habitat. Approximately 32% of the existing occupied habitat will be directly impacted, and much of the remainder will be significantly disturbed by construction of channels and berms in the middle of the occupied breeding territories (compare Figure 2-1 and Figure 3.4-12). If this were a development project, mitigation of 112.4 acres would be required. The project does not meet this standard (it proposes 97.7 acres of potential habitat), which is only a net increase of 69.6 acres to offset a loss of 28.1 acres and construction in the middle of breeding habitat.

The Draft EISIEIR fails to recognize that not all of the new or old habitats will be suitable because of the trail system proposed for the project. Based on field observations, ornithologists recommend at least a 63 m (200 ft) buffer around potential Belding’s Savannah Sparrow breeding habitat (Fernandez-Juricic et al. 2009). This means that mitigation credit should not be allowed for any existing or restored habitat that is located within 200 ft of any of the recreational infrastructure. Because males defend territories around dry, non-inundated sites in the upper marsh zone (Fernandez-Juricic et aL 2009), the potential is high for the recreational trail system to substantially degrade the habitat quality of the salt marsh areas assumed to mitigate for loss of existing habitat.

The proposed project envisions a scenario where new potential habitat is created during Phase 1 and then Phase 2 (with larger impacts on occupied habitat) would proceed when the species nests in habitat created in Phase 1. All that is necessary for the new Phase 1 habitat to be considered as providing acceptable mitigation for loss of occupied habitat is one nesting pair of sparrows (p. 3.4-10 1). This threshold is far too low; only when a number of breeding pairs of sparrows is supported in created habitats that equals the number to be impacted in Phase 1 and Phase 2, should the Phase 2 efforts be allowed to proceed.

Despite nesting in the upper salt marsh, Belding’s Savannah Sparrow is a terrestrial species; it nests on and forages on dry ground in grasslands, fields, and upper marsh and transition zones. Creation of lower marsh habitats and additional mudflat and subtidal habitats does not help this species, which by all rights should be the primary focus of Ballona Wetlands management as a resident endangered species. It would be a far greater conservation benefit to create only mid-and high-marsh habitats in Area A, which would have a range of advantages, including 1) reducing the amount of grading, 2) increasing the amount of Belding’s Savannah Sparrow habitat, 3) providing more habitat farther from pedestrian disturbance, and 4) being more resilient to sea level rise.

4. 7.2 California Gnatcatcher

As discussed above, the project site is used regularly by California Gnatcatchers, which appear to be dispersing individuals. The Draft EIS/EIR dismisses this use as inconsequential, but in doing so fails to grapple with the use and value of the site for the dispersal of the species and its recovery in the region. The future upland plantings on the site are unknown and undetermined, so any conclusion that impacts to this species are insignificant cannot be supported. One of the key areas of analysis in CEQA is the value of habitat to animals moving across the landscape and the Draft EISIEIR categorically denies that the site has any role in local wildlife connectivity.

We documented above that gnatcatchers are capable of using more than scrub habitats for foraging, which further undermines the conclusion in the Draft EISIEIR that the project would not adversely impact California Gnatcatchers.

4.7.3 California Horned Lark

As one of the last remaining open grasslands in the Los Angeles basin, the ecological reserve is disproportionately important to grassland species. The Draft EISIEIR should analyze the impacts of the proposed project on California Homed Lark. Dean Schaff observed this species at the Ballona Freshwater Marsh in 2016 (submitted to eBird by D. Cooper S31800195). We also have provided an image taken by Jonathan Coffin of Homed Lark foraging in Area C of the project site (Figure 10). The Draft EISIEIR provides no analysis of impacts on this sensitive species.

4.7.4 Burrowing Owl

The proposed project would impact wintering (and former breeding) habitat for Burrowing Owl. The Draft EIS/EIR acknowledges that grading of the project site would destroy existing ground squirrel burrows, but then it states that ground squirrels would construct new burrows. This claim is disingenuous because it is not reconciled with the reality that much of the new ”uplands” will be in the form of earthen levees, which must be managed according to regulations to maintain safety. Those regulations include steps to destroy animal burrows in the levees by filling them and taking steps to prevent burrows from being constructed in the levees at all (U.S. Army Corps of Engineers 2014).

Furthermore, although the Draft EISIEIR expresses a desire to avoid lethal control of rodents (“limiting or prohibiting lethal rodent control measures,” p. 3.4-109), it does not commit to this as a mitigation, nor does it commit to banning rodenticides on the project site. Unless the Operations and Management plan is revised to specifically prohibit the use of poisons, impacts on serisitive native mammals and birds, especially predator species, must be analyzed.

The analysis does not take disturbance (especially pedestrians with dogs) from the recreational infrastructure into account when projecting future habitat area (Cavalli et al. 2016).

Furthermore, the project description is incomplete in that it does not include a map of vegetation types to be established and maintained in the uplands or reconcile the competing needs of Burrowing Owls (low, open vegetation) with those of other species that would be found in the uplands. The claim in the Draft EISIEIR that lost habitat for Burrowing Owl will be mitigated at a 7:1 ratio is therefore not supported by the project description. The map of the extent of current Burrowing Owl activity is an educated hypothesis at best, and only a fraction of the future upland would be suitable for the species once taking rodent control measures and disturbance from recreation into account.

The Ballona project site is one of the few locations where it would be possible to re-establish a breeding population of Burrowing Owl on the Los Angeles coastal slope. Sadly, the design of the restoration would not accomplish this reasonable and appropriate goal, squandering the opportunity to maintain and improve native biodiversity appropriate to the local ecology.

4.7.5 Nesting Raptors

The analysis in the Draft EISIEIR should address impacts on raptors nesting both in and near the project site because of the importance of foraging in breeding ecology. The Draft EISIEIR only includes Cooper’s Hawk as a nesting species and downplays the importance the site for foraging.

Based on historical records and current photographic evidence, impacts to nesting raptors, including impacts to the foraging areas necessary to support nesting, should also consider White-tailed Kite, Red-tailed Hawk, and Red-shouldered Hawk.

The Draft EISIEIR argues that the post-restoration site would provide improved foraging habitat for raptors, which is meant to apply to Merlin, Northern Harrier, Osprey, Peregrine Falcon, Sharp-shinned Hawk, Short-eared Owl, White-tailed Kite, and Turkey Vulture.

Recent research (Wolf et al. 2017) suggests that replacing annual grassland with native perennial grassland would significantly reduce native raptor densities, so a species-by-species approach is necessary to predict impacts. We focus on two species for the purpose of discussion.

White-tailed Kite forages at the project site but nesting was not detected in studies for the Draft EISIEIR. However, juvenile White-tailed Kites are regularly observed at the project site and it was a probable breeder in 1995-1999 (Allen et al. 2016). White-tailed Kite territories must include foraging habitat rich in rodent prey, which could be high marsh, grasslands, rangelands, agricultural land, “barren” land, and weedy fields. Preferred prey items are small mammals of 20-70 g (Dunk 1995). Voles are likely the preferred prey item at Ballona because of their size, and White-tailed Kites have been observed at the project site with this prey item. South Coast Marsh Vole (Microtus californicus stephensi) at Ballona Wetlands is closely associated with Satlgrass (Distichlis spicata) as well as the high marsh (Friesen et al. 1981). In a study of diet of White-tailed Kites in grassland habitat in California, Microtus spp. was found in 80% of pellets and Mus musculus in 20% (StendellI972).

Evaluation of the impacts on White-tailed Kite depends on the abundance of its rodent prey in the post-restoration landscape. The analysis should compare the current areas of ruderal grassland, high marsh, brackish marsh, and saltgrass habitats and their Mus and Microtus densities with their areas and rodent densities after the project. To conserve and enhance White-tailed Kite on the project site (as required for a Fully Protected Species), it would be necessary to include more high marsh and transitional habitats compared with middle and low marsh, tidal channels, and open water to make up for the predictable reduction in Mus density with restoration of annual grassland to a native vegetation type (Wolf et al. 2017).

The Draft EISIEIR does not provide an analysis with fmal vegetation and habitat maps showing the needs of all of the foraging and resident raptor species would be met and increased after the proposed project.

The analysis in the Draft EISIEIR does not incorporate the dramatic increase in disturbance that would result from the recreational trail network. This is evident for Northern Harrier, a sensitive species. This species needs open habitats, making use of freshwater or brackish marshes, wet meadows or pastures, and grasslands. It is considered rare and declining locally (Gallagher 1997), and the species is extremely rare in southern California (Price et al. 1995). It is at risk of being extirpated completely from cismontane southern California because it requires “large areas of undisturbed open space” (Gallagher 1997). Females defend habitats of 9.6-308.6 acres (mean 83.0 acres) in California (Temeles 1987, 1989). The total area used as foraging territory is larger (Dechant et al. 1998). The species preys on a variety of small mammals and birds (Selleck and Glading 1943). The analysis of impacts on this species does not consider the effects of construction of multi-modal trails that fragment the open spaces, nor the effects of adding the topographic variation of levees and dredge spoils piles on a species that needs large, undisturbed open space habitats.

Finally, the Draft EIS/EIR describes a project that only includes habitat enhancement for birds if it is required as mitigation, rather than because it is the right thing to do to promote sensitive bird species at the project site. For example, an excellent design feature for the project would be a nesting platform for Osprey, which is probably all that is needed for the species to become resident (Allen et al. 2016). The Draft EISIEIR only treats this possibility from an impact mitigation perspective, stating, “The inclusion of one or more osprey nesting platforms in the Project under Alternative 1, 2, or 3, therefore, is both possible and recommended although no potential significant adverse impact has been identified in Section 3.4, Biological Resources, that would support a requirement that they be included” (p. 2-241). If it is possible and recommended, what is stopping the designers of the restoration from including it?

4. 7.6 Additional Special-Status Upland Bird Species

The Draft EIS/EIR analysis of impacts to the remainder of upland species other than raptors is lumped into one section. As background to this analysis, the proposed project would reduce upland habitats from 271.9 acres to 195.8 acres (a loss of 76 acres that is acknowledged), further reduce them by approximately 12 acres of trails, and constrain them by the conversion of uplands to over 36 acres oflevees with specific limits on vegetation (e.g., grasses only, no rodents, and clearance for fire safety). Nevertheless, the Draft EISIEIR presents one mitigation measure for all special-status upland bird species, without regard to the habitat requirements of each:

Although a portion of suitable upland foraging habitat would be converted to tidal marsh, the marsh also would provide suitable foraging habitat for these species, and thus no net loss of foraging habitat is expected. Enhancement of existing non-native habitats within the site also is likely to expand foraging and potentially nesting habitat for these species resulting in a potential net beneficial effect (p. 3.4-112).

Evidence is not provided to support the conclusion that all of the upland bird species of concern could: a) also forage in salt marsh, and b) have more habitat post-restoration if not salt-marsh foragers. Because final vegetation types for restoration have not been established, at best the conclusion that all upland species will benefit is premature. At worst, it is woefully misguided and will result in the extirpation of certain species and result in contraction of the range of grassland species in the Los Angeles basin

To illustrate this problem, we compiled the foraging habitat requirements of all of the upland special-status bird species (Table 3). For some species, more riparian forest would be needed to have a beneficial impact, while for others more scrubland. For other species, additional shrub cover would be deleterious.

Table 3. Foraging habitat requirements of special-status “upland” species according to Birds of North America (Cornell Lab of Ornithology! American Ornithological Society).

Species                                       Habitat

Belted Kingfisher                        Open water

Black-headed Grosbeak            Large trees with well-developed understory

Blue Grosbeak                          More medium than small trees and low shrub density

California Towhee                     Array of shrubby habitats

Gray Flycatcher                       Riparian habitats

Hermit Thrush                         Trees with shrubs and undergrowth

Hermit Warbler                        Riparian and oak woodland, suburban park

Lincoln’s Sparrow                   Shrub-dominated habitats, particularly riparian

Loggerhead Shrike                 Open country with short vegetation

MacGillivray’s Warbler            Dense shrubs or well-shaded habitats

Nashville Warbler                    Drier habitats along forest edges

Olive-sided Flycatcher             Riparian forest

Purple Martin                           Aerial habitats, often near beaches during migration

Red-breasted Nuthatch           Winters in wide range of forest habitats

Ruby-crowned Kinglet             Winters in wide range of forests and shrub lands

Swainson’s Thrush                  Willow thickets

Tree Swallow                           Freshwater marsh

Tricolored Blackbird                Cattail and bulrush marshes near open foraging habitat

Vaux’s Swift                             Aerial forager

Vesper Sparrow                      Scrub, areas with sparse vegetation

Virginia’s Warbler                    Riparian corridors

Western Meadowlark              Grasslands with good litter cover, little shrub cover

Western Wood-Pewee            Forest edge and riparian zones

Wilson’s Warbler                     Riparian shrub understory

Yellow Warbler                        Scrub/shrub, often near wetlands

Yellow-breasted Chat              Riparian and shrubby habitats

Yellow-headed Blackbird         Forages in open fields, roosts in emergent wetland vegetation

It is highly unlikely that with less upland habitat, additional and extensive human disturbance from a trail system that fragments the remaining habitat blocks, and an unnatural topography created by hills of dredge spoils and levees, that all of the upland species will have additional habitat after project creation.

The project has a significant probability of extirpating Loggerhead Shrike. This sensitive species is already nearly extirpated from the coastal slope of Los Angeles County. The habitat for this predaceous songbird is grassland and open scrub habitats. Surveys in 2003 for breeding Loggerhead Shrikes recorded fewer than six pairs within the Los Angeles basin (Kimball Garrett, Los Angeles County Museum of Natural History, pers. comm.), and the species had disappeared by the early 2000s from regularly surveyed sites such as Holy Cross Cemetery, Madrofia Marsh, and other Los Angeles locations (Professor Hartmut Walter, UCLA Department of Geography, pers. comm.). Territory size for Loggerhead Shrikes is 10.9-39.5 acres (Miller 1931). Despite use of scrub habitats, the species is typically found in a “scraggly open field” (Gallagher 1997), which is precisely the type of habitat that will not be protected once the project is built. Loss of

Loggerhead Shrike as a breeding species would represent a significant adverse impact and the current plan does not provide reassurance that the specific needs of the species will be addressed in the restoration design when it is finally completed.

4. 7. 7 Special-Status Shorebirds

Similar to the analysis of upland special-status bird species, the Draft EIS/EIR treats all shorebird species as if they have the same habitat requirements, which they do not (Table 4).

The argument that the specific conditions needed for each of these species will be increased is easier to make for shorebirds than for upland birds, but it is not a given, nor has the Draft EISIEIR provided the assessments and calculations necessary to evaluate the proposed project and alternatives.

Table 4. Foraging or nesting habitat requirements of special-status shorebird species according to Birds of North America (Cornell Lab of Ornithology/American Ornithological Society).


American Pipit

Black Skimmer

Black-bellied Plover

Bonaparte’s Gull


California Brown Pelican

California Gull

California Least Tern

Caspian Tern

Common Loon

Eared Grebe

Elegant Tern

Long-Billed Curlew

Red Knot



Coastal beaches and marshes

Open water

Coastal beaches and estuaries

Wetlands, bays, estuaries

Shallow marine waters, eelgrass

Coastal marine and estuarine habitat

Open habitats for foraging

Open sand or salt flat for breeding, shallow water for foraging

Shallow-water habitat

Coastal waters

Open water, including coastal lagoons

Inshore coastal waters

Estuary, salt marsh, sandy beach

Sandy beach, salt pan, mud flats

Shallow, low-energy, coastal habitats with grasses

Royal Tern

Spotted Sandpiper

Western Snowy Plover

White-faced Ibis

Wilson’s Phalarope

Inshore coastal open water for foraging

Coastal, forages in open habitat

Beach and dunes, historically nested on salt pan at Ballona

Nests in freshwater marsh and historically nested at Ballona (Grinnell 1898); forages in shallow, flooded wetlands

Open, shallow-water habitats

4.7.8 Special-Status Marsh Birds

The analysis of impacts on special-status marsh birds states that all marsh bird species will benefit from an increase of 38.6 acres of habitat. This cannot be possible because each of the species listed has different habitat requirements (Table 5). For those species needing brackish marsh, the increase in area would be at most 6 acres. The Draft EIS/EIR should include a species-by-species analysis, which would reveal that these sensitive species would benefit by more brackish marsh in general, rather than the focus on the mid-marsh, low marsh, open water, and subtidal habitats of the proposed project. Furthermore, brackish and freshwater marsh conditions are created by designing wetlands that have freshwater inputs, an approach that the project designers have eschewed.

Table 5. Foraging or nesting habitat requirements of special-status shorebird species according to Birds of North America (Cornell Lab of Ornithology! American Ornithological Society).


Light-footed Ridgway’s Rail

American Bittern

Clark’s Marsh Wren

Common Gallinule

Least Bittern


Virginia Rail


Salt and brackish marshes near the coast (Willett 1912)

Breeding in freshwater wetlands with tall emergent

vegetation; wintering sometimes in brackish coastal marshes

Winters in salt marsh

Well-vegetated ponds and marshes, forages throughout lower Ballona

Breeds in brackish marshes

Freshwater, brackish, and salt marshes

Typha and bulrush in freshwater and brackish marshes for breeding

4.8 Special-Status Mammals

The analysis in the Draft EISIEIR to support a conclusion that the project will have no impacts to special-status mammals lacks necessary information. Maps of habitat for each of the two species pre- and post-restoration are not provided. The association of South Coast Marsh Vole with Distichlis spicata as a food source (Coulombe 1970, Friesen et al. 1981) is not considered or evaluated. The assumptions about current distributions need to be updated with an appropriate trapping method for Southern California Salt Marsh Shrew (Sorex ornatus salicornicus) (see details in Friesen et al. 1981).

The Draft EIS/EIR puts forth the notion that impacts from the project will be minimized by incorporating a plan to “salvage native wildlife species … ” (p. 3.4-88). Presumably this applies to small mammals and reptiles; it certainly cannot apply to invertebrates. Relocating native wildlife is, however, at best a controversial mitigation measure and often such relocations are incorporated more to facilitate development than to benefit the species. As summarized by Villasenor et al. (2013), “Wildlife rescues seem to be performed for conservation purposes but are really aimed at solving conflicts between development projects and wildlife.” Simply “moving” the wildlife out of the path of immediate harm is not a mitigation measure because any suitable destination site would very likely already be occupied. Translocation can also move diseases and disrupt genetic structure (Villasenor et al. 2013). Relocation should only be undertaken as a last resort and then must be properly planned.

Relocation is difficult and can be counterproductive because wildlife is often already at carrying capacity in nearby areas and introducing new individuals can cause adverse interactions within species. For example, male California Meadow Voles maintain territories and are aggressive to interlopers, which is especially true during breeding (Ostfeld 1985a, Ostfeld 1985b). Female voles are aggressive toward unfamiliar females (Ostfeld 1986). This makes relocation a wholly inappropriate mitigation measure for this group of animals. Any recipient site for relocated individuals would have to be unoccupied by the species to avoid intraspecific interactions, and the density of the relocated individuals could not exceed the carrying capacity of the habitat. In addition, translocated small animals have low site fidelity and suffer high mortality after relocation as they try to return to their native habitats (Villasenor et al. 2013).

Since the project proponents have been unable to locate the population of Southern California Salt Marsh Shrew, it is not at all likely that they would be able to relocate them in advance of construction.

4.9 Night Lighting

As can be seen from a view of the project area from space at night (Figure 16), very little outdoor lighting currently exists, with the exception of roadway lighting on Culver Boulevard through Area C, a roadway light at the intersection of Culver Boulevard and Jefferson Boulevard, and at the Southern California Gas Company facility. The Draft EISIEIR should recognize the relative darkness as an intrinsically valuable feature of the project site and include measures to reduce illumination sources associated with the project.

The mitigation measure for lighting (AE-4b; Lighting Plan) is insufficient to protect natural resources. The measure does not appear in the wildlife section and the language about lights being “directed downward and focused away from adjacent sensitive uses and habitats” does not address quantitative performance measures and cannot be adapted to all of the different lighting scenarios. For example, lighting is proposed for a multi-story garage (which appears to serve nearby commercial uses instead of the reserve) and on bridges. Light that is “directed downward” from such infrastructure could be shining into habitat (Longcore and Rich 2004).

The inclusion of extensive recreational trails within the ecological reserve raises the issue of adverse impacts from lights on bicycles and nighttime access by pedestrians (Longcore and Rich 2017). Even the short burst of light from bicycles can interfere with vision of wildlife species (Baker and Richardson 2006). Political pressure to light bike paths can be high and the Draft EISIEIR should establish that no night lighting of any sort will ever be allowed on the property.

Figure 16. Nighttime image of project vicinity from International Space Station in 2010 (NASA image 23 UT ISS026-E-6229). Note the only lighting visible is the intersection of Culver Boulevard and Jefferson Boulevard, Culver Boulevard through Area C, and the Southern California Gas Company facility.

4.10 Noise

The monitoring locations and analysis approach for noise impacts only applies to people. This may be appropriate for the Noise section of a CEQA analysis, but the noise analysis is useless for purposes of analyzing the impacts to wildlife in the pre- and post-project conditions or during construction.

The noise analysis does not employ the generally accepted techniques needed to describe the impacts of noise on wildlife and other sensitive receptors. The Draft EISIEIR analysis does not provide accurate estimates of cumulative noise levels resulting from the many noise-generating aspects of project construction and use (e.g., maintenance, recreation), and/or changes in noise distribution resulting from changes to the topography. Current technology allows for production of maps to show sound level contours throughout a project site and to compare pre- and postdevelopment sound levels. This analysis can be completed by a professional sound engineer employing commercially available, widely used sound level prediction software that takes into account site topography, building shape and size, and location of noise sources (including construction equipment, bells, playgrounds, roads, loading docks, etc.). Several software packages are available, including NoiseMap, CadnaA, Predictor-LimA, and SoundPLAN, all of which incorporate three-dimensional georeferenced site plans with automated sound propagation calculations to produce maps of sound levels.

5 About the Authors

Dr. Travis Longcore and Catherine Rich are principals of Land Protection Partners. Dr. Longcore is Assistant Professor of Architecture, Spatial Sciences, and Biological Sciences at the University of Southern California. At USC, and previously at UCLA, he has taught, among other courses, Bioresource Management, Environmental Impact Analysis, Field Ecology, and Ecological Factors in Design. He was graduated summa cum laude from the University of Delaware with an Honors B.A. in Geography, holds an M.A. and a Ph.D. in Geography from UCLA, and is professionally certified as a Senior Ecologist by the Ecological Society of America.

Catherine Rich is Executive Officer of The Urban Wildlands Group. She holds an A.B. with honors from the University of California, Berkeley, a ID. from the UCLA School of Law, and an M.A. in Geography from UCLA. She is lead editor of Ecological Consequences of Artificial Night Lighting (Island Press, 2006) with Dr. Longcore. Longcore and Rich have authored or co-authored over 35 scientific papers in top peer-reviewed journals such as Auk, Avian Conservation and Ecology, Biological Conservation, Conservation Biology, Environmental Management, Trends in Evolution and Ecology, and Frontiers in Ecology and the Environment.

Longcore and Rich have provided scientific review of environmental compliance documents and analysis of complex environmental issues for local, regional, and national clients for 19 years.

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