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CC SR 20170404 N - Palos Verdes Reef Restoration ProjectRANCHO PALOS VERDES CITY COUNCIL AGENDA REPORT AGENDA DESCRIPTION: MEETING DATE: 04/04/2017 AGENDA HEADING: Consent Calendar Consideration and possible action regarding the proposed Palos Verdes Reef Restoration Project RECOMMENDED COUNCIL ACTION: (1) Authorize the Mayor to sign a letter to the California State Lands Commission expressing the City Council's opposition to the granting of an off -shore lease for the proposed Palos Verdes Reef Restoration Project. FISCAL IMPACT: None Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: Kit Fox, AICP, Senior Administrative Analyst,;;; Ara Mihranian, AICP, Director of Community Development, REVIEWED BY: Gabriella Yap, Deputy City Manager. - APPROVED BY: Doug Willmore, City Manager' ATTACHED SUPPORTING DOCUMENTS: A. Draft letter to the California State Lands Commission (page A-1) B. November 2011 City Council Staff report (page B-1) C. March 18th Daily Breeze article (page C-1) D. Public comments copied to City Council via email (page D-1) E. City Council Policy No. 29 (page E-1) BACKGROUND AND DISCUSSION: From the late 1940s until the early 1970s, Los Angeles -area industries (most notably Montrose Chemicals in Torrance) discharged tons of DDTs and PCBs into the ocean waters off the Palos Verdes Peninsula. In October 2000, the Federal and State governments and the remaining defendants settled the so-called Montrose case. The Trustees for the Montrose Settlements Restoration Program (MSRP) received tens of millions of dollars to reimburse past damage assessment costs and to implement the actions necessary to restore the natural resources and their services that were injured by the DDTs and PCBs. Additional information about the MSRP is available on-line at httD://www.montroserestoration.noaa.00v/. 1 Since this project would be constructed within waters of the State of California, the City has no jurisdiction over its permitting or construction; rather, such jurisdiction resides with the California State Lands Commission (CSLC). However, the City has been aware of and monitoring this project for several years. The City offered comments on the draft Environmental Impact Report (EIR) that included this project in 2005. Also in 2005, the California Coastal Commission considered and found this project to be consistent with the Coastal Act. In November 2011, a public meeting was held at the Point Vicente Interpretive Center (PVIC) to present the MSRP Trustees' proposal for the second and final phase of MSRP restoration efforts. The Phase 2 Restoration Plan (P2RP) included two (2) fish habitat restoration projects with the potential for direct effects upon segments of the City's coastline: Kelp Forest Restoration and Subtidal Reef Restoration. The Kelp Forest Restoration project commenced in late 2012, and has been very successful in restoring kelp forests along the Peninsula coastline between the Palos Verdes Estates city limit and Abalone Cove. Staff prepared a letter in support of the P2RP projects for the City Council's review and approval in November 2011 (Attachment B). The MSRP Trustees are now ready to proceed with the Subtidal Reef Restoration project, which involves restoring subtidal rocky reefs along the southerly shoreline of the Peninsula that have been degraded by sedimentation. On February 21, 2017, Staff was notified that the MSRP Trustees would be holding another public meeting at PVIC on Thursday, March 2, 2017, to present the Palos Verdes Reef Restoration Project for public review and comment. In order to share information about this project with the community, Staff posted information about this meeting on the City's Facebook and Nextdoor pages on February 21, 2017. A large number of residents attended the public meeting at PVIC, and many subsequently expressed disappointment and frustration that the format of the meeting did not provide them the information that they needed to understand the proposed project. As currently envisioned, the project would involve the placement of 70,300 tons of quarry rock from Santa Catalina Island on 40 acres of sandy ocean bottom within a 69 - acre site located 0.3 miles offshore of Trump National Golf Course. Construction of the underwater reef would be accomplished using equipment and materials brought to the site on barges. The project is expected to take 40-60 working days to complete. The Environmental Assessment for this project may be reviewed on the CSLC website at http://slc.ca.gov/Info/Reports/PalosVerdes/Enviro Assess.pdf. Public comments on the Environmental Assessment were due by March 22, 2017, and it is Staff's understanding that the CSLC will be considering the Environmental Assessment and related lease for this project at its upcoming meeting on April 20, 2017, in Berkeley. On March 18, 2017, the Daily Breeze published an article (Attachment C) describing objections to the project by environmental groups and residents. The City Council has also been copied on several recent emails objecting to the project (Attachment D), including comments from Trump National Golf Club and residents in the nearby Seaview and Ladera Linda neighborhoods. 2 As discussed above, the City Council has previously expressed support for the P2RP projects, at least in concept. However, it is clear that many City residents and property owners are currently opposed to this current project, at least in part because the MSRP Trustees and/or CSLC have not adequately addressed their questions and concerns about it. Furthermore, it appears that the effectiveness and long-term viability of this project is questionable, given its close proximity to the toe of the Portuguese Bend Landslide. Among the stated purposes of this project is to restore reef habitat that has been buried by silt and sediment, but erosion at the toe of the landslide will continue to deposit silt and sediment in the proposed project area. Pursuant to City Council Policy No. 29 (Attachment E), a majority of the City Council must approve any formal City position taken with respect to proposed legislation or projects, whereas individual City Council members are free to express their personal opinions about such legislation or projects as individual private citizens. Although the public comment deadline for the Environmental Assessment for this project was March 22, 2017, there is still time for the City Council to express its concerns about the project to CSLC prior to its April 2017 meeting. Therefore, Staff has prepared a draft letter to CSLC for the Mayor's signature (Attachment A). ALTERNATIVES: In addition to the Staff recommendation, the following alternative action is available for the City Council's consideration: Do not take a formal City position regarding the Palos Verdes Reef Restoration Project. 9 April 4, 2017 Betty T. Yee, Chair California State Lands Commission 100 Howe Ave., Ste. 100 South Sacramento, CA 95825 SUBJECT: Objection to Granting Lease for Palos Verdes Reef Restoration Project Dear Chair Yee and Members of the State Lands Commission: On behalf of the Rancho Palos Verdes City Council and presidents, I wish to respectfully express our opposition to the granting of a lease for the Palos Verdes Reef Restoration Project, which we understand will be appearing on the Commission's agenda on April 20, 2017. Our City Council had expected to express our objections in comments on the related Negative Declaration for the project, but were unable to do so timely due to the unexpected cancelation of our March 21, 2017, meeting. The City of Rancho Palos Verdes is supportive of the goal of the project to restore recreational and commercial fishing resources that were destroyed by the dumping of DDTs and PCBs in the waters off the Palos Verdes Peninsula in the 1940s through 1970s. In 2011, our City Council expressed conceptual support for such a project. However, we do not support the project at its proposed location just over a quarter -mile offshore from the City's Founders Park and Rancho Palos Verdes Beach. The location of the proposed reef is only a short distance downcoast from the toe of the active Portuguese Bend Landslide. It is primarily the silt and sediment from this landslide that has covered the reef that this project seeks to restore. However, the proposed project will do nothing to stop or redirect this downcoast flow of silt and sediment, which will likely result in any restored reef being quickly covered before any self-sustaining fishing habitat can be re-established. Furthermore, we question the wisdom of re-establishing fishing habitat in such close proximity to the DDT- and PCB - laden sediments that lie not much further off our City's coastline. We urge the Commission to reject the proposed lease agreement, and to direct the applicant to work with environmental advocacy groups and affected local communities to develop a more effective and acceptable project. Sincerely yours, Brian Campbell Mayor A-1 CITYOF MEMORANDUM RANCHO PALOS VERDES TO: HONORABLE MAYOR & CITY COUNCIL MEMBERS FROM: CAROLYNN PETRO, DEPUTY CITY MANAGEI t DATE: NOVEMBER 1, 2011 SUBJECT: MONTROSE SETTLEMENTS RESTORATION PROGRAM: KELP FOREST AND SUBTIDAL REEF RESTORATION REVIEWED: CAROLYN LEHR, CITY MANAGER Staff Coordinator: Matt Waters, Senior Administrative Analyst RECOMMENDATION Authorize the Mayor to sign the attached draft letter of support for the Montrose Settlements Restoration Program's Restoration Plan to restore lost fishing opportunities in and around the Palos Verdes Shelf through kelp forest and subtidal reef restoration. BACKGROUND Local industries discharged approximately 2,000 metric tons of DDTs and PCBs into the ocean off the Palos Verdes Peninsula from the late 1940s until the early 1970s. Almost all of the DDTs came from the Montrose Chemical Corporation manufacturing plant in Torrance, reaching the ocean via the Los Angeles County Sanitation District's (LACSD) White Point sewer outfall. Wastewater treatment methods employed during those years did not contain or capture the DDTs prior to discharge into the ocean. Montrose Chemical Corporation also dumped DDT -contaminated waste from barges into deep ocean waters between the Peninsula and Santa Catalina Island. Large quantities of PCBs from numerous sources throughout the Los Angeles Basin were released into the ocean via the LACSD and City of Los Angeles wastewaters outfalls and the regional storm drain systems during this period. The Santa Monica Bay Restoration Foundation (SMBRF) states that these chemicals entered the ocean's food system, leading to breeding failures in bald eagles, peregrine falcons, and other seabirds. Chemical levels in some fish have been detected at such high levels that the State of California has issued warnings and restrictions to reduce the risk of cancer, liver disease and birth defects. In March 2001, after over ten years of litigation, the Courts approved a final settlement M MSRP: Kelp Forest and Subtidal Reef Restoration Projects November 1, 2011 Page 2 between the Federal and State governments and the remaining defendants in the Montrose case. Montrose and other defendants agreed to pay $140.2 million plus interest to the Federal and State governments. The trustees for the Montrose Settlements Restoration Program (MSRP) received $63.95 million. $35 million of the MSRP funds have gone to reimburse past damage assessment costs. The remainder of the funds, plus accumulated interest, is being used to restore the natural resources damaged by the discharge of DDTs and PCBs. MSRP Phase I Restoration efforts began in 2005. Phase I Projects include: • Restore nesting habitats for seabirds on the Channel Islands • Retore bald eagles to the Channel Islands • Monitor Peregrine Falcons on the Channel Islands • Restore recreational fishing in Southern California • Restore 140 acres of wetland habitat to full tidal exchange Phase I Restoration projects are in various stages of implementation. DISCUSSION MSRP trustees now propose the second and final phase of MSRP restoration efforts. The Phase 2 Restoration Plan (P2RP) contains two fish habitat restoration projects which could have a direct effect upon sections of the City's coastline: Kelp Forest Restoration and Subtidal Reef Restoration. Kelp Forest Restoration The extensive kelp forests along the Palos Verdes Peninsula shoreline have been degraded, largely because of the urchin barrens that have formed in these areas. Urchin barrens are the result of uncontrolled urchin populations caused by the loss of natural predators. The expanded urchin population overran rocky tidal areas and prevented kelp plants from anchoring to the sea floor. The P2RP has identified seven potential restoration sites, six of which are located in the waters off of Rancho Palos Verdes. The affected coastline sites extend from the City's boundary with Palos Verdes Estates to Abalone Cove. One goal of the plan is to replace fishing opportunities lost because of chemical contamination. Fish that live in kelp forests have lower levels of DDT and PCB contamination in their tissue than in that of fish living on soft -bottom habitats. By restoring kelp habitat, the MSRP will increase the number of fish known to be lower in DDT and PCBs. One of the goals of the MSRP's restoration efforts is to restore lost or diminished fishing opportunities. However, new regulations associated with the Marine Life Protection Act are scheduled to go into effect on January 1, 2012 that will restrict or halt fishing in sections of Southern California's coastal waters including areas off the Palos Verdes Peninsula. These Fish and Game Commission regulations will ban fishing off of Point MSRP: Kelp Forest and Subtidal Reef Restoration Projects November 1, 2011 Page 3 Vicente, including the recently re -named Pelican Cove (formerly Point Vicente Fishing Access) and will limit what fish can be taken from the waters adjacent to Abalone Cove Shoreline Park. Activities such as recreational diving will be enhanced by the eventual restoration of kelp forests and reefs. The P2RP proposal calls for the SMBRF to partner with urchin divers and local non- profit organizations to perform urchin barren control which would allow for natural kelp forest re -growth. The SMBRF estimates that 133 acres of Peninsula -adjacent kelp beds are still in need of restoration. Divers would access the affected coastline areas by boat to remove sea urchins in phases over a three-year period. The proposed budget for Kelp Forest Restoration is $2.5 million. Subtidal Reef Restoration Subtidal rocky reefs along the southern shoreline of the Palos Verdes Peninsula have been degraded by sediment from the active Portuguese Bend Landslide and by the 1999 landslide at Trump National Golf club which covered near -shore reefs. The P2RP identifies eighty acres of degraded reefs at three potential restoration sites, two of which are located wholly or partially adjacent to Rancho Palos Verdes; a 56 -acre area off Rancho Palos Verdes Beach below Trump National Golf Club; and a 12 -acre area off Shoreline Park at the boundary with the City of Los Angeles. The P2RP proposes to build artificial reefs in those areas. According to the P2RP, the construction of artificial reefs in those areas could "impact various human uses," including recreation and navigation. The proposed budget for subtidal reef restoration is $6.49 million and will take an estimated seven years to complete. Other P2RP projects include reduction of seabird disturbances on the Channel Islands, restoration of seabirds to Santa Barbara Island and Scorpion Rock, and the restoration of Ashy Storm -Petrels on the Channel Islands. On Wednesday, November 9, 2011, the MSRP Trustees will hold a public meeting on the P2RP at the Point Vicente Interpretive Center from 6-8pm entitled "Restoring Natural Resources Harmed by DDT and PCBs within the Southern California Marine Environment." A previous public meeting was held on October 26, 2011 in Ventura. The forty-five day public comment period for the P2RP will end on December 12, 2011. Staff intends to attend the November 9 meeting. Attached is a draft letter from the City of Rancho Palos Verdes, under the Mayor's signature, offering support for the MSRP Phase 2 kelp forest and sub -tidal restoration projects. FISCAL IMPACT Approval and submittal of the attached letter of support will have no discernible negative fiscal impact. M MSRP: Kelp Forest and Subtidal Reef Restoration Projects November 1, 2011 Page 4 ATTACHMENT: Draft Letter of Support for MSRP Kelp Forest and Subtidal Reef Restoration Projects MSRP PVIC Public Meeting Flyer MSRP Phase 1 Restoration Highlights and Phase 2 Proposed Projects SMBRF Phase 2 Restoration Plan Information Sheet November 1, 2011 Montrose Settlements Restoration Program 501 W. Ocean Boulevard. Suite 4470 Long Beach, CA 90802 Attention: Jennifer Boyce, Program Manager Dear Montrose Settlements Restoration Program Trustees: On behalf of the City Council of the City of Rancho Palos Verdes, I am pleased to offer our support for the Montrose Settlements Restoration Program's (MSRP) proposed Phase II Kelp Forest and Subtidal restoration projects. The damage done to kelp forests and a wide range of bird and fish species by the release of DDTs and PCBs into the ocean waters off of the Palos Verdes coastline, combined with damage to subtidal reefs by landslides has had a profound and devastating effect.. Kelp forests are one of the most diverse and productive ecosystems on the planet. Giant kelp forests in southern California support more than 716 species of marine life. Sadly, there are far fewer kelp beds around Los Angeles than there were 100 years ago. Improvements at wastewater treatment facilities have allowed some kelp beds to recover, but many other beds around the Palos Verdes Peninsula have not. Thoughtful, controlled thinning of the over- abundance of purple sea urchins from these bare rocky areas would allow the kelp beds to recover. Additionally, the artificial reef restoration project has the potential to help recover over 65 acres of degraded reefs. Please accept this letter as formal recognition of the City of Rancho Palos Verdes' support for the MSRP's Subtidal Reef and Kelp Forest Restoration Projects. Sincerely, Tom Long Mayor cc: City Council Members City Manager IN MONTROSE SETTLEMENTS RESTORATION PROGRAM PRESENTS "Restoring Natural Resources Harmed by DDT and PCBs within the Southern California Marine Environment" Join Us For Our Public Meeting Wednesday, November 9, 2011 at the Point Vicente Interpretive Center 31501 Palos Verdes Drive West Rancho Palos Verdes, CA 90275 (310) 377-5370 YOU WILL LEARN ABOUT: • Restoration completed during Phase 1 involving: Bald Eagles, Peregrine Falcons, Seabirds, Fishing, and Fish Habitat • Proposed Restoration Projects within the Phase 2 Restoration Plan • How to submit a comment on the Phase 2 Plan • How to stay connected with MSRP in the future • The latest news from the Fish Contamination Education Collaborative www.montroserestoration.gov Cassius Auklet chick during banding. (Laurie Harvey, NPS) Xantus's Murrelet chicks in nest. (DarreiWhitworth, CIES) MSRP Phase 7 restoration projects are in various stages of implementation. The following are highlights for each project that was proposed in the Phase 1 Restoration Plan. Restore Nesting Habitat for Seabirds on the Channel Islands MSRP is restoring nesting seabird habitat on the Channel Islands, specifically on Scorpion and Orizaba Rocks, Santa Barbara, Santa Cruz, and San Nicolas Islands. Seabird restoration projects include non-native plant and animal removal, revegetation of native plants, and social attraction. Since 2007, MSRP planted 20,000+ native plants with help from volunteers, installed 50+ artificial nests, removed feral cats from San Nicolas Island, and completed several years of seabird and oceanographic monitoring surveys among the islands. in 2011, biologists discovered nine Cassin's Auklets seabirds nesting in newly restored habitat on Santa Barbara Island. Seabird nesting habitat restoration work will begin on several Baja California Pacific Islands in 2012. Restore Bald Eagles to the Channel Islands MSRP implemented a feasibility study to determine whether the northern Channel Islands could support a self-sustaining population of Bald Eagles. Institute for Wildlife Studies biologists successfully released 51 eagles on Santa Cruz Island and initiated a comprehensive monitoring program.The first natural hatching of a Bald Eagle in 2006 on Santa Cruz island was a milestone for the study. Since the first natural hatchling, biologists have continued to observe a high nesting success rate among the Channel Island Bald Eagles with breeding occurring on four of eight Channel Islands. Approximately 65 eagles live among the Channel Islands and new pairs are expected to establish breeding territories across the Channel islands. M Restore Recreational Fishing In Southern California MSRP is restoring recreational fishing by providing information to the public about fish contamination and by improving access to a diversity of healthy fish species. MSRP, along with partners, created several popular outreach products including a "Common Subsistence and Sport Fish of Southern California" identification card with safe fishing tips and the "What's the Catch?" comic book, both in three different languages, which are distributed to the public every year. Outreach mini -grants awarded to youth fishing organizations by MSRP are spreading the word about safe fishing and how to avoid "Do Not Consume"fish species. In 2012, MSRP hopes to build artificial reef modules along the Belmont Pier in Long Beach, California, that will attract a greater diversity of fish species that are available for consumption. Restore Fish Habitat In Southern California MSRP focused on two major areas of fish habitat restoration for Phase 1 restoration, wetlands and Marine Protected Areas (MPA). Partial funding for Huntington Beach Wetlands was used to restore Talbert and Brookhurst Marshes in this complex and opened up approximately 140 acres of wetland habitat to full -tidal flow. MSRP funding for Bolsa Chica Wetlands allowed dredging of the ocean inlet maintaining full tidal exchange. MPA funding went to the National Park Service and to the Partnership for Interdisciplinary Studies of Coastal Oceans to collect data on the effective management of these areas. Monitor Peregrine Falcons on the Channel Islands In 2007, a comprehensive Peregrine Falcon monitoring effort across all eight of the Channel Islands was cc m )I: *ec . Uc Ir gi-ts found 25 active territories and 15 pairs successfully hatched eggs that produced 35 young. One of the highlights of the 2007 survey was the documentation of a successful breeding pair on Santa Barbara Island. This event was the first documented breeding on the island in over 50 yearsl MSRP is planning to conduct a second monitoring survey in 2013. Aerial view of Huntington Beach Wetlands restoration. (Earthcam,NOAA) Peregrine falcon chicks in nest after banding. (Orion Latta, SCPBRG) Divers working in kelp fore (David Witting, NOS Young girl during youth fishing derl (Gabrielle Dorr, N01 Ashy Storm -Petrel using marine debris for nest. (Darrell Whitworth, CIES) Diver collecting urchins during removal project. (David Witting, NOAH) MSRP projects proposed in the Phase 2 Restoration Plan are described below. Restore Subtidal Reef and Kelp Forest Habitat on the Palos Verdes Shelf MSRP proposes to restore critical fish habitat on the Palos Verdes Shelf. Kelp forests and rocky reefs are known to produce more fish than other habitat types and fish that have lower levels of DDT and PCB concentrations in their tissues. MSRP is propsing to build artificial reef modules in areas that have been impacted by sediment erosion along the coast. Kelp forests in this area have been impacted by the loss of urchin predators which resulted in an increase in urchins essentially wiping out kelp forests. For this project MSRP would partner with commercial urchin divers and local non-profit organizations to perform urchin barren control allowing for natural kelp recruitment and growth. Monitor Said Eagles on the Channel Islands MSRP proposes to monitor Bald Eagles on the Channel Islands to determine if a self- sustaining population is feasible. The proposed monitoring program would continue to focus on breeding activities, investigation of diet, survival and contaminant analysis. The program would shift from extensive year- round monitoring to a more directed focus of understanding the eagle's annual population status. Monitor the Recovery of Peregrine Falcons on the Channel Islands MSRP proposes to conduct two additional comprehensive monitoring efforts on the Channel Islands during Phase 2. Biologists would monitor active Peregrine Falcon territories to determine their reproductive success and levels of DDT and PCBs will be measured from egg and blood samples. Restore Seabirds to Santa Barbara Island and Scorpion Rock MSRP proposes to continue and expand the restoration work on Santa Barbara island and Scorpion Rock. On Santa Barbara Island, biologists would expand existing restoration sites and add new sites. If this project moved forward, MSRP would continue removal of non-native vegetation and planting of native plants on Scorpion Rock until native plants can fully establish and outcompete non-native plants. Biologists would also install nest boxes and social attraction devices on Santa Barbara Island and continue monitoring of seabirds at both areas. Restore Ashy Storm -Petrels on the Channel Islands MSRP identified projects on Anacapa and Santa Cruz islands in Phase 1 but was unable to complete this work. if this project moved forward, biologists would continue to work on these projects in Phase 2 but also may expand to include restoration projects throughout the Channel Islands as appropriate. MSRP proposes to improve nesting habitat, Install social attraction devices, install artificial nesting boxes, perform annual monitoring at nest sites, and perform contaminant analysis. Reduce Seabird Disturbance on the Channel Islands This proposed project will build upon on-going seabird disturbance reduction efforts that have been developed by other groups. Primarily this project would focus on developing and enforcing appropriate seabird colony protective measures, educating the public and specific user groups about protective measures, and evaluating program effectiveness for integration into statewide seabird management programs. S MSRP PHASE II RESTORATION PLAN Meeting Dates October 26 (Ventura) and November 9, 2011 (Rancho Palos Verdes) Email Scott Valor (svalorgsantamonicaba_y.org) for details The federal government will soon be accepting comments on the Montrose Settlements Restoration Program (MSRP) plan to restore lost fishing opportunity in and around the Palos Verdes Shelf. The plan includes $2.4 million for the Santa Monica Bay Restoration Foundation (SMBRF) to restore 60 acres of rocky subtidal habitat. As a member of the SMBRC Governing Board, we hope you will write a letter supporting the SMBRF project as part of the overall MSRP restoration plan. What is the MSRP? The MSRP was formed by several federal and state agencies to oversee restoration activities funded by a settlement agreement between these agencies and several chemical companies in the Los Angeles area. What was the settlement about? Between the 1940s and 1970s chemical companies, including the Montrose Chemical Corporation, disposed nearly 2000 metric tons of DDT and PCBs through the Los Angeles County Sanitation Districts wastewater outfall. These chemicals have been incorporated into the ocean food web causing breeding failures in bald eagles, peregrine falcons and other seabirds. These chemicals are now found in some fish at levels so high the state has issued restrictions and warnings to reduce the human health risk of cancer, liver disease, and birth defects. What is the SMBRF's rocky subtidal restoration project? The Palos Verdes Peninsula historically supported hundreds of acres of large, productive, and stable kelp beds. Some kelp beds have recovered due to restoration in the early 1970's and improvements in wastewater treatment (decreased turbidity). However, 133 acres of former beds are still bare due to the development of extensive and persistent urchin barrens. SMBRF plans to partner with the Santa Monica Baykeeper and local commercial urchin divers to restore these kelp beds. Sites already restored by Baykeeper now have persistent kelp forests that support abundant and diverse marine life. Kelp Forest Urchin Barren Why should MSRP fund SMBRF's kelp restoration? The contaminated sediments on the Palos Verdes shelf represent lost fish habitat services. SMBRF's project will restore critical fish habitat to compensate for these lost services. The Daily Breeze (http://www.dailybreeze.com) Why environmentalists aren't ready to support artificial reef off Palos Verdes Peninsula Residents, environmentalists worry NOAA project could affect coastline, stir up chemicals By Cynthia Washicko, The Daily Breeze Saturday, March 18, 2017 A plan to create an artificial reef off the coast of Rancho Palos Verdes would be a boon to underwater plants and animals, but environmental groups and some residents are concerned that building the reef could do more harm than good. Proposed by the National Oceanic and Atmospheric Agency, the project would place 70,300 tons of rock from quarries on Catalina Island at various points along a 69 -acre area of coastline to re-create a rocky reef that was partially buried years ago by landslides. Officials at environmental nonprofit Heal the Bay, however, say the process of building that reef could stir up chemicals that have leached into the underwater soil. Collaborative design The artificial reef was proposed in 2011 as part of the second phase of NOAA's Montrose Settlements Restoration Program, which helps fund projects to address the effect of DDTs and PCBs, chemicals used as pesticides and flame retardants, that washed offshore and contaminated coastal habitats. "Our goal here is really to restore the function of that rocky habitat," said David Witting, an NOAA biologist. The reef design is a product of work between biologists, who focused on such elements as the varying heights of the reef and the channels between each section, and engineers, who ensured the project was feasible, Witting said. "We put a lot of design into the way that they're going to be placed, and we've had biologists who have worked with rocky reef habitat in California for decades look at the design and provide input into it," Witting said. RELATED: Abalone restoration efforts in coastal waters could use the public's help, say scientists The reef isn't being built to support any particular species of flora or fauna, Witting said. Still, it could have a positive impact on several types of abalone, including white abalone, which are endangered, and pink abalone that are a species of concern. "Southern California rocky reefs ... support hundreds of invertebrate species and many dozens — likely over 100 fish species, so it's really trying to create these areas to support this high -diversity assemblage," he said. Environmental concerns That lack of specificity is an area of concern for some environmental groups, though. Dana Murray, senior coastal policy manager for Heal the Bay, said for a project like this one, some biological targets should be included in the proposal, which would help determine when the reef could be deemed successful. C-1 A larger issue, however, is the fact that the reef will be built on top of soil that's been contaminated by toxic chemicals. Those chemicals, specifically DDTs, which were used as pesticides, and PCBs, used as flame retardants and insulators, have washed offshore and contaminated the soil along the coastline. Even though both substances were banned in the 1970s, they can remain in the sand along the ocean floor, and building the reef atop that sand could stir up and redistribute those toxic chemicals again, Murray said. That could create issues at all levels of the food chain. Once small organisms that live in the sand consume the chemicals, fish that feed on those organisms can then take in the chemicals, and larger predators that feed on the fish eventually will be contaminated as well, she said. "That's the crux of our concerns for a project like this," she said. Those chemicals could have an effect on humans as well, as people fish in the area and run the risk of consuming contaminated sea life. RELATED: The decline and hopeful resurgence of Southern California's abalone population And aside from the environmental issues that go with constructing the reef, she added that officials at Heal the Bay would like to see the scientific backing that an artificial reef is the right project for the area in the first place. Other projects, such as wetland restoration, could help the area, but there's been little information about why an artificial reef was chosen over some of those, she said. Residents also have raised concerns about what they said was too little public outreach, and, in some cases, the possibility that the reef could change the quality of surf in the area or exacerbate coastal erosion. "The report does not include any wave refraction computer analysis to determine the impact of the reef on near - shore wave energy, currents and sediment transport," Rancho Palos Verdes resident Gary Randall said in an email. Randall also criticized NOAA for a lack of public outreach about the project and pushed the agency to postpone starting construction until more people can learn about the plan and comment on it. "It's important that they reach out to different stakeholders about this," Murray said. A representative from the Surfrider Foundation said the organization is still researching the project and declined to comment further. RELATED: Divers off Palos Verdes Peninsula begin fight against algae invading Southern California coast Project Hurdles Before any stones can be dropped to the ocean floor, though, the project still has several hurdles to clear. The public comment window for the project is open through Wednesday, and NOAA staff will have to coordinate several state and federal agencies before anything can get started, Witting said. Even after all that is finished, it will still take several months to gather the more than 70,000 tons of rock that eventually will make up the reef. And this is all after nearly a decade of planning to get the project off the ground. If everything goes according to plan, the reef could be in place within about six weeks after the first stones are pushed off the barge from Catalina, Witting said, and some species could start using the man-made structure within hours once it's complete. C-2 Those likely will be adult fish, the most mobile of all the animals that could eventually call the reef home, he said. From there, it'll be a slower process as invertebrates and some underwater plants put down holds on the reef. All told, Witting said, it could be up to six years before the reef is a fully functioning ecosystem. Anyone interested in submitting a comment on the project can send an email to msrp@noaa.gov. URL: http://www.dailybreeze.com/environment-and-nature/20170318/why-environmentalists-arent-ready-to-support-artificial-reef-off-palos-verdes-peninsula C 2017 The Daily Breeze (http://www.dailybreeze.com) C-3 From: edmundo hummel To: CEOA.comments(abslc.ca.aov, msrp(abnoaa.gov Cc: CC; Kit Fox; Ara Mihranian; DirectoOlwildlife.ca.gov; Roberto. Uranga(acoasta1.ca. gov; staff. liemamail. house. gov; Craig W. Cadwallader; jalamillo(ahealthebay.org; dmurray(ftealthebay.org; fourthdistrict(,5bos.lacountv.gov Subject: Creation of Artificial Reef Off Coast of Rancho Palos Verdes Date: Wednesday, March 22, 2017 11:56:52 AM NOAA/CSLC/MSRP Trustees: My name is Edmundo Hummel. I have been a resident of Rancho Palos Verdes for four years. One of the main reasons I live in this area is for the incredible beauty of the ocean and coastline. I am writing to you today to express my strong opposition to the proposed Palos Verdes Reef Restoration Project, as presented in NOAA's Environmental Assessment Report dated February 22, 2017 (NOAA EA 2017). Instead, I am asking that NOAA/CSLC pursue the "No Action Alternative" at this time. Below are a few of the reasons I oppose the project. Future Sediment: The NOAA EA 2017 report fails to adequately answer an obvious question: if this new reef were constructed, what would prevent new. Sediment continues to be added to this area due to the active and well known Portuguese Bend Landslide (PBL), adding to the concern that the artificial reef will simply be covered with sediment over a relatively short time period. In fact, it is interesting to note that the primary cause for some loss of rocky -reef habitat in this area is more likely due to effects of the PBL and other smaller recent landslides along the coast, rather than due to any effects of DDT and PCBs from the White Point outfall. This brings into question whether Montrose Settlement Funds should even be considered for this project. Kelp Forests: What impact will 70,300 tons of rock have on the kelp forests that have begun to rebound in the area? Is growth of kelp forests a goal or not? The report indicates both that the kelp forests are a priority and that they are NOT an objective of the project. The proposed artificial reef would be placed "adjacent to existing nearshore kelp beds." (NOAA EA 2017, Page 7) How will damage to existing kelp beds and rocky reef be mitigated? How high is the risk of damage to existing kelp beds? PCB and DDT: What will dumping 70, 300 tons of rock have on existing PCB and DDT embedded in deposits on the ocean floor? This project is located within an active superfund site, and yet this aspect does not appear to be addressed at all in the report. Disturbing of these deposits during construction, or post -construction due to altered sediment transport patterns, could release previously trapped DDT and PCB into the water column, creating further environmental harm. Project Success: How likely is this project to be successful? Nowhere in the report is there mention of the odds of success of the artificial reef. Where else has this type of project been undertaken (with the similar situation of a nearby ongoing landslide) and how successful was it. Is this project, in the end, experimental? I strongly oppose experiments of this magnitude being conducted in this sensitive area for numerous reasons. Beach/wave Impact: There is a beach located between the Portuguese Land Slide Area and the proposed near -shore project. The report indicates "The placement of reefs in nearshore areas has the potential to alter the transport of sediment and affect the topography of adjacent sub -tidal and beach areas." What, exactly will this artificial reef do to wave action and beach erosion/build-up in the area? D-1 In summary, I feel too many unanswered questions, far too much unmitigated risk, and far too much bias in the 2017 report to support the construction of the Palos Verdes artificial reef. As such, I am strongly opposed to this project and respectfully request that all the MSRP Trustees, including project lead agencies NOAA and CSLC, do NOT approve this project. Stated a different way, I am requesting that the MSRP Trustees select the No Action Alternative. Thank you for your consideration. Respectfully, Edmundo Hummel D-2 From: Bill Foster To: cc Subject: Fwd: Palos verdes reef restoration project Date: Wednesday, March 22, 2017 9:25:02 AM Sent from my iPad Begin forwarded message: From: Bill Foster <bfosna,cox.net> Date: March 22, 2017 at 9:22:58 AM PDT To: msrp&noaa.goc, CEOA.comments&slc.ca.gov Cc: Marty Foster <martycrnan.cox.net>, grapecon(4cox.net, BrianCU%gov, rgdewevn.cox.net Subject: Palos verdes reef restoration project I have been a Rancho Palos Verdes resident for 38 years. Over this time I have seen several projects along our coast line that according to experts would improve and eliminate various problems. 2 in particular were at the Portuguese Bend area. About 40 years ago these geological experts places a granite jetty at the east end of The Portuguese Bend club area in an effort to save the sandy beach. It did quite the opposite for the past 25 years all of the sand has disappeared or is covered with rocks. About 20 years ago and enormous effort was done to decrease dirt erosion on the west side of Portuguese Bend by installing very costly and unsightly heavy wire rock containers along the cliffs. This project also ended in failure and the amount of dirt that continually falls into the Bay Area has continued and possibly increased. The ocean front area from Point Fermin to to Abalone Cove is one of the most unstable geological areas in all of Los Angeles County and perhaps Southern California. The prospect of putting the proposed amount of material on the ocean floor ,so close to an unstable and fragile area that has experienced tremendous land movement, such as the Whites Point massive landslide, which has not been remedied and of course the Portuguese Bend slide which seems continue despite efforts such as dewatering wells that are ineffective, could result weakening the geology of our unstable shoreline. I realize the health of Marine life of our Ocean is important, but to try to improve that with the risk of unknown future catastrophes is irresponsible and dangerous. We live in earthquake country and changing the geology, which this project will certainly do, increases our risk of the unimaginable. Bill Foster Bill Foster Sent from my iPad D-3 From: Susan Brooks To: msroCcbnoaa.aov; cequa.comments( slc.ca.aov Cc: cc Subject: Palos Verdes Reef Restoration Project Date: Wednesday, March 22, 2017 9:18:49 AM Dear Agency Leaders: This proposed project was last seen by representatives of our city in 2011. A lot has occurred in the ensuing 6 years. I respectfully request that you delay any action on this project until current day Stakeholders have an opportunity to assess and offer input on this project. I served on this City Council in the 1990's and returned in 2011 to tend to the People's and Environmental needs. As a member of the Sanitation District Board (past and Present), I've been concerned about when and how the Montrose Chemical Cleanup program would commence. After 45 years of DDT lying on the ocean floor, 7 miles long (as long as the southern portion of the PV Peninsula and the City of RPV) and 1 mile wide, this contaminated ocean floor has been remediated with a systematic release of particulates in order to suppress the toxic chemical due to wave activity. My request is that we take a new look at today's findings. Just a half mile westward lies the largest landslide in the Western Hemisphere, The Portuguese Bend Landslide. We are actively seeking remedy to this slide, knowing that solutions similar to what you propose, might very well be part of the answer to stopping this ongoing loss of land, buildings, roadways and disruption of the ocean environment. However, current studies must be considered before embarking on the project you have outlined. In the early 1990's, the Army Corp of Engineers bolted huge Gabions (boulders encased in thick wire mesh) against the seawall in an effort to mitigate environmental damage. It took only a year before they began to break off and eventually fall apart completely due to strong currents. Our City Council would have likely issued a strong letter urging you to halt this project for some of the aforementioned reasons, but last night's meeting was cancelled due to unforeseen circumstances which led to a lack of a quorum. Please halt any plans to embark upon this project until further input and study. Thank you. Susan Brooks U Susan Brooks Councilwoman, Rancho Palos Verdes (310) 541-2971 From: John R. (Rod) Jensen To: CE0A.comments(c0slc.ca.aov, msro(abnoaa.gov Cc: Kit Fox; Ara Mihranian; Director(awildlife.ca.gov; Roberto. Urangaftcoastal.ca.gov; staff. lieuftmail.house.gov; Craig W. Cadwallader; jalamillo(clhealthebay.org; dmurray(ftealthebay.ora; fourthdistrict(a bos.lacountv.gov Subject: Proposal for an artificial reef off of Palos Verdes Date: Tuesday, March 21, 2017 7:41:36 PM NOAA/CSLC/MSRP Trustees: My name is John R. (Rod) Jensen. I have been a resident of Rancho Palos Verdes for 30 years, residing in Abolone Cove. One of the main reasons I live in this area is for the incredible beauty of the ocean and coastline. I am writing to you today to express my strong opposition to the proposed Palos Verdes Reef Restoration Project, as presented in NOAA's Environmental Assessment Report dated February 22, 2017 (NOAA EA 2017). Instead, I am asking that NOAA/CSLC pursue the "No Action Alternative" at this time. Below are a few of the reasons I oppose the project. Future Sediment: The NOAA EA 2017 report fails to adequately answer an obvious question: if this new reef were constructed, what would prevent new. Sediment continues to be added to this area due to the active and well known Portuguese Bend Landslide (PBL), adding to the concern that the artificial reef will simply be covered with sediment over a relatively short time period. In fact, it is interesting to note that the primary cause for some loss of rocky -reef habitat in this area is more likely due to effects of the PBL and other smaller recent landslides along the coast, rather than due to any effects of DDT and PCBs from the White Point outfall. This brings into question whether Montrose Settlement Funds should even be considered for this project. Kelp Forests: What impact will 70,300 tons of rock have on the kelp forests that have begun to rebound in the area? Is growth of kelp forests a goal or not? The report indicates both that the kelp forests are a priority and that they are NOT an objective of the project. The proposed artificial reef would be placed "adjacent to existing nearshore kelp beds." (NOAA EA 2017, Page 7) How will damage to existing kelp beds and rocky reef be mitigated? How high is the risk of damage to existing kelp beds? PCB and DDT: What will dumping 70, 300 tons of rock have on existing PCB and DDT embedded in deposits on the ocean floor? This project is located within an active superfund site, and yet this aspect does not appear to be addressed at all in the report. Disturbing of these deposits during construction, or post -construction due to altered sediment transport patterns, could release previously trapped D-5 DDT and PCB into the water column, creating further environmental harm. Project Success: How likely is this project to be successful? Nowhere in the report is there mention of the odds of success of the artificial reef. Where else has this type of project been undertaken (with the similar situation of a nearby ongoing landslide) and how successful was it. Is this project, in the end, experimental? I strongly oppose experiments of this magnitude being conducted in this sensitive area for numerous reasons. Beach/wave Impact: There is a beach located between the Portuguese Land Slide Area and the proposed near -shore project. The report indicates "The placement of reefs in nearshore areas has the potential to alter the transport of sediment and affect the topography of adjacent sub -tidal and beach areas." What, exactly will this artificial reef do to wave action and beach erosion/build-up in the area? In summary, I feel too many unanswered questions, far too much unmitigated risk, and far too much bias in the 2017 report to support the construction of the Palos Verdes artificial reef. As such, I am strongly opposed to this project and respectfully request that all the MSRP Trustees, including project lead agencies NOAA and CSLC, do NOT approve this project. Stated a different way, I am requesting that the MSRP Trustees select the No Action Alternative. Thank you for your consideration. Respectfully, John R Jensen 21 Barkentine Road Rancho Palos Verdes, CA 90275 Msg: 310 594-8323 Sent from my iPad A e From: Maft Foster To: CEOA.comments(@slc.ca.gAra Mihranian; kit rpvca.gov; r4deweyCG)cox.net Subject: Palos Verdes Reef Restoration Project Date: Tuesday, March 21, 2017 12:40:33 PM I am writing to express my strong disapproval of the above project. There is a good chance that creation of a reef may well not achieve the goal of increasing marine mammal life in the area. There is an excellent chance that in this geologically sensitive site the risks outweigh any benefit. Thank you Marty Foster RPV resident Sent from my Wad D-7 From: Clayton Kuhlman To: msrp(cbnoaa.gov; gabrielle dorr Cc: CEOA comments; Kit Fox; Ara Mihranian; CC; fourthdistrict(obbos.lacounty_.gov; craigc(obsurfrider-southbay. or; Roberto. U ra nga (a)coasta l.ca. oo Subject: Palos Verdes Reef Restoration Project Comments Attention: Kelly Keen Date: Monday, March 20, 2017 3:03:30 PM Attachments: Palos Verdes Reef Restoration Project reject west site 3 16 2017.pdf Palos Verdes Reef Restoration Project Comments re: httl2://www.monsroserestoration.noaa.gov/wp-content/uploads/2017/02/PV_EA-_15-Feb-2017.1df Hello my name is Clayton Kuhlman, a former resident and local activist for coastal public access in Portuguese Bend, Ca. I have an enormous interest in this project and felt obligated to share my feelings and thoughts about the proposed reef. My greatest concern is outlined in greater detail in a .pdf file located here: hftl2://sharksseafoodbar.com/Palos—Verdes—Reef Restoration Project_ reject_ west site 3_ 16 2017, Please review and note this report intends only to illustrate and identify any potential problems associated with the geographic location of the planned reef and facts used are annotated "" or italicized within the report. My experience and relationship with this particular area is profound and extensive indeed. I grew up just across PV Drive South in the Seaview tract. I spent countless hours and days at a time in the 1950s - 1990s diving or fishing or exploring or studying the unique and special environment. In college a semi -comprehensive study of the tidal zone inhabitants was undertaken by myself and Nick Housego. It documented myriad species along with other pertinent info. with a number of over -leafs. My entire life I have been a proponent of open areas, access to public domain and am an conscientious user of ocean resources. In 1973 I met with California Coastal Zone Commission officials, Army Corps. reps and SOC members at the Federal Bld in Los Angeles to discuss protection and action regarding intentional habitat destruction just west of this exact spot of coastline, including the reconstruction of the seawall. We also discussed access rights as per California Statues and I feel I was instrumental in the future formation of the Ocean Trails network and access to open space(s). This area, now a golf course was a blow to saving the pristine bluff and the wildlife within that I cherished. I support most restoration projects and techniques however like the artificial reef design of this project, to encourage and enlarge the local kelp forests. Wh This projects location needs to be abandoned from consideration. There are too many variables to realize a successful outcome. It is quite possible the new reef would not prevail. Please review the paper: by Dr. R.E. Kayen*, H.J. Lee, J.R. Hein https://walrus.wr.usgs. goy/reports/reprints/Kayen_ CSR_22.pdf Continental Shelf Research 22 (2002) 911-922 Influence of the Portuguese Bend landslide on the character of the effluent -affected sediment deposit, Palos Verdes margin, Me southern California R.E. Kayen*, H.J. Lee, J.R. Hein US Geological Survey, 345 Middlefield Road, Menlo Park, CA 94025, USA Received 12 July 2000; accepted 12 December 2001 I look forward to a supporting a successful reef project. Thank you for your time and consideration. With respect, sincerely, Clayton Kuhlman me From: Lili Amini To: CEOA.comments(a)slc.ca.aov; msrwabnoaa.aov Cc: CC; Kit Fox; Ara Mihranian; Director(c wildlife.ca.gov; Roberto. UrangaCacoasta1.ca. gov; staff. lieu(omail.house.gov, Craig W. Cadwallader; jalamillo(ftealthebay.org; dmurray(ftealthebay.org; fourthdistrict(a)bos.lacounty.gov Subject: Trump National Opposing PV Reef Restoration Project Date: Monday, March 20, 2017 1:17:48 PM Attachments: imaae002.pnng image004.png imaae006.pnng Importance: High Good afternoon, On behalf of Trump National Golf Club Los Angeles, please be advised that we strongly oppose the proposed Palos Verdes Reef Restoration Project. There are numerous unanswered questions about this project, both short term and long term, that make this project unsupportable and detrimental to us as well as other members of the community. Importantly, two weeks ago we raised several concerns about the Project. Although we were promised that our concerns would be answered, we have yet to receive a response. Not only does this demonstrate a blatant disregard to the valid and substantial concerns of the property located closest in proximity to the project and potentially most impacted, but it impliedly admits that the Project applicant is unable to address the concerns. The lack of communication about the impacts of the Project can only be interpreted as a way of attempting to avoid valid criticism and concerns that the Project Applicant would rather leave hidden from the public. Aside from the lack of communication, we have major concerns about issues such as safety, exact project location, noise levels, and potential impacts to business operations -- all of which have not been addressed. Therefore, we are asking that NOAA/CSLC pursue the " NO ACTION ALTERNATIVE". Thank you for your time and attention to this very important matter. Lili Amini General Manager Trump National Golf Club, Los Angeles One Trump National Drive I Rancho Palos Verdes, CA 1 90275 p. 310.303.3256 1 f. 310.265.5522 www.trumpgolf.com I www.trumpnationallosangeles.com 01MID 30" D-10 From: Laureen Claire Vivian To: CEOA.comments(@slc.ca.aov; msrD(abnoaa.aov Cc: CC; Kit Fox; Ara Mihranian; Director(c wildlife.ca.gov; Roberto. Uranga(dcoasta1.ca. gov; staff. lieu(amail.house.gov, Craig W. Cadwallader; jalamillo(ilhealthebay.org; dmurray(ftealthebay.org; fourthdistrict(a)bos.lacounty.gov Subject: NOAA Date: Monday, March 20, 2017 12:10:30 PM NOAA/CSLC/MSRP Trustees: My name is _Laureen Vivian . I have been a resident of San Pedro for _50 years. One of the main reasons I live in this area is for the incredible beauty of the ocean and coastline. I am writing to you today to express my strong opposition to the proposed Palos Verdes Reef Restoration Project, as presented in NOAA's Environmental Assessment Report dated February 22, 2017 (NOAA EA 2017). Instead, I am asking that NOAA/CSLC pursue the "No Action Alternative" at this time. Below are a few of the reasons I oppose the project. Future Sediment: The NOAA EA 2017 report fails to adequately answer an obvious question: if this new reef were constructed, what would prevent new. Sediment continues to be added to this area due to the active and well known Portuguese Bend Landslide (PBL), adding to the concern that the artificial reef will simply be covered with sediment over a relatively short time period. In fact, it is interesting to note that the primary cause for some loss of rocky -reef habitat in this area is more likely due to effects of the PBL and other smaller recent landslides along the coast, rather than due to any effects of DDT and PCBs from the White Point outfall. This brings into question whether Montrose Settlement Funds should even be considered for this project. Kelp Forests: What impact will 70,300 tons of rock have on the kelp forests that have begun to rebound in the area? Is growth of kelp forests a goal or not? The report indicates both that the kelp forests are a priority and that they are NOT an objective of the project. The proposed artificial reef would be placed "adjacent to existing nearshore kelp beds." (NOAA EA 2017, Page 7) How will damage to existing kelp beds and rocky reef be mitigated? How high is the risk of damage to existing kelp beds? PCB and DDT: What will dumping 70, 300 tons of rock have on existing PCB and DDT embedded in deposits on the ocean floor? This project is located within an active superfund site, and yet this aspect does not appear to be addressed at all in the report. Disturbing of these deposits during construction, or post -construction due to altered sediment transport patterns, could release previously trapped DDT and PCB into the water column, creating further environmental harm. Project Success: How likely is this project to be successful? Nowhere in the report is there mention of the odds of success of the artificial reef. Where else has this type of project been undertaken (with the similar situation of a nearby ongoing landslide) and how successful was it. Is this project, in the end, experimental? I strongly oppose experiments of this magnitude being conducted in this sensitive area for numerous reasons. Beach/wave Impact: There is a beach located between the Portuguese Land Slide Area and the proposed near -shore project. The report indicates "The placement of reefs in nearshore areas has the potential to alter the transport of sediment and affect the topography of adjacent sub -tidal and beach areas." What, exactly will this artificial reef do to wave action and beach erosion/build- up in the area? In summary, I feel too many unanswered questions, far too much unmitigated risk, and far too much bias in the 2017 report to support the construction of the Palos Verdes artificial reef. As such, I am strongly opposed to this project and respectfully request that all the MSRP Trustees, including project lead agencies NOAA and CSLC, do NOT approve this project. Stated a different way, I am requesting that the MSRP Trustees select the No Action Alternative. D-11 Thank you for your consideration. Respectfully, Laureen C, Vivian D-12 From: - To: CEOA.comments(oslc.ca.gov; "msrp(canoaa.gov Cc: Kit Fox; Director(abwildlife.ca.gov; Roberto. Uranga(abcoastal.ca.gov; staff.lieu(a mail.house.gov; fourthdistrict(c bos.lacountyyov Subject: Objection to ENVIRONMENTAL ASSESSMENT PALOS VERDES REEF RESTORATION PROJECT Send March 20 2017 Date: Monday, March 20, 2017 8:06:00 AM Summary: This study is inadequate and poorly researched in reference to surfing, so biased that the project should be put on hold until professionals not currently involved in the project can review the entire project, and come to an objective conclusion based on new research based on the study area. Anonymity: Due to current legal issues in which Plaintiffs' attorneys are using public Coastal Commission documents from over 10 years ago to publicly name potential defendants without any recourse, I respectfully ask my name and address not be public. I am a 14 years resident of RPV and lived the area for 57 years. I have only know about this project for about a month, and am alarmed it has been planning for over 4 years with little public notice. I attended the Open House Palos Verdes Reef Restoration Project Open House, Hosted by City of Rancho Palos Verdes, March 2 but there was no presentation so it answered none of my concerns. I object to any of this project as it based on inadequate and incorrect information. I will take one area but there are probably others that are similar. In the appendices C 15 15.0 lists: RECREATION, c) Would the Project substantially interfere with recreational surfing activities or have a substantially adverse effect on surfers? "Less Than Significant Impact" This conclusion is based on incorrect information. The impact will be great as the study does not correctly identify the surfing spots in the area, nor gives any reference to where this information comes from. Page 32 5.5.3.1 Surfing list three surfing spots, including a new politically correct name "Japan Cove" and a spot called "Pickle's ... located just south of White's Point Nature Preserve" The study does not give a reference for these spots but only two intemet websites I can find identify Pickles. Unlike most of the study, there are NO references for this information. Based on the description, I suspect the study used a website, Wannasurf.com https://wannasurf.com/spot/North_America/USA/California/LA_County/Pickles/index.html Wannsurf.com is a website that anyone can post on, and the webmaster makes no attempt to correct incorrect information. To use it in any study without verification is ridiculous and makes the whole study questionable. The best reference guide for this area is still Surfing Guide to Southern California by Bill Cleary/David H. Stern, 1963. (Clearly/Stern) ISBN -10: 091144906X While over 50 years old it is still the best reference for this area as more recent guides seem to have copied this D-13 work but make incorrect changes - it is clear they never visited the area to verify their information, similar to this study. Cleary/Stern identify 9 surfing spots from the Portuguese Bend Club to White (White's) Point. I suspect the author of the study never visited the area and simply used the incorrect information from Wannasurf.com This would also explain why the study omits other surfing spots in the area: Wannasurf incorrectly identifies a spot in the study are as "BEE HIVES" and states it "is actually out front of the Terranea Resort in Rancho Palos Verdes." haps://ww-w.wannasurf. com/spot/North_America/USA/California/LA_County/BA_s/ Based on the publically research I have noted, the impact to surfing should be changed to: "Potentially Significant Impact" and reject the conclusion the West Area is the choice for this project. Based on this small sample, there are probably other areas in the study that are similarly incorrect. In particular: "Blwany, MHS; Flick, R; Reitzel, J; and Lindquist, A, 1998. Possible impacts of the SCE Kelp Reef of San Clemente on the marine environment. Coastal Environments, Encinitas".. This study is not available for me to review but there are many differences in the bathymetry in this study area and San Clemente, and is inadequate for any conclusions to be made in the RPV area. "Our goal here is really to restore the function of that rocky habitat," said David Witting, an NOAA biologist. No! Your goal is add rocks to an area that will damage the existing reef, to what extent the study does not address. If the goal is to add to kelp forest, then the East area would be more beneficial since, simply based on visual observation, there is less kelp there than in the West area. In conclusion, it is distributing how both government and academic researchers could put together such a poorly researched study in 4 years time. It is as if they assumed no one would read the study and be outraged, as if they simply mailed it in because no one would read it. That is why I am so outraged. D-14 From: Francisco Bernues To: CEOA.comments(@slc.ca.aov Cc: msrp(a noaa.gov; CC; Kit Fox; Ara Mihranian; Director(awildlife.ca.gov, Roberto. Uranga(cbcoastal.ca.gov, staff. lieu(a)mail.house.gov; "Craig W. Cadwallader"; ialamillo(ftealthebay.org; dmurray(abhealthebay.org; fourthdistrict( )bos.lacounty_gov Subject: NO action alternative Date: Sunday, March 19, 2017 4:14:34 PM NOAA/CSLC/MSRP Trustees: My name is Francisco Bernues. I have been a resident of Rancho Palos Verdes for40+ years. One of the main reasons I live in this area is for the incredible beauty of the ocean and coastline. I am writing to you today to express my strong opposition to the proposed Palos Verdes Reef Restoration Project, as presented in NOAA's Environmental Assessment Report dated February 22, 2017 (NOAA EA 2017). Instead, I am asking that NOAA/CSLC pursue the "No Action Alternative" at this time. Below are a few of the reasons I oppose the project. Future Sediment: The NOAA EA 2017 report fails to adequately answer an obvious question: if this new reef were constructed, what would prevent new. Sediment continues to be added to this area due to the active and well known Portuguese Bend Landslide (PBL), adding to the concern that the artificial reef will simply be covered with sediment over a relatively short time period. In fact, it is interesting to note that the primary cause for some loss of rocky -reef habitat in this area is more likely due to effects of the PBL and other smaller recent landslides along the coast, rather than due to any effects of DDT and PCBs from the White Point outfall. This brings into question whether Montrose Settlement Funds should even be considered for this project. Kelp Forests: What impact will 70,300 tons of rock have on the kelp forests that have begun to rebound in the area? Is growth of kelp forests a goal or not? The report indicates both that the kelp forests are a priority and that they are NOT an objective of the project. The proposed artificial reef would be placed "adjacent to existing nearshore kelp beds." (NOAA EA 2017, Page 7) How will damage to existing kelp beds and rocky reef be mitigated? How high is the risk of damage to existing kelp beds? PCB and DDT: What will dumping 70, 300 tons of rock have on existing PCB and DDT embedded in deposits on the ocean floor? This project is located within an active superfund site, and yet this aspect does not appear to be addressed at all in the report. Disturbing of these deposits during construction, or post -construction due to altered sediment transport patterns, could release previously trapped DDT and PCB into the water column, creating further environmental harm. Project Success: How likely is this project to be successful? Nowhere in the report is there mention of the odds of success of the artificial reef. Where else has this type of project been undertaken (with the similar situation of a nearby ongoing landslide) and how successful was it. Is this project, in the end, experimental? I strongly oppose experiments of this magnitude being conducted in this sensitive area for numerous reasons. Beach/wave Impact: There is a beach located between the Portuguese Land Slide Area and the proposed near -shore project. The report indicates "The placement of reefs in nearshore areas has the potential to alter the transport of sediment and affect the topography of adjacent sub -tidal and beach areas." What, exactly will this artificial reef do to wave action and beach erosion/build-up in D-15 the area? In summary, I feel too many unanswered questions, far too much unmitigated risk, and far too much bias in the 2017 report to support the construction of the Palos Verdes artificial reef. As such, I am strongly opposed to this project and respectfully request that all the MSRP Trustees, including project lead agencies NOAA and CSLC, do NOT approve this project. Stated a different way, I am requesting that the MSRP Trustees select the No Action Alternative. Thank you for your consideration. Respectfully, F. Bernues D-16 From: Bryce Lowe -White To: msrp(&noaa.gov; CEQA.commentsCa)slc.ca.gov Cc: CC; Kit Fox; Ara Mihranian Subject: Palos Verdes Reef Restoration Project Comments Date: Sunday, March 19, 2017 8:52:00 AM I am opposed to the Palos Verdes Reef Restoration Project I am a local resident and frequently surf in the proposed project area. I am worried that the manipulation of the bottom offshore will change wave refraction to our coastline and therefore effect our beautiful waves that we are so lucky to have in our backyard. We have some of the most pristine, natural coastline and surf breaks in Southern California. It would be a shame if the surf breaks were effected negatively because of this proposed manmade proj ect. Also I agree with statements made by Heal the Bay that this project will stir up dormant pollutants that have settled on the ocean floor in the area. Our local ocean habitat is fragile and has already sustained damage from the initial dumping of these chemicals. I would suggest to leave it be now that those pollutants have settled. Interference could cause water quality and wildlife issues if these chemicals were to resurface. I would like to propose the money be held and kept on hand in case of a future environmental emergency in the area. We are in close proximity to the Port of LA and there is a large amount of ship traffic off our coast throughout the year. There is a high risk of potential oil spill or other natural disaster in the ocean that could effect our coast in the future. We should be prepared with the necessary funds to implement immediate action in any case. Thank you for your consideration. Bryce Lowe -White San Pedro Resident D-17 From: Gary Randall To: CEOA.comments(dslc.ca.aov, msrpC(bnoaa.gov Cc: CC; Kit Fox; Ara Mihranian; DirectoOlwildlife.ca.gov; Roberto. Uranga(acoasta1.ca. gov; staff. lieuCabmail. house. gov; Craig W. Cadwallader; jalamillo(ftealthebay.org; dmurray(ftealthebay.org; fourthdistrict(5bos.lacountv.gov Subject: Opposing Palos Verdes Reef Restoration Project Date: Saturday, March 18, 2017 12:20:12 PM NOAA/CSLC/MSRP Trustees My name is Gary Randall. I have been a resident of Rancho Palos Verdes for over 40 years, and am an avid surfer and ocean enthusiast. I am writing to you today to express my strong opposition to the proposed Palos Verdes Reef Restoration Project, as presented in NOAA's Environmental Assessment Report dated February 22, 2017 (NOAA EA 2017). Instead, I am asking that NOAA/CSLC pursue the "No Action Alternative" at this time. I have a number of concerns with the proposed project and/or information provided. I will enumerate a number of those concerns in this email. Before doing so, I would like to restate the "Purpose and Need" present by NOAA for this project: "The purpose of the Palos Verdes Reef Restoration Project is to restore historic rocky reef habitat that was buried by sedimentation from nearby landslides, thereby providing essential fish habitat and substrate for kelp, other marine algae, and marine invertebrates, creating a productive rocky -reef ecosystem in an area with limited hard substrate. This reef restoration project will compensate for biological resource losses caused by contaminated sediments from the Palos Verdes Shelf Superfund Site as identified in the Montrose Settlements Restoration Program (MSRP) Phase 2 Restoration Plan." (NOAA EA 2017, section 1.2, page 4) The following are my comments, questions, and concerns that lead me to my position of strongly opposing this project: 1. First of all, the project name and purpose themselves are misleading. The fact is that this project does not "restore" any existing rocky reef. Instead, it creates a new artificial reef by placing 70,300 tons of quarry rock on an area that is either already sandy bottom or sediment covering existing rocky reef. According to section 6.1.4.3 (NOAA EA 2017, page 40), "The majority of the project site contains sandy bottom habitat and areas of buried reef." Using the word "restoration" in the project name and in all reports, public notifications, etc. is misleading and, I believe, has been done (perhaps unintentionally) to bias public reaction in the direction of support of this project. 2. The NOAA EA 2017 report fails to adequately answer an obvious question: if this new reef were constructed, what would prevent sediment from covering it? The NOAA EA 2017 report, section 2.3.2, page 7, indicates that "the West Area was selected for the proposed action because the fine grained sediments are thinner..." and goes on to state "The relative absence of fine grain sediments means the quarry rock would be less likely to sink into or otherwise be covered by sediments." These statements are hardly definitive; they only offer a "relative likelihood" as compared to the East study area. Sediment continues to be added to this area due to the active and well known Portuguese Bend Landslide (PBL), adding to the concern that the artificial reef will simply be covered with sediment over a relatively short time period. In fact, it is interesting to note that the primary cause for some loss of rocky -reef habitat in this area is more likely due to effects of the PBL and other smaller recent landslides along the coast, rather than due to any effects of DDT and PCBs from the White Point outfall. This brings into question whether Montrose Settlement Funds should even be 0 i considered for this project. 3. Is growth of kelp forests a goal or not? In the purpose statement contained in the NOAA EA 2017 report, it appears to be a significant aspect. Additional statements on page 8 of the report referring to kelp recruitment being facilitated and "expand(ing) the footprint of existing kelp beds" support the impression that increasing kelp beds is a now major goal. Section 6.6.5 (page 47) further indicates "The objective is to create hard, rocky substrate upon which kelp will become established." However, in the MSRP 2012 Final Phase 2 RP/EA/IS, there is a clear statement on page 5-28 that "...the goals of this restoration project do not include the production of kelp forest." So which is it? Has the goal been changed between 2012 and 2017 in an effort to garner greater public sympathy and support? If a major element of the goals has indeed changed from 2012 to 2017, why is this not highlighted and specifically addressed in the NOAA EA 2107 report, with any new data and reasoning included? This significant readjustment of project goals should not be brushed over. 4. The proposed artificial reef would be placed "adjacent to existing nearshore kelp beds." (NOAA EA 2017, Page 7) How will damage to existing kelp beds and rocky reef be mitigated? How high is the risk of damage to existing kelp beds? There is some discussion of this aspect in the report, indicating the use of GPS positioning systems, only conducting work during calmer times, anchor positioning, etc., but this specific aspect does not appear to be adequately addressed and discussed in convincing detail. 5. There is already substantial rock reef habitat throughout the Palos Verdes area. What percentage increase in rocky -reef habitat does this project contribute, if constructed? I cannot find any mention of this in the report. A 2% increase in rocky reef habitat would likely result in significant public opposition to the project, as the benefits would likely not outweigh the costs and risks, while a 50% increase might be viewed entirely differently. The fact that this figure appears nowhere in the report is a major oversight. Certainly, any well rounded and unbiased presentation would include this information so that interested parties can make appropriate rational judgements based on facts. 6. Will construction of the reef disturb embedded PCB and DDT deposits on the ocean floor? This project is located within an active superfund site, and yet this aspect does not appear to be addressed at all in the report. Disturbing of these deposits during construction, or post - construction due to altered sediment transport patterns, could release previously trapped DDT and PCB into the water column, creating further environmental harm. 7. How likely is this project to be successful? Page 7 of the NOAA EA 2017 report states the west area was selected because of its "greater likelihood of restoration success" than other study areas. Page 8 indicates that "this location is considered to have the highest potential for restoration benefits and success." But, these are both relative statements. No indication is given to the "absolute" likelihood of success. Does this project, if constructed in the West Area, have a 10% chance of success or a 90% chance of success? I find no indication in the report. Furthermore, what metrics are established to determine "success" or "failure" of the project, if it were constructed? I cannot find any objective metrics for measuring success anywhere in the report. Based on these issues, this project appears to be very experimental in nature. I strongly oppose experiments of this magnitude being conducted in this sensitive area for numerous reasons. 8. According to the NOAA EA 2017 report, "There are three recognized surfing breaks in the vicinity of the project site." (Page 27). While the three areas listed exist, there are a number of additional well known surfing breaks, including a surfing break located directly in front of D-19 the west end of the proposed project site, that are not even mentioned or addressed in the report. It is offensive to the local surfing community that the potential impact of the proposed reef on surfing breaks has been glossed over to such an extent. The NOAA EA 2017 report dedicates a total of two very brief sections (5.5.3.1 and 6.1.4.1) to a discussion of surfing, and any impact to surf breaks in the area is brushed off as being insignificant. This minimal discussion, and lack of any substantive research or data, is in direct contrast to Page 5-27 of the MSRP 2012 Final Phase 2 RP/EA/IS, where the authors refer to board, body and windsurfing as recreational uses of the area, and they further indicate that "the potential impacts to recreational and navigational uses will be a significant consideration as the proposed restoration sites are evaluated." 9. Section 6.1.4.1. of the NOAA EA 2017 report (page 39) discusses some of the environmental consequences that the proposed reef might have on waves and currents. The report assumes additional kelp forest will be created over this rocky reef, despite this having not been an original goal (2012), and despite the fact that no probability of success for kelp forests being sustained over this new artificial reef is stated anywhere in the report. Furthermore, in this same section and also in section 6.5 (page 45), a study and report by Hany Elwany (1998) is referred to and used an argument that offshore reefs would not have a substantial or measureable effect on littoral zone sedimentation processes, beach habitat, surf quality. The report fails to mention that this 1998 study by Elwany is specific to an artificial reef project in San Clemente, NOT the proposed reef project in Rancho Palos Verdes. This is misleading and does not accurately represent the lack of actual study performed of this aspect on this specific site. Additionally, it is noteworthy that the MSRP 2012 Final Phase 2 RP/EA/IS indicates "The artificial reefs proposed in this project will be designed to increase erosion of inshore sediments and to increase offshore transport of sediments." (Page 5-26). So, based on the 2012 report, one of the goals is in fact to alter currents and wave activity toward an end of transporting sediment. This is confusing and in contrast with the 2017 report, and is indicative of a lack of clear goals and objectives for this project. 10. There is no indication that wave refraction modeling, both with and without the proposed artificial reef, has been done for this specific project, despite the fact that comprehensive bathymetric surveys have been conducted in the area (NOAA EA 2017, pages 15 and 16). This is a major oversight. Computer models and tools exist and are readily available to provide greater insight to the effect a reef would have on wave energy reaching surfing breaks and the shoreline. Alteration of the amount of energy could impact surf quality, sediment transport and beach erosion throughout the affected area. In fact, the MSRP 2012 Final Phase 2 RP/EA/IS, page 5-27, indicates that "The placement of reefs in nearshore areas has the potential to alter the transport of sediment and affect the topography of adjacent sub -tidal and beach areas." Use of existing wave refraction and sediment transport modeling tools, applied specifically to the bathymetry of the proposed reef location, must be done before making a decision to move forward with this project. If the modeling suggests any change in wave energy or currents reaching the nearshore area, no matter how small, the project should be seriously reconsidered or outright rejected in favor of the No Action Alternative. 11. Section 6.4. discusses a public outreach program that would be planned during construction. The report states "This will inform the public that the purpose of the proposed action is ecological restoration and that no permanent structures are being constructed." Does this then imply that the placement of 70,300 tons of quarry rock on the ocean floor is not intended to be a "permanent structure?" If so, what is the anticipated lifetime? When is the planned removal date? On the contrary to the statement in Section 6.4, I believe the structure is actually intended to be permanent and the statement in Section 6.4 is misleading and biased D-20 in order to minimize adverse public reaction to this project. In summary, after a thorough review of the 2012 and 2017 reports, and significant additional research, I have come to the conclusion that there are far too many unanswered questions, far too much unmitigated risk, and far too much bias in the 2017 report to be in a position to support the construction of the Palos Verdes artificial reef. As such, I am strongly opposed to this project and respectfully request that all the MSRP Trustees, including project lead agencies NOAA and CSLC, do NOT approve this project. Stated a different way, I am requesting that the MSRP Trustees select the No Action Alternative. Thank you for your consideration. Respectfully Gary Randall 40+ year resident of Rancho Palos Verdes D-21 From: Michelle Ernst To: msrpCcbnoaa.gov; cega.comments(dslc.ca.gov Cc: CC; Kit Fox; Ara Mihranian Subject: Palos Verdes Reef Restoration Project Comments Date: Friday, March 17, 2017 10:02:21 AM To Whom It May Concern: I am writing to express concern over the recently proposed Palos Verdes Reef Restoration Project. As a lifetime environmentalist with a Masters in Environmental Science from the Yale School of Forestry and Environmental Studies, and also as a native of San Pedro, where I attended the Marine Science Magnet program at San Pedro High School, I have a deep-rooted love for the coastline. I fully support efforts to protect and restore the unique marine habitat of the Palos Verdes Peninsula. But there is no evidence supplied in the Environmental Assessment that the proposed project would improve fish habitats. Furthermore, the project would likely have a very negative impact on recreational activities (mainly surfing) at the site, and those are only cursorily considered. Specifically, I have two primary concerns about the proposed project: 1) The Environmental Assessment acknowledges in the Purpose and Need section that the "historic rocky reef habitat ... was buried by sedimentation from nearby landslides." Though the Portuguese Landslide has slowed in recent years, it continues to move at a rate of 1 to 2 feet per year, and could be exacerbated by heavy rainfall as had recently been experienced in the area. There is no consideration given in the Environmental Assessment that this costly project will be buried by sedimentation just as the historic rocky reef was. 2) Southern California kelp forests have suffered in recent years from an explosion of sea urchins, following the decline of predators such as sea otters and California Sheephead. The sea urchins have decimated large areas of kelp forest, particularly in Southern California. The Environmental Assessment notes the presence of sea urchins at the site. The proposed project seems to operate under the presumption that "if you build it, they will come;" that by dumping 70,300 tons of rock at the site, a kelp forest will materialize. But with a population of sea urchins already at the site, this assumption seems tenuous at best. In conclusion, I believe that far better uses for the $6.5 million slated for this project can be found. Sincerely, Michelle Ernst D-22 CITY COUNCIL POLICY NUMBER: 29 DATE ADOPTED/AMENDED: 08/01/95 (amended 02/19/02 & 03/04/14) SUBJECT: Legislative Activities of the City Council POLICY: It shall be the policy of the City Council that the staff shall prepare and present periodic legislative updates for the Council's review and consideration. The legislation monitored Legislative Guidelines shall address issues at the regional, County, State and Federal level and shall focus upon anticipated or proposed laws, regulations, rules, or policies that may impact the City or the region. The legislation monitored will include both those issues that the City Council decides either to support or oppose and those that they choose to identify as issues of concern, but not take a position on. The determination of what position to take on pending legislation shall be solely that of the City Council. Staff will periodically, at the request of a Council member, place matters of pending legislation on the City Council agenda for consideration. Staff will provide regular updates on the status of any legislative action affecting any issues of concern to the City Council through the Weekly Administrative Report. If the majority of the Council votes to support or oppose legislation, staff shall prepare the appropriate correspondence to the appropriate Federal, State, County and/or regional legislative representative(s) expressing the position of the City. Individual Council members may wish to support or oppose a specific piece of legislation whether the Council has taken a position on such legislation or not. Any legislative activity by an individual Council member, including preparing legislative correspondence, may be conducted by any Council member, who shall state that he or she is not acting on behalf of the City and is representing his or her own personal views. However, staff shall not assist in any legislative activity of an individual Council member, including the preparation of legislative correspondence, unless the legislative item has appeared on a Council agenda and has received a majority vote of the Council. The League of California Cities' "Legislative Bulletin" and any appropriate publication that summarizes legislation shall be provided as part of the Weekly Administrative Report to each member of the Council for review. E-1 BACKGROUND: The City Council initially adopted a policy for Council involvement in Federal and State legislative advocacy in 1995. Although the policy seems to have worked adequately over the first seven years, by 2002 it was thought that it did not allow the City to respond rapidly to requests to support or oppose legislation that may be before a committee or on the floor or the Assembly or before Congress and needs immediate action on the part of supporters or opponents. Therefore, the policy was amended in 2002 to address these perceived deficiencies. In 2014, the policy was amended again to revise the procedure for monitoring legislation, and to explicitly include legislative issues at the County and regional level. The City Council's revised legislative policy establishes an internal process for identifying, tracking and advocating its position on pending legislation synchronized to the fast -paced "legislation time clock." Through this proactive policy, the City Council hopes to have a stronger "voice" in the Peninsula/South Bay region, Los Angeles County, Sacramento and Washington, DC. E-2