Old Salt Lake | Virtual Museum
Report with analysis (text)
| Sept. 05 | Looking North-to-South at the Old Salt Lake Site
| Sept. 16 | Writ of Nature
| Sept. 18 | 48 Hours Later
| Sept. 21 | Report with analysis (text)
Report with analysis (text by Galen Hunter)
[The following analysis is based on research and observations of the site on September 18, 2015 and prior.]
The power plant owners have filed a Writ of Mandate against the California
Coastal Commission (CCC). The CCC has designated the Old Salt Lake site as a wetland.
The power plant owners don't want it to be a wetland, so they have hired a consultant
to construct an argument that the Old Salt Lake site is not a wetlands. The construct
the consultant has come up with is that the water in old oil tank basins is from an
artificial source. Specifically, argument is the artificial water is from injection of
water along Prospect Avenue, which is a government project to deal with the sea water
Remember irony, the sea water intrusion problem in large part was caused by the
previous owners of the salt lake property due to their over pumping of the native fresh
water aquifers right there. Regardless, the consultant hired by the current power
plant owners is arguing its not a wetlands because the water is coming from an
artificial (note: "groundwater") source.
Here is an except from the Writ of Mandate. What follows is an analysis of the logic of
the argument in the Writ framed in terms of whether the basin liners are porous to
water or not (either ground to surface or surface to ground) and also taking into
consideration the recent documented observations of the site before and after the
September 15th rainstorm leaving a half an inch of rainwater in the basins which were
[ Excerpt: Writ of Mandate ]
"The Commission has violated the law by exceeding its statutory authority and
attempting to classify 5.93 acres of the Redondo Beach Generating Station site as
Commission-jurisdictional wetlands. The area identified by the Commission as
"jurisdictional wetlands" includes four concrete-lined retention basins (that held
oil tanks until as recently as 2006) and a constructed pit (collectively, the
"Retention Basins"). The 5.93 acres of long-developed industrial land the Commission
claims to be "jurisdictional wetlands" do not demonstrate natural wetland conditions.
Instead, the features of this area that the Commission claims support its
determination, including the occasional presence of water, are the result of
artificially induced hydrological conditions created at least in part by a
long-running injection well project operated by the Los Angeles County Department of
Public Works ("LACDPW") to prevent seawater intrusion into the groundwater aquifer.
These conditions in no way support a determination that the site contains
jurisdictional wetlands under the California Coastal Act's definition of the
[ / Excerpt ]
The Writ of Mandate is saying the concrete liner is porous, of course, otherwise
arguing the site is not a wetland would not be logical. Test the contention it is not a
wetland by briefly stepping through the scenario where the basin barrier is not porous.
_____ [ Scenario A - Not Porous ] _____
If the three barriers or liners are not currently porous - then the recent
documented rainfall on the site is being held by the barriers. Of course, then water
can't come into these barriers from the other direction, the ground. So, neither
artificial or natural water would be able to enter the basin from the ground. Since,
the water experts argument is based on water flowing into the basin from the ground,
this argument would not be valid if the barrier was not porous.
OK, next consider scenario B, the barriers are indeed porous.
Also consider for this scenario that the Old Salt Lake right there did have a clay
bottom. My interpretation of the old Edison geotechnical reports, the few publically
obtainable, is that the oil storage tanks previously in those basins areas currently
holding water from the rainstorm on the 15th were actually were built right into the
clay bottom of the lake with fill added around them. So, even in the scenario where the
barriers are not porous, the original clay bottom of the lake or remnants of it at
least, could still be there and currently playing a part of the famously complex flow
of ground water at the site.
_____ [ Scenario B - Porous ] _____
While it is theoretically possible some of the water currently in the basins could be
from the artificial injection on Prospect Avenue the reality is no artificial
groundwater (or natural groundwater for that matter) was observed to be in the basins
in the weeks before the rainstorm on the 15th which put at least one half an inch of
natural rainwater in the basins and that water level was observed to hold after two
full sunny days.
So, the argument that the site is not a wetlands because the water in the basins is
artificial is a false argument even under the scenario that the barriers are
Moreover, if the barriers are porous, something is indeed currently holding the natural
rain water in the basins. If the basin is porous then the basin barriers or liners
themselves are not at least entirely holding the water and something else is. I'm
speculating what this something else may be the original clay bottom of the original
lake which existed for thousands of years right there.
Long time before any oil storage tanks and basin areas were constructed at the site
there was a lake and the lake had a clay bottom right there where the basins are. This
clay bottom of the lake held ground and rain water. In the scenario that the current
basins are porous, it is reasonable to speculate that at least a remnant of original
lake bottom is still holding in the current natural rainwater in the basins.
In the scenario that the current basins are porous, perhaps artificially injected water
from Prospect Avenue has made it into the basins in the past and/or may do so in the future.
In the scenario that the current basins are porous, perhaps at least remnants of the
original natural fresh and salt water aquifers, the status and source of which is still
an open scientific inquiry but which may have been originally flowing into the lake
from the east, could have been in the basins in the past and/or may do so in the
The conclusion under either scenario whether the barriers are porous or not and
particularly when also considering recent observations of the site before and after the
rainstorm of September 15th, is that the argument that the water is the basins is
artificial is not true. Therefore, the argument the site is not a wetland because the
water is artificial is also a false argument.