September 28th, 2014
To: Ms. Stacey Zee – FAA, c/o ICF International, 9300 Lee
Highway, Fairfax, VA 22031
Dear Ms. Zee,
Comments on the Kodiak Launch Complex Launch
Pad 3 Draft Environmental Assessment.
I am completely opposed to any further development of the
Kodiak Launch Complex at Narrow Cape. Public access to public land, public
safety, cumulative environmental impacts, the past negligence of due diligence
by the AK Aerospace Corporation, natural resource degradation and
contamination, unjustified cost to the state, lack of clear vision or business
plan, questionable economic sustainability, and impacts on rare plant species
in the area are among my many concerns.
Kodiak has been my home since 1980 and I have been actively
interested in the details of this facility since the very beginning when there was a public advisory committee. That committee was
disbanded very quickly after members of the public, including myself, raised
concerns and questions that former CEO, Pat Ladner, did not want to answer.
Rather than be transparent with the intended purpose of military launches, he
fed the public with promises of commercial satellite launches and bringing our
little fishing village into the 21st Century with high tech jobs and
reeducation for unemployed fisherman.
We were also told that public access would be guaranteed,
and there would never be more volatile and toxic liquid rocket fuels or
fissionable nuclear materials used.
From the start, the AAC (formerly the AADC) has lacked any
real long- term business plan. All they have ever had for a business plan is, “Build
it and they will come.” Even our state representative, Rep Alan Austerman, who
was also an AAC board member, was quoted in the Kodiak Daily Mirror recently
saying that the KLC has no business plan. There have only been 17 launches
since 1998 and 15 of those successful. There has been so little business and
generated revenue to sustain their operations, the state has had kick in
millions of dollars annually to keep it open. Unlike General Motors, the KLC
has never been a viable business to justify government subsidy. With a
dwindling state budget, I just can’t see the justification for more corporate
bail out for Space Pork Kodiak.
My husband and I live in Kodiak and also live part of the
time at Pasagshak that is within the circles of impact in your EA document. We
are very familiar with the area and natural resources surrounding the KLC as
that has been our backyard playground and grocery store since the early 1980’s.
We live a subsistence lifestyle and that is where we get our fish, deer and
berries for the freezer. As most Pasagshak residents, we collect rainwater for
drinking water off our rooftop as wells are brackish. We are concerned about
perchlorate and other contamination of drinking water, berries, fish and the
deer that graze on the grass on Narrow Cape.
The KLC was built on some of the only public land along our
road system and perhaps the choicest piece. Most roadside property is privately
owned by Native Corporations with limitations on public access. It was a very poor
choice for the location of the KLC as it also happens to be one of the most
beautiful and popular recreational destinations. It was a very impractical choice as it is at the extreme
opposite end of a narrow, winding road for safely, efficiently, and the
all-season transporting of rockets and related materials. What were they
thinking?
The well documented, geologic instability and activity of
the area with major, shallow earthquake faults running through Narrow Cape
should be enough to nullify the entire plan of increasing the infrastructure of
the KLC and especially, introducing a liquid fueling facility. Had a proper EIS
been done initially before the KLC was built, this data alone would have shown
what an irresponsible location Narrow Cape is for such a facility!
Some of the recreational activities that have been and will
be impacted include: hiking, fishing, birding, photography, whale watching,
beach combing, surfing, botanizing, camping, ice skating in winter on backwater
lagoons, wildlife watching, tide pooling, fossil collecting, and general nature
appreciation.
Our late senator Ted Stevens managed to get the KLC built
with federal money and without having to jump through the hoops of a thorough
EIS that it deserved, thanks to a rider he secretly attached to a Sunset
Transportation bill. He and the
military promoters knew that area had far too many environmental issues and
would probably never have been built had it gone through the customary process.
So, there is really very little reliable baseline data on that area and its
resources since all of the studies were done quickly after the fact with money
from the military by hand picked government contractors that just went through
the motions.
Since the rocket accident on August 25th, the
area has been completely cut off to the public and we have been told next to
nothing about the impacts, contamination issues, clean up efforts or when it
will reopen. Solid rocket fuel contains perchlorates, normally discharged in
rocket exhaust, but since the fuel blew up, it was scattered all over the area.
Perchlorate contamination in the environment has
been extensively studied as it has effects on human health. Among the health
impacts, perchlorate has been linked to its negative influence on the thyroid and can block hormone production in people and
wildlife. Exposure to perchlorates has also been linked to various
cancers. And this, among other contaminants,
is what has been and will be added to the environment of this public
recreational area in the future.
How can you even begin to evaluate
the cumulative impacts of a third launch pad and the accuracy of your
environmental data before knowing the compounded levels of contamination that
resulted from previous launches, the August 25th accident and
without reliable baseline data?
The location of proposed Launch
Pad 3 is located on a ridge on the south side of the public road leading down
to Fossil Beach. Presently, all of the KLC structures are on the north side. If
built, this would extend the footprint and area of impact as well as straddle
the public road. That would give
the KLC and AAC even more reason to block it off and maintain complete control
over the area. This is unacceptable!
If there is to be more
construction, it should be confined to the north side of the road so that
public access is guaranteed to Fossil Beach and Narrow Cape. Why spread out the
impacts more than necessary? I
have read the geologic justification for the preferred location but do not
think others on the north side were adequately evaluated or considered,
especially in respect to the public access issue.
At present, we can’t even access
the beautiful long beaches to the north of the KLC.
And what about the damaged
facility? Who will pay for the repairs and mitigation?
As a real, viable alternative for
the EIS, why not consider dismantling the entire KLC?
How can the construction costs of
yet another launch pad be justified with so few launches in the past, no
contracts on the horizon, and in the aftermath of the accident, the rising
cleanup costs? And, at the expense of such valuable public land!
In closing, the best option for the KLC is to dismantle it,
not to expand it.
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