29 September 2014

28 September 2014: Kodiak Resident Comments on Launch Pad 3 Draft Environmental Assessment

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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