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

September 28^th, 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 21^st 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 25^th, 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 25^th 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.

29 September 2014: FAA Draft EA for Launch Pad 3 Call for Comments, Public Meeting

Dear Recipient –

In compliance with FAA policy and procedures (Order 1050.1E, Change 1) for implementing the National Environmental Policy Act, as amended (42 U.S.C. 4321 et seq.), the FAA has initiated a public review and comment period for the Draft Environmental Assessment (EA) for the Kodiak Launch Complex Launch Pad 3 (Draft EA).  The Draft EA also is available on the FAA Office of Commercial Space Transportation website at: http://www.faa.gov/about/office_org/headquarters_offices/ast/environmental/nepa_docs/review/documents_progress/kodiak_launch/[[

[Note – the full Draft EA will be posted on the website by 9/16]

The FAA encourages all interested parties to provide comments concerning the scope and content of the Draft EA by October 15, 2014.  Comments should be as specific as possible and address the analysis of potential environmental impacts and the adequacy of the Proposed Action or merits of alternatives, and the mitigation being considered.  Reviewers should organize their comments to be meaningful and inform the FAA of their interests and concerns quoting or providing specific references to the text of the Draft EA. Matters that could have been raised with specificity during the Draft EA public comment period might not be considered if they are raised for the first time later in the decision process.  This commenting procedure is intended to ensure that the FAA receives substantive comments and concerns in time to address them in a Final EA.

The FAA will hold an open house public meeting on October 7, 2014, from 5:00 p.m. to 8:00 p.m.in the Katurwik Room of the Kodiak Inn Best Western, located at 236 E Rezanof Drive, Kodiak. The public will be able to speak to project representatives one-on-one and submit written comments or provide oral comments to a stenographer.

Please submit comments in writing to Stacey M. Zee, Federal Aviation Administration, c/o ICF International, 9300 Lee Highway, Fairfax, VA 22031.  Comments may also be submitted via e-mail to FAAKodiakEA@icfi.com

For any media inquiries, please contact Hank Price at 202-267-3447.

Stacey M. Zee

Office of Commercial Space Transportation

Federal Aviation Administration

800 Independence Ave, SW

Washington, DC 20591

Spaceport Infrastructure Still an Unknown Frontier

Wednesday, October 24, 2012  |  as of 8:07 PM ET

Washington - Infrastructure

Spaceport Infrastructure Still an Unknown Frontier

by: Kyle Glazier

Wednesday, October 24, 2012

WASHINGTON — Spaceports are popping up all over the United States, as both existing airports and brand-new facilities position themselves to profit from a new age of commercial space travel and transport, but the industry is still in its infancy and faces significant challenges.
Currently eight facilities in the U.S., some of which are bond-funded or are owned by bond-issuing authorities, are licensed for space launches by the Federal Aviation Administration’s office of commercial space transportation.
The facilities that are leading the way are the Mid-Atlantic Regional Spaceport in Wallops Island, Va., the Cecil Field Spaceport in Jacksonville, Fla., Spaceport Florida at Cape Canaveral, Spaceport Oklahoma in Burns Flat, Okla., Spaceport America in New Mexico, Mojave Air and Spaceport in Mojave, Calif., Vandenberg Air Force Base near Lompac, Calif., and the Kodiak Launch Complex on Kodiak Island, Alaska. Those facilities have been planned and financed with an eye to the future.
The idea is that, especially with the end of the Space Shuttle program in 2011, the day is fast approaching when space tourism and transport will be big business, and spaceports capable of handling vertical rocket launches and returning craft will be in position to reap economic benefits for their regions and investors.
These launchpads could also become centers for commercial satellite launches, educational trips sponsored by universities, and other possibilities, causing the FAA to estimate increased demand for them.
The agency annually produces a forecast for space launch demand, and it has been growing. The 2012 report projects a yearly demand for 29.1 commercial space launches worldwide from this year through 2021. That number was 28.6 in the 2011 forecast, and 27.6 in the 2010 projection.
The first U.S. commercial spaceport, Spaceport America, signed a 20-year lease with billionaire Richard Branson’s Virgin Galactic in 2009. Construction of the more than $200 million facility was supported by $100 million of New Mexico oil and gas severance-tax bonds and $51 million of sales-tax revenue bonds issued by a spaceport district comprising the local Sierra and Doña Ana counties.
In September, the Virginia Commercial Space Flight Authority, a body legislatively empowered to issue debt, reached a memorandum of understanding with Orbital Sciences Corp. pledging state support for improvements at the Mid-Atlantic Regional Spaceport. The MARS facility will play host to a series of 10 rocket launches under the agreement, and the VCSFA will retain the improved facility for use by future customers.
Jacksonville’s Cecil Field Spaceport, owned by the Jacksonville Airport Authority, obtained its spaceport designation in August. As with Spaceport America and MARS before it, Cecil’s new space-age bona fides generated excitement about the potential for future economic growth.
“It is critical that we continue to focus on, and invest in, infrastructure projects that will directly benefit our state’s economy,” said Florida Gov. Rick Scott after signing into law the facility’s designation as a spaceport. “Having Cecil Field designated as a spaceport will play a major role in the continued development of Florida’s aerospace and aviation industries and will continue to keep our economy heading in the right direction.”
While both the FAA and private firms agree that demand for commercial spaceports is likely to increase in coming years, the industry is still so young that the potential for growth variance is huge and the unknowns are vast.
“We are dealing with an industry which has not yet begun to operate,” said Derek Webber, director of commercial space flight consultant firm Spaceport Associates in Damariscotta, Me. “It will probably not begin before 2014. How many spaceports will be needed to satisfy the market once it gets started? No one knows.”
A revenue and demand study produced by the Tauri Group in Alexandria, Va., produced three divergent 10-year scenarios, including a “constrained” forecast, a “baseline” scenario, and a “growth” estimate. The baseline estimate, extrapolated from today’s consumer demand and research budgets, predicts $600 million of revenue from suborbital space flights over a decade. The constrained estimate, based on a possible drop in demand, cuts that in half to $300 million.
The growth estimate reflects an increase in demand, and hits $1.6 billion of revenue. The study also notes the possibility that demand could react to “game-changing unknowns,” such as price reductions, new research, sponsorships and other variables.
“Demand for suborbital flights is sustained and appears sufficient to support multiple providers,” the study concludes.
Webber said it’s impossible to know now whether states and localities that undertake the cost of building spaceport infrastructure will see a payoff any time soon. Spaceport America has pledged to be self-sustaining through the collection of tourism revenue from visitors popping by to take a look at the launch pad. Some of the facilities are not yet at the imminent operations stage, and their future is even more uncertain.
A Moody’s Investors Service analyst said said Cecil Field remains a general aviation airport that hopes to become a spaceport someday. Even knowing when the economic payoff has been reached could prove tough, according to Webber.
“We shall have to monitor a whole range of items,” he said. “How many people are employed at the spaceport? How many were employed in building it? What impact has the spaceport had on the education in neighboring schools? Do the kids become more interested in science, math and technology? How much money do the rich space tourists spend in the region of the spaceport in goods and services? How many family and friends do the space tourists bring with them when they do their trip? How long do they spend in the spaceport region before, during and after the flight? How successful is the new spaceport at attracting terrestrial tourists who come merely to visit for the day, and are not necessarily associated with any specific space tourism flight?”
There is a small amount of federal money available for spaceport development. The FAA’s space transportation infrastructure matching grants program provided $500 million for the initial development of three possible new spaceports in Colorado, Hawaii and California.
The majority of costs, though, will still fall on state and local entities and their private sector partners. The grants can fund up to 50% of a project, but require that at least 10% of development dollars come from the private sector.
“Those states that are supporting these developments are betting on a future which is based on known American values,” Webber said. “Pushing boundaries, taking risks, making a buck, looking forwards rather than backwards. The citizens of New Mexico who have supported the building of Spaceport America are doing this to ensure that their children and grandchildren in this poor part of the country will have something exciting in their futures instead of simply tumbleweed.”