January 17, 2014

Michael Collins Sec 106 PA Comments

Thank you for considering my Consulting Party comments regarding the Draft Programmatic Agreement (PA) among the National Aeronautics and Space Administration (NASA), the California State Historic Preservation Office (SHPO) and the Advisory Council on Historic Preservation for demolition, soil and groundwater cleanup at the Santa Susana Field Laboratory (SSFL).


1. NASA’s decision to include its entire portion of SSFL as a “Traditional Cultural Property” was imparted to its Consulting Parties (CPs) in a December 19, 2013 e-mail from NASA’s Allen Elliott in which he wrote;

“The PA also includes mitigation for the impacts to the Traditional Cultural Property. The TCP study did find a TCP at SSFL but its location is considered confidential, so for the purposes of S106 and NEPA, NASA has assumed that its entire property is a TCP as this coincides with the Indian Sacred Site. The Indian Sacred Site does not fall under Section 106 but the TCP does. For the purposes of S106 we are assuming that the TCP meets the criteria of the National Register.”

While I disagree with designation as it relies on two assumptions not vetted publicly, it is still important to note that with this designation, if NASA fails to comply to the letter with the Agreement on Consent (AOC) and not clean up its portion of SSFL to background levels of contamination, it will have disrespected and abused the Native Americans who hold this land sacred. Therefore, by designating its entire portion of SSFL at a TCP, NASA is even more indebted to Native Americans, and Americans in general, to clean the entire area up to background while making sure not to disturb the Burro Flats Site, the Rock Shelter, Sparse Lithic Scatter and the sites where Chumash grinding depressions, or mortars, are clearly identified (as in the Boeing’s 2014 Santa Susan Calendar given out at a recent Community Advisory Group meeting in a photograph by Merilee Fellows on the January 2015 page).

2. Alpha, Bravo and Coca should be demolished entirely as it will be impossible to clean these areas to background without removing these structures. While these structures certainly have historical significance, there are other NASA facilities in the country that have kept older test stands to commemorate America’s race to space as Mr. Elliott has pointed out in a meeting with the CPs.

3. Alpha, Bravo and Coca should be demolished entirely because to ‘renovate and encapsulate’ these structures, freeing them of lead paint, asbestos and other toxic materials, would be cost prohibitive and not feasible over the long haul as they would have to be repainted approximately every five years according to NASA.

4. Should NASA choose to keep one of these structures standing, then it should fully note its historical origins in relation to Wernher von Braun and his Nazi past. NASA should assure the CPs and public that this past will be part of the historical presentation along should Alpha or Bravo be ‘saved.’ Von Braun’s work was responsible for much of the activity at SSFL and it is part of the historical record.

Indeed, NASA should do this anyway even if all three test stands are demolished as the first test stand built at SSFL was to test von Braun’s designs. As I wrote in “Bowled Over” for EnviroReporter.com in 2009:

The Vertical Test Stand I, or VTS-I, is an exact copy of a German World War II test facility at Peenemunde that developed and tested the terrifying Nazi V-2 rocket.

The V-2, or Vergeltungswaffe 2, was the first ballistic missile to reach sub-orbital spaceflight and was the forerunner of modern rockets. Over 3,000 V-2s were launched at Allied targets by the German Wehrmacht in World War II, killing an estimated 7,250 military personnel and civilians, mostly in London.

Over 20,000 Mittelbau-Dora concentration camp inmates died constructing V-2s, with 9000 dying from exhaustion alone. Around 350 of these Nazi slaves were hanged, including 200 for sabotage, with the remainder shot or dying from disease and starvation. Von Braun, an officer in the Waffen-SS from May 1940 until the end of the war when he escaped with 120 scientists to surrender to the Americans, admitted working at the V-2 plant many times but denied ever visiting the nearby concentration camp.

However, von Braun disclosed in an August 15, 1944 letter to the manager of V-2 production that he personally selected labor slaves from the Buchenwald concentration camp to work at the rocket factory, slaves he described 25 years later in an interview as being in “pitiful shape.”

Equally at home in photographs with Hitler and Himmler as well as Presidents Eisenhower and Kennedy, von Braun’s work on the Apollo Space Program earned him the National Medal of Science from President Ford in 1977.

NASA should consult with the Los Angeles Museum of the Holocaust over the proper way to accurately depict this shameful history.

In summation, I strongly suggest that the only way to appropriately respect Native American history at the site is to abide by the AOCs and clean to background.

Any Native American, or Native American representative, who doesn’t insist on this does not have the right to claims on the land for any supposed historical or religious reasons, in my opinion.

Any American who uses taxpayer dollars to maintain historic structures at SSFL without clearly outlining its connection to a famed Nazi rocketeer, who killed thousands of innocent civilians and concentration camp victims, is tacitly approving of those horrendous crimes against humanity, in my opinion.

Thank you for the opportunity to submit these comments.

Michael Collins
NASA Section 106 SSFL Consulting Party