August 11, 2020

To: State Historical Resources Commission


Re: Burro Flats Cultural District [Traditional Cultural Property]

Dear Commissioners;

My name is Michael Collins. I am the lead reporter at, an online news organization since 2006. I have reported on the Santa Susana Field Laboratory (SSFL) since 1998.

I was a Section 106 Consulting Party for NASA beginning in 2013. I am compelled to write to you to warn of the grave consequences of granting this historic designation at this time based on information I have put together over the last six weeks.


The nomination is actually invalid as it does not fulfill your regulations, is demonstrably fraudulent in misrepresenting the true condition of the site, and will be used by the NASA and the Santa Ynez Band of Chumash Indians (Chumash) as a way to get out of all cleanup of SSFL, not just some of it.

That would be disastrous for Chumash who end up visiting the site, the region and people around SSFL, and countless thousands of future visitors lured to the site because of your actions today.


Evidence shows that NASA deceptively switched the objects of its ‘historic designation,’ the rocket test stands and their “districts” to the entire site as an American Indian ‘sacred site.’ The plot came after this reporter repeatedly called the agency on its failure to properly acknowledge SSFL’s notorious and controversial Nazi origins when I was a Section 106 Consulting Party from 2013 to 2014.

It was a classic bait and switch. Now the test stands are just “noncontributing buildings and structures” and the Nazi history not even needed to be recalled and retold in relation to the rockets, stands or Rocketdyne back in the day.

I also found information in NASA’s Final Supplemental Environmental Impact Statement for Soil Cleanup Activities at SSFL (FSEIS) July 24 showing that while the Chumash claim that their “church” has been contaminated publicly and that they don’t want to impede the cleanup with their involved oversight, the tribal chairman Kenneth Kahn actually spoke out against all cleanup by all entities at the lab.

Kahn decried the cleanup and declared that “The local Native American communities consider the area significant and believe the area retains all aspects of integrity.”

“Cultural resources at SSFL have been, and would continue to be, impacted by previous and future actions, particularly grounddisturbing [sic] activities such as soil excavation and test stand removal, which could impact archeological deposits,” Kahn wrote in Tribe Comments. “The cumulative impacts of NASA, DOE, and Boeing activities would result in increased significant and negative impacts to cultural resources at SSFL.”

That would include remediation plans to remove the rocket test stands which are vectors for enormous amounts of soil and groundwater pollution underneath them as well as the incredibly radioactive sites in Area IV.

Killing the cleanup through ceding the property to the Chumash after this designation’s eventual passing could leave enormous amounts of radiation and chemical contamination throughout Rocketdyne. Allowing that kind of environmental menace, and ongoing threat to the public health of the hundreds of thousands who live downhill of SSFL of all colors, is a grave insult to Native Americans and to their neighbors and friends.

It’s an insult to your intelligence. You can stop it. Now or never.

Consider the consequences if you don’t. Tribal chairman Kahn indicates a complete cleanup shutdown to stop “increased significant and negative impacts to cultural resources at SSFL.”

Kahn should be taken at his word. He should also be taken at his word in an interview with the Los Angeles Times. “I don’t care how many casinos we build,” he said in 2004. “We could never overcome what was taken from our ancestors.”

This isn’t the first time NASA has tried to unload the fouled land on willing Native Americans, in this case the very same casino-operating Santa Ynez Band of Chumash Indians. The band seems willing to accept the entire lab in recent statements even with the enormity of the contamination at the rocket test stands and the mountain of toxic garbage on NASA’s Area II property.

NASA declared its 451.2 acres as “excess” federal property in September 2009. The federal General Services Administration then tried to transfer the land to the tribe. There, again, was public outrage, and Ventura and Los Angeles counties opposed such a transfer and it didn’t occur.

That appears to remain the strategy of NASA, except for one hiccup when this reporter called the agency on whitewashing out SSFL’s extensive Nazi history. That may have forced the agency to consider selling the giant hot zone more as a unique and unblemished religious complex of ancient indigenous peoples. Or it was the cynical plan all along.

Then NASA could continue to ignore its sordid past and exploit the 11.4-acre painted cave site as just being part of a much more massive ancient complex that just happens to have Boeing’s exact property lines as a historic district, declare it on the National Register of Historic Places, transfer it to a local tribe or tribal consortium and build a casino, exempt from environmental laws.

The result would be no cleanup which would continue the ongoing saga of contamination, cancer, threatened property values and, perhaps most importantly, people of color are on the receiving end of these poisons which afflict them far more seriously than whites. That includes the Native Americans that would own and work on land the tribe developed as a casino, shops or anything they want. It would also include the millions of Southern Californians that are downwind and downstream of it for generations to come.

NASA’s Burro Flats Historic District plan boldly states obvious falsehoods such as the “district retains all aspects of historic integrity” and that the “places still look very much as they did before the Europeans arrived; they have not been torn out or built over. They are a part of the local Native American identity that has endured into the twenty-first century.”

That ridiculous and racist lie reflects the insidious influence of the Trump Administration where telling the most outrageous falsehood is somehow acceptable. In fact, NASA’s plan cites as one of its “Major Bibliographical References” a notorious race-baiter of American Indians already exposed for his public, racist Native American and homophobic jibes, John Luker, as widely reported in 2016.

The plan falsely characterizes the consultants as indicating that “the district has been used for various scientific purposes since the 1940s, overall integrity is still excellent. The use of SSFL by the government and Boeing resulted in keeping the area in a state similar to when the consultants’ ancestors used and occupied the area.”

The consultants did no such thing. Indeed, we were actually talking about a different subject – historic districts involving the rocket test stands since the Native American sacred cave on the site had been federally protected and inaccessible to the public since 1976. We were consulting about the aerospace historical value of the place’s missile test stand districts.

NASA pulled a bait-and-switch once it ran into a wall of its own making – SSFL’s Nazi history. This reporter, who has kept this NASA consultancy information confidential until now, called NASA on Rocketdyne’s Nazi past and the space agency switched gears and started seriously pushing this scheme to rebrand the lab, call the whole thing a Chumash church, and walk away congratulating themselves.

When this reporter asked to join the NASA Section 106 process for its SSFL property in 2013, the consultants had already been meeting for a year and a half, including John Luker. The focus of the NASA-led group was the historic significance of SSFL’s rocket test stands sited at the Alfa, Bravo and Coca complexes and should they be saved.

Many of the consultants at the Nov. 1, 2013 meeting argued for keeping the Coca test stand complex over the admonitions of NASA which preferred the Alfa and Bravo complexes. “The most contaminated district is Coca,” said NASA moderator Jennifer Groman.

“The overall estimate is that it’s going to be extremely hard to achieve cleanup at Coca with the test stands in place,” Groman continued. “Secondly, based on the comments we have including those of Native Americans, the Santa Ynez themselves… it’s in a highly sensitive location on the site.”

Groman also addressed the Burro Flats Painted Cave, reflecting NASA’s focus on the test stands and the cleanup in 2013, not 2020. “We only have a small imprint that’s even near it [the cave]. Our hope is not to go in [to the cave during cleanup].”

NASA said as much when summarizing the previous Sec. 106 Consulting Party meeting in notes given to the consultants including this reporter. “[B]ecause the site is already on the National Register and NASA has also provide a buffer area to further protect it, NASA believes it has met its obligations to identify historic properties under Section 106,” NASA wrote.

That was then and this is now. Now, the rocket test stands and district buildings don’t even matter according to the historic plan you are asked to sign off on:

“Fifty-eight noncontributing resources include Santa Susana Field Laboratory (SSFL) buildings, sites, and structures that do not add to the historic associations for which this the property is significant because they are not related to the documented traditional cultural significance of the property.”

“The noncontributing buildings and structures occupy a small fraction of the district, and removal of many of them is anticipated,” the NASA proposal boldly lies before adding another falsehood. “The community has indicated that the presence of these noncontributing resources does not affect the overall integrity or significance of the cultural district.”

The space agency’s untruths in the historic designation proposal reach new heights with this whopper: “These places still look very much as they did before the Europeans arrived; they have not been torn out or built over. They are a part of the local Native American identity that has endured into the twenty-first century.”

Not only is that history wrong, it is dangerous. Removing environmental promises meant to remediate SSFL endangers the entire region. The true history of contamination can’t be argued away by new definitions of what “history” is. History is truth. Your job is to make sure it stays that way.

The cave ostensibly needing to be protected already is by law. It has been since 1976. It’s outlined in the 2010 Administrative Orders on Consent where NASA and DOE agreed with the state DTSC to clean up to background levels of contamination. No cave or tree or anything even remotely associated with the Chumash would be touched if the cleanup actually were to start.

The Burro Flats cave paintings, for example, would thus be protected, as would other artifacts. But the entire 2850 acres of land surrounding the cave paintings are not exempt from cleanup; to the contrary, the agreements require their cleanup.

That, however, is what NASA is attempting to now create—a potential “get out of jail free” card for it and the other SSFL Responsible Parties from cleaning up the widespread radioactive and toxic chemical contamination and damage to the site created by seven decades of their environmentally irresponsible actions.

While the Trump Administration’s NASA dangles the polluted lab in front of the Chumash as ripe for the picking, it’s actually the Chumash who will end up being picked, pickpocketed that is. Should Trump’s NASA somehow succeed getting the tribe to take responsibility for these rusting rocket test stand hulks, it would be a stunning coup by the U.S. government.

Getting a sophisticated gambling powerhouse tribe’s pride and greed to fool it into taking on Rocketdyne’s tainted land and test stands would set a new standard for institutional own-goals. White Man wins again.

Don’t do it. Send NASA packing because it has tried to sell you on completely false representations. It assumes you are too daft or too corrupt or a combination of both to see through this sad turn of events.

When the place is finally cleaned up, all the artifacts found will be immediately handled carefully and correctly. The land will [be] as it was when the Painted Cave began so long ago.

Then will be the time to take this action. Now isn’t that time.

Michael Collins