To the Keeper at the National Register of Historic Places (NRHP);

I urge you to reject NASA’s nomination of the “Burro Flats Cultural District” as a former Section 106 Consultant on this site.

If successful, NASA can claim that exemptions in the 2010 cleanup agreement designed to protect Native American artifacts that are “formally recognized” apply to the entire site – meaning none of it would get cleaned up.

The Ventura County Board of Supervisors, who have long supported the full cleanup of SSFL, voted unanimously to oppose the plan July 28. The historic designation scheme encompasses the whole site, not just NASA’s land. That would include Area IV which saw three partial nuclear meltdowns on its land including America’s worst in 1959 when a third of the Sodium Reactor Experiment’s fuel melted releasing huge amounts of radiation over the lab and surrounding expanse.

NASA deceptively swapped the objects of its former push for historic designation which were its rocket test stands, for a new “Burro Flats District” that includes the entire SSFL. Now the test stands are just “noncontributing buildings and structures.”

NASA’s use of NRHP status to exploit exemptions in the cleanup agreement could leave enormous amounts of radiation and chemical contamination throughout the site, which would remain an ongoing public health threat for hundreds of thousands who live downhill of SSFL and serve as a grave insult to Native Americans and to their neighbors and friends.

NASA did not mention a word about SSFL’s contamination in its nomination for the NRHP. Its sole justification for expanding the 11.74-acre Burro Flats Painted Cave site to 2,850 acres is that site activities protected the land, claiming that, “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.” This ghastly twisting of truths not only omits SSFL’s contamination, but also the physical degradation of the property as it was developed into a field lab with roads, buildings, nuclear reactors, enormous rocket test stands as well as toxic earthen pits.

At the same time that NASA announced its intention to leave most of the contamination on its portion of SSFL not cleaned up, it was pushing a scheme to gain NRHP status for SSFL by expanding the Burro Flats boundaries to encompass the whole site. The Burro Flats complex is already listed in the NRHP and has been since 1976. Just last month, based on subsequent studies, the NRHP reduced the Burro Flats area from 25 acres down to 11.74, making NASA’s attempt to expand it to 2,850 acres even more astonishing.

The nomination 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.”

NASA’s consultants did no such thing. I know because I was one of those consultants. 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.

When this reporter asked to join the NASA Section 106 process for its SSFL property, the consultants had already been meeting for a year and a half and the group was heavily populated by anti-cleanup people eager to declare all the rocket test stands as “historic.” That would gut the cleanup of NASA property because the test stands are built over where the heaviest contamination is, like the subterranean dirt lake of the solvent TCE which was used to hose down rocket engines to clean them inside and out after test firings.

“NASA accepts your request to become a Section 106 Consulting party,” wrote NASA’s Merrilee Fellows Sept. 25, 2013. “Your interest and experience will be helpful as we move through the NHPA Section 106 process concerning proposed actions that could impact historic districts and archaeological sites on NASA property at SSFL.”

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. Or at least that’s what it seemed to be according to NASA moderator, Jennifer Groman. “You’re the new guy,” Groman said by way of greeting over the telephone.

“The undertaking in this case; it’s very complex,” Groman explained, bringing me up to speed as the other consultants listened. “It’s the demolition of the structures here on the NASA site as well as the ground cleanup and the groundwater cleanup. And that’s all shown in the draft EIS and our scoping, and the role of the consulting parties is to give NASA a perspective of different folks, what their concerns are regarding the proposed undertaking effects the historic properties and those are defined in that regulation and then our role as an agency is to try to avoid, or minimize or mitigate adverse effects if there are adverse effects.”

Indeed, the work of the Section 106 consultants was to advise NASA on, most importantly, removal or preservation of the test stands. The groundwater cleanup was a function of getting remediation “air-stripping” wells to evaporate off the TCE. Before the prior air stripping extraction wells were turned off over a decade ago, they were successfully removing just 10 gallons of the carcinogen a year which would take close to 100,000 years to complete at that anemic rate.

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 Groman.

“In terms of the sacredness of this site, people came along after the Chumash and have defiled it,” this reporter-as-consultant said at the meeting, noting that the test stands had to come down to get at the goo. “The removal of the defilement of a site is the best way to honor a sacred Native American site.”

“The costs to keep them up exceeds the cost of demolishing them, since you brought that up,” said Groman to me. Groman also addressed the Burro Flats Painted Cave, reflecting NASA’s focus on the test stands and the cleanup in 2013. “We only have a small imprint that’s even near it [the 11.74-acre cave site area]. Our hope is not to go in [to the 11.74-acre cave site area 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.

I again urge you to reject NASA’s nomination of the “Burro Flats Cultural District” as a former Section 106 Consultant on this site. Please people first by allowing full remediation of the site before such a designation, which should only be for the already-protected 11.74 acres of the Burro Flats Painted Cave.

Thank you for this opportunity to comment.

Michael Collins