A Response to John Luker's Open Letter from Chris Rowe

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A Response to John Luker's Open Letter from Chris Rowe

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To: Santa Susana Field Laboratory Community Advisory Group (SSFL CAG)
SSFL Community Advisory Group
Website: ssflcag.net
Email: mail@ssflcag.net
February 28, 2014
“An Open Letter to Elected Officials Concerning Cleanup at Santa Susana Field
Dear SSFL CAG members,
I do not take any enjoyment in writing to you about a CAG member’s personal post.
I do believe in working in a civil manner with other stakeholders. However, when I
saw the letter referenced above, I wrote to Mr. Luker, and I requested that he
respectfully make changes to his letter to indicate that the letter was from him as an
individual, and not as a representative of the CAG or the Section 106 Consulting
Parties. He refused to make those changes.
The comments that I received from CAG members was that the letter was posted
with a disclaimer on the website that stated that the letter was from Mr. Luker as an
I see two problems:
1. It is signed by John as the Chair of the Communications Committee
with no disclosure within the body of the letter that was sent out that
it is from him as an individual;
2. In the paragraph below, and throughout the letter, Mr. Luker
references “the community”, “our”, “us”, and “we”.
“To: Local, State, and Federal Elected Officials (See specific addressees on final page)
On February 13, 2014, the community participated with NASA in the final meeting
of National Historic Preservation Act (NHPA) Section 106 Consultations about historic
and cultural preservation at the NASA-administered section of the Santa Susana Field
Laboratory. Our observations and our request for your engagement follow.”
“The potential loss of these test stands concerns us.”
“The community needs to do several things before January 2016”
“Our Request”
“Our community”

“We need your help”
“We need the rest of the community to join us in this important endeavor.”
“Until the community can agree on common goals”
“We are committed to clean up, preserve, and protect human health and the
“We need your offices to engage in reasoned discourse toward these goals.”
Frankly, I find it difficult to keep up with the public comment documents, the
documents that are uploaded, and the information that is put out by “stakeholders”
who either have not read the technical documents, or who are misled by others who
are involved in the SSFL cleanup process. I do not want to be going to the CAG
website to look for additional documents to comment on.
The bottom line is this – it is my opinion that the letter that was written by Mr.
Luker and was distributed by Mr. Luker is full of misinformation regarding the
position of the NASA SSFL Section 106 Consulting Parties. Furthermore, it is my
opinion that the discussions of what was said in those meetings is supposed to be
confidential with the exception of minutes that are posted by NASA.

In the letter that was posted on the website, Mr. Luker stated:
“The consensus of the Section 106 consultants is that at least one stand from each area
should be preserved in place.”
In the FINAL version, Mr. Luker states:
“Three opinions were held by Community members and resource
professionals at the Section 106 Consultations.”
I. “At least one test stand from each of the three historic districts, Alpha,
Bravo and Coca, should be preserved as the physical embodiment of a
watershed development in Human History: leaving the earth and
traveling to another celestial body. The Santa Ynez Band of Chumash
Indians does not support this position for Coca.”
Mr. Luker makes these statements as if they are the ONLY positions of the
“community members and resource professionals” at the Section 106 Consultation
meetings in my opinion. Furthermore, many people, including the Native Americans
(in my opinion), hesitate to state their opinions at these meetings and on the calls
because they want to give their opinions to NASA and to the SHPO – quietly.
It is obvious that Mr. Luker made changes to his letter from v3-4 to the 106 +Final.
So it is obvious that Mr. Luker took the time to revisit the letter before he sent it out, he
chose, in my opinion, to ignore the many comments that I highlighted and made
comments to in a letter to him and other members of the SSFL CAG.
NASA has, in my opinion, accurately stated why they intend to demolish COCA. I do
not believe that this opinion was made without consultation of NASA’s upper
management, and without consideration of many factors including the ability to
remediate the area around and under COCA, and the problems with painting and
sealing the COCA test stand and associated structures.
Discussion related to COCA is within these minutes from the November 1, 2013, NASA
Section 106 Consulting Party meeting.
“A consulting party asked why the Coca test stands could not be preserved as well. Ms.
Groman replied that the Coca test stands were the most highly contaminated and would be
the costliest to maintain. The area is also within view of a sensitive Native American site and
one of the tribes would prefer the buildings at Coca be removed. Two consulting parties
suggested that the prehistoric astronomical use of the area by local tribes and the modern
space program use of the area dovetail together and only a small part of the Coca facility is
visible from the Native American solstice viewing area.
Multiple parties suggested the Coca stands are the most historically significant; since both the
Apollo and Space Shuttle programs tested engines there, it is the pinnacle of research at SSFL.
Another party stated that none of the test stands could be saved since they are all
contaminated and could possibly contaminate the Los Angeles River and thus the city of Los
Angeles, and that the test stands represent a safety risk as they could fall down and injure
someone. Ms. Groman suggested that the results of the FS6 sampling program will influence
which test stands and control houses would need to be demolished.”
I have been asked if there are any community stakeholders who can speak on behalf
of all of the Section 106 Consulting Parties; there are not in my opinion. The
opinions of the Section 106 Consulting Parties are too diverse for one person to
represent all positions. There is no unanimous consensus on most positions.
I also want to make it very clear that the Section 106 Consulting Parties have not
ever considered a hotel as part of the future use of the U.S. Government aka: NASA
property. Furthermore, this concept needs to be vetted by the real community – the
neighbors of the Santa Susana site that would bear the traffic, and who would bear
the problems associated with commercial development on this property.
This line is absolutely inappropriate in a public document due to a complete lack of
sensitivity and a lack of cultural awareness in my opinion.
“A member of a Native American group (who shall remain nameless) has said: “…Data Recovery! You’re NOT going to dig up my grandmother, clean her
femur and give it back to me in a box!”
I highly recommend that the CAG not allow letters signed by one person to be
posted with the terms “we” without signatures and reference to who the “we” are.
I also recommend that titles of individuals writing individual opinions be listed as
“for identification purposes only”.
 And furthermore, Mr. Luker’s presentation at the most recent CAG meeting was a
reflection, in my opinion, of presentations that he has made including at the
SSMPA. It did not reflect the definition of what a Section 106 Consultation was (in
my opinion), or what was discussed there without, in my opinion, combining it with
his views of the future use of the property.
Finally, as an FYI, Mr. Luker makes reference to how archaeology is defined, but he
does not define it:
“The definition is vague and inconsistent with how archaeology is defined by
CEQA, NEPA, NHPA, and resource professionals who use these laws on a daily basis.”
“The National Parks Service has spoken publicly and stated in their comments
on the NASA DEIS that they look to acquire “Nationally Significant
Properties.” They cannot take contaminated land, but, if all the test stands and
archaeology are removed, the significance of the property disappears and a
multi-year, multi-million dollar weed abatement and re-vegetation project will be
needed. NPS will not want the property under those circumstances.”
You cannot remove the archaeology. Archaeology is defined, by Stein and
Rowe Physical Anthropology 11th
 Edition as: “The scientific study of the past
and current cultures through the analysis of artifacts and the context in
which they are found.”
Therefore, the appropriate term to have used is artifacts. You could state:
“They cannot take contaminated land, but, if all of the test stands and
artifacts (and the context in which they are found) are removed…”

Chris Rowe
NASA SSFL Section 106 Consulting Party
SSFL Community member and technical stakeholder
West Hills resident of 36 years