Waking up the Military Reprinted from Earthpulse Flashpoints, Newtext Number
Two.
Editor's Note: The following letter is reprinted with
permission of Trustees for Alaska. This organization is pursuing
inquiries into the HAARP program. We are cooperating with them in
their attempt to help in this matter. The letter encapsulates the
latest information on this project.
The primary support for our efforts in opposing the
HAARP program has come from conservative organizations who have, over
the last year, asked us where the environmental community was on the
issue. We are pleased to be joined in our opposition to HAARP with
what is quickly becoming a coalition of both conservative and liberal
organizations. The true American character is demonstrated when issues
of mutual importance can be embraced by diverse interest groups and,
most importantly, by remarkable individuals.
Please forward your own letter to John Heckscher
expressing your concerns and opinions on this project. May 8, 1996
John Heckscher PL/GPIA Hanscom AFB, MA. 01731-5000 Re: High-frequency
Active Auroral Research Program (HAARP)
Dear Mr. Heckscher,
Trustees for Alaska, on behalf of itself, Greenpeace,
National Audubon Society, Alaska Center for the Environment, Sierra
Club, Alaska Wildlife Alliance, Northern Alaska Environmental Center
and National Wildlife Federation, hereby request that the United
States Air Force prepare a
supplement to the July 1993 Final Environmental Impact Statement
(FEIS) for the operation of the High-frequency Active Auroral Research
Program (HAARP). As you have correctly noted in various fora
(including at the recent State of Alaska House of Representatives,
State Affairs Committee HAARP Oversight Hearing), the Air Force has a
continuing duty to comply with the National Environmental Policy Act
(NEPA) by preparing a supplemental EIS should certain conditions be met.
As detailed below, given the apparent substantial
changes in the project and significant new information relevant to
environmental concerns about HAARP, we believe this duty has been
triggered. Should the Air Force disagree as to the mandatory nature of
this duty, we still request that a supplemental EIS be prepared using
your discretionary authority to do so. Finally, the Air Force should
fund and support an independent review and
monitoring effort to alleviate the public's concerns about the project.
I. The National Environmental Policy Act:
To put our request in context, and before we enter into
a discussion of the changed factual circumstances mandating the
preparation of a supplemental EIS, we set out a brief overview of the
relevant legal structure. As you know, NEPA requires a federal agency
to prepare an EIS whenever it undertakes a "major...action
significantly affecting the quality of the human environment."
42U.S.C.'4332(2)(C). The Air Force recognized that HAARP triggered the
NEPA duty to prepare an EIS and, in the summer of 1993, the Air Force,
in cooperation with the Navy, released the Final Environmental Impact
Statement for HAARP. See FEIS Volumes I and II (July 15, 1993). Later
that year, the Air Force issued its decision to proceed with the
project. See Record of Decision (ROD) (October 18, 1993).
The Council on Environmental Quality (CEQ) is the
principal agency responsible for the administration of NEPA.
42U.S.C.'4342. CEQ has enacted regulations implementing NEPA. 40
C.F.R. 1500.1 et seq. The CEQ regulations require federal agencies to
supplement an EIS when: (i) The agency makes
substantial changes in the proposed action that are relevant to
environmental concerns; or (ii) There are significant new
circumstances or information relevant to environmental concerns and
bearing on the proposed action or its impacts. 40 C.F.R. '
1502.9(c)(1).
In addition to the CEQ regulations, each federal agency
has its own set of regulations adapting the CEQ regulations to the
activities of each agency. See e.g. 32 C.F.R. Part 187 (Department of
Defense); 32 C.F.R. Part 989 (Department of the Air Force); 32 C.F.R.
Part 775 (Department of the Navy).
Consistent with the CEQ regulations, the Department of Defense
regulations require EIS supplementation when: substantial changes to
the proposed action are made relative to the environment of the global
commons or when significant new information or circumstances, relevant
to environmental concerns, bears on the proposed action or its
environmental effects on the global commons. 32 C.F.R. Part 187,
Enclosure 1, para. D4; see also 32
C.F.R. Part 18, Enclosure 1, para. D4 (requiring supplementation for
Department of Defense actions with effects in the United States); 32
C.F.R. 989.20(b) (same for the Air Force).
As the United States Supreme Court has stated, the test
for supplementation is based on a "rule of reason": If there remains a
"major federal action" to occur, and if the new information is
sufficient to show that the remaining action will "affect the quality
of the human environment" in a significant manner or to a significant
extent not already considered, a
supplemental . . . [impact statement] must be prepared. Marsh v.
Oregon Natural Resources Council, 490 U.S. 360, 373-74 (1989).
Finally, an agency also has the discretion to prepare a
supplement to an EIS if it "determines that the purposes of [NEPA]
will be furthered by doing so." 40 C.F.R. ' 1502.9(c)(2).
II. Factual Background:
As you know, in late 1993, the Air Force, in cooperation
with the Navy, began construction of HAARP in Gakona, Alaska. The main
element of HAARP is a large radio wave transmitter which "utilize[s]
powerful, high frequency (HF) transmissions and a variety of
associated observational instruments to investigate naturally
occurring and artificially induced ionospheric processes that support,
enhance or degrade the propagation of radio waves." ROD at 1.
Construction of the HAARP facility is currently scheduled to be
completed within six or seven years and presently it runs at about ten
percent of projected power levels. See O'Harra, HAARP's Mixed Signals;
Solid Research Or Menace To Alaskans, Anchorage Daily News (April 7,
1996).
As the Air Force originally explained, HAARP is aimed at
studying the ionosphere, "with particular emphasis placed on being
able to better understand and use it to enhance communications and
surveillance systems for both civil and defense purposes." FEIS Vol. I
at iii. As an example, one touted potential military benefit from the
project is the development
of a communication system for use with submerged submarines.
The Air Force, in the FEIS, detailed its view of the
impacts of the project. The Air Force focused almost exclusively on
the local and regional impacts of HAARP, primarily on things such as
impacts to animals, degradation of air quality and vegetation loss due
to construction activities. FEIS at 3-1 to 3-165. The Air Force deemed
HAARP's effects to the atmosphere and biological effects to be
non-existent or insignificant. See id; see also ROD at Table 2.4-1.
The only admitted potentially
significant impact is "interference to radio communication systems and
electroexplosive devices during transmitting periods." Id.
In the years since the EIS process was completed,
several groups and individuals have raised questions concerning the
uses to which HAARP will be put and the likely effects flowing from
those uses. Some of these assertions are set forth in a book,
published in 1995, called Angels Don't Play This HAARP. Manning,
Begich, Angels Don't Play This HAARP, Earthpulse
Press (1995).1 In this book, the authors set forth a detailed and
fully-referenced description of HAARP and its potential uses and
effects. During the course of their research for the book, the authors
found that, rather than the innocuous project described by the Air
Force, HAARP represents a technology which could lead to a new class
of weapons that could change our world profoundly - an all-purpose
military tool. If misused, the tool could mess up the weather. It
could be used against humanity in a way that would change what people
think, believe and feel. . . . [HAARP could]:
.manipulate global weather; A detailed recitation in this discussion of the
assertions and facts contained in Angels Don't Play This HAARP would
serve no useful purpose; the book stands on its own as a question mark
affixed to the Air Force's contrary description of the uses and
effects of HAARP.2 As set out below, this request is based upon
questions and concerns about HAARP raised by facts surrounding both
the Air Force's current intended uses for the
project and scientific evidence raising questions about HAARP's
effects.
III. The Air Force Should Supplement the HAARP EIS:
The following discussion is organized into three
sections. In the first section we set out the information, gathered
since the completion of the FEIS, which suggests that substantial
changes have been made to the purposes of the project as originally
described and analyzed in the FEIS. These changes implicate
environmental concerns with HAARP and require
supplementation of the EIS.
In the second section we describe the significant new
information concerning HAARP, information which is relevant to
environmental concerns about the project. The data in this section
also leads to the conclusion that the EIS must be supplemented.
Third, even if the Air Force does not determine that
NEPA mandates it to supplement the EIS, it should do so voluntarily.
As the Air Force is well aware, HAARP has resulted in a tremendous
outpouring of concern about its purposes and potential effects. This
controversy - well-founded in science
or not - convincingly demonstrates that the public participation
purposes of NEPA have not been satisfied. Thus, it is highly advisable
for the Air Force to re-do the process, reaffirming its oft-stated
position that HAARP is an open and above-board project and quelling
the fears and concerns of so many people.
A. HAARP Has Undergone Substantial Changes:
Again, as described by the Air Force, HAARP is a
"scientific endeavor aimed at studying basic properties and behavior
of the ionosphere, with particular emphasis placed on being able to
better understand and use it to enhance communications and
surveillance systems for both civil and defense purposes." (FEIS Vol.
I at iii). As the Air Force has stated both in the ROD and FEIS, the
environmental concerns which flow from this rather benignly-presented
project are not significant. (See e.g., ROD at Table 2.4-1).
Clearly, the Air Force's treatment of HAARP has been
less than confidence-building. For example, it is incongruous for the
Air Force to conclude that no significant effects will flow from HAARP
(with the exception of electromagnetic and radio frequency
interference which the Air
Force has pledged to mitigate when an EIS is required only for those
federal actions which have a "significant impact on the quality of the
human environment." 42 U.S.C. ' 4332(2)(C); compare 40 C.F.R. ''
1501.4(b), 1508.9 (1988) (EIS unnecessary for major federal action
that does not significantly affect the environment). Certainly, the
Air Force should recognize this incongruity and realize that it
provides a reasonable basis
for the public to question the accuracy of other assertions made by
the Air Force.
In any event, plentiful evidence exists that raises
questions about HAARP and its current and intended uses and effects.
In 1994, for example, the Senate Committee on Armed Services stated
the following in a report attached to its passage of the National
Defense Authorization Act for Fiscal Year 1995: The committee is aware
of the promising results of the high frequency active auroral research
program (HAARP). This transmitter in Alaska, besides providing a world
class research facility for ionospheric physics, could allow
earth-penetrating tomography over most of the northern hemisphere.
Such a capability would permit the detection and precise location of
tunnels, shelters, and other underground shelters. The absence
of such a capability has been noted as a serious weakness in the
Department of Defense plans for precision attacks on hardened targets
and for counterproliferation. 103d Congress, 2d session, Report
103-282 at 86 (June 14, 1994).The Armed Services Committee went on to
state that it would condition future funds for a "full-scale HAARP
facility" on the Department of Defense's commitment to exploring the
counterproliferation possibilities
of HAARP.
The very next year, the Committee on Appropriations
recommended passage of the Department of Defense Appropriation Bill
for 1996, with specific recommendation that the Senate include
substantial monies for HAARP. 104th Congress, 1st session, Report
104-24 at 190 (July 28, 1995). This appropriation appeared under the
heading "Counterproliferation support -
advanced development."
Nowhere in the HAARP FEIS does the Air Force so much as
mention, much less evaluate, the earth-penetrating tomography aspects
of HAARP or its use for counterproliferation purposes. Indeed, the
Index to the FEIS does not even contain a reference to these terms.
(See FEIS Vol. I at 8-1.)
In response to a letter from a concerned citizen who
raised this issue, the Air Force admitted that earth-penetrating
tomography was "not specifically documented in the EIS" yet stated
that this use is "within original design and operating parameters
which have been identified in the FEIS." (Letter from John Heckscher,
Air Force, to Arthur Gray, NTIA November 17, 1994). Given the total
lack of reference to earth-penetrating tomography and
counter-proliferation in the FEIS, this statement does not appear
supported by the record. (See 40C.F.R.'1502.8 EIS' "shall be written
in plain language . . . so that decisionmakers and the public can
readily understand
them"); 40 C.F.R. ' 1502.13 (agency shall "briefly specify the
underlying purpose and need" of the proposed action). Indeed, given
the attention focused on this specific application of HAARP and the
substantial federal monies apparently dedicated to it, the Air Force
should not so easily dismiss this issue.
In the same Senate Report referencing the
counterproliferation purposes of HAARP, the Senate also recommended
substantial appropriations for HAARP under the heading "advanced
weapons." 104th Congress, 1st session, Report
104-24 at 190 (July 28, 1995). The Committee provided no explanation
for this appropriation. Available literature on advanced weapons
systems seems to support the ability of a HAARP-type facility to be
used for these purposes. See e.g., International Committee of the Red
Cross, Expert Meeting on Certain Weapons Systems and on Implementation
Mechanisms in
International Law (July 1994); see also Metz, Kievit, The Revolution
In Military Affairs And Conflict Short Of War, Strategic Studies
Institute, U.S. Army War College at 9 (July 1994); Heating Up The Air
Waves, Jane's Defense Weekly, Vol. 23, No.13; Hayeslip, Preszler, NIJ
Initiative On Less-Than-Lethal Weapons, National Institute of Justice!
at 16-18 (March 1993); Edwardson, The Right To Prevent The Commission
Of International
Crimes, International Health And Alternative Medicine Conference
(October 9-10, 1993); Smith, Best, Electromagnetic Man, Chapter 10
(St. Martin's Press, N.Y. 1989).
Nevertheless, "advanced weaponry" is certainly not
within the Air Force's claimed purposes for HAARP. See FEIS. Further,
in several fora, the Air Force and other project participants
repeatedly have assured the public that there is no "classified"
aspect to HAARP. See e.g., Tape of Alaska State House of
Representatives, Committee on State Affairs, HAARP Oversight Hearing
(April 2, 1996); see also O'Harra, "HAARP's Mixed Signals; Solid
Research Or Menace To Alaskans", Anchorage Daily News (April 7, 1996).
Thus, if indeed there is an "advanced weaponry" aspect to HAARP, the
Air Force's "open-project" pronouncements counsel that such use would
be public knowledge.
Consequently, it appears that HAARP has indeed taken on
a different direction than the Air Force originally reported. NEPA
thus requires supplementation of the EIS to address these uses of
HAARP and their effects on the environment. 40 C.F.R. '
1502.9(c)(1)(i)
B. Significant New Information Exists Concerning HAARP
The question whether significant new circumstances or information will
require EIS supplementation turns on several factors. These factors
include the environmental significance of the circumstances or
information, its probable accuracy and the degree to which the agency
had considered the circumstances or information and evaluated its
impact. See e.g., Warm Springs Dam Task Force v. Gribble, 621 F.2d
1017 (9th Cir. 1980).
Based on three draft and final reports concerning the
Radiofrequency Radiation (RFR) bioeffects of HAARP, the Air Force
concluded in 1993 that there would be "[n]o bioeffects from RFR." (ROD
at 9; see also FEIS Vol. I at 3-146, 3-149, 3-150.) The primary
concern with non ionizing radiation such as RFR, as outlined by the
Air Force, is the potential for "gross heating"; that is, heat
produced at relatively high RFR intensities
exceeding the thermoregulatory capabilities of a given animal and thus
causing deleterious effects. See FEIS Vol. I at 3-147.
The Air Force also noted, however, that "[s]ome
researchers have reported bioeffects at RFR levels below those giving
rise to gross heating." The Air Force dismissed these effects because
"such reports are not universally accepted by the large majority of
the research community."
New scientific information, gathered since the 1992 date
of the studies relied upon by the Air Force, strongly counsel that the
Air Force rethink this conclusion and reexamine the bioeffects of
HAARP. As an initial matter, it is important to note that while HAARP
generates electromagnetic waves at frequencies "between approximately
3 kilohertz (kHz) and 300
gigahertz (Ghz)," (FEIS Vol. I at 3-146,4) it does have a secondary
effect in the ELF range. (HAARP Research and Applications, A Joint
Program of Phillips Laboratory and the Office of Naval Research,
Executive Summary at June 6, 1995). Specifically, the Office of Naval
Research stated that HAARP, "using the ionosphere as an active medium,
can provide secondary
radiation sources in the IR, visible, and ULF/ELF/VLF ranges."
A frequent scholar and renowned expert in the field of
biophysics writes that "there is evidence from a number of studies
that extremely low frequency (ELF) fields in the range 0-100 Hz and
radiofrequency (RF) fields amplitude-modulated in this same ELF range
. . . are involved in essential physiological functions in marine
vertebrates, birds and mammals." Adey, W.R., "Biological Effects of
Electromagnetic Fields", Journal of Cellular Biochemistry 51:410 at
410-411 (1993). Further, "evidence has mounted confirming occurrence
of bioeffects of RM fields" in the low-frequency range. (see also
Polk, Handbook of Biological Effects of Electromagnetic Fields,
Chapter 12 (2d ed. CRC Press, Fla. 1996); Litovitz, Montrose, Doinov,
Brown and Barber, "Superimposing Spatially Coherent Electromagnetic
Noise Inhibits Field Induced Abnormalities In Chick Embryos", Journal
Bioelectromagnetics, Vol. 15, No.2 at 105-113 (1994); Adey, Whispering
Between Cells: Electromagnetic Fields And Regulatory Mechanisms In
Tissue, Frontier Perspectives, Vol. 3, No. 2 (Fall 1993); Smith, Best,
Electromagnetic Man, Chapter 10 (St. Martin's Press, N.Y. 1989).
Indeed, the Air Force itself, at least at some levels,
is aware of the biological effects of ELF fields. For example, Dr.
Cletus Kanavy, chief of the biological effects group of the Phillips
Laboratory's Electromagnetic Effects Division at Kirkland Air Force
Base in New Mexico has stated that "the entire issue of human
interaction with electromagnetic (RF & microwave) radiation is...a
major national population health concern."
Biological Effects of Microwave Radiation: A White Paper, Microwave
News at 12 (September/October 1993). Dr. Kanavy noted the "large
amount of data [], both animal experimental and human clinical [], to
support the existence of chronic, nonthermal effects." Id. These
effects include behavioral aberrations, neural network perturbations,
fetal (embryonic) tissue damage
(inducing birth defects), cataractogenesis, altered blood chemistry,
metabolic changes and suppression of the endocrine and immune systems.
Dr. Kanavy also notes that:
"[r]esearchers stress the chronic, nonthermal nature of
these effects as opposed to acute exposure level thermal effects.6
Ample experimental evidence exists from credible researchers from
well-established and highly regarded institutions, both government and
university, to justify a
national research program into the full spectrum of biological effects
of electromagnetic radiation".
Further, the Air Force's reliance on standards
established by the Institute of Electrical and Electronics Engineers
(IEEE) to downplay the likelihood of adverse bioeffects, FEIS Vol. I
at 3-149, is seriously misplaced. In
discussing the IEEE and the issue of bioeffects, Dr. Kanavas states:
"The U.S. has lagged behind badly in this kind of
research. Initially, the principal concern for human exposure to
microwave radiation was that of thermal heating of the tissues.
Permissive exposure limits were based on such criteria. These
limits...are...derived by the...IEEE. Under IEEE, a blue-ribbon panel
of experts periodically reviews the research database and
assesses the need to revise the standards. Until 1991, these standards
did not consider the possible biological effects of "pulsed" micro
waves. The 1991 standards do address the pulse condition (rather
shabbily, I believe), place [some] restrictions...and continue to use
the continuous wave time
averaging technique for thermal criteria. The existence of non-thermal
effects is essentially denied by omission...The literature published
in the late 1980s is abundant with information on nonthermal effects
which are produced at levels below the [IEEE-derived] standards."
Perhaps the Air Force rejected full consideration and
analysis of the biological effects of ELF fields in 1993 (when the Air
Force issued its ROD for HAARP) due to the rather cutting-edge nature
of then-available information. This excuse no longer exists.
Scientific understanding of bioeffects has evolved now to the point
where the Air Force can no longer deny its existence or simply dismiss
this information as "not universally
accepted by the large majority of the research community." FEIS Vol. I
at 3-147. This is especially true when the Air Force's own expert
states that bioeffects are a "major population health concern." White
Paper at 12.
NEPA regulations mandate the preparation of a
supplemental EIS when there "are significant new circumstances or
information relevant to environmental concerns and bearing on the
proposed action or its impacts." 40 C.F.R. ' 1502.9(c)(1). The
scientific information on the bioeffects of ELF fields, coupled with
the fact that HAARP causes ELF fields, mandates that the Air
Force supplement the HAARP EIS.
C. NEPA Purposes Counsel Supplementation
The increasing controversy over the type and range of
HAARP's effects and public concern and outright fear of the project,
especially among those who live near the HAARP site, counsel that the
Air Force reopen the EIS process, if only to quell these fears and
concerns. Indeed, NEPA and its implementing regulations contemplate
just this type of action. The Air Force "may also prepare supplements
[if it] determines that the purposes of [NEPA] will be furthered by
doing so." 40 C.F.R. ' 1502.9(c)(2). As described below, NEPA purposes
would certainly be furthered by supplementing the EIS.
Congress established through NEPA that it is the policy
of the federal government to "create and maintain conditions under
which man and nature can exist in productive harmony." 42 U.S.C. '
4331(a). The goals of NEPA, intended to further this policy, are to
"place upon [a federal] agency the
obligation to consider every significant aspect of the environmental
impact of [a] proposed action [and to] ensure[] that the agency will
inform the public that it has indeed considered environmental concerns
in its decisionmaking process." Baltimore Gas & Elec. Co. v. NRDC, 462
U.S. 87 (1983). An EIS, furthermore, "serves as an environmental full
disclosure law, providing information which Congress thought the
public should have concerning the particular environmental costs
involved in a project." Silva v. Lynn, 482 F.2d 1282 (1st Cir. 1973);
see also Sierra Club v. Hodel, 848 F.2d 1068, 1094 (10th Cir. 1988);
City of Aurora v. Hunt, 749 F.2d 1457, 1465 (10th Cir. 1984).
As the CEQ states, "public scrutiny [is] essential to
implementing NEPA" and "NEPA's purpose is not to generate paperwork --
even excellent paperwork -- but [rather] to foster excellent
decisions." 40 C.F.R. ' 1500.1(b), (c). CEQ speaks to the importance
of the public participation purposes of NEPA in various regulations.
For example, the regulations provide that federal agencies "shall to
the fullest extent possible . . .
[e]ncourage and facilitate public involvement in decisions which
affect the quality of the human environment." 40 C.F.R. ' 1500.2(d);
see also 40 C.F.R. ' 1505.5(a) (agencies should make diligent efforts
to involve the public).
Evidence of this concern emanates from Alaska, where
some long-time members of the State legislature have stated that they
have never had so many constituents voice fear and concern on one
topic. (See e.g., Tape of Alaska State House of Representatives,
Committee on State Affairs, HAARP Oversight
Hearing, April 2, 1996); see also O'Harra, "HAARP's Mixed Signals;
Solid Research Or Menace To Alaskans", Anchorage Daily News (April 7,
1996). In response to the concerns of their constituents, several
members of the State Legislature have held oversight hearings on HAARP
and stated that they would seek agreement from the Air Force for a
thorough, public, review
of the project.
Furthermore, significant public debate about HAARP has
occurred in many other areas of the globe, including a significant
debate played out on the internet over the last couple of years. See
Att. A at F-11. Indeed, HAARP has been the subject of numerous
documentary and investigative television
programs aired in Canada, Great Britain, Japan and the United States.
Additionally, radio talk shows have held innumerable programs focused
on HAARP.
The vast majority of these programs have focused on the
types of concerns expressed above; that the purposes and effects of
HAARP were never fully disclosed and that the effects have the
potential to be much more far-reaching than those noted in the FEIS.
In contrast, the EIS process resulted in comments from
the public primarily focused on construction, physical presence and
radio-interference effects of HAARP. See e.g. FEIS Vol. II, sec. 11.0.
The commenting public was most concerned with issues such as gravel
source, specific siting questions, impact on migrating birds and
impact to communication and transportation
from HAARP.
In the end, NEPA's integrity is tied to the
participation of the public in the process. Sierra Club v. Hodel, 848
F.2d 1068 (10th Cir. 1988); Note, The Tenth Circuit Rediscovers NEPA's
Public Participation Policies In Sierra Club v. Hodel, 30 Natural
Resources J. 203, 215 (1988). While the
Air Force may have made a good faith effort to further the purposes of
NEPA through the EIS process, for whatever reason, intense controversy
about the HAARP continues. Therefore, we request that the Air Force
exercise its discretion to supplement the EIS through a NEPA process
which addresses the concerns of the affected public.
IV. The Air Force Should Support Independent Review And
Monitoring:
Finally, regardless of whether the Air Force agrees to
supplement the HAARP EIS, the Air Force should establish and support
an independent review and monitoring effort for HAARP. This effort
would be aimed at objectively confirming for the public the Air
Force's representations about HAARP. In this manner, the concerned
public's distrust and fear of HAARP could be directly confronted and
diffused. An independent monitoring effort would result in increased
confidence among both the local people, who must live with HAARP in
their backyard, and those far away but who are concerned about the
reach of HAARP, that it cannot and will not cause the biological and
other effects of which they are so concerned.
Such a program need not be complicated. The purpose of
the effort would be to independently verify that the HAARP facility is
operating in the manner espoused by the project participants and to
make independent determinations about whether the facility is
operating with safe levels. This is exactly the type of program
members of the State legislature have requested and is also supported
by many concerned members of the public and the scientific community.
Specifically, the Air Force could work with the public,
the State Legislature and perhaps the University of Alaska to convene
a conference on HAARP. Different viewpoints could be represented at
such a conference, which could then provide a foundation for an
independent review and monitoring effort.
Finally, implementation of an independent monitoring
program could also be relevant to whether or not a supplemental EIS is
necessary. See e.g., Portland Audubon Soc'y v. Babbitt, 998 F.2d 705
(9th Cir. 1993); State of California v. Watt, 683 F.2d 1253 (9th Cir.
1982), rev'd on other grounds sub nom, Secretary of Interior v. State
of California, 464 U.S. 312 (1983) (alternative agency procedures
relevant to need to prepare a supplement to an EIS); New England
Coalition on Nuclear Pollution v. Nuclear Regulatory Comm'n, 582 F.2d
87 (1st Cir. 1978) (same).
V. Conclusion:
While seemingly benign if one were to look solely to the
government's description of the purpose, use and effects of HAARP,
information from the popular press, independent scientists and
investigative researchers raises flags of caution. This information
suggests that HAARP might be a government project with potential
impacts on many levels, including
far-reaching and little understood biological effects on humans and
animals.
Despite the data supporting the claims of these project
critics, the Air Force has not analyzed these admittedly Jules
Verne-esque qualities or potentials of HAARP. Nevertheless, an
evaluation of the history of the technology used in HAARP suggests the
possibility of exactly these kind of uses for HAARP. To the extent
that the government is either unknowingly or
intentionally exploring and implicating these types of uses and
effects of HAARP, HAARP represents a potentially significant global
threat.
To be perfectly clear, we do not suggest by this request
that the Air Force, the United States or other project proponents have
intended to deceive or otherwise mislead the public about HAARP, its
purposes and effects. The fact of the matter is, however, that there
simply is not enough information about HAARP to answer all the
questions raised and referenced above and in various other fora.
Perhaps it is, as the ROD and
FEIS suggest, an environmentally-benign project which may bring only
beneficial effects to mankind. If this is the case, Alaska would
rightfully be proud to be the site for such a worthy endeavor. On the
other hand, significant controversy has surrounded the project since
its inception and, as detailed above, the questions raised about HAARP
have a reasonable basis
in fact.
The continuing and serious questions about HAARP reveal
that, regardless of the attempts of the Air Force to comply with the
law and otherwise inform the public, these efforts have failed.
Supplementing the EIS to address these concerns, and establishing an
independent review and monitoring
program to provide objective evidence of the Air Force's honesty and
good faith, would go a long way in changing the current climate of
uncertainty and mistrust.
Thank you very much for your careful consideration of
this request. Given the rather lengthy time it can take for an agency
to consider a request such as this, we would appreciate some
indication of the time frame in which you feel it would be reasonable
for us to expect a decision. For this purpose, and to direct any
comments, questions or further information having to do with this
request, please contact:
Peter Van Tuyn, Litigation Director Sincerely, cc (w/out att.): Vice President Al Gore 1.We assume that the Air Force is familiar with this
book and has a copy of it. If this is not the case, please let us know
and we will gladly provide one for the record. Throughout the
remainder of this request letter, we reference multiple authorities,
most of which, due to their HAARP-focused
subject matter, we assume the Air Force has in its possession. To the
extent this is not true, again, just let us know and we will provide
copies for the record. Other, less HAARP-specific or more recent
references are provided as attachments to this request.
2.Several other popular press articles have raised
similar questions about HAARP and its purpose and effects. See e.g.,
Farmer, "Mystery in Alaska", Popular Science (September 1995);
Zickuhr, "Project HAARP: The Military's Plan To Alter the Atmosphere",
Earth Island Journal (1994). Most recently, the Anchorage Daily News
presented a cover story on HAARP in its We
Alaskans Sunday magazine. O'Harra, "HAARP's Mixed Signals; Solid
Research Or Menace To Alaskans", Anchorage Daily News (April 7, 1996).
3.The Air Force recently stated that "biologists and
environmental specialists advising HAARP indicated that there is no
rational reason to be concerned" about biological and geophysical
issues regarding ionospheric facilities. Letter from John Heckscher,
Air Force, to NTIA (Nov. 17, 1994).
4.A recent report from the Office of Naval Research
describes HAARP's operating frequency somewhat narrower than the FEIS:
"the primary energy of [HAARP] is confined in the frequency range from
2.8 to 10 Mhz." HAARP Research and Applications, A Joint Program of
Phillips Laboratory and the Office of Naval Research, Executive
Summary at 6 (June 1995).
5.There are over 50 references dealing with the topic of
electromagnetic fields and bioeffects cited in this article alone. See
id. at 415-16.
6.Compare FEIS at 3-146 to 3-147 (noting "gross heating
and subsequent thermal distress" concern).
by Trustees for Alaska