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;
- hurt ecosystems;
- knock out electronic communications; or
- change our moods and mental states.
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" microwaves. 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
725 Christensen Dr., #4
Anchorage, Ak, 99501
e-mail : trustees@igc.org
Sincerely,
Peter Van Tuyn
cc (w/out att.): Vice President Al Gore
Governor Tony Knowles
United States Senator Ted Stevens
State of Alaska Representative Gene Kubina
State of Alaska Representative Jeannette James
Tim Wirth, United States State Department
Katie McGinty, United States Council on Environmental Quality
- 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.
- 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).
- 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).
- 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).
- There are over 50 references dealing with the topic of electromagnetic fields and
bioeffects cited in this article alone. See id. at 415-16.
- Compare FEIS at 3-146 to 3-147 (noting "gross heating and subsequent thermal
distress" concern).
