Terminal High Altitude Area Defense (THAAD) Weapon System

Photograph Attribution: By Ben Listerman - Missile Defense Agency, Public domain, via Wikimedia Commons

Tuesday, January 24, 2017

Missile Defense Agency (MDA) Response to Comments: Proposed Final Environmental Assessment (EA) dated 4-14-17, Excerpt from Appendix C:

Summary of comments received from the Electronic Review for the Environment, Inc., Berkeley, California, via electronic mail on January 24 and February 13, 2017:

1. Impact on marine mammals. The commenter asked several questions about the potential incidental take of marine mammals (take by harassment noise causing disruption in behavior including resting, nursing, and breeding). The commenter also suggested that monitoring and reporting should be addressed in the document.

MDA’s Response: As noted in Section 3.4.1 of the EA, NMFS determined that space vehicle and missile launches at the PSCA would result in the incidental take of small numbers of marine mammals, but that the total taking would have a negligible impact on the affected species or stocks. Additionally, NMFS does not anticipate take of any cetaceans (e.g., gray whales, humpback whales, Dall's porpoises, harbor porpoises, and killer whales) incidental to the specified activity (76 FR 16311). For Steller sea lions, northern fur seals, and harbor seals that haul out on Ugak Island, the NMFS Level B harassment threshold noise levels identified in Table 3-9 of the EA would apply.  In addition, for northern sea otters, USFWS determined that authorization for incidental take would not be required due to the infrequency of the rocket launches and the temporary disturbances at PSCA (FAA 2016).  However, specific to MDAs proposed action, the expected BMD launch noise levels on Ugak Island would be well below the NMFS thresholds.  Because the BMD flight tests proposed in this EA would have negligible effects on protected marine mammal species, and are not likely to adversely affect threatened and endangered species or critical habitats in the PSCA vicinity or elsewhere, a new biological opinion is not required, nor are wildlife monitoring surveys required or planned. In addition, as described in Section 5.1 under cumulative effects for biological resources, launch noise from the proposed BMD missile launches would be below in-air thresholds used by NMFS for pinnipeds, thus no cumulative increase in takes would occur.

2. Noise impact to wildlife. The commenter suggested that specific noise data for this type of rocket should be presented and the data should be current. 
 
MDA’s Response: As noted in Section 3.4.2.2, Vandal missile launch noise data were used for the analysis at PSCA and represents the best available information at this time. The sound levels generated during a Vandal launch would be comparable and likely louder than the proposed BMD missiles, which are smaller.

3. Results of a recent launch failure at PSCA. The commenter asked for information concerning the most recent launch from PSCA in August 2014 and noted that the EA did not explain that a launch failure occurred. The commenter asked that reports and available information be included in an appendix.

MDA’s Response: The launch failure that occurred at PSCA in August 2014 was a three-stage test vehicle substantially different from the proposed BMD interceptor missiles and not related to the MDA’s mission.  The test vehicle was much larger (approximately 48 feet in length) and it did not have the same history of successful flights as those interceptor missiles analyzed in this EA.  The launch failure is not discussed or analyzed in this EA because it is an unrelated program using an unrelated launch vehicle.  As such, it is outside the scope of this EA. The environmental cleanup that occurred following the 2014 launch failure was completed in 2016. For information on cleanup or other emergency operations at PSCA, contact the Alaska Aerospace Corporation at This email address is being protected from spambots. You need JavaScript enabled to view it..

4. Critical habitat areas. The commenter asked that additional maps showing critical habitat areas in the vicinity of the proposed action be included in the EA, including a map with noise contours.

MDA’s Response: Maps showing critical and protected habitat areas; noise contours applicable to wildlife effects; and notional missile debris impact zones were added to Sections 3.4 and 4.1.

5. Additional alternatives and relocating endangered/protected species. The commenter asked that additional alternatives in less environmentally sensitive areas be considered. The commenter also asked about evacuating critical habitat areas or relocating endangered/protected species.

MDA’s Response: For MDA to conduct the proposed BMD flight test at a location other than PSCA would not support the agency’s need to implement cost-effective system tests. It would also limit the agency’s ability to validate BMD weapon system capabilities against various short-, medium-, and intermediate-range threat representative target missiles. PSCA is a well-established and licensed launch facility that has been previously analyzed and used for rocket launches substantially larger than those proposed for the BMD flight tests. As described in Section 3.4.2, the Proposed Action would have negligible effects on protected species and is not likely to adversely affect threatened and endangered species or critical habitats in the PSCA vicinity or elsewhere. As for evacuating or relocating endangered/protected species such as cetaceans, sea lions, or seals from the test areas, such actions would likely constitute harassment under applicable laws and thus would be prohibited.  Additionally, it is not feasible to control the movement of these species. 

6. Worst case scenarios. The commenter asked that the discussion on risk management include worst case scenarios for impact events related to endangered species in case an inadvertent launch were to strike a critical habitat area.

MDA’s Response: As noted in Section 2.1.3.1, the THAAD weapon system in particular has been successfully used for over 10 years for flight testing at other test ranges without safety-related incidents. Because of the flight test success rates, onboard flight destruct systems, and other flight safety requirements described under Section 2.1 of the EA, the risk of BMD missiles directly impacting land areas or causing underwater explosions is very low. Low probability events such as those mentioned were not addressed in the EA.

7. Hazardous substances. The commenter asked that the EA include a full listing of hazardous substances and asked whether “miscellaneous constituents” included toxic materials (e.g. strategic metals, depleted uranium).

MDA’s Response: In addition to the rocket propellants, the majority of missile components and resulting debris are typically composed of aluminum, titanium, steel, carbon fabric, silica, and other alloys that are mostly inert. There are no plans to use depleted uranium on proposed BMD flight tests. As noted in Section 4.1.2 of the EA, previous studies of missile tests have concluded that the release of residual hazardous materials carried onboard rocket systems (e.g., propellants and battery electrolytes) would not be significant. Following launch and intercept, such materials would be rapidly diluted in the seawater and, except for the immediate vicinity of the debris, would not be found at concentrations identified as producing adverse effects.

8. Target debris in the ocean. The commenter asked that the EA include the amount (or tonnage) of anticipated waste.

MDA’s Response: Incidental deposits of debris or other material into the ocean from military activities, such as debris from missiles and missile intercepts, are not a form of deliberate disposal at sea under the Marine Protection, Research and Sanctuaries Act of 1972 (33 USC § 1401 et seq.). The amount of incidental wastes in the ocean from BMD flight tests would consist primarily of metal components and amount to several tons per year. Such quantities, however, are relatively small compared to other military, research, and commercial launch programs.
April 2017 | C-4
 
9. Emissions from missile launches. The commenter asked for additional discussion and analysis of air emissions from the missile flights, specifically mentioning aluminum, black carbon and hydrochloric acid. The commenter also requested additional information on whether such emissions might impact fish, marine mammals, and habitat.

MDA’s Response: The black carbon and aluminum oxide particles, and hydrogen chloride, are released as rocket motor air emissions during missile flight. These emissions would be dispersed over the entire flight and would not be concentrated in any one area. Because the emissions would be widely dispersed and mostly over ocean waters, they would never reach the ground or ocean surface in concentrations that could have adverse effects on humans or wildlife. As noted in Section 3.3.2.2 of the EA, this finding is supported by water chemistry studies conducted at PSCA (FAA 2016), which indicated no adverse water quality effects (including pH and aluminum levels) from prior launches of rockets much larger than the proposed BMD interceptor missiles.

To see the Missile Defense Agency's revised Environmental Assessment (EA) report go to https://www.mda.mil/global/documents/pdf/env_PacificSpaceportComplexAlaska_FinalEA.pdf

From: Thomas Price <This email address is being protected from spambots. You need JavaScript enabled to view it.> February 12, 2017