Camden County Spaceport
The following is a broad overview of the proposed Camden Spaceport and our initial reactions to the March 2018 Draft Environmental Impact Statement (Draft EIS) compiled by the Federal Aviation Administration (FAA). The Georgia Conservancy is currently reviewing the Draft EIS, will continue to make updates regarding our concerns, and will issue to the FAA formal and detailed comments prior to the June 14, 2018 deadline.
Camden County is seeking economic development by building a facility to launch rockets from an abandoned munitions plant, owned by Union Carbide Corporation, in a rural location four miles west of Cumberland Island National Seashore.
The landscape setting on which the proposed Spaceport Camden sits is east of I-95 and borders the Saint Andrews Sound, a dynamic body of water which touches several islands, including Cumberland Island, Little Cumberland Island, Jekyll Island and Raccoon Key, and one which contains the extensive and high-functioning estuary of the Satilla River. Many threatened, endangered and/or protected species are found in and around the property, including bald eagles, wood storks, indigo snakes, striped newts and gopher tortoises.
Several years ago, the county seized upon this unique opportunity to redevelop the abandoned site as a privatized satellite launch site. This unique enterprise (a spaceport) has been undertaken by the county as an economic development opportunity that would provide jobs and diversify the county employment base. Building a spaceport, though, is an uncommon proposition, which makes it very important for Camden County and the Federal Aviation Administration to explain to the citizens of Camden County, as well as all others who may be impacted by the facility, what to expect from the project. While this is certainly a project never undertaken in the state of Georgia there are several other spaceports that have been built in recent years across the United States from which lessons must be drawn.
The feasibility of such an enterprise is a concern, but is beyond the ability of the Georgia Conservancy to fully analyze, therefore, in keeping with our mission, we have chosen to use our resources to analyze environmental impacts from rocket related operations at the landscape scale and to address issues related to property rights, both public (State of Georgia and U.S. Department of the Interior) and private.
During the scoping phase of the EIS in January 2016, the Georgia Conservancy submitted comments related to the Spaceport Camden project. The next step, a draft Environmental Impact Statement for the proposed Spaceport Camden, which was issued in March 2018 for comment, addresses the environmental concerns through the FAA framework of National Environmental Policy Act (NEPA). The cumbersome NEPA Draft EIS was paid for by Camden County as part of the three-step site licensing for a facility to launch medium lift rockets (250 feet tall with boosters that weigh up to 1,500,000 pounds).
The Spaceport Camden site has long-term detailed project characterization and detailed information related to previous industrial waste pollution by previous industrial users, therefore Georgia Conservancy is currently focused primarily on the offsite impacts to the landscape (St. Andrews Sound, Cumberland Island, etc.).
This spaceport is unique in that the launch trajectory will go over private property in addition to a National Seashore and Wilderness Area. The National Park Service issued a list of concerns during the scoping period for the Draft EIS. Their concerns, as well as those of the Georgia Conservancy, were primarily centered on impacts to the park experience and operations, along with impacts to the complex ecology of the island environment, as rockets from Spaceport Camden will be launched directly over Cumberland Island National Seashore. While the Draft EIS comments on potential impacts to the experience of wilderness visitors from lighting and noise associated with spaceport facility operations and launches, it fails to adequately address tower and facility lighting issues that will impact the nesting of federally-threatened loggerhead sea turtles and federally-endangered leatherback sea turtles (Endangered Species Act). For these species, there could be additional impacts from night launches during nesting season.
Furthermore, the Draft EIS does not adequately detail the impacts that catastrophic events and launch disasters may have on the ecological integrity of nearby ecosystems, including Cumberland National Seashore and Wilderness. We recommend that the FAA further study and provide a detailed report on worse-case scenarios as they relate to failed launches, crashes, in-air and on-ground explosions and errant rockets, and the impacts that such scenarios would have upon nearby landscapes and waterways, including barrier islands, salt marshes, mainland uplands, rivers, estuaries and nearshore ocean. The history of rocket launches by both public and private organizations is riddled with catastrophic disasters. The Draft EIS should take serious the effect that potential disasters pose to the surrounding areas.
Property Rights - Public & Private
It is important to note that NEPA and the framework of requirements of the EIS do not deal with property rights and feasibility issues which are primary concerns in regards to the Spaceport Camden project. From the Draft EIS we learn that there will be up to twelve such launches per year requiring the closure of locations within Cumberland Island National Seashore, as well as the evacuation of campers, hikers and visitors. Notice of closures range from one month to as little as three days prior. The Draft EIS is unclear on how such closures and evacuations are to be handled and does not describe the impacts to National Park visitors or staff operations.
The project seems challenged by Wilderness Act issues related to the National Park lands under its launch trajectories - issues that should be more fully addressed. Separately, the issue of private property use (takings) related to evacuation of property during launch operations needs to be more fully explained.
Initial readings of the Draft EIS for Spaceport Camden lead us to request further study and clarifications as they relate to certain environmental impacts and property rights. It is important to note that this is a preliminary document and that there will be several updates to complete information not provided for in this draft.
The Federal Aviation Administration will hold two public hearings to solicit comments on the Draft Environmental Impact Statement for the proposed Camden Spaceport on Wednesday, April 11 and Thursday, April 12, 2018, from 5:30 pm - 8:30 pm at the Camden County Public Service Authority Recreation Center Community Room, 1050 Wildcat Drive, Kingsland, GA.
The FAA encourages all interested parties to provide comments concerning the scope and content of the Draft EIS by June 14, 2018.
Send comments by email to firstname.lastname@example.org, or by mail to Ms. Stacey M. Zee, Environmental Specialist, Federal Aviation Administration, c/o Leidos, 2109 Air Park Road SE, Suite 200, Albuquerque, NM 87106.