Comment Letter - Proposed Spaceport Camden
The Georgia Conservancy is pleased to provide comments related to the proposed Spaceport Camden, located in the northeast corner of Camden County near the confluence of the Satilla River and Saint Andrews Sound in Georgia. This area is one of the highest functioning estuarine ecosystems on the East Coast of the United States and, as such, has extensive value to plants, animals and the people of Camden County and the State of Georgia.
Founded in 1967, The Georgia Conservancy is one of Georgia’s oldest nonprofit conservation organizations. Working to protect our coast for almost 50 years, The Georgia Conservancy is a statewide conservation organization whose goal is to develop practical solutions for protecting Georgia’s environment. We develop policy decisions under a vision statement centered on a Georgia where people and the environment thrive. The magnitude of the proposed spaceport, at this critical location, is of significant concern. The comments and questions in this letter are derived from our Coastal Policy and are based on the limited amount of development and operation data available at this early stage of design/ implementation.
We applaud Camden County, the local citizens and the Federal Aviation Administration on the exemplary manner in which the federal Environmental Impact Statement (EIS) process has been handled to date. We look for a judicious and comprehensive review of all questions submitted to date. Our concerns center on the following general topical areas:
- Environmental issues at a larger scale (regional, continental)
- Impacts to adjoining sites and landscape scale natural resources, and
- Site-specific development, mitigation and conservation measures.
Environmental issues at a larger (county, Georgia/Florida, ocean ecosystem) scale include:
Georgia’s estuarine and saltmarsh ecosystems, which adjoin the Spaceport Camden site, provide a nursery for commercially and recreationally valued species of fish, shellfish and other wildlife, as well as a valuable recreation resource. These coastal land and water resources provide habitat for more threatened and endangered species than any other region of the state. The sum of these resources is a highly integrated, interdependent ecosystem that is vitally linked to Georgia’s economy and quality of life.
- How will the spaceport operations address migration patterns, foraging and local nesting areas for threatened and endangered bird species?
- How will the survey and consultation for the EIS specifically address high priority species such as the bald eagle, glossy ibis, black-crowned night heron and local wading bird colonies?
- How will the operational and contingency plans for the Spaceport Camden address fisheries and marine mammal (right whale and manatee) impacts?
It is important for southeast Georgia and Camden County to have an economy that offers diverse options including healthy, sustainable nature-based businesses such as commercial fishing and recreation-based tourism.
- In what ways will the project benefit the local economy?
- In what ways will it have economic costs (public, private and ecosystem services)?
- Will the EIS process include the results of planned economic studies that the Spaceport Camden Steering Committee or other groups undertake as part of this project?
Impacts to adjoining sites and landscape scale natural resources include:
Barrier island wilderness, refuges and other coastal public lands are an incomparable resource that provide clean air and water, safeguard biological diversity, offer people a safe haven for solitude, enjoyment and spiritual renewal; and preserve an unspoiled natural heritage for future generations.
- What will be the project related impacts to Cumberland Island, Jekyll Island, Raccoon Key and Little Cumberland Island?
- How will property rights issues be enforced for privatized spaceport operations related to the exclusion zones and other limitations on offsite property?
It is important for Camden County and other coastal communities to use smart growth practices to promote compact patterns of growth that: 1) are located away from environmentally unsuitable areas (i.e., sensitive coastal resources and areas prone to flooding and storm surge); 2) are sited, designed and constructed to respect, restore and maintain ecosystem functions; and 3) engender respect by the people who live there for the land and water around them.
- How will the County Comprehensive Land Use Plan (CLUP) be updated to reflect the conservation, residential, recreational and industrial uses planned in and around this project?
- Will a local planning study guide the related industrial development that provides economic benefits to Camden County?
- Will overlay zoning or local tax incentive districts (TAD, CID, etc.) be used as part of the planning and incentives package for local spaceport related businesses?
A sustainable coastal ecosystem is vital to the Georgia’s prosperity. It is essential to promote a healthy, resilient and diverse coastal ecosystem that can endure natural and human disturbances, continue to perform its functions, and support self-sustaining populations of native fish, birds, wildlife and plants.
- How will this project and the related development impact the critical habitat (see figure below) that is located on this site and adjoining properties (Bayer, Ceylon, Cabin Bluff, etc.)?
- Construction of site roads, support supplier facilities, and future expansion of the spaceport industry in Camden County will have a direct impact on the habitat that supports the gopher tortoise, indigo snake and a number of other rare plants and animals. Much of the habitat in this area is rank G2 and G3 under the NatureServe habitat ranking system. This includes unusual combinations of proximate mesic longleaf pine on higher sandy soils and rare forested (hydric) wetlands, which benefit wildlife greatly.These habitat types are similar to those found on Cumberland Island, Little Cumberland Island and other wilderness areas that are already protected and compose vital components of the landscape scale ecosystem.
Responsible planning for growth and conservation of sensitive coastal lands is essential to preserving the integrity of natural coastal systems and, in turn, the health and welfare of coastal Georgians.
- What specific sound mitigation and operational measures will be taken to protect surrounding properties and wildlife?
- Has consideration been given to creative use of conservation resources (easements, transfer of density rights, development boundaries, etc.) in the preservation of sensitive habitat and buffering of the site? Compatible use buffers at nearby Fort Stewart and Townsend Bombing Range have served conservation efforts well.
- What role have Stratford Properties (Ceylon) Cabin Bluff and other adjoining property owners played in the planning of site design, conservation and mitigation measures?
Site specific development, mitigation and conservation measures:
The State of Georgia has a unique stewardship role with respect to coastal marshlands, waterbottoms and estuarine systems that is critical to preserving the integrity of the saltmarsh ecosystem and the public’s safe access and enjoyment of our common coastal treasures. Every water body has a carrying capacity in terms of point and nonpoint pollution inputs, bank erosion and safe navigation. Potential harm to marine mammals from spaceport operations is a critical limiting factor that must be respected.
- How will “lessons learned” from other recent spaceport construction projects be incorporated into the Spaceport Camden Project?Is it feasible for the site design at Spaceport Camden to reuse the existing onsite industrial footprint and facilities (roads/wastewater/fire suppression)? How will sewage and industrial wastewater be treated at the spaceport site? How will related (offsite) industries that locate near the spaceport on adjoining sites treat their waste water?
- What will be the total impact to streams, wetlands and marshes for the spaceport and related facilities? What mitigation measures are planned? What site specific site measures will be taken to treat stormwater to the current codes and standards as outlined in the Coastal Supplement of the Georgia Stormwater Manual?
- Will the site be brought up to current development codes for storm water and operational runoff? Will both storm water quality treatment and detention be provided?
- Will the information related to the recent Todd’s Creek stream bank stabilization project be included in the EIS considerations? How will sea level rise considerations be incorporated into the site design?
- What are the site related planning and permitting issues for waterfront areas and overwater operations (flights, explosions, etc.)? Will the design documentation for the site include an assessment of both site-specific and cumulative impacts with an eye toward the overall carrying capacity of our estuaries?
Rigorous application and coordination of existing laws and regulations — especially Georgia’s Coastal Marshlands Protection Act, Shoreline Protection Act, Coastal Management Plan and Program Guidelines, as well as the federal Clean Water Act — are critical to preserving the coast’s ecological integrity as human activity expands.
For the reasons stated above, the Georgia Conservancy has significant concerns related to the development and operations for Spaceport Camden and the related ancillary development that will support the enterprise. We look forward to working with federal, state and local agencies to address these concerns