Dear DNR Representatives,

Georgia\'s coastal waters and tidal marshes are a public resource belonging to every Georgian. It is unconscionable that the Georgia Department of Natural Resources would allow Spaceport Camden to appropriate them from the public, for the benefit of private, for-profit space companies to launch commercial rockets of dubious economic value while posing significant risk to these fragile natural resources. Closures of Georgia\'s waterways and marshes will occur far more often than is indicated in the Spaceport Camden impact study.

• For every rocket that leaves a US launchpad, a recent five-year history shows that 3.1 launch attempts are required. Considering just the law of averages, 37 closures of the Intercoastal waterway from Jekyll Island to Kings Bay will occur every year.

• Visitors will be restricted from Cumberland Island’s beaches and Wilderness campgrounds.

• Some Georgia residents will be told to shelter-in-place in their own homes for hours at a time to avoid becoming a casualty. Resident population exposure would also include NPS employees, First Responders, Sheriff\'s deputies, and others put at increased risk because of their required proximity to an eminent potential emergency.

• The actual number of rescheduled closures is likely to be larger because the proposed rockets are either new designs or are altogether untested. Kodiak Alaska\'s spaceport has experienced three consecutive rocket explosions from a prospective Spaceport Camden launch operator since 2018.

An example of constructive use is SpaceX\'s closure of the public beach at its Boca Chica site. The 2014 Final Environmental Impact Statement and Record of Decision allowed up to 180 hours of annual closures; however, the US Fish and Wildlife Service has documented that more than 1,000 hours of closures occurred in 2019. That rate has only increased this calendar year. Are you willing to allow that to happen on the Georgia coast?

The Spaceport Camden Draft EIS/EIS process did not account for cumulative risk to the environment. Since Georgia\'s marshes and Cumberland Island cannot move out of the way (or be forced out), the risk to natural resources will exist for every flight, in perpetuity.

The Georgia Coastal Management Act (1997) states:

• The General Assembly further finds and declares that activities and structures in the coastal area must be regulated to ensure that the values and functions of coastal waters and natural habitats are not impaired and to fulfill the responsibilities of each generation as public trustees of the coastal waters and habitats for succeeding generations. Debris scattered from rocket crashes would spread rocket fragments and toxic fuel in the tidal marshes where it would be virtually impossible to mitigate the damage or repair the harm.

The Affected Closure Area is not fully described and sufficiently evaluated. FAA regulations require a series of hazard zones extending from Spaceport Camden\'s launch pads. The first is the Launch Hazard Area (LHA), extending 7,300 feet from the center of the launchpad. This circle cannot have a single human present. Even workers involved with launch operations are prohibited. Seventy-four percent (74%) of Camden\'s LHA will extend over Georgia\'s protected tidal marsh.

A second, larger restricted safety area is the Overflight Exclusion Zone (OEZ). In the case of a small rocket launch from Spaceport Camden, that area covers about 14 square miles of wetlands and tidal marsh and extends onto Cumberland Island's western shoreline. Not a single person is allowed in the OEZ: security forces will prohibit boaters and recreational and commercial fishermen from inter-coastal waters during each launch attempt.

The Overflight Exclusion Zone contains more thousands of marsh acreage designated by Congress as - Potential Wilderness-. The routine operation of Spaceport Camden would add environmental stress and introduce other non-conforming uses. A debris event over the marsh would almost certainly prevent the addition of this potential wilderness to Cumberland\'s existing Designated Wilderness.

The Spaceport Camden Trajectory Hazard Area will extend miles beyond Cumberland Island’s beach. The first three miles offshore will be patrolled by the US Coast Guard to prevent any boating or commercial fishing. Another 12 miles or more will be a Maritime Exclusion Zone that boaters will be advised to avoid due to launch failure hazard. At least twice in 2020, launches have been canceled due to intrusions by single boats into offshore exclusion zones.

The Department of Interior informed the FAA that spaceport operations would result in 4(f) Constructive Use of CUIS.

Even if an accident never happens over Georgia\'s marshes, constructive use of the marshes will occur.

Georgians depend on our DNR officials to guard and steward our natural resources for the benefit of all present and future generations; eschewing short-term political or commercial pressures in order to preserve the long-term health of our environment and to serve the public good.

Sincerely,

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