Opposition for Spaceport Camden

Dear Governor Kemp,

You can stop Camden County’s proposed private spaceport from launching rockets over Cumberland Island National Seashore and the largest federally-protected Wilderness Area on the Eastern seaboard.

Cumberland Island has long been recognized as the ‘crown jewel’ of Georgia’s 'Golden Isles'. Allowing the spaceport to become reality would, instead, make this irreplaceable treasure a ‘doormat’ to 'Georgia's gateway to space.'

The two (2017 and 2020) Georgia Southern 'economic impact' studies produced to support Spaceport Camden are riddled with methodological and logical errors: data can be used to learn something, or abused to sell something. These studies are, regretfully, the latter.

It's unconscionable that Camden is currently paying lobbyists, consultants and public relations firms with taxpayer dollars, misleading the public to market Spaceport Camden.

Over the past five years, more than $8,000,000.00 has left the county to pay them. The economic experience of every other non-NASA spaceport in the country suggests those much-needed dollars were misspent. Worse, Camden is willing to throw the destruction of Cumberland Island into the bargain.

In 2019, a record-breaking number of endangered sea turtles made nests on the island’s shores. Cumberland is a major stopping point on the transatlantic migratory flyway, with more than 335 species of birds recorded; threatened and endangered species include Bald Eagles, Wood Storks, Wilson's Plovers, and American Oystercatchers. Its surrounding waters are migration channels for whales and manatees and the epicenter of endangered North Atlantic Right Whale calving grounds.

Wilderness is unique among all other categories of U.S. protected lands -- it retains an exalted, added layer of protection, classified as 'self-willed' land, specifically reserved, by statute, to have unequivocal precedence over incursions by technology, commerce and human misuse or manipulation - full-time, untrammeled, forever.

Spaceport Camden appropriates over 9,000 acres (more than 14 square miles) of protected wetlands and tidal marsh adjacent to the proposed launch site - plus 610 acres of upland on Cumberland Island - to be used as hazard buffer zones.

This is critically important because launch failures most often occur adjacent to the proposed launch site. The Launch Hazard Zone (LHZ) immediately surrounding the launch pad extends 74% of its area over Georgia’s inter-coastal tidal marsh: a delicate habitat and a primary economic force in our state’s economic success.

The larger Overflight Exclusion Zone (OEZ), will close 14 square miles of marsh and intercoastal waterway used by recreational fishermen, boaters, and commercial fishermen. FAA regulations require these safety zones to protect human life; in this instance, the marsh will be used as a buffer area — absorbing rocket failures occurring close to the launch pad. At all other spaceports, these 'buffer zones' exist on spaceport property, or over open ocean.

Spaceport Camden implies that closures will occur up to 12 times a year. However, nearly every launch in recent history has been rescheduled or postponed during final countdown - resulting in multiple closures for a single launch.

The Coastal Marshlands Protection Act (CMPA) is state law that protects the public trust tidal wetlands (Coastal Marshlands Protection Act, O.C.G.A. Section 12-5-280 et. seq.). Launch risk to Georgia's tidal marshlands is clearly implicated under the Georgia Coastal Management Act (1997), which recognizes that damage to this critical economic and cultural resource is difficult, if not impossible, to mitigate in advance or repair after damage.
Governor Kemp, it is your responsibility to ensure enforcement of the Georgia Coastal Management Act (1997):

The General Assembly finds and declares that the coastal area of Georgia comprises a vital natural resource system. The General Assembly recognizes that the coastal area of Georgia is the habitat of many species of marine life and wildlife which must have clean waters and suitable habitat to survive. The General Assembly further finds that intensive research has revealed that activities affecting the coastal area may degrade water quality or damage coastal resources if not properly planned and managed.

The General Assembly further finds that the coastal area provides a natural recreation resource which has become vitally linked to the economy of Georgia's coast and to that of the entire state. The General Assembly further finds that resources within this coastal area are costly, if not impossible, to reconstruct or rehabilitate once adversely affected by human related activities and it is important to conserve these resources for the present and future use and enjoyment of all citizens and visitors to this state.

The General Assembly further finds that the coastal area is a vital area of the state and that it is essential to maintain the health, safety, and welfare of all the citizens of the state. Therefore, the General Assembly declares that the management of the coastal area has more than local significance, is of equal importance to all citizens of the state, is of state-wide concern, and consequently is properly a matter for coordinated regulation under the police power of the state.

'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.'

Important precedent would be set in Georgia that would negatively impact every American and every wilderness in the U.S. National Wilderness Preservation System (NWPS). YOU can put a stop to it.

The stakes couldn’t be higher. As Governor of the great state of Georgia, you have the responsibility to stop rockets from launching over this federally-protected Wilderness Area and to steward Georgia’s unique coastal resources for present and future generations.

Thank you listening.

Sincerely,

%%your signature%%

Dear FAA Representatives,

Your agency has the authority and responsibility to stop Camden County from allowing a private company to launch its rockets over Cumberland Island National Seashore and the largest federally-protected Wilderness Area on the Eastern seaboard.

Events suggest that In 2015, without performing the required due diligence, Camden County (GA) commissioners decided to build a private commercial spaceport on land left contaminated by prior industrial waste. The spaceport was to be the catalyst for economic development.

At every step of this process, it appears the commissioners have diligently worked to pervert the necessary environmental studies and approval process in order to deliver this predetermined outcome.

You have provided insufficient challenge to - or oversight of - the commissioners or their agents' activities in developing the project's Environmental Impact Statement (EIS) and Launch Site Operator License (LSOL).

The Draft EIS has been challenged by the Southern Environmental Law Center (SELC) and others for serious deficiencies in methodology, legal sufficiency regarding the National Environmental Policy Act (NEPA), and violations of the Administrative Procedure Act (APA).

The proposed launch site is landlocked 10 miles inland from the Atlantic Ocean and 4 miles due west of Cumberland Island National Seashore and Wilderness Area. Every possible trajectory from Spaceport Camden would immediately overfly and threaten Cumberland and Little Cumberland Islands, including the homes of private citizens.

Cumberland Island Wilderness, part of the National Wilderness Preservation System (NWPS), is stringently protected by the Wilderness Act and NEPA to remain self-willed land, exempt from exactly this kind of trammeling.

By ignoring the gross inadequacies of the EIS and accelerating a Final EIS and Record of Decision (ROD) for Spaceport Camden under the guise of Executive Order 13927, your agency is failing in its responsibility to the public.

The FAA-sanctioned DEIS ignored or perverted requirements, thereby failing legal sufficiency.

An FAA desire to promote commercial space by increasing launch capacity does not justify approving Spaceport Camden. National need can be met without endangering Cumberland Island's irreplaceable natural resources.

The DEIS allowed a 6% rocket failure rate. Astra, the commercial launch company's rocket referenced in the revised LSOL application, currently has a 100% failure rate. Even a 6% rate is unacceptable for wilderness and a national seashore under the NEPA mandate to maintain them, in perpetuity, untrammeled by man.

FAA Maximum Probable Loss (MPL) calculations value Cumberland's Wilderness at zero. That's illogical, capricious and arbitrary.

Moving forward with Spaceport Camden declares to Americans that you are willing to endanger our citizens’ most highly-protected lands, our Wilderness, to promote the interests of private, for-profit companies to the detriment of future generations.

Thanks for listening and doing your part to preserve the Cumberland Island ecosystem.

%%your signature%%

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,

%%your signature%%