The Public Comment period for the Spaceport Camden Draft Environmental Statement (“DEIS”) closed on June 14, 2018, after more than 1,000 negative comments were submitted to the Federal Aviation Agency. The FAA must respond to all substantive comments in the Final EIS. Camden County Commissioners have already invested over $4,000,000 in the spaceport and have budgeted an additional $1,500,000 for the next 12 months’ spaceport expenses. Purchase of the spaceport properties, hazardous site remediation, infrastructure, or construction are not included.
A review of significant Comments indicates the DEIS fails to meet the legal requirements of the National Environmental Protection Act (“NEPA”).
NEPA requires a favorable Record of Decision determination before Camden County can apply to the FAA for a spaceport site license. A favorable decision cannot be issued unless a project achieves “a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation;” The President’s Council on Environmental Quality has established comprehensive standards the FAA must meet to satisfy NEPA requirements.
In 129 pages of NEPA Comments, the Southern Environmental Law Center points out, “The DEIS is rife with failures to properly address critical aspects of the proposed project and comply with applicable laws. The FAA can cure these shortcomings only by preparing a new DEIS containing the necessary information and analysis. But even if the FAA corrects the DEIS’s deficiencies, it will not be able to correct problems that are inherent in the proposed site, including the fact that any rocket launched would travel over populated areas and significant public lands.”
The Center for a Sustainable Coast NEPA Comments to the FAA describe an FAA EIS process that “allows the safety analysis to select a narrow launch corridor and hypothetical rocket to expedite approval of a spaceport license. This does a disservice to the taxpayers of Camden County because it misrepresents actual real-world rockets and launch requirements. The DEIS’s unrealistic portrayal of this proposed spaceport could result in the construction of a spaceport which will never launch a rocket.”
Camden County’s Spaceport Environmental Sub-committee found, “A large number of factual errors can damage the quality of a decision. In many of these instances, the EIS preparers seem unfamiliar with the local area.” A small sampling of the range of errors and omissions the Sub-committee found includes:
The DEIS preparers use undocumented technical terms involving safety that are not standard in FAA regulations and have no defined meanings.
The DEIS preparers fail to address the environmental consequences of launch accidents impacting marshes, private property or Cumberland Island National Seashore which are also not investigated at any later licensing stage.
The DEIS preparers abruptly and without explanation make “statements of insignificant impact” after identifying numerous adverse impacts on many topics.
The DEIS preparers on page 3-82 incorrectly reported that rainbow and brown trout in the Cumberland River. These fish cannot survive in Georgia’s coastal waters.
The DEIS preparers incorrectly evaluated the visual impacts from a viewpoint on the east side of Little Cumberland Island where . o study could have .
A vibration study of the Union Carbide hazardous landfill concluded no concern. H, a second vibration study indicated damage to buildings. The DEIS preparers do not explain the contradiction.
Among more than 1,000 citizen-submitted comments, Private commenters noted:
The DEIS illegally failed to study Alternative launch sites outside of Camden County.
The FAA has never developed a NEPA-required “significance threshold” for Children’s Health and Safety because rockets have never over children. Therefore, the DEIS violates NEPA requirements since no impact study
The DEIS preparers expressly ignore NEPA-mandated Health-related Impact analysis for adults (and children.)
The DEIS Proposed Action is for the launch of Medium/Large-lift class rockets however, the included Noise study is for Medium-lift-class rockets which can have one-quarter of the thrust of a Medium/Large rocket.
The DEIS preparers fail to identify an existing rocket exhibiting the performance characteristics necessary to allow the unrealistically smaller Spaceport Camden Launch Hazard Study Area. The DEIS studies a Hazard Area
The DEIS preparers briefly mention extremely toxic hypergolic fuels will be stored on site but do not address the environmental impacts or mitigation requirements of transportation on Camden roadways, spillage, or rocket accidents when these fuels are present.
The DEIS preparers did not investigate NEPA environmental impacts for the Bayer property although Camden explicitly states Bayer for the spaceport project. Regulations require Bayer due to minimum boundary limits for even the smallest FAA-licensed rockets.
The Spaceport Camden DEIS fails to meet NEPA requirements due to abundant and significant errors, omissions, contradictions, and misrepresentations of material facts.
Unabridged EIS Comment documents are posted at spaceportfacts.org
More about Spaceport Camden: Spaceport Camden is proposed as a public-private partnership that will establish Camden County as the Commercial Space Center of the United States. However, no federal, state or private investment dollars have been committed to the spaceport. Camden officials are now pursuing General Obligation Bond debt which will obligate Camden County property owners for full repayment.
More about www.spaceportfacts.org: Spaceportfacts.org is the citizen-driven website shedding daylight on the Spaceport Camden project and its likely outcomes of economic failure and unacceptable environmental risk. We’re working to prevent a $100,000,000 political mistake.
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