A Really Simple Question

We have a Really Simple Question for spaceport promoters:

“Why did Camden County spend tens of thousands of dollars for a new Spaceport Safety Analysis PR piece long after they submitted their application to the FAA?”

We know from spaceport billings that the October “Safety Analysis” at least the 2nd or third analysis Camden taxpayers have bought from Andrew Nelson. We also paid more than a million dollars for the inaccurate and incomplete Draft Environmental Impact Statement. We know from Georgia Open Records Act responses that Andrew Nelson spent many billable hours trying to convince Camden’s Washington, DC attorney that important Draft EIS submissions were based in established law so that the attorney could, in turn, try to convince the FAA. The FAA was not convinced.

Despite qualifiers touting the provenance of the PR Safety Analysis, Camden never claims they submitted the document to the FAA. The reference to ITAR is entirely a red-herring. ITAR stands for International Trade in Arms Regulations. The use of the term is meant to provide gravitas to a safety analysis that has nothing to do with Arms trafficking. The scope of the Department of Defense endorsement does not include validation or approval of the analysis or conclusions. The DOD only verified that the piece does not expose national defense secrets. Camden's work was meant for public relations, not for the FAA.

An FAA Hazard analyses is far more comprehensive than Camden’s PR Safety Analysis, which is not a complete nor serious study of Spaceport Camden’s risks to the public and public property. Having read a number of real Hazard Analysis documents, we can say for certain that Camden’s is a mere wisp of a document.

When considering the following, it’s important to remember that NASA facilities at Kennedy, Wallops, and Vandenberg launch all rockets only over land they control, directly over the ocean, or they have agreements with downrange landowners such as the oil rigs off California’s Coast. These regulations apply to the much smaller class of sub-orbital rockets. The following is a real test of the validity of Camden’s Safety Analysis conclusions:

The NASA Sounding Rocket User Handbook (2015) Section 7.4.2 Overflight Criteria states:

“Vehicle overflight of a populated area may only be planned when flight termination capability exists and one or more of the following criteria are met:

  • The probability of a land impact and resultant CE due to an overflight failure does not violate established criteria.

  • Formal government or private agreements are established which allow the overflight.”

  1. The Camden study fails to study the impacts to private property from fire or toxic materials which are expected consequences of a rocket accident. The FAA regulations require that the safety of private property and ownership rights are part of its safety consideration.

  2. Camden County has not attempted to acquire the required private agreements from the more than 100 at risk private properties. Per the Georgia Constitution, eminent domain is forbidden. If Camden attempts to call the spaceport a transportation project, they are barred under the Wilderness Act (see below).

  3. Camden County has not received formal government agreement to launch rockets over the Cumberland Island Wilderness Area which is protected from such risk under the 1964 Wilderness Act.

  4. Transportation corridors are specifically excluded by the Wilderness Act. An Act of Congress was required to allow commercial tours on Cumberland’s Main Road through the Wilderness. Only backpacker cook stoves are allowed in the Wilderness. No open fires are allowed.

NASA SRHB Section 7.4.5. Flight Planning Criteria continues:

“Launch vehicle flight safety is usually associated with the containment of spent stages, hardware, and payload components within planned impact areas. Since the entire set of variables (vehicle aerodynamic/ballistic capabilities, azimuth and elevation angles, wind, air, and sea traffic, and proposed impact areas) is never duplicated, each flight is unique. It is, therefore, imperative that the vehicle design, reliability, performance, and error predictions for each flight case be analyzed by the Safety Office (Code 803) to ascertain the flight-worthiness of each launch vehicle.”

  1. Camden only studied a single set of variables that would be applicable to its chosen criteria. Those criteria are not disclosed so it is safe to say that they were carefully chosen to provide a predetermined outcome.

  2. Camden’s study uses a notional (fictional) rocket and trajectory. Notional rockets will not be launched from Camden.

  3. In 2017, Camden denied the FAA a copy of the hazard study’s debris list. Validation of the calculations requires an accurate debris list. What possible legitimate reason could Camden have in withholding its list from the FAA? Has the FAA has tolerated such behavior because of their well-documented institutional bias favorable to the space industry?

We have plenty of the communication between Andrew Nelson, Camden County, and the FAA indicating that Camden’s submissions have been incomplete. After years of preparation, and millions had been spent, the February 2019 Launch Site Operator’s License, which required proof of only a single, viable trajectory, was rejected by the FAA. It was not until June 2019 that Camden filed an application that was deemed “complete enough.” Not "complete" but just "complete enough." Since the PR Safety Analysis was dated after Camden's license submission, what did they give to the the FAA?

So why did Camden spend tens of thousands of tax dollars on a public relations piece when it’s the job of the FAA to make that decision? Neither ITAR, NASA experts, Camden consultants, or the DOD matter when it comes to the FAA making a decision based on the law.

We suspect that Camden politicians are laying the groundwork for their excuses when the FAA denies their application. After all, they can claim they had gold-plated “proof” from “unimpeachable” sources that rocket launches were "safe" as they spent our millions.

Or, they could be trying to build political pressure on the FAA to approve a spaceport license they would otherwise deny. But that’s a sure-fire way to Federal Court and a possible breach of their oaths of office.

Perhaps, some at Spaceport Camden have known for some time that the FAA is no longer playing Camden’s game. We have submitted Camden’s Safety Analysis to the FAA to make sure the FAA has a complete picture of Spaceport Camden’s actions.