July 15, 2021
General Wayne Monteith
Associate Administrator FAA/AST
800 Independence Avenue SW
Washington, DC 20591
RE Spaceport Camden FEIS Commentary
New evidence about hazardous waste sites in the vicinity of the proposed spaceport site suggests one of two possibilities, both of which have disturbing implications that should greatly concern you regarding FAA’s obligations to the public.
If Camden County has not shared this information with you, then FAA/AST has been seriously misled by the calculated omission of factors critical to the agency’s NEPA responsibilities in reviewing Spaceport Camden. Conversely, if county representatives have shared this crticial information with FAA, yet you have not considered it in the DEIS and FEIS’s analysis of spaceport impacts, then FAA would be implicated for aiding the county’s deception by shielding disqualifying facts about the project from the various decision-makers and the public.
I think the following diagram explains why Spaceport Camden has never presented an EIS environmental analysis of the Bayer CropScience property that is necessary to execute Spaceport Camden operational requirements. There are likely additional undisclosed environmental problems.
Three landfills and disposal sites are located within 2 miles of each other, violating the Official Code of Georgia § 12-8-25.4.
· The much-discussed Union Carbide RCRA Landfill
· The permitted Bayer Landfill located 600-feet outside the LHA
· The Mystery 50-acre Bayer CropScience Contamination Site within the LHA that is also surrounded by Union Carbide/Spaceport Camden property.
Given these circumstances, it is vital that further investigation of the 10 identified Bayer potentially hazardous sites is carried out under careful public scrutiny. Even if the Bayer property is never acquired, the remaining environmental issues at Union Carbide and Bayer cannot be ignored, which seems to be the case, since your staff has not required the appropriate risk analysis. Although the three waste sites mentioned above may be grandfathered under state laws (a fact still to be determined), their presence in the LaunchPad Hazard Area’s operational proximity, coupled with the waste sites’ proven instability, as well as mandated monitoring and mitigation requirements, should have dictated full DEIS and FEIS inclusion, public discussion, and official Commenting.
Can I assume that you are aware that Arsenic spiked in the Bayer Landfill soon after mandatory seismic testing was performed for the spaceport? Please note the Arsenic chart from the January 18, 2021 semi-annual test report demonstrating the Bayer landfill’s instability and sensitivity to seismic or unknown events:
Although Arsenic is a somewhat familiar poison, I've included the EPA drinking water data sheet for your reference. The 92 mg/L exceeded the reporting limit by 3,000%. The amount equates to 92,000 parts per billion(ppb) which is 9,200 times the EPA acceptable limit for drinking water of 10 ppb. The FEIS fails to analyze any Bayer property, including the 50-acre Bayer "Mystery Disposal Field" within the LaunchPad Hazard Area and surrounded by Spaceport Camden.
What’s more, the FEIS deceitfully describes current conditions in a section on page 3-57 titled Bayer CropScience Contamination Sites. “Detailed information on the presence of hazardous constituents is unavailable from by [sic] Bayer CropScience.” I possess a consultant’s email describing Bayer’s unwillingness to share hazardous site information. That does not not bode well for Camden’s acquisition of the property and should red-flag any assumptions based on Bayer property. In any case, I’ve attached the latest copy of the Bayer Landfill SECOND EVENT SEMI-ANNUAL GROUNDWATER DETECTION MONITORING REPORT containing extensive testing results for hazardous contaminants from one of Bayer’s Camden landfills. Did Camden and the FAA choose to ignore this testing which has been conducted since 2004? Or has this information been concealed from the public and the ROD Decision-maker because at the very least, it raises unresolved questions about environmental risks that are not disclosed?
Finally, in the context of Bayer property, 438-acres of Bayer upland are included in the LaunchPad Hazard Area but have not been described or analyzed in the Draft or Final EIS. Camden’s references to Bayer define their desire to locate the Alternate Control Center and Visitor Center, “…outside of the Spaceport Camden site boundary on what is currently Bayer CropScience property. Should the County not purchase the property nor reach an agreement to build on Bayer CropScience property, this facility would have to be relocated.”
The truth is the spaceport cannot operate without Bayer’s 438-acre upland portion of the LaunchPad Hazard Area which includes at least one of the ten Bayer CropScience Contamination Sites mentioned on page 3-57. The FEIS repeats Camden’s dependence on the availability of Bayer’s property for access to communications, potable water and electricity, and the Bayer access road to the launch site. Yet, the DEIS and FEIS distinctly ignore that Bayer property is required to meet the regulatory requirements for the 7,300-foot Launch Hazard Area (LHA) for SLV launches. This omission is consequential and appears deliberate.
Rocket fuel will be transported across Bayer property but the risks are not identified nor are alternative routes discussed in the DEIS or FEIS should Camden “neither purchase the property nor reach a lease agreement with Bayer CropScience.” Spaceport Camden is dependent on drawing “16.3 million gallons of water” from Bayer wells, yet no alternative is identified if no Bayer agreement exists. The DEIS and FEIS omission of environmental impacts from the use, or failed acquisition, of Bayer is inexcusable and legally indefensible.
The FAA’s experience at properly located spaceports is deceitfully applied to Spaceport Camden when the FEIS repeats this inappropriate canard: “Over the past 25 years, there have been no fatalities, serious injuries or significant property damage to the public (i.e., persons/properties not involved in launch activities) from commercial space launch operations licensed or permitted by the FAA.”
Although the statement itself may be true, the FAA knows, with certainty, that Spaceport Camden is AST’s first experience with high-risk exposure to US citizens, US citizen residents in their homes, a visitor-active National Park unit, and overflight of state-owned public-trust properties. The regulations were written when no launches were permitted over US citizens in their homes, on hiking trails, or in boats in US territory. The FAA’s own internal guidance admits its methods are estimates that can exhibit extraordinary inaccuracy; however, the following policy statement is not displayed in any Spaceport Camden document (emphasis SW).
By highlighting the “No Fatalities” claim in an emphasis box in the Spaceport Camden Coastal Consistency Certification document, the FAA allows Spaceport Camden to deceive the Georgia Department of Natural Resources, the Department of Interior, and the public.
As a consequence, Georgia DNR’s concurrence letter distressingly exhibits a complete misunderstanding of the risks when it includes numerous statements such as this: "The overflight exclusion zone, or area where the public will be excluded during launch closures, will be approximately 1/3 smaller since it was narrowed from 10,600' wide to 7,300' wide and extends out twelve (12) nautical miles (nm) offshore;". Obviously, if the overflight exclusion zone (OEZ) extends 12 miles offshore, the plan to allow normal human activity on Cumberland Island is impossible. The State is truly confused.
Even more confusing is the US Coast Guard Safety/Exclusion zone restricting boating activity to ostensibly protect humans on the water on three sides of Cumberland Island while allowing human activity on the island itself. Simple logic indicates the FAA regulations were written never anticipating a circumstance as illogical as the downrange risks at Spaceport Camden. No wonder the State and the Department of Interior/NPS are confused.
After five years of work, the following intentionally disjointed and fact-twisting paragraph in FEIS Section 184.108.40.206, Launch Failures on page 2-35, should be immediately disqualifying:
“As stated previously, a typical trajectory starts with a nearly vertical climb for 45 to 75 seconds, and then slowly tips horizontally, continuing to gain altitude until it achieves orbit. Based on launch and trajectory modeling information as included in the Launch Site Operator License Application for Spaceport Camden, the instantaneous impact point (IIP) clears the island from west to east in about 5 to 7 seconds of dwell time. The IIP is the projected landing spot of the rocket should thrust be terminated at that instant. For the 100-degree trajectory, around 60 seconds into mostly vertical flight, the IIP starts to cross the western edge of Cumberland Island, taking about 5 to 7 seconds to reach the Atlantic Ocean (the “IIP dwell time”). The rocket passes directly above Cumberland Island at an altitude of approximately 72,000 feet and departs 6 to 10 seconds later at about 97,000 feet. During this physical crossing, if an incident were to occur, the debris would fall forward along the trajectory and beyond the island.”
A non-specialist would never derive from the above statement that a launch failure in the first 90 seconds would result in 100% of debris fragments or an intact rocket falling on coastal Georgia. Thrust termination (“The IIP is the projected landing spot of the rocket should thrust be terminated at that instant”), is not a flight termination option. Earlier in 220.127.116.11., a Destructive Flight Termination System is described to assure readers that the whole, fueled rocket will not fall to earth (“The flight termination system is designed to destroy the vehicle…“). So which is it? Such contradictory statements in a Final Environmental Impact Statement are sloppy, unprofessional, and fundamentally dishonest.
I have attached a comprehensive, though not exhaustive, accounting of a single paragraph in GDNR's concurrence letter to Stacy Zee. It is self-evident that Camden's frequent, contradictory information releases have confused the public and decision-makers. The FAA knows that GDNR and NPS are inexperienced and cannot recognize Spaceport Camden’s choices of self-serving facts, twisted logic, and wishful thinking. As those who can be harmed, we hope your staff is not similarly deceived.
Space launch is a frontier science. But it must conform to safety standards to protect the public and public property. The FAA seems conflicted by its preoccupation, seemingly politically coerced, to approve a spaceport license for Spaceport Camden that should have never been seriously considered.
The irregularities in the FEIS and the process that got us to this point appear to border on fraudulent misrepresentation to Georgians, especially those in Camden County. Irrespective of the political pressure AST has received, the General with the ultimate authority must say, "We cannot and must not do this. Our Wing’s credibility is at stake, and the public is entitled to responsible decisionmaking."