Comments For the Administrative Record

July 25,2021

Daniel Murray

Stacey Zee

Office of Commercial Space Transportation

Office of Operational Safety, ASA-001

800 Independence Avenue SW (AST)

Washington, DC 20591


Comments For the Administrative Record of the Spaceport Camden FEIS and Record of Decision


Mr. Murray and Ms. Zee,


“Never attempt to win by force what can be won by deception.” ― Niccolò Machiavelli, The Prince


Spaceport Camden is grounded in deceit. We know that the FAA is aware of all the problems the following deceptions attempt to conceal. We just want to make sure that the FAA knows that we see what is going on and want to make sure our objections are part of the Administrative Record.


The DEIS was deceptive from the beginning. Public safety depended on “Authorized person(s)” – a term of convenience rather than law, a term that was quickly repudiated by the FAA. The FAA ultimately required Camden to downsize the risk to allow the pubic to exercise their Constitutional rights to remain on their property and to avoid project-killing 4(f) impacts to CINS. Camden was forced to downsize their rocket, but they have been allowed to seek approval for facilities for medium-large rockets, implying their deceptive future intents. The plans retain the 490,000 square foot “Landing Pad” – now renamed a “Mission Preparation Area,” a feature that is not found at other SLV spaceports. The FEIS trajectory intricately and deceptively describes a case-specific risk of failed rocket debris falling beyond Cumberland Island National Seashore, conveniently ignoring failures within the first 90 seconds of launch that will fall in public-trust tidewaters, on public and private land, and a visitor-active National Park unit. The deception is sustained by a willful FAA, three gullible county commissioners, and millions paid to consultants and lobbyists. Political pressure has been applied by lobbyists and a U.S. Congressman who made a $2,050,000 real estate investment near the spaceport, then promptly orchestrated a letter encouraging the FAA to quickly approve its licensing.


Here's a bit of the proof:


Deceit #1 : 1.3.1 Camden County Board of Commissioners’ Purpose and Need [1] “[… Camden] County to offer a commercial space launch site to a growing number of small to medium-large lift-class, orbital and suborbital, vertical launch vehicle operators …”


The Draft EIS is the only NEPA document that has been provided for public examination and Comment. The FAA rescinded its early 2020 intention to conduct a public hearing and additional public comment period prior to the release of the Final EIS. The public has been denied the opportunity to evaluate and Comment regarding the significant changes of the original scope presented in the Draft EIS.

  • Spaceport Camden no longer seeks launches of Medium-large rockets, thus the economic benefits to Camden County are consequently diminished.

  • Only one (a decidedly small number) new rocket has been licensed, though it is not operational, by the FAA since 2018. The economic benefits to Camden County are not readily apparent.

  • No US manufacturer is currently known to be developing a rocket meeting Camden’s representative rocket used in the Final EIS, thus no economic benefits can be reasonably anticipated due to award of a Launch Site Operator License.

The Final EIS contains a modified statement regarding economic development, but adds a new purpose not listed in the Draft EIS:


Deceit #2 : “The County's proposal is also needed to create launch site redundancy on the east coast.” [2]


There is no elaboration on this statement in the FEIS. The FAA does not indicate a similar Purpose or Need for Spaceport Camden. The vast majority of trajectory azimuths provided by Kennedy/Canaveral and Wallops MARS cannot be served by Spaceport Camden. Excess launch capacity exists at those spaceports. Spaceport Camden only seeks a license for SLV rockets.


Deceit #3 : “Medium-large rockets will launch from Spaceport Camden.” [3]


SpaceX was the only successful commercial launch company in 2015, so of course, the spaceport deceptions in the Draft Environmental Impact Statement formed around a rocket like the SpaceX Falcon 9. The Draft EIS is the only NEPA document the public has seen that gives it the opportunity to respond with Comments. On 9/11/2018, the U.S. Coast Guard proposed in the Federal Register that it would delineate a Safety Zone (aka Limited Access Area or LAA) encompassing Medium-large rockets launched from Spaceport Camden. Camden County’s Statement of Purpose and Need for Spaceport Camden is focused on providing economic development opportunities,[4] yet the public has only been presented Economic Summaries predicated on Medium-Large rocket launches. But after $10 million, Camden’s fictional rocket is so small, no company has made one the FAA can license.[5]


Deceit #4 : ES.1.2 FAA’s Purpose and Need [6]

The need for the FAA action of issuing a Launch Site Operator License and Vehicle Operator Licenses results from the statutory direction to [….] promote commercial space launch and reentry activities by the private sector in order to strengthen and expand U.S. space transportation infrastructure.


Spaceport Camden neither “strengthens” nor “enhances” the US Space transportation system.”

Camden County would join 19 total U.S. sites available to launch commercial rockets. Five are U.S. government sites such as Cape Canaveral in Florida. Two private sites in Texas were built for the sole use of their owners, SpaceX and Blue Origin.

Camden County would join the remaining dozen, which are essentially launch pads for hire by companies with their own rockets. The FAA knows that seven of those sites—in Florida, Texas, Colorado, and Oklahoma—have never held a licensed launch.


The FAA has stated on several occasions that rocket launches might not be licensed from Spaceport Camden. That doubt alone proves Spaceport Camden will neither strengthen nor expand U.S. spaceport transportation infrastructure.

The previously used term “notional rocket” is now described in the Final EIS as,

“The representative small launch vehicle used for this analysis is a two-stage, liquid-fueled (liquid oxygen and RP-1) launch vehicle with approximately 18,500 pound-feet of thrust at lift-off, carrying a small (100- to 300-pound) payload/satellite to low Earth orbit.” [7]


The vehicle remains theoretical because no US-licensed orbital rocket has this specification proving Spaceport Camden will neither strengthen nor expand U.S. spaceport transportation infrastructure. If the FAA follows its own logic, the only outcome can be rocket companies desiring to launch from the most constrained and regulated spaceport in the United States, and one that must develop a rocket unique to Spaceport Camden.

“The representative launch vehicle is considered to be similar in design and performance to a RocketLab Electron launch vehicle, which Camden County identified as a representative launch vehicle for purposes of hazard analysis in the Launch Site Operator License application.” [8]


The FAA has no reference rocket with 18,500 pound-feet of thrust manufactured primarily of carbon-fiber composites, using Rocket Labs exclusive rocket engine and avionics. No other US manufacturer uses Rocket Labs’ design or engines, and Rocket Lab has announced it will build a much larger Medium-lift class rocket. The existence in theory-only of the rocket used in the LSOL application and the Final EIS proves Spaceport Camden will neither strengthen nor expand U.S. spaceport transportation infrastructure.

“The representative launch vehicle is anticipated to carry approximately 1,000 gallons of liquid oxygen and 750 gallons of RP-1.“ [9]


No FAA-licensed rocket meeting this specification has achieved orbit, and none is known to be under active development. However, the LSOL Application provided to Georgia Department of Natural Resources indicates,

“The primary launch point may accommodate small launch vehicles (e.g., RocketLab Electron, Vector R, ABL Launch Systems, FireFly Launch Systems, etc.).[10],[11]


Only the Rocket Lab Electron (2.3 times larger than Camden’s representative rocket has been licensed. All others are under development or speculative and therefore are “unproven” and wholly untested, and in any case, are up to 9 times more powerful and proportionally riskier to the Georgia coastal environment. These rockets represent only the middle-sized rockets in the SLV class and which could be double the capacity of those under development. The FAA knows the FEIS does not represent any rocket within the SLV class. The FAA’s acceptance of analysis of a non-existent, smallest-in-class rocket instead of a real rocket proves Spaceport Camden can neither strengthen nor expand U.S. spaceport transportation infrastructure as the spaceport is proposed to do in the FEIS.


U.S. approved launch slot capacity for SLV rockets is currently utilized at less than 5%, plus already approved expansions at Vandenberg and Kennedy/Canaveral Spaceport will “strengthen and expand U.S. space transportation infrastructure.

Such tenuous dependence on a speculative class of unproven rockets launched on a unique and highly manipulated “lofted” trajectory seems unlikely to validate Spaceport Camden’s potential “to strengthen and expand U.S. space transportation infrastructure.


The FEIS presents no evidence that Spaceport Camden benefits the U.S. space industry. In fact, the FAA should fear the political fallout and loss of trust resulting from the first accident (could even be on the first launch) from Spaceport Camden causing environmental harm or personal injury that could not have happened at an appropriately located spaceport.


Deceit #5 : [Spaceport Camden] “provides a nearly unrestricted launch range for the launch of spacecraft to a wide range of orbits… without the addition of costly propulsive maneuvers to change the orbital plane” [12]


The Final Environmental Impact Statement includes only a single “lofted” trajectory for a fictional SLV that may not be able to provide for “costly propulsive maneuvers.[13] The FEIS, and a LSOL based on the FEIS fails to achieve both Camden County’s and the FAA Statements of Purpose and Need.


Deceit #6 : “The representative launch vehicle is considered to be similar in design and performance to a RocketLab [sic][14] Electron launch vehicle.” [15]


No, it is not. Camden’s rocket has only 43% the thrust of the Electron. Camden’s cannot be “similar” to the Electron because aerodynamic forces and its inefficiencies will be far greater due to Camden’s unique (theoretical?) “lofted” trajectory necessary to reduce the OEZ, reduce risks to Cumberland Island National Seashore, and to provide a favorable EIS Record of Decision. Camden’s rocket must be stronger, heavier (unless new materials and more powerful fuels are invented), and require more fuel, reducing the already limited payload. Camden’s rocket will have to be engineered, built, tested, and “proven.” [16]


Deceit #7 : ”The Spaceport Camden Launch Site Operator License Application does not include a request for permission to support the launch of unproven launch vehicles.”

[17]

Not surprisingly, this comment, emphasized in the Final Georgia Coastal Consistency Certification to fool our DNR, and repeated in the Launch Site Operators License Application [18] is entirely missing in any form in the Final EIS. The FAA does not have a definition describing “proven” or “unproven” rockets. There are no “proven” rockets meeting the FEIS-defined rocket specifications. The supposedly “proven” Rocket Lab Electron Mission #20 failed, “from a previously undetectable failure mode within the ignition system that occurs under a unique set of environmental pressures and conditions.” [19]


Deceit #8 : “Most payloads would include some additional propellants onboard, either for orbit maintenance or orbital insertion. Payload propellants may include fuels such as UDMH, MMH, and NTO, as well as pressurized gases, including helium and nitrogen or solid propellants. Quantities would vary but could be as much as 1,000 pounds for combined weight of MMH and NTO for the representative launch vehicle. The MMH/NTO propellant weight for a representative capsule is approximately 600 pounds. Total payload weight (dry weight plus propellant weights) could be up to 4,400 pounds for the representative launch vehicle.[20]


The FEIS anticipates,

“… representative” toxic payload fuel loads of up to 600 pounds of MMH/NTO propellants known toxic to humans and that pose environmental hazards if released in sufficient quantity to the environment. MMH is highly reactive and is listed by the International Agency for Research on Cancer as a possible human carcinogen. [21]

Yet, other than for the immediate Expected Casualties (Ec) risk analysis purposes, the human health and environmental impacts of these hazardous materials resulting from a foreseeable rocket failure are not analyzed in the Spaceport Camden FEIS.


More deceitfully, this FEIS statement confirms that rockets launched from Spaceport Camden could be 44 times larger than the fictional representative rocket used to obtain the Record of Decision approval.


Deceit #9 : Storage is planned for 350,000 gallons of Liquid Oxygen and 250,000 gallons of RP-1 Rocket fuel. [22]

Why is fuel storage provided for 28 years of “representative” rocket launches? Is the FAA cooperating with Camden’s bait-and-switch scheme that depends on hiding the risks and impacts of planned larger rockets and more frequent launches from the Navy and Department of Defense, GDNR, NPS, SHPO, ACHP, property owners, and taxpayers?

The rocket has been downsized to meet risk requirements, but the original spaceport remains.


Deceit #10 : FEIS Environmental Consequences, 4.2.1.3 Launch Failures

“In the event of a launch failure, an explosion could injure or kill species or damage habitat adjacent to the launch pad or within areas impacted by debris. It is anticipated that vehicle debris and propellants from a launch failure within the first seconds of a launch would be confined to the immediate area around the launch site and would not spread to the Satilla River, Cumberland River, and associated estuaries and habitats or any portion of the Cumberland Island National Seashore or Atlantic Ocean. Therefore, protected and sensitive habitats and wildlife species in these areas are not anticipated to be significantly impacted by a launch failure. Portions of Floyd Creek and associated tidal marshes and wildlife species may be impacted from a launch failure. Impacts would be adverse to affected areas and individuals. While adverse impacts to Floyd Creek and associated tidal marshes, vegetation, and wildlife may occur from a launch failure, the potential exists only within the first 45 to 75 seconds of flight before the vehicle tips horizontally. Therefore, the potential for impacts to biological resources from launch failures is low.”


This section of the FEIS is intentionally deceptive violating NEPA requirements. 71% of the mandatory hazard zone immediately surrounding the launch pad incorporates state-protected “associated estuaries and habitats.” “Significantly” is used as a qualifier to describe impacts to wildlife and tidal marshes, yet “significantly” is not defined. Critically, FAA Order 1050.1(f) has not established a significance threshold for Coastal Resources so determinative studies of significance impacts must be performed. The “first few seconds” is not quantitative.[23] However, the information provided confirms by omission that during the first 75 seconds, or so, every launch failure will have adverse impacts on a few, several, or all of the following: Satilla River, Cumberland River, and associated estuaries and habitats or any portion of the Cumberland Island National Seashore, Atlantic Ocean, Floyd Creek and associated tidal marshes, vegetation, and wildlife – all within Camden County boundaries. “Low” is not a statistical term, has no precise meaning, is not defined by the FAA or NEPA, and therefore has no legal meaning. The author of this FEIS section deliberately misleads the cooperating agencies, public, and the licensing decisionmaker.



Deceit #11 : “… the likelihood of getting hurt or worse on Little Cumberland Island ranges from less than 1 in 10 million to 1 in 100 million per launch and does not require evacuation of the island. [24]


However, population management and control is necessary as evidenced by the USCG LAA and checkpoints on water approaches and Cumberland Island National Seashore. Seems quite contradictory.


What degree of sheltering is modeled? Will a trajectory azimuth of less than 100-degrees, that would significantly increase risks to Little Cumberland Island, be permitted under any circumstance? Stating a statistic that is highly constrained by choice of rocket, trajectory, and ideal circumstances is deceitful.

  • The risk analysis was performed using a theoretical rocket on a novel trajectory to lessen the evacuation impacts. The rocket is clearly “unproven” since it has not been built. There is no evidence such a rocket will be built or could perform as envisioned by the risk programmer.

  • The novel “lofted” trajectory holds the rocket over Camden County and Georgia’s coast far longer than the Rocket Lab Electron which uses a more traditional arc trajectory that is more fuel-efficient and locates the MAX-Q moment to far offshore. The MAX-Q moment for the Spaceport Camden appears to occur over Georgia, increasing the risk of debris fragments impacting our coast.

  • It is undisclosed if the Rocket Lab Electron is structurally or performance-capable of withstanding the proposed “lofted” trajectory.

  • As explained later in this document, the FAA has inappropriately substituted human risk for environmental risk. Human risk is determined by the probability of a fragment of debris, toxins, or explosive force sufficient to cause an ASI-3 or greater injury to an adult male. The resident population of Little Cumberland Island is representative of the general US population and includes children who are likely to be more susceptible to serious injury from rocket accident risks.


The following paragraph[25] from the FEIS proves that 100% of rocket debris from a self-failure or intentional flight termination will contaminate Georgia’s coast and tidewaters, yet the Final ENVIRONMENTAL Impact Statement contains is no evaluation of that environmental risk. According to FAA and Camden County-engineered hazard dialog, all debris fragments fall in oddly narrow bands. Which would increase lethality.


Since Camden Camden’s representative rocket is supposedly “similar in design and performance to a RocketLab Electron launch vehicle” why is the Electron Launch Hazard Zone routinely 6 to 10 miles wide 6 miles downrange while Georgia DNR’s concurrence letter is dependent on the Spaceport Camden trajectory hazard zone being just 7,300' (1.4 miles) wide to a minimum of 12 miles offshore (20 miles downrange)?



In any case, the applicant has been inclined to present only favorable presentations and deliberately ignores the required “HARD LOOK” at the foreseeable, likely, or worst-case analysis.

Most ominously, the FAA has often admitted that injury risk calculations can vary as much as three orders of magnitude (1,000 times) [26]:


The FAA’s calculation of Maximum Probable Loss Insurance is likely inadequate for the human risks at Spaceport Camden. That is because the normal 3rd-party risk analysis assumes the random, accidental injury to a random member of the public who is inadvertently harmed. Spaceport Camden will be different because members of the public at risk are likely to be the same persons for repeated launches. Their risk will be cumulative rather than random. Any person exposed will have been “authorized” by spaceport authorities, who will be solely responsible for the rocket launch activity causing the harm. Because there has been so much deception and secrecy about the project, and intentional disregard for the required public participation, it will be very difficult for the FAA and launch operators to justify accident losses as “just bad luck.” Human, property and NPS risks will be cumulative. A case can be expected to be made that the FAA and launch site operator are negligent despite sufficient prior warnings.


Deceit #12 : “…maximum population determinations will serve as the basis for the maximum allowable populations on LCI, CI and the surrounding waters for day-of-launch.” [27] Should population estimates exceed these allowable limits, a launch hold would be implemented until populations have been reduced below the agreed upon limits.” [28]

More specifically, the LSOL Application includes a Population Monitoring and Management Plan document that includes likely illegal enforcement activities. [29]For example, the entire section on population control for Little Cumberland Island is based on the fiction that the owners and the LCI/HOA have agreed to the plan proposed in the LSOL application. As the FAA well knows, the private parties on LCI are not a party to the so-called agreement. Decisions made on such misrepresentation are clearly fraudulent.


The ruse of shrinking the rocket and launching it on a dubious trajectory to produce NEPA-compliant environmental values and “acceptable” Expected Casualties may seem logical to those sitting in Washington, DC offices, or consultants in Illinois, Texas, or California, but the concept is patently deceptive.


Is Camden County’s plan Constitutionally enforceable?

  • How can Spaceport Camden legally “reduce population below agreed upon limits?”

  • Who is agreeing on what the limits can be?

  • Is it legal for the Camden County Sheriff or the U.S. Coast Guard to agree to compel the public to leave their property or stop their legal activities to benefit a private commercial rocket launch company? Repeatedly?

The expectation appears to be a forthright illegal taking under Georgia’s Constitution.


It is difficult to comprehend what might cause the FAA to knowingly subject local citizenry to the tortured path the FAA has charted for an unnecessary Spaceport Camden. After all, the entire Purpose and Need of the FAA can be stopped dead in its tracks by the election of three commissioners who have their constituent’s best interests at heart. Spaceport Camden is purely speculative. Its costs have deprived citizens of well-kept parks, paved roads county-wide, and left citizens with a county pool that could not hold water for the 2021 summer season.


However, the FAA’s actions at Boca Chica are instructive. Camden County appears to be following the lead of SpaceX, Texas, and Cameron County government. It appears that in the LSOL application, Camden County is granting itself the authority to impose public access controls by misusing its emergency powers. A rocket launch is no such “emergency” – a word which means,

“a situation of urgent need for help and relief, brought about by a natural disaster, act of terrorism, or other crisis, especially as declared by a governor, president, mayor, or other official.”:[30]


A commercial rocket launch is not an “emergency” but Camden’s distortion of reality may be enough for an FAA licensing decision, but it is illegal. So, we assume Camden County’s consultants have advised that since Georgia’s Property Owners Bill of Rights would prevent the takings required for spaceport operations, they will appeal to the Georgia legislature for a bill empowering the County to compel private-party cooperation.


The FAA has dirty hands in all of this. We have dozens of emails between the supportive parties documenting the politicization of a process that is supposed to be based on merit and the protection of the public. FAA/AST’s behavior, especially the exclusion of the required and necessary public participation, is the worst possible expression of a federal agency that has lost its mission.


Unlike Boca Chica residents, more than 3,000 Camden voters have already signed a petition to force a special election rejecting the Commissioners’ use of any tax revenues or grants to acquire or develop the contaminated Union Carbide and Bayer CropScience properties.


Imposition of constraints on activities on Cumberland Island National Seashore are clearly Section 4(f) violations. It is unlikely the US Congress will consent to the Camden County Commissioner’s dream of yet another unnecessary spaceport.


The FEIS and the LSOL Population Monitoring and Management Plan both depend on the current limit of 300 visitors per day to Cumberland Island. However, increasing the 300 daily limit has been encouraged by no less than the National Park Service and the Camden County Chamber of Commerce.[31] The limit is a relic from 1984 and has been the subject of multiple studies to determine the feasibility of increasing CINS visitation.[32] The limit is arbitrary and there is no legal limit to the number of park visitors or private visitors to Cumberland and Little Cumberland Islands. The FAA must anticipate that private owners and commercial operations such as Greyfield Inn may invite an indeterminant number of guests who will have a legal right to access and movement.


The Camden County Chamber of Commerce certainly expects few constraints will be imposed when it states,

“The local, regional and state economy will benefit from the impact that increased island visitation and expanded tourism can bring to our local businesses” due to spaceport launch activities.[33]


Deceit #13 : “Operations at the site would not produce any noticeable seismic effects (ground vibrations)”[34]

“An analysis of the potential effects of ground vibration on the landfill site located 1.65 miles from the launch site concluded that launches would result in peak ground accelerations (i.e., the maximum amount of ground shaking) equivalent to a minor earthquake (magnitude 3.9) and is approximately equivalent to vibrations produced by a passing truck.”[35]


There is no record of an earthquake (minimum 2.0 magnitude or greater) occurring on the Georgia coast during the last 50 years. Therefore, the sensitivity of surrounding areas to seismic activity has not been evaluated in modern times. Tests specific to the area’s geologic structure must be performed to determine if any of the multiple Bayer CropScience contamination sites, the shallow Brunswick Aquifer and deeper Floridian Aquifers, off-site wells, riverbanks, and other seismic-sensitive environments will be destabilized by repeated seismic shocks during repeated launch and testing operations, even if not “noticeable.”

Deceit #14 : “Vibrations at this level (3.9 magnitude) would not be anticipated to contribute to the migration of contaminants in the soil. [36]


Following investigative seismic testing in 2017 for Spaceport Camden, and after 12 years of stability, levels of detectable Arsenic in groundwater dramatically rose indicating migration of contaminants in one of the 10 known Bayer CropScience contaminated sites. The peak contamination detected was 9,200,000 (nine million, two hundred thousand) times the EPA approved limit of 10ppb for Arsenic in drinking water.



The FEIS makes no reference to this information. The Bayer CropScience Contamination sites are not identified on FEIS exhibits although one of approximately 40-acres lies entirely within the Launch Pad Hazard Area but is not analyzed in the FEIS.”


FEIS page 3-57, Bayer CropScience Contamination Sites, advises,

“Preliminary investigations have also identified 10 additional sites that may be potentially contaminated within the Bayer CropScience property. These sites are identified with the name of the suspected contaminant(s): (1) sanitary wastewater disposal; (2) gas/diesel compounds/benzene, toluene, ethylbenzene and xylene (BTEX); (3) pesticides; (4) BTEX; (5) munitions waste; (6) munitions waste; (7) acids and pesticides; (8) pesticides; (9) munitions/rocket fuel waste; and (10) pesticides.” [The Bayer landfill containing Arsenic is not identified in this list.] “They are located on the northwest quadrant of the Bayer CropScience property, with most of the sites adjoining or located near Union Carbide Road (which would be improved as part of the Proposed Action).” “Detailed information on the presence of hazardous constituents is unavailable from by Bayer CropScience.”


Spaceport Camden operations require the purchase or lease of Bayer property containing contaminated sites which have not been analyzed in the FEIS.

Several other areas of contamination not discussed above are located within the spaceport site boundary (see LSOL Exhibit 3.7-1).


What exactly is the function of an Environmental Impact Statement if known areas of contamination on spaceport property are not evaluated?


Deceit #15 : “The rocket uses 1,000 gallons of LOX and 750 gallons of RP-1.” [37]

Yet facilities are proposed to hold 350,000 gallons of liquid oxygen (LOX), 250,000 gallons of RP-1 rocket propellant, and 2,600 gallons of toxic fuels [38] providing enough fuel for the equivalent of 300 launches – enough for 28 years of SLV launches. This statement confirms the concerns that classic bait-and-switch tactics are being employed to understate the risks to achieve an approval allowing eventual changes to the constraints that will not require the public’s participation. Incredibly, the Final EIS contains visuals (including the cover image) showing operations of Medium-Large lift Class rockets and landing activities same as originally displayed in the Draft EIS. Such deception is not allowed under NEPA.


Deceit #16 : “Over the past 25 years, there have been no fatalities or serious injuries to the public (i.e., persons not involved in launch activities) from licensed or permitted commercial space launch operations” [39]

This is an overtly deceptive use of a factual statistic since the FAA fully understands that Spaceport Camden would be the first spaceport to intentionally launch rockets over the American public, private residences, and a visitor-active National Park unit – all are immediately downrange. The FAA knows that rocket launches have been routinely delayed or postponed at all US spaceports due to public intrusions into launch hazard zones.


Since the FAA has demonstrated that it cannot manage execution of an accurate, error-free FEIS, how can your office claim to meet the legal thresholds required under NEPA and FAA Order 1050.1F, and applicable regulations? Issuing a Record of Decision approval for Spaceport Camden and the subsequent issuance of a launch site operator license will be a clear indictment that the FAA is not willing to undertake its mandate to protect public safety, public health, private property rights, and environmental responsibilities.

Respectfully,


WWW.SPACEPORTFACTS.ORG

Steve.spaceportfacts@gmail.com



Footnotes: [1] Draft EIS, 2018, page 1-5 [2] FEIS, 2021, page 3 [3] Draft EIS, 2018 [4] FEIS, 2021, page 3 [5] Author’s review of FAA vehicle licenses, July, 10, 2021 [6] FEIS ,2021, Page 3 [7] FEIS, 2021, Page 2-22 [8] Ibid [9] Ibid [10] LSOL Application, January 2020, Page 15 of 20 [11] The smallest Astra Space rocket being offered commercially by 2022, is now upsized to minimum of 10x thrust of the Spaceport Camden representative rocket. The original Vector R with 18,300 pounds thrust was never built and has been speculatively upsized to 3 times the thrust of Camden’s rocket. [12]www.spaceportcamden.us claim July 18, 2021 [13] Ibid [14] The FAA should spell its client’s name correctly as two words, “Rocket Lab”. [15] Final EIS, 2021, page 10 [16] LSOL, Spaceport Camden Launch Site Review, page 28, “Spaceport Camden is not applying for these permissions in this application.” [17] Spaceport Camden Final Coastal Consistency Certification, June 2021, page 2 [18] LSOL, Spaceport Camden Launch Site Review, page 28, “Spaceport Camden is not applying for these permissions in this application.” [19] http://www.parabolicarc.com/2021/07/19/rocket-lab-completes-anomaly-review-next-mission-on-the-pad-in-july/ [20] FEIS, 2021, page 2-22 [21] FEIS, 2021, page 4-4, “Both MMH and NTO are toxic to humans and pose environmental hazards if released in sufficient quantity to the environment. MMH is highly reactive as well, and is listed by the International Agency for Research on Cancer as a possible human carcinogen.” [22] FEIS, 2021, page 4-75 [23] In common use, a few is more than a couple (two), while several often means more than a few, though it is sometimes the same as both. Adapted from Merriam-Webster.com, “'Couple,' 'Few,' and 'Several': The (Mostly) Definitive Guide.” [24] Final Georgia Coastal Consistency Certification, page 13. [25] FEIS, 2021, page 2-21 [26] FAA Flight Safety Analysis Handbook, 2011, FAA, page 189 [27]Spaceport Camden LSOL 2020 – “Population Monitoring and Management Plan”, page 5 [28] Ibid [29]Spaceport Camden LSOL 2020 – “Population Monitoring and Management Plan”, page 1 [30] OCGA 38-3-3(7): "State of emergency" means the condition declared by the Governor when, in his judgment, the threat or actual occurrence of a disaster, emergency, or energy emergency in any part of the state is of sufficient severity and magnitude to warrant extraordinary assistance by the state to supplement the efforts and available resources of the several localities and relief organizations in preventing or alleviating the damage, loss, hardship, or suffering threatened or caused thereby. [31]http://www.camdenchamber.com/pages/CumberlandIsland, “SUPPORT INCREASED VISITOR CAPACITY AND EXPANSION OF ACCESS TO CUMBERLAND ISLAND NATIONAL SEASHORE” [32] https://www.researchgate.net/publication/325490643_The_Experiential_Carrying_Capacity_of_ a_Barrier_Island_A_Norm-Based_Approach_at_Cumberland_Island_National_Seashore-- [33] Ibid [34] FEIS, 2021 page 4-16 [35] TetraTech. (2017). Preliminary Evaluation of Rocket Launch Vibrations Impact on Union Carbide Corporation (UCC) Resource Conservation and Recovery Act (RCRA) Landfill. Woodbine, Georgia. [36] FEIS, 2021, page 4-134 [37] FEIS, 2021, Page 2-24 [38] Ibid [39] FEIS, 2021 Page 2-35

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