Diana Taylor
Georgia DNR
One Conservation Way
Brunswick, Ga. 31520
January 7, 2021
RE: Spaceport Camden Public Notification Comments
Ms. Taylor,
In and of itself, the Public Notice announcing the comment period for the Launch Site Operator License (“LSOL”) Coastal Consistency Certification document (“CCC”) has several defects that must be corrected to frame DNR, Spaceport Camden, and the FAA’s actions and intents accurately.
Defect 1: The Coastal Consistency Certification (“CCC”) document incorrectly describes the spaceport location. The document describes the spaceport location multiple times as being “at the end of Harrietts Bluff Road (also referred to as Union Carbide Road).” The official Camden County GIS map shows the Harrietts Bluff Road and Union Carbide Road are distinctly-named roadways. Harrietts Bluff Road terminates in Harrietts Bluff residential community. Union Carbide Road begins near the Harrietts Bluff community and continues for 6 miles to the Union Carbide site. Properties facing Union Carbide Road have Union Carbide Road mailing addresses, as would the spaceport. Although this seems like a small error, it is indicative of the profusion of uncorrected technical and mundane errors still found throughout the Spaceport Camden documents after five years of public comments and editing by spaceport consultants. A decision-maker cannot determine the facts from the errors and omissions.
Defect 2: 14CFR Part 420 License to Operate a Launch Site FAA regulations do not provide a definition for “proven” or “unproven” launch vehicles. Regardless of the regulations, the Spaceport Camden Public Notice statement “proven (not unproven/experimental)” directly conflicts with the rocket examples provided in the LSOL and CCC. Those documents list rockets from four rocket companies as examples of those that “may” be launched from Spaceport Camden. Only one of the four has launched licensed orbital rockets. That company requires a unique launch infrastructure not shown in the documents. A second of the three still experimental companies also requires a unique launch infrastructure that is substantially different from the first company. Two of the four companies have never launched a rocket. Their safety and performance characteristics are entirely speculative. The remaining company, Vector Launch has recently reformed under new ownership after bankruptcy liquidation. Vector had previously launched only amateur rockets. Vector now intends to offer sub-orbital flights that are not included in Spaceport Camden licensing.
Defect 3: Camden County has caused the public and the State of Georgia to believe that Georgia Tech and other researchers will use the spaceport facilities for non-commercial, experimental rocket launches. The Spaceport Camden Facebook page posts stories and images of student rocket activity at Spaceport Camden. If these types of uses are allowed, then the Spaceport Camden Public Notice is misleading each time it states “commercial operators.” Commercial launches are required to carry Maximum Probable Loss insurance. Student rocket club and university launches do not qualify for MPL insurance.
Defect 4: No US university has launched an “orbital rocket.” The safety or environmental impacts of commercial or non-commercial sub-orbital or unguided rockets are not investigated in the Draft EIS and LSOL. It is unlikely the Department of Defense would allow such launches near Naval Submarine Base Kings Bay. The FAA does not license amateur rocket launches or launch operators, so those launches would not be subject to FAA “separate review for consistency” described in the Spaceport Camden Public Notice. Alarmingly, FAA procedures do not incorporate public input in subsequent environmental reviews.
Defect 5: The Spaceport Camden Public Notice states that the proposed spaceport property consists of “the approximately 1,200 acre existing commercial upland site owned by Union Carbide Corporation and Bayer CropScience.” However, the Coastal Consistency Certification document describes the 1,200 acres as owned exclusively by Union Carbide Corporation. Camden County further states that they do not have a lease or purchase agreement with Bayer CropScience. At the very least, access easements over the Bayer property will be required, or new roads will be necessary but are not addressed in any of the EIS documents. Bayer CropScience property is included in the launch safety zone and Overflight Exclusion Zone for every legal launch trajectory. There is no evidence in the relevant documents that Bayer has agreed to such activities.
Defect 6: The LSOL, Draft EIS, Draft Final EIS, and the Coastal Consistency Certification (“CCC”) documents are indeterminant about the role of the Bayer property. In any case, none of those documents demonstrate that the required environmental risk assessment was performed for the Bayer property.
Defect 7: The Public Notice is not dated.
The issues mentioned above indicate that the project parameters are not well-understood by the DNR or that the DNR is confused by the various documents’ contradictory statements. After five years of ever-morphing spaceport scope, Camden County continues to provide inaccurate, confusing, incomplete, and deceptive information about their planned activities. It is understandable that the DNR and the public remain confused about the ultimate impacts of Spaceport Camden on Georgia's coastal environment and safety.
It is incumbent upon the Georgia Department of Natural Resources to post an accurate Public Notice for the Spaceport Camden Coastal Consistency Certification.
Comments specific to the Coastal Consistency Certification document will be forthcoming.
Respectfully,
www.spaceportfacts.org