July 9, 2021
Shannon A. Estenoz
Principal Deputy Assistant Secretary for Fish and Wildlife and Parks
U.S. Department of the Interior,
1849 C Street NW, Washington, DC 20240
RE: Spaceport Camden and Cumberland Island National Seashore
Dear Deputy Assistant Secretary Estenoz:
We write to raise concerns about Spaceport Camden, a proposed rocket launch site that would be located immediately inland from Cumberland Island National Seashore and Wilderness Area. The planned spaceport would launch rockets across the island and require a “limited access area” across the park. (See attached at Figure 1). The Federal Aviation Administration (“FAA”) is finalizing its review of the project’s launch site license application and recently released the project’s Final Environmental Impact Statement (“FEIS”)1June 25, 2021 EPA Notice of Availability: Final EIS No. 20210082, Spaceport Camden, www.federalregister.gov/ documents/2021/06/25/2021-13558/environmental-impact-statements-notice-of-availability
The National Park Service and the Department of the Interior Region 2 (collectively, “the DOI”) have raised serious concerns about Spaceport Camden since the project’s inception. The FAA’s decision to release the FEIS despite these concerns and the DOI’s repeated requests for basic information regarding the project’s potential impacts have brought this matter to a head. Shortly after the FAA released the FEIS, the DOI once again requested information regarding the risk of failed rocket launches and the spaceport’s potential impact on park operations.2June 24, 2021 Letter from G. Ingram to D. Murray re Comments on Section 106 Programmatic Agreement. This information is essential to properly evaluate the adverse impacts of the project, and the DOI has previously requested this information on multiple occasions.
The DOI’s concerns are well-founded. The FAA has advised the applicant that a failed launch from Spaceport Camden could trigger an “uncontrollable fire” on Cumberland Island.3Dec. 16, 2019 Letter from K. Wong (FAA) to J. Starline (Camden County).
And Spaceport Camden’s license application describes the use of “temporary controls on public access” on Cumberland Island during launch activities.4Revised Launch Site Operator License Application: Population Monitoring and Management Plan (Jan. 14, 2020) at 6. Without more information on these and other potential impacts, it is impossible for the DOI to properly evaluate the risk that Spaceport Camden poses to Cumberland Island National Seashore as required under the National Environmental Policy Act, Section 106 of the National Historic Preservation Act, and Section 4(f) of the Department of Transportation Act.
In the context of the Section 106 review, the DOI and the other consulting parties continue to raise objections which remain unresolved even after the release of the FEIS. For example, the Gullah/Geechee Sea Island Coalition has raised concerns about the adverse impacts of the project on significant resources within the Gullah/Geechee Cultural Heritage Corridor. Many Gullah/Geechee people live within or near the project area, and cultural resources such as the First African Baptist Church on Cumberland Island would also be at risk.
The DOI must take all steps necessary to ensure that the risks of Spaceport Camden are fully evaluated and all mitigation measures are employed to protect Cumberland Island National Seashore. These measures include identifying and clearly documenting the FAA’s numerous failures and omissions in its review of this project. Further, the DOI should lodge formal objections to the FAA’s review as authorized by Section 4(f) and Section 106. And, given Cumberland Island National Seashore’s national importance and the dangerous precedent that the FAA’s mishandled review could set, the DOI should consider a predecisional referral of this matter to the Council on Environmental Quality under 40 C.F.R. § 1504.1 et seq.
Thank you for your attention to this matter and all of the efforts by DOI staff to protect Cumberland Island National Seashore. We are happy to provide any additional materials or discuss this matter further if it would be helpful.
Figure 1: Proposed Spaceport Camden in Relation to Cumberland Island National Seashore and Wilderness Area