FAA Concerned Georgia Spaceport Could Kill Residents, Burn Down Islands

Spaceport Camden launch complex (Credit: Camden County)

by Douglas Messier
Managing Editor

Camden County is facing a series of significant challenges in winning FAA approval to build a spaceport for vertical launches in the coastal Georgia county. At the root of the county’s problems: the launch site isn’t actually on the coastline.

“Camden County’s application includes populated areas within an overflight exclusion zone. Camden County has not demonstrated that it can control and manage the population in the vicinity of the proposed launch site, particularly on Little Cumberland Island,” according to a letter the FAA sent to county officials on Oct. 17.

“A launch accident may cause an uncontrollable fire on [Little Cumberland Island (LCI)] or Big Cumberland Island. Access to LCI for firefighting and egress from LCI for evacuation are limited,” the FAA said in a subsequent letter dated Dec. 16.

While launching over populated areas hasn’t been a problem for the Russians and Chinese — with the latter dropping spent rocket stages on or close to inhabited villages — the FAA has imposed far stricter safety standards on U.S. orbital launches. Principle among them: no one not involved in the launch is injured or killed.

A group of homeowners Little and Big Cumberland islands are counting on these strict standards to defeat Camden County’s spaceport plans, which they believe will endanger their properties and lives.

The Protect Cumberland Island group recently obtained two letters the FAA sent to the county updating officials on the status of the application. The Oct. 17 letter was an 120-day status report on the FAA Office of Commercial Space Transportation’s (FAA AST) 180-day review of the application.

“An applicant must demonstrate that there are times when the public is not present or that the applicant has an agreement in place to evacuate the public from the overflight exclusion zone during a launch, if populated areas are located within an overflight exclusion zone,” wrote Kenneth Wong, manager of the FAA AST’s Licensing and Evaluation Division.

Wong also listed two other concerns the FAA AST had about the spaceport:

  • the lack of an agreement with the local U.S. Coast Guard district for issuing a notice to mariners and performing other measures to protect public health and safety; and,
  • the lack of certain information needed to evaluate environmental impacts from launch operations, including a coastal consistency review to the Georgia Department of Natural Resources.

In a press release released on Dec. 17, Camden County officials said the FAA AST’s analysis about the risk to island residents and their properties was erroneous.

“This information did not comport with the expert analysis conducted by the Aerospace Corporation on behalf of Camden County and released to the public,” the county said. “Analysis from the Aerospace Corporation showed that neither their overflight exclusion zone calculation nor their individual risk curves (100 times more stringent) reached Cumberland Island or Little Cumberland Island.”

Camden County official said they met with FAA AST officials on Dec. 10 to discuss the concerns.

“In this meeting it was revealed that the FAA’s own data largely supported the Aerospace Corporation’s conclusions,” the press release said. “Notably, that the independent analysis performed on the FAA’s behalf demonstrated that the overflight exclusion zone for a medium-large launcher and the individual risk contours did not extend to habitable structures or private property on Cumberland Island or Little Cumberland Island even if they possibly touched the islands or marsh.”

Four days after the meeting, Camden County modified its spaceport application to shift operations from launching medium-large launch vehicles to small satellite boosters.

“In coordination with the FAA, Camden County’s application has been revised to focus solely on small launch vehicles, which are the types of vehicles manufactured by commercial entities that are expressing the highest interest in operating from Spaceport Camden. Small launch vehicles generally pose fewer environmental and safety concerns, which is of utmost importance to Camden County,” the press release stated.

The modification came on the 178th day of the FAA’s 180-day review period. The changes resulted in a “tolling” (suspension) of the deadline so the agency could evaluate new information submitted by Camden County.

In a Dec. 16 letter, Wong laid out the agency’s concerns about uncontrollable fires on the Cumberland islands and reminded county officials that they had not completed the environmental assessment process.

There are also concerns about the proposed spaceport’s proximity to the Naval Submarine Base Kings Bay.

“Department of Defense (DoD) has concerns that the proximity of launch operations to a vital U.S. Navy base might jeopardize foreign policy or national security interests of the United States,” Wong wrote.

“Even with the proposed narrowing of your application scope, there is no assurance the FAA will make a favorable license determination in view of the issues raised above,” Wong added.

The two FAA letters follow. Camden County’s press release of Dec. 17 can be found here.


Commercial Space Transportation
800 Independence Ave., SW.
Washington, DC 20591

December 16, 2019

Mr. James H. Starline
Chairman, Camden County Board of Commissioners
P.O. Box 99
200 East 4th Street
Woodbine, Georgia 31569

Dear Mr. Starline:

Per your request, under the provisions of 14 CFR § 4 13.15(b), the FAA agrees to toll the review period for the evaluation of your license application to operate a launch site in Camden County, Georgia. The tolling is effective December 14, 2019, the 178th day of the 180-day review period.

This action is in response to your letter dated December 14, 2019, in which you notified the FAA of Camden County’s amendment to its license application, in accordance with 14 CFR § 413.17(b), to limit operations to the launch of small launch vehicles from its proposed site. Furthermore, you requested in your letter that the FAA pause its 180-day review period until the FAA has an opportunity to perform an independent safety analysis on a representative small launch vehicle and address any other issues or concerns. Prior to receiving your December 14 letter, the FAA had conducted an independent review of the medium-large vehicle, the heaviest weight class planned to be flown from the proposed Camden County launch point per 14 CFR § 420.19(c). However, because you indicated in your December 14 letter that Camden County is amending its license application to limit operations to only the launch of small launch vehicles, the FAA will no longer provide a license determination on a medium-large launch vehicle with a first-stage return.

Camden County must ensure the continuing accuracy of its application, which includes the addendum Camden County submitted to the FAA on December 12, 2019, by removing any references to the medium-large vehicle in its application. You must submit your revised application to the FAA before we begin our analysis of the launch of small launch vehicles from your proposed site.

Also, please be advised there remain issues/concerns that have not yet been satisfactorily resolved:

Fire – A launch accident may cause an uncontrollable fire on LCI or Big Cumberland Island. Access to LCI for firefighting and egress from LCI for evacuation are limited.

U.S. National Security –The Department of Defense (DoD) has concerns that the proximity of launch operations to a vital U.S. Navy base might jeopardize foreign policy or national security interests of the United States.

Environmental Assessment – Camden County has not completed the environmental review process. Even with the proposed narrowing of your application scope, there is no assurance the FAA will make a favorable license determination in view of the issues raised above.

Sincerely,

Kenneth Wong
Manager
Licensing and Evaluation Division


Commercial Space Transportation
800 Independence Ave., SW.
Washington, DC 20591

October 17, 2019

Mr. Steve Howard
County Administrator, Camden County
200 East 4th Street
P0 Box 99
Woodbine, GA 31569

Dear Mr. Howard:

The FAA accepted your launch site operator’s license application for Spaceport Camden as complete enough to start the 180-day review period on June 19, 2019. We inform applicants within 120 days of accepting a license application of any outstanding information needed to complete our review, or of any issues that would affect the decision. As reflected below, the FAA has not received sufficient information to find that Camden County has satisfied the requirements set forth in 14 CFR § 420.17(a).

As such, the FAA continues to have concerns that include the following:

1. Per 14 CFR § 420.27(j), an applicant must demonstrate that there are times when the public is not present or that the applicant has an agreement in place to evacuate the public from the overflight exclusion zone during a launch, if populated areas are located within an overflight exclusion zone. Camden County’s application includes populated areas within an overflight exclusion zone. See 14 CFR § 420.5. Camden County has not demonstrated that it can control and manage the population in the vicinity of the proposed launch site, particularly on Little Cumberland Island.

2. Per 14 CFR § 420.3 1(a), an agreement with the local U.S. Coast Guard district to establish procedures for the issuance of a Notice to Mariners prior to a launch and other such measures as the Coast Guard deems necessary to protect public health and safety is required. Camden County has not provided such an agreement.

3. Per 14 CFR § 420.15(b), Camden County has not provided the FAA with certain information for the FAA to analyze the environmental impacts associated with the operation of the proposed launch site. Specifically, Camden County has not submitted the coastal consistency review to the Georgia Department of Natural Resources, thereby preventing the FAA from being able to complete its review under NEPA.

Should you have any questions concerning this matter, please contact me at (202) 267-8465.

Sincerely,

Kenneth Wong
Manager
Licensing and Evaluation Division