FAA Concerned Georgia Spaceport Could Kill Residents, Burn Down Islands
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
15 responses to “FAA Concerned Georgia Spaceport Could Kill Residents, Burn Down Islands”
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There are good places for spaceports and there are bad places for spaceports. This location is a bad place. If the local development authority really want to benefit from the new space economy they need to be thinking in terms of a space technology research and development based industrial park instead of a launch faculty.
If my vertical launch system works, they might be able to launch from there. The system works by firing nearly vertical with just enough off vertical to clear the pad from falling debris if it blows up. The rocket goes up in to space then shuts the down. It falls straight down until it slows down to near zero. The thrusters then fire and it pivots on its’ cg. Pointing any direction you wish. The 2nd stage then fires and heads for orbit. The 1st stage then either crashes, parachutes or lands like F-9. No Dogleg is possible because of the Laws of Motion. It can pivot on CG. In the air the rocket may be torn apart by unequal slipstream. In space it will just keep going straight or do a large arc. There was this poster a long time ago that said why not a vertical launch? I could not see at that time how it would work. I think this will work. I think I got it all.
That’s possible, but it’s also a far less efficient trajectory. You’ll sacrifice a lot of payload with this trajectory.
Also, the vertical trajectory still doesn’t eliminate range safety issues. In fact, it can compound them! If something goes wrong, this thing is going to come, more or less, straight down. It’s the “more or less” part that’s the problem. The higher up the problem occurs, the further away from the launch site this thing will drift when it reenters and comes crashing down. So, you still have to have a huge exclusion zone around your launch site.
The other challenge with this is you’re still going to overfly land downrange with the upper stage, so you still don’t eliminate the “downrange” problem even if you can solve abort issues with the first stage.
At the end of the day, you’re far better off launching on a coastline with a trajectory that takes the vehicle out to sea.
It’s really choice that a Camden County Press Release tells the FAA that they got it wrong. Camden officials bought into George Nield’s advocacy for needing a spaceport on every corner but have spent millions trying to convince the FAA (that’s now acting responsibly) that Camden’s calculations are more accurate than the FAA’s. It’s a few politicians and a few consultants wagging the dog. Why does the FAA put up with this?
The so-called “Spaceport Camden” is so constrained they are having difficulty finding a single legal trajectory. Yet their website still claims they have a range of launch azimuths competitive with Wallops and Kennedy. A recent Grand Jury presentment lambasted the County for failing to keep the public accurately informed and forwarded their work to the currently-seated grand jury.
Spaceport Camden’s plans were drawn suspiciously similar to those SpaceX showed for Boca Chica in their 2014 EIS. Camden County residents have closely watched Boca Chica unfold. In 2014, the FAA complied a Final EIS that under-represented almost all risks to the public and public property.
After SpaceX won FAA approval, they surprisingly discovered they needed to bring in 300,000 cubic yards of dirt to support their launchpad. Did that get an environmental review?
SpaceX insurance requirements exploded. Wasn’t that because the public risk was greater than that represented in the Record of Decision?
Fires consumed a few hundred acres of public land during a test. The FAA didn’t anticipate that happening. Then Starship 1 blew up.
Now, Boca Chica residents must cut a deal with SpaceX to sell their homes under the threat of losing them to eminent domain. The 2014 FEIS said the worst impact might be they have to wear earmuffs.
The public beach access road Hwy 4 is closed by Sheriff’s deputies whenever SpaceX needs to use it or to protect the public during testing, not just those few days they claimed in the FEIS for scheduled launches.
The FEIS claimed construction disruption would “typically occur during normal working hours between 8:00 a.m. and 5:00 p.m., Monday through Friday.” But Musk is pushing Boca Chia on a 24/7 schedule.
We understand that the space industry is in flux and that the FAA is being asked by Camden to predict the future. Camden taxpayers are fed up with a project that has no budget, that’s supported by a 2-page, fictional economic impact summary, and where residents have had to resort to the Georgia Attorney General and the courts to get Camden to comply with our Open Records Act.
Camden residents are trying to protect their private property and their homes located just four miles downrange from rocket overflight. We are protecting our local industry built around Cumberland Island National Seashore. The entire NPS is already seriously underfunded and our park would have to bear new security and management costs like removing visitors from Wilderness Areas and telling campers their reservations made six months in advance won’t be honored — because of ‘tomorrow’s launch attempt.’ We are protecting our Kings Bay Naval Submarine Base (8,800 jobs) from being added to the BRAC list.
The FAA has to decide if it can handle its dual mandate to both promote commercial space activity and to regulate it including its responsibilities to public safety. Spaceport Camden has already wasted an immense amount of FAA resources while Camden brazenly tells them they don’t know how to do the calculations.
Perhaps a portion of the FAA budget can be shifted to the Cumberland Island Seashore account to fix the public docks damaged by a hurricane three years ago.
They changed the purpose of the site from F9/FH launch to Starship development and launch. This accounts for a lot of the changes. AMOS-6 was surprisingly large driver here along with the natural delays incurred by the soil remediation. The post AMOS-6 pad rebuild basically duplicated Boca’s planned F9 facility at LC-40 (And probably budget too). One of the issues with LC-40 was its original infra was hacked together as the vehicle was evolving and wasn’t as easy to turn around as more modern setups like 39A. The pad was a lot more labor intensive to operate and repair. Once LC-40 was modernized and rebuilt the pressure was off to find another F9 pad. This allowed the opportunity to redefine the Boca site for Starship development and flight test.
Of course, all of what you say is accurate and well known. The issue is that the FAA has a dual mandate to protect the public and the public’s property along with accommodating the commercial space industries needs. A bully corporation is not supposed to “have government on its side.” National defense should be an exception and Camden County has accommodated the Atlantic home port for our submarine nuclear deterrent force since 1978, so we get it. Surely you’ll admit that SpaceX’s commercial goals, no matter how lofty, should not take precedence over everything. SpaceX has two launch sites where they can conduct national security missions. Boca Chica is the Starship skunkworks because it is experimental (thus no Launch Site Operator License scrutiny yet) and it’s proven too dangerous and potentially too messy for the Cape or McGregor. Camden County residents have the only stake that matters so far in Spaceport Camden. Imagine our surprise when we discovered our Spaceport Project Lead, County Administrator Steve Howard had such confidence in his spaceport sales pitch to citizens that has been (unsuccessfully) job hunting out of state for two years. We don’t want a Boca Chica-type mess left in the wake of consultants and politicians whose incentive is a paycheck and who can leave this gig at any moment.
Yes, SpaceX should have done more research instead of just picking a location based on latitude. They would have saved a lot of money building their facility at the abandoned Matagorda Island Air Force Base. They could have even moved their rocket test facility from McGregor to the island and integrated it with a factory to build Raptors on the mainland providing them with a fully integrated facility.
It makes zero sense moving Raptor production away from Hawthorne with the rest of the propulsion team (which shares resources). McGregor has had huge investment prior to any of this and suites them well (easier to get to from interstates with F9 engines and cores as well as Raptors). This is a long term plan, most of the residents in Boca are >65, just a blink of the eye.
You are still thinking the way of Old Space. Elon Musk just closed his Florida Starship plant down and moved that workforce to Boca Chica to work on Starship Sn1. Remember, it’s about building rockets, not employing residents of a specific Congressional District like Old Space worries about.
BTW the consolidated workforce just pressured test their new method for welding fuels tanks this morning and it worked.
Dude, he closed the rental property while they are building up the Roberts Rd side outside the Cape….
https://imgur.com/a/1ER5KPN
And shipped a lot of the components to Boca Chica along with some of the workers. Of course there will be a presence in Florida, but the effort shifted for the first test flights.
So what? You built an entire argument based on them closing down Florida claiming with some bunk about Old Space and “specific Congressional District”. They are building the factory now, moved components to Roberts Road and continuing to build the Starship/Superheavy launch site at 39A. Superheavy booster will most likely fly first from the Cape.
The tank exceeded the performance of the previous iteration and the anticipated operating pressure, but it fell short of the margin required for crewed flights.
https://twitter.com/elonmus…
Yes, it is a work in progress. Pioneering new methods for building rockets at low cost is an iterative process and this is a big step on the road to doing so.
It is interesting to see them evolve their way to an optimized solution. Clearly this isn’t about how to build a stainless steel pressure vessel. The food industry has been using stainless steel retorts since forever. But they are expensive bespoke items, with long lead times, and they are, no doubt, generously over-engineered. It doesn’t matter how heavy your potato cooker is. They don’t move around much. But they are expected to lasted forever.