KSC Roberts Road Expansion Comments

The Indian River Lagoon (IRL) Roundtable is a group of environmentally aware citizens who are concerned that the cumulative effect of current and planned development at KSC presents a serious threat to the future health of the lagoon. If realized, this will damage our local economy, culture and quality of life.

The IRL is a Federally designated Estuary of National Significance. It is declared by EPA and FLDEP an impaired waterway. It is in steep decline due primarily to human development. Hundreds of millions of dollars are being spent repairing the results of past development done with inadequate consideration of impacts on the lagoon. Today KSC and the surrounding area is experiencing unprecedented new growth due to booming commercial space development.  

The following comments apply:

1. Require analysis of current measures of IRL water quality and habitat health and   expected changes post development.
2. Calculate and publish IRL impacts, from facility construction and operation, on stormwater runoff, wetlands infill, and industrial and operational wastes (including rocket manufacturing, testing, launch).
3. Calculate IRL impacts from sewage and the adequacy of existing wastewater treatment facilities and establish action to mitigate. 
4.  Require implementation of Low Impact Development techniques to be consistent with EISA Section 438 as exemplified in DOD directive UFC 3-210-10 change 3, dated March 1, 2020
5. The IRL and the impoundments of the Merritt Island National Wildlife Refuge are vital hatcheries for many threatened or endangered, and commercially or recreationally valuable Atlantic and Caribbean marine species. We request full consultation with the National Marine Fishery Service of NOAA to determine the impact current and planned development will have on these breeding grounds within the IRL. 

If you have questions or need additional information, please let us know.  

Lew Kontnik, for the Indian River Lagoon Roundtable

The Brevard Indian River Lagoon Coalition (BIRLC) is pleased to present the following comments related to the above-referenced project. Founded in 2016, BIRLC is an all-volunteer, 501(c)(3) non-profit, nonpartisan organization seeking and facilitating education and collaboration–bringing together organizations, businesses and individuals who share the goal of supporting restoration of the Indian River Lagoon. 

In defining the scope of the EA, we recommend that the EA include the following specific areas for in-depth comprehensive review: 

1. Rather than relying on outdated information, obtain current data to evaluate the IRL water quality and habitat health data as the basis for determining the impact of the proposed actions.
2. Identify the wetland and water course systems on the site and assess their functions and value to assure impacts are avoided. If impacts cannot be avoided, they should be mitigated on-site and not rely on an off-site wetland bank.
3. Assess the impacts on the IRL from the construction and operation of the facility including the management stormwater runoff, and industrial and operational wastes. This would include the management of sources of pollution from PFOS, heavy metals, or chemicals on the EPA list of contaminants, carcinogens, herbicides, and pesticides.
4. Evaluate the impact from the consumption of water resources either supplied by local utilities or pumped from underground wells.
5. Evaluate opportunities under the proposed action to implement any technologies to remove pollutants from existing sources, while not adding and new sources. 
6. Require the implementation of Low Impact Development measures as the principal method for the treatment of stormwater prior to discharge into the IRL.
7. Asses the impacts from domestic sewage and the adequacy of existing wastewater treatment facilities. 
8. Consult with the National Marine Fishery Service of NOAA to determine the impact the planned development may have on the breeding grounds of the IRL for the marine species that are threatened or endangered.
9. Identify the impacts of sea level rise and the adequacy of mitigation measures to protect the proposed site and building improvements. 

We look forward to your reply to this request.

Brevard Indian River Lagoon Coalition

Craig Wallace, Chairman

The Merritt Island Wildlife Association is a group of passionate citizens who support the mission of the US Fish and Wildlife Service (USFWS) and the Merritt Island National Wildlife Refuge (MINWR). Our board includes local business leaders, current and retired KSC employees, two current and two past presidents of local Audubon Society chapters as well as educators and those with avid interests in wildlife observation, photography, kayaking, hunting, fishing, and hiking. 

A crown jewel in our nation’s collection of natural lands, MINWR provides habitat for more than 1500 species of plants and wildlife, including more than 61 federally- and state-listed endangered and threatened animal and plant species. MINWR is responsible for more protected species than any other federal property in the continental United States, including the second largest remaining population of threatened Florida Scrub-Jays. MINWR includes 22% of the open waters and more than 120 miles of shoreline of the imperiled Indian River Lagoon (IRL), a federally designated Estuary of National Significance, which is in steep decline due to human development. 

MINWR holds several special designations. The State of Florida designated MINWR as an Outstanding Florida Water in 1979. In 1997, the refuge was designated under the Federal Magnuson-Stevens Fishery Conservation and Management Act as Essential Fish Habitat to conserve and enhance the habitats necessary for fish to carry out their life cycles. Due to MINWR’s importance to resident and migratory birds, the Florida Fish and Wildlife Commission (FWC) designated the refuge in 2000 as one of three gateways to the eastern section of the Great Florida Birding Trail. In 2001, the American Bird Conservancy recognized MINWR as a Globally Important Bird Area. 

The Kennedy Space Center (KSC) and the surrounding area is experiencing exceptional new growth due to a flourishing commercial space industry. We are concerned that the cumulative effect of current and planned development at KSC is a serious threat to the upland wildlife populations of MINWR and to the future health of the IRL and its surrounding salt marshes. This damage could impact not only the wildlife refuge itself — it could jeopardize our local economy, culture and quality of life. 

The following comments apply to Space X’s request for an expansion of their facilities at Roberts Road: 

1. According to USFWS biologists, the habitat for threatened scrub species is of higher quality on the north side of the current “Hangar X” than it is on the south side of Roberts Road. In order to preserve this high quality habitat, require the Space X expansion to take place on the south side of Roberts Road. In addition, all Gopher Tortoises and Eastern Indigo Snakes found within the impacted area (including on access roads) must be relocated per FWC guidelines. 

2. The proposed new connector road is an unnecessary convenience for SpaceX since their employees, contractors and clients can use existing roads to access the SpaceX properties. The proposed road passes through virgin salt marsh. If the road is deemed necessary, it must be routed through lower quality habitat.

3. Hundreds of millions of dollars are being spent by citizens through a sales tax as well as by many government agencies on projects to repair damage to the IRL from past development. One such project by MINWR involves planting millions of clams in Refuge waters to enhance filter feeding to clean up the IRL waters. Freshwater from an unnatural source is a pollutant to the IRL. Too much freshwater will interrupt the reproductive cycles of clams and fish, or even worse, make it impossible for them to survive. Freshwater going into the Refuge impoundments will threaten vital hatcheries for finfish and shellfish. Require that all stormwater runoff and treated wastewater from SpaceX operations be kept on site through the application of Low Impact Development.

4. Require any wetland mitigation to take place on MINWR or within the Northern IRL basin. 

5. At a minimum, the Environmental Assessment should assess the adequacy of current data on IRL water quality and habitat health and should use generally recognized techniques for assessing post development changes and impacts. 

This letter is fully endorsed by the members of the Merritt Island Wildlife Association. We appreciate the opportunity to comment and look forward to working with KSC to preserve the Merritt Island National Wildlife Refuge during this exciting time of expansion. Future development at KSC must not add to the damage that has already been done to the IRL. 

Sincerely, 

Charlie Venuto, President Merritt Island Wildlife Association