Indian River Lagoon Roundtable is reviewing and commenting on the NASA-KSC Roberts Road Supplemental Environmental Assessment. We are encouraging fellow environmentalists to respond to Kennedy Space Center’s request for public comment because this assessment involves the loss of 100 acres of wildlife habitat and an additional 35 m/g of stormwater run-off into the Indian River Lagoon watershed annually.
The undisturbed land to be developed is located inside the KSC Master Plan Conservation Boundary and encompasses 31 acres of upland pine and 68 acres of critical wetland habitat. We estimate that better land management, low impact development and space saving construction techniques could reduce the loss of conserved land by 50%.
Of note to the IRL Roundtable is Section 3.5 Biological Resources of the EA.
EA Section 3.5.2.1 Page 27: “With 100 percent build-out of the site, up to 31.8 acres of upland shrub and forest habitat, and up to 68.2 acres of wetland and waterway habitats would be lost and converted for purposes of development under the Proposed Action.”
Of special interest is the possibility of impact on the endangered animals that inhabit this area. The U.S. Fish and Wildlife Survey did not find Gopher tortoise or its commensal partner, the Eastern indigo snake, on 31 acres of upland. The recommended mitigation if a burrow is found calls for the construction crew to stop work until the animal leaves the area. Both the wildlife survey and its recommended remedy are inadequate.
EA Section 3.5.2.4 Page 29: “As a precaution, land clearing, construction, and maintenance personnel would be instructed to report any found burrows, and to halt activities if a gopher tortoise or indigo snake was encountered and allow the animal to leave the area before activities resumed.”
The IRL Roundtable fully expects this project’s Environmental Assessment, as have most EA’s generated by KSC since 1970, to be given a “Finding of No Significant Impact” (FONSI). We can only hope to mitigate the loss of conserved land, lessen the impact on wildlife and limit the amount of stormwater run-off entering the IRL watershed.
Please join us in our effort to preserve the Indian River Lagoon National Estuary while Kennedy Space Center rapidly develops into America’s premiere commercial Spaceport.
IRL Roundtable Roberts Rd EA Comments
IRL Roundtable has submitted the following to Don Dankert, KSC Environmental Management Branch Planning Team Lead, in response to KSC’s request for public comments on the NASA-KSC Roberts Road 100 Acre Expansion Supplemental Environmental Assessment (SEA).
Indian River Lagoon Roundtable is a group of informed citizens that recognizes the importance of both the Indian River Lagoon (IRL) and the space industry, and seeks to create a synergistic relationship between America’s irreplaceable environmental treasures and its premier launch facility, Cape Canaveral Spaceport. We are concerned with the KSC Roberts Road 100 Acre Expansion Supplemental Environmental Assessment (SEA) as it entails the destruction of critical wetlands and preserved wildlife habitat.
Brevard County and the State of Florida are spending millions to preserve and restore the Indian River Lagoon watershed including wetlands, wildlife habitat and submerged land. The destruction of thirty one acres of uplands and sixty eight acres of wetlands from the KSC Conservation Buffer originally set aside in the 2020 KSC Master Plan and managed by the Merritt Island National Wildlife Refuge (MINWR) will set a dangerous precedent that contradicts NASA-KSC’s long standing legacy as a steward of Cape Canaveral’s endangered wildlife and the habitat it needs to survive.
IRL Roundtable seeks to maximize science and minimize impact while supporting a growing Spaceport embedded in the last undisturbed land remaining on Florida’s Atlantic Coast. We urge Spaceport stakeholders to consider all of Cape Canaveral as a SINGLE SITE and to work cooperatively in its development and stewardship of America’s priceless natural resources.
These are early steps in Cape Canaveral Spaceport’s commercial development. A variance of the KSC Master Plan’s Conservation Boundary will set an unfortunate precedent for what will follow. It is possible that most of KSC’s planned Conservation Buffer will be exploited and the resulting environmental impact on the Indian River Lagoon National Estuary watershed could be catastrophic.
IRL Roundtable Comments on the KSC Roberts Road 100 Acre Expansion Supplemental Environmental Assessment
- EA Section – Executive Summary – This proposal violates the 2020 Spaceport Development Boundary and other development restrictions. The Conservation Boundary variance, if approved, indicates that these restrictions are void as future such proposals must be given equal treatment.
- 3.12.2.1 Environmental Consequences of Proposed Action – We estimate that this 100 acre expansion will result in more than 35 million gallons of stormwater run-off annually. Current FDEP permitting allows the Lessee to discharge excess stormwater into MINWR’s Oyster Prong, an Outstanding Florida Water. Any form of excess freshwater added to an estuarine waterbody is chemical pollution.
- 3.5.1.1 Affected Environment – The project expansion is north of the existing Roberts Road facility. The original 2018 plan shows future expansion to be east and west of the current land. Why was the west segment not considered an alternative? The map provided indicates west is available rangeland and that an expansion westward would destroy much less wetland than the proposed action. Please consider western expansion.
A maximum footprint of 1.5 million sq. ft. is 35% of 100 acres with 65% open space. Using proper Low Impact Design for the site this footprint could be accommodated on 50 acres and still retain 30% open space. Please review the preliminary site plan and reconsider the area allocation. - 3.5.2.4 Wildlife and Protected Species – The U.S. Fish and Wildlife Survey did not find Gopher tortoise or its commensal partner, the Eastern indigo snake, on 31 acres of upland. The EA’s recommended mitigation if a burrow is found calls for the construction crew to stop work until the animal leaves the area. Both the wildlife survey and its recommended mitigation are inadequate. Local Florida Wildlife Conservation Commission professionals should be consulted and their relocation recommendations followed.
- 3.9.2 Environmental Consequences – The frequent reference to Best Management Practices (BMP) to manage stormwater is inadequate. The site design must provide reasonable assurance that post development hydrology will be less than or equal to pre-development (SJRWMD). Please include required site calculations, hydrology, topography, natural drainage information and a plan to manage an estimated 35 million gallons/year of new stormwater run-off.
- 3.9.2.1 Surface Waters – Total Maximum Daily Load (TMDL) values given here are incorrect. Basin Management Action Plan (BMAP) load allocations are calculated based on existing in-place conditions and do not consider additional load expected from new and planned development. Local authority is required to factor in new and planned development and adjust load requirements accordingly (FDEP).
- 5.0 Cumulative Impact – Continuous air, soil, water and wildlife monitoring, recording and reporting is required in order to reach an understanding of the spaceport’s cumulative environmental impact. This section requires, at least, data on current ambient conditions of water quality as well as pre and post development hydrology of significant existing sites.
Tables 5.1 and 5.2 show some of the Spaceport’s ongoing projects but do not indicate the land use area or footprint of any. Recently reported information from Space Florida indicates 74 projects are under consideration. These future developments must be considered to determine the space industry’s true cumulative environmental impact on the Indian River Lagoon National Estuary.