Re: Scoping Comments on SpaceX Starship-Super Heavy Cape Canaveral Space Force Station Environmental Impact Statement
Dear EIS Team at Jacobs Engineering:
The Marine Resources Council (MRC) is a not-for-profit organization of 700 members with headquarters in Palm Bay, FL. We are dedicated, for over 30 years, to the restoration and preservation of one of our nation’s grandest ecosystems – the Indian River Lagoon (IRL). The IRL is home to over 4000 species, the most in North America. Its annual value in commercial and recreational activity is 7.6 billion dollars. Our treasured lagoon is one of the mainstays of our quality of life. Our lagoon is badly impaired today and does not meet water quality standards (EPA/FLDEP). We have lost over 70% of our seagrass coverage, the primary measure of estuary health; our once thriving fishery has nearly disappeared, and manatees are starving to death in historic numbers. Millions have been spent and will be spent to repair and correct the damage done to the lagoon by years of badly managed development. The northern lagoon adjacent to Cape Canaveral suffers the worst water quality of the lagoon (FLDEP/BMAP update 2023).
We are concerned that the proliferation of piecemeal space industry development at the Cape will result in irreparable future harm to our lagoon. The Cape is critically integral to the NIRL ecosystem and must be developed to address this. We strongly recommend that a DAF/USSF, NASA, and Space Florida cooperative authority manage intelligent development throughout the Cape.
We are encouraged that USSF/SLD45 has committed to apply DOD Directive UFC 3-210-10 Low Impact Development to all qualifying development at CCSFS/PSFB. We trust Low Impact Development will prevail on this project to reduce cost and ensure a healthy, thriving future IRL.
COMMENTS
Alternative 1: The destruction of acres of undisturbed land and critical habitat in the face of an opportunity to build on already developed property is unthinkable. Acres of new impervious surfaces will add millions of gallons of freshwater runoff entering the lagoon instead of recharging our diminishing aquifer. We request that this alternative be removed from consideration.
Wildlife: The disaster in Boca Chica, Texas, resulting from the explosion of a Super Heavy, has been unprecedented and monumental. Migratory bird populations have plummeted in the surrounding areas. Cape Canaveral is a critical bird sanctuary habitat. We request full exploration into the impacts Super Heavy launches will have on ALL wildlife in the IRL.
Cumulative Effect: This area is not shown in documentation as a candidate for study in the EIS. The size and impact of the Super Heavy and the hardware that surely will follow make it essential to study past, present, and especially future development and operations. The near future proliferation of space industry activity will severely impact every resource area considered in the EIS. Space Florida has stated they are considering over 70 new projects and soon, 10 launches a DAY, not all at the Cape. We request that the Cumulative Effect be added to the EIS list of study areas.
Expectation: We request that study results be presented as actual current data with source references and dates. We request that calculations and modeling to determine present conditions and those used to estimate post-development conditions be stated. We request that EIS results include specific information regarding the choices and implementation techniques of UFC 3-210-10 Low Impact Development.
Sincerely,
James Moir
Chairman of the Board of Directors
Marine Resources Council