The Indian River Lagoon Round Table has reviewed NASA’s Programmatic Environmental Assessment for the Implementation of a 15-Year Development Plan at the Kennedy Space Center Visitor Complex and Launch Complex 39 Viewing Gantry and submitted the following comments to the KSC Environmental Branch on September 11, 2024.
The Indian River Lagoon Round Table is a group of environmentally aware citizens who are concerned that the cumulative effect of current and planned development at Cape Canaveral Spaceport presents a serious threat to the future health of the Indian River Lagoon National Estuary. Further degradation of the already impaired “Estuary of National Significance” will negatively impact Brevard’s local economy, culture and quality of life.
The proposed action in this Programmatic Environmental Assessment (PEA) does not qualify as a matter of national security, space technology advancement or KSC mission achievement. It is an enhancement of a tourist attraction. The development site location is within the Indian River Lagoon (IRL) Basin and environmental impact must be VIGOROUSLY minimized.
This PEA does not indicate knowledge or consideration of the IRL’s impaired condition. A proposed action for development using modern Low Impact Development/Green Infrastructure (LID/GI) strategy and technology will present to the expected hundreds of thousands of visitors a distinctive model of KSC’s and Delaware North’s dedication to its stewardship responsibility. It is well proven that LID/GI, when properly executed, reduces cost of development 15 – 80% (EPA, USF, DOD). Proof to the taxpayer that NASA-KSC works to save money.
IRL Round Table Comments by Numbered Section
2.5 Best Management Practices Included in Proposed Action
Best Management Practices (BMP) are specific actions as part of a site design strategy that includes natural and engineered means to capture and store rainwater on site for infiltration and reuse in order to reduce fresh polluted runoff into nearby surface waters. The only BMPs “inherent” to this action are old, proven to be ineffective, retention ponds, canals and ditches.
NASA/KSC must advance to modern, intelligent development in order to reduce its current contribution to fresh water runoff pollution in the IRL and ensure that future developments pose no risk.
We request that NASA/KSC adopt a LID/GI standard of development similar to DOD UFC 310-2-10 Low Impact Development.
3.5.1 Habitat and Vegetation
Table 3.8 shows proposed land impact of 111.0 acres, including 18.2 acres of wetland. Notice is made that many acres are old orange groves and invasive Brazilian Pepper. All of this land remains valuable to naturally capture, store and infiltrate rainwater and prevent runoff to the IRL. The estimated new impervious surface proposed will produce annually millions of gallons of new fresh water runoff into our Lagoon. This is a major impact to an already damaged IRL. See our Section 2.5 comments above.
3.9.1 Surface Water
The statement “Surface water quality is generally good in the KSC area” is misleading and casts doubt on the integrity and value of the draft PEA. The IRL is, in its entirety, an impaired waterway and does not meet water quality standards (EPA/FDEP). Hundreds of millions of federal, state and local dollars are being and will be spent to repair and correct the impact of past and current development practices. The North Banana River Lagoon Zone A, contiguous with the Cape, is rated the worst water quality (FDEP).
This PEA’s data collection, review and presentation are all questionable. It does not mention the dire condition of the lagoon or the need for extraordinary action to save it. We request that the PEA be changed to include actual current data on IRL water quality and specific stormwater management systems planned for the proposed action.
4.4.7 Water Resources (Cumulative Effects Analysis)
A major cause of the Indian River Lagoon’s impairment is the degradation of its salinity due to stormwater runoff. The PEA does not consider the cumulative impervious surface area added by development nor its stormwater runoff impact on the IRL. The statement “these systems will discharge to one of the existing surface water ponds or ditches/canals” indicates failure to realize or consider the true impact of freshwater runoff on adjacent brackish surface waters.
We request the PEA be corrected to include modeling data that proves the proposed action will not add to the cumulative polluting runoff that now risks the future of one of Florida’s most important ecosystems.
We congratulate NASA/KSC, Delaware North and BRPH on achieving LEED’s Silver certification on the new Gateway Attraction. Applying the same Green Path© commitment to the Indian River Lagoon National Estuary would likely reduce the Visitor Center’s cost of development and bring even greater accolades to NASA’s Kennedy Space Center and Delaware North.
References
- https://irlroundtable.com
- https://netspublic.grc.nasa.gov/main/DNC%20Final%20VC%20PEA_08-09-24%20(Appendices).pdf
- https://lovetheirl.org/education/low-impact-development
- https://www.wbdg.org/FFC/DOD/UFC/ufc_3_210_10_2023.pdf
- https://www.delawarenorth.com/who-we-are/corporate-social-responsibility/greenpath
Download: IRL Round Table – Visitor Complex PEA Comments (PDF, 75KB, 3pp)
The IRL Round Table’s comments on stormwater run-off point to the need for a engineered wetland reservoir to contain and filter KSC’s stormwater instead of continuing to use the harmful and outdated practice of discharging salinity reducing freshwater into drainage canals connected to the Indian River Lagoon National Estuary.