As the Volusia/Flagler Chapter of the Surfrider Foundation, our mission is the protection and enjoyment of oceans, waves and beaches through a powerful activist network. While something like the Shiloh proposal is not generally within our purview of concern, we are certainly concerned with the delicate ecosystems that support those areas that we strive to keep open and clean.

At the outset we, as the voice of hundreds, perhaps thousands of volunteers and activists within the Volusia and Flagler Counties, would like to express our objection and disapproval of the option to use the Shiloh site for a commercial spaceport as proposed. However, at these early stages and during this comment period, we understand that you are requesting suggestions of what to consider in the Environmental Impact Statement (“EIS”).

With all of the recent attention and concerns regarding the Indian River and Mosquito Lagoons, we must be certain that any environmental evaluation of the impacts of the Shiloh option for a spaceport considers not only the immediate impacts of the space port and its operations on the surrounding environment, but also the compounding effect an additional stressor would have on the already delicate ecosystem; ecosystems do not operate in a vacuum and certainly should not be evaluated as such. The Indian River Lagoon and potentially the Mosquito Lagoon are in danger of failing from a number of different and vicious external and internal stressors. The addition of such an invasive, poisonous and impactful operation in an otherwise pristine and untouched locale could potentially have the effect of being the straw that breaks the camels back so to speak. When ecosystems reach a tipping point, they fail catastrophically and are often prohibitively expensive to repair, or worse, can never be repaired. In conclusion, please consider the already delicate and stressed nature of the ecosystem and the large area it services in your studies.

The National Environmental Policy Act (“NEPA”) requires reasonable alternatives to be considered in studies.  The only “reasonable alternative” being considered in the current EIS, is apparently a “No Build” option. There are no other actual reasonable alternative sites being considered so the “No Build” alternative will necessarily produce skewed results towards building.  It is likely where there are no other actual alternatives the majority, being economically minded and focused, will have only one option for build. The “No Build” should certainly serve as a baseline, but other alternatives should be considered. One logical, but oddly avoided alternative, is the existing NASA site and its unused pads. Therefore, please also consider actual alternatives in the EIS as required by NEPA.

Finally, while we are not certain economics play a role in the EIS stage, they should certainly be considered in the selection process. Briefly, fully functioning ecosystems have vast and almost immeasurable economic worth such as filtering water, providing nurseries for young and often commercially viable fish and wildlife, not to mention the tourism and use worth that they represent. Consider the cost to replace these ecosystem services with a mechanical and/or manmade option. The start up and continuing cost of reproducing all the services provided by this ecosystem would undoubtedly be staggering in comparison to any worth a commercial space station could provide. It is clear that if the Shiloh site is built, it will without a doubt have a negative impact on the functioning, and already fragile, ecosystem; the financial benefits, however much they are, would be inversely related to all other sources of income and economic worth of this system. As the worth of Shiloh increases the industries related to the ecosystem will decrease at a likely alarmingly faster rate. When the space industry has moved on to other states or countries, we are left with a used up and non-repairable resource that once brought in much more than the space industry ever had or will. Is this what we want to be our legacy? Does this option truly have vision? It seems like supporting this proposal will create a focus on two competing economic goals; one in the spaceport and one in the ecosystem, which, considering its expansive impacts, is effectively the economic juggernaut of the two. This tact is about the fastest way to get nowhere. Please consider the inverse and competing relationships of economic impacts.

We have such a pristine, beautiful and productive ecosystem that needs to be preserved. We are at a significant tipping point for our environment and need to fight to keep it alive.

The Executive Board
Volusia/Flagler Chapter
Surfrider Foundation