CCA Florida Opposes Placement of Space Launch Facility in Wild Refuge Area

CCA Florida opposes the use of Merritt Island National Wildlife Refuge and Mosquito Lagoon area for private, commercial space launch site.

aboutCCA

CCA Amendment 40 Lawsuit

Coastal Conservation Association's stand against Amendment 40 has now drawn formal opposition from all the groups actively promoting privatization of public marine resources in the Gulf of Mexico. The Charter Fishermen's Association formally intervened on behalf of the federal government's highly controversial plan for Gulf red snapper in May and in recent weeks both the Environmental Defense Fund and the Shareholder Rights Alliance have filed Amicus Briefs in support of the federal government. Standing with CCA is the State of Louisiana, which filed an Amicus Brief in support of recreational anglers in May. "The lines are clearly drawn," said Bill Bird, chairman of CCA's National Government Relations Committee. "The nation's fisheries are facing a united threat from those who seek to severely limit access to public marine resources through privatization schemes. This case may very well determine if this country continues to adhere to the principles of the public trust doctrine in the management of our wildlife resources, or if it will simply allow those resources to be given away to stakeholders that have joined forces to game the system." Amendment 40, also known as sector separation, created a new charter/for-hire sector and reserved a significant percentage of the overall recreational red snapper quota solely for use by the charter/for-hire industry. The measure was narrowly approved by the Gulf Council in October 2014 and resulted in seven representatives to the Council submitting a scathing minority report that was ultimately ignored. CCA filed suit in United States District Court shortly after Amendment 40 was signed by the U.S. Secretary of Commerce in April 2015. Amendment 40 resulted in a private-boat recreational angling season of just 10 days in 2015, compared to 44 days for the new charter/for-hire sector. The commercial sector, which already operates under a privatized system known as a catch share program, is allowed to fish year-round. "The Environmental Defense Fund, a select few charter/for-hire operators, and the commercial shareholders are working hand-in-glove to privatize roughly 70 percent of the entire red snapper fishery, and the federal government is facilitating it," said Bird. "The merger of a major environmental group with for-profit harvesters is making a mockery of the federal council system, and we are confident that the court will not allow such flagrant manipulation to continue. " Oral arguments in the case are scheduled for Oct. 28 in New Orleans.

The area encompassing Mosquito Lagoon, the northern reaches of the Indian River Lagoon, the Canaveral National Seashore and Merritt Island National Wildlife Refuge are some of the most pristine lands and waters left along Florida's east coast. The area is also essential habitat for many birds and aquatic animals, some of which are endangered or federally protected. A large number of anglers, hunters, bird watchers, manatee watchers, paddlers and other wildlife and outdoor enthusiasts consider the area a prime destination for their avocations. According to CCA Florida, the economic benefit from those enthusiasts to the State of Florida and those who live in the vicinity is immense, which is to say nothing of the recreational benefits conferred upon those enthusiasts by experiencing the area in what is largely its natural condition.

The Mosquito Lagoon is one of Florida's premier saltwater fishing areas. Anglers from all over the world come to fish for huge redfish in the clear shallow waters of the Lagoon. The refuge has issued permits for 71 fishing guides in the Refuge.

CCA Florida states that the Florida Kennedy Space Center (KSC) sits nearby and the fate of much of its facilities is unknown. Recently, several capable launch facilities have been used. In fact, one was used by a potential beneficiary of the proposed Shiloh site, Space X, which recently launched a rocket and spacecraft from KSC. NASA began exploring ways to increase future commercial use of the Shuttle Landing Facility at KSC well before the end of the Shuttle Program. Unfortunately, this is not the first time this area has been proposed for a new launch site. In 2008, NASA itself proposed 2 alternative new launch sites very near Shiloh. At the time, Coastal Conservation Association of Florida and other groups protested loudly, imploring NASA to find a way to use the facilities at KSC rather than impose the enormously adverse environmental impacts a new launch facility would have created. That proposal by NASA did not proceed, nor should this one.

All of the proposed sites are in the same area - Shiloh. CCA Florida says the most obvious alternative locations, the unused sites in the Kennedy Space Center and the Canaveral Air Force Base in Brevard County, are not even included! At previous hearings Space Florida assured many speakers that the environmental analysis would include a number of different options including the idle sites in Brevard County. However, throughout the process Space Florida has remained tightly focused on the Shiloh area in the Merritt Island NWR.

The development of the Shiloh site seems questionable in light of the tremendous impact the proposed launch complex would have - construction and post-development traffic and their attendant noise, smoke and heat from the launches, and storm water runoff, among them. What of access by the public to nearby lands and waters, including the Mosquito Lagoon and the Intracoastal Waterway? This heavily travelled waterway would be closed before, during and after launches. The Federal Register Notice states that Space Florida "proposes to construct and operate a commercial space launch site (The Shiloh Launch Complex) and two offsite operations support areas. The Shiloh Launch Complex would include two vertical launch facilities that could accommodate up to 24 launches per year, as well as up to 24 static fire engine tests or wet dress rehearsals per year. The launch vehicles would include liquid fueled, medium to heavy-lift class orbital and suborbital vehicles. In addition to the 24 launches per year, the first stage of the launch vehicle could return to and land at the Shiloh Launch Complex."

Supporters of the plan argue that the Governor is being strong in his push for jobs and economic benefits for Florida. However, opponents point out that the jobs and economic benefits of placing the launch facilities in Shiloh can be achieved by placing the project in Brevard County at Kennedy Space Center or at the Canaveral AFB.

The public hearings will be held at New Smyrna Beach High School at 5 pm February 11 and at the Eastern Florida State College Titusville campus at 5 pm February 12.

If you wish to email comments, they must be received by February 21. Send them to Stacy M. Zee, FAA Environmental Specialist -** [faashiloheis@cardnote.com](mailto: faashiloheis@cardnote.com)**

CCA Florida also recommends to copy to U.S. Senators Bill Nelson at and Senator Marco Rubio of Florida and Congressional Representatives, there addresses can be found here and here.