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Page 1: Spaceport Camden – Launch Site Operator License Application · 2 days ago · Spaceport Camden – Launch Site Operator License Application Modified FOIA EXEMPT – PROPRIETARY
Page 2: Spaceport Camden – Launch Site Operator License Application · 2 days ago · Spaceport Camden – Launch Site Operator License Application Modified FOIA EXEMPT – PROPRIETARY

Spaceport Camden – Launch Site Operator License Application

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REVISION HISTORY 25 January 2019 Initial Submittal 14 January 2020 Revised based on feedback from FAA/AST during application consultation after

submission in January 2019 through December 2019. Revised based on changes in scope of the intended Spaceport Camden

operations driven by perceived market demand. Principally, the reference to medium-large launch vehicles has been removed, with small launch vehicles as the sole remaining vehicle class.

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TABLE OF CONTENTS

Contents 1.0 General Information ......................................................................................................................... 5

1.1 Launch Site Operator .................................................................................................................... 5

1.2 Launch Site .................................................................................................................................... 6

1.2.1 List of Downrange Equipment ............................................................................................... 8

1.2.2 Launch Site Points and Launch Site Layout Description ....................................................... 8

1.2.3 Types of Launch Vehicles at Each Launch Point .................................................................. 15

1.2.4 Range of Launch Azimuths Planned from Each Launch Point ............................................. 15

1.2.5 Scheduled Operational Date ............................................................................................... 17

1.3 Foreign Ownership ...................................................................................................................... 17

2.0 Environmental ................................................................................................................................. 17

3.0 Launch Site Location ....................................................................................................................... 17

4.0 Explosive Site Plan ........................................................................................................................... 18

5.0 Launch Site Operations ................................................................................................................... 18

Attachment 1 Spaceport Camden Draft Environmental Impact Statement

Attachment 2 Spaceport Camden Launch Site Location Review (May Contain ITAR Data)

Attachment 3 USCG / Spaceport Camden Draft Letter of Agreement (Signed)

Attachment 4 FAA ATO / Spaceport Camden Letter of Agreement (Signed)

Attachment 5 Access Control Plan

Attachment 6 Explosive Site Plan

Attachment 7 Accident Investigation Plan

Attachment 8 Camden County Emergency Operations Plan

Attachment 9 Spaceport Camden Comprehensive Launch Plan (Example)

Attachment 10 Population Monitoring and Management Plan

Attachment 11 Little Cumberland Island Fire Mitigation Plan

Attachment 12 Scheduling and Notification Plan

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1.0 General Information This launch site operator license (LSOL) application is submitted to the Federal Aviation Administration (FAA) Office of Commercial Space Transportation (FAA/AST) in accordance with the requirements of the Code of Federal Regulations (CFR) Section 14 CFR Part 420, specifically the requirements of Subpart B (Criteria and Information Requirements for Obtaining a License), § 420.15 (Information requirements). The Camden County Board of Commissioners (the County) is proposing to construct and operate a commercial space launch site, called Spaceport Camden, on the Atlantic seaboard in Camden County, Georgia. The County could offer the commercial space launch site to vertical launch vehicle operators for the orbital and suborbital launch of small liquid propulsion launch vehicles. Launch vehicles are classified by FAA regulations1 based on payload weight in pounds according to orbital inclination. Table 1 of 14 CFR § 420.19 provides payload weights for both 28 degree and 90 degrees inclinations; at 28-degrees inclination small is less than or equal to 4,400 pounds. Launch operations include preparatory activities to ready and test up to 12 annual launches (one at night) of small launchers, including mission rehearsals and static tests.

1.1 Launch Site Operator Within 14 CFR § 420.15(a)(1) it states the LSOL application must contain the following:

“Launch site operator. An applicant shall identify the name and address of the applicant, and the name, address, and telephone number of any person to whom inquiries and correspondence should be directed.”

The LSOL applicant and contact details are:

Launch Site Operator Applicant: Camden County Board of Commissioners 200 East 4th Street PO Box 99 Woodbine, GA 31569 Point of Contact for Inquiries and Correspondence: Steve Howard County Administrator, Camden County 200 East 4th Street PO Box 99 Woodbine, GA 31569 Office Phone: +1-912-510-0464

1 14 CFR § 420.19, Table 1.

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1.2 Launch Site Within 14 CFR § 420.15(a)(2) it states the LSOL applicant must provide the following information about the proposed launch site:

“Launch site. An applicant shall provide the name and location of the proposed launch site and include the following information:

(i) A list of downrange equipment; (ii) A description of the layout of the launch site, including launch points; (iii) The types of launch vehicles to be supported at each launch point; (iv) The range of launch azimuths planned from each launch point; and (v) The scheduled operational date.”

This proposed launch site information is provided in the subparagraphs of this section 1.2, after an introduction below. Camden County has identified the development and operation of a commercial launch site as a desirable means to support its local economic growth. Camden County’s Strategic Plan 2019, 2024, 2034, which addresses its long-range planning, mission, and vision, identifies a launch site, or “spaceport,” as one of four pillars of economic growth and sustainment. In developing its plan for a spaceport, the County undertook a search for a suitable location for a launch site and identified the property shown in Exhibit 1, a former industrial site that is currently used for tree-farming in discrete areas. The site is located in southeast Georgia, in an unincorporated area of Camden County, Georgia, approximately 11.5 miles east of the city of Woodbine, at the mouth of the Satilla and Crooked Rivers and west of Cumberland River and Cumberland Island (see Exhibit 1). The property, on which two plantations and a ship-building enterprise operated in the 1800s, was first redeveloped in 1927 as a hunting preserve. In the early 1940s, the property was used as a tree farm and source of fiber for a local paper mill. During the 1960s, the Thiokol Chemical Company produced and tested solid rocket motors for the National Aeronautics and Space Administration (NASA). When NASA decided to focus on liquid-fueled rockets, the site was converted to manufacture military hardware and supplies, including mortar ammunition, illuminating ordnance devices (trip flares), tear gas, and assorted chemicals. From the mid-1970s to 2012, the property was the site of a pesticide manufacturing facility. The entire project site is currently owned by two companies, the Union Carbide Corporation (UCC) and Bayer CropScience. The County has entered into an option agreement to purchase most of the UCC property (about 4,000 acres) and is considering an option to purchase the Bayer CropScience property2 (an additional 7,800 acres). The former industrial site is a combination of uplands and marshlands. Spaceport Camden is proposed to be primarily constructed on approximately 100 noncontiguous acres of the approximately 1,200 acres of uplands on the UCC property. The four facilities that would be built to support spaceport operations would be constructed on upland portions of the former industrial site, three would be located fully within the UCC property and one, the Alternate Control Center / Visitors Center, would be constructed on either UCC property or on the Bayer CropScience property in the same general vicinity near the main gate that is shared by both properties.

2 Bayer CropScience has indicated a willingness to sell the property to Camden County, should the County pursue the purchase.

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1.2.1 List of Downrange Equipment It is the primary plan to require all launch operators from Spaceport Camden to utilize FAA-approved fully autonomous flight safety system (AFSS) equipment, thereby greatly reducing the need for downrange tracking equipment. Currently, there is no downrange equipment owned or operated by Spaceport Camden. As an augmentation to future operations with AFSS, traditional fixed base and mobile tracking systems (radar, telemetry, and optical trackers) are under evaluation. Primary radar is probably not going to be used; however, other solutions are possible such as a combination of S-Band telemetry and GPS metric tracking systems / algorithms (as currently utilized on Electron, Atlas, and Delta launchers) with other sensors such as optical trackers and highly reliable and secure communication links (such as satellite based communications links). Utilization of government owned and contracted tracking services may also be employed.

1.2.2 Launch Site Points and Launch Site Layout Description The four facilities of the proposed Spaceport Camden are as shown in Exhibit 2. They are the: Launch Control Center Complex, Vertical Launch Facility, Mission Preparation Area, and Alternate Control Center / Visitor Center (shown in this Exhibit to be just inside the Bayer CropScience property line, but may also be just across the road on the UCC property). Related infrastructure (e.g., roads and utilities) would also be improved within the existing industrial site. The facilities are further described later in this section as individual subsections. Each of the launch site facilities and the western property boundary of the site would be fenced to provide security and access control. The Spaceport Camden upland property boundary on the UCC side of the property is shown in yellow on Exhibit 2. The four facilities and their fence lines are shown as heavy black lined boxes. The proposed official Spaceport Camden 14 CFR § 401.5 compliant “Launch Site” border where FAA/AST regulated 14 CFR § 417.3 defined “Launch Processing” would occur is shown as a heavy yellow lined box that mirrors the upland property boundary.3 The remainder of the UCC and Bayer CropScience property, much of which is marshland, would be used as tactical buffer on launch and test days. Control of marshland for hazardous operations shall be pursuant to agreements with the United States Coast Guard (USCG) for the implementation of an appropriate Safety Zone in accordance with 33 CFR 165.20 and the Letter of Agreement (LOA) found as Attachment 3.

3 Updates to the launch site boundary wording reflects the agreed upon revision between FAA/AST (Randal Maday & Karen Perez) and Spaceport Camden (Andrew Nelson).

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Exhibit 2. Proposed Spaceport Camden Facilities and “Launch Site” Borders per 14 CFR part 401

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As can be seen in Exhibit 2, the Alternate Control Center / Visitors Center facility is located near the shared main gate of the two properties. Should the County not purchase or secure a long term lease of the Bayer CropScience property, this facility would be relocated about 100+ yards to the north, just north-northeast of the main gate, on UCC property. Also, there is an existing dock with deep water access on Bayer CropScience property that could be utilized in the future during operation of the spaceport, given that repairs are performed and updated permitting by Georgia authorities is provided; but use of the dock is not currently planned.

1.2.2.1 Vertical Launch Facility Exhibit 3 includes an artist’s rendering of a Vertical Launch Facility and a schematic of the facility layout. The Vertical Launch Facility would be approximately 29 acres in size and, as indicated in Exhibit 2, would be located in the northeastern portion of the spaceport. The Vertical Launch Facility, depending on lunch customer needs, could include a launch pad and its associated structures, storage tanks, and handling areas; vehicle and payload integration facilities; a lightning protection system; deluge water systems and associated water capture tank; water tower; and other launch-related facilities and systems including shops, office facilities, and storm water retention ponds (also referred to simply as ‘retention ponds’). There would also be lightning warning systems installed at Spaceport Camden, pursuant to 14 CFR § 420.71(a)(3), that would enable the termination of operations at or near an explosive hazard facility and withdrawal of any public to, or beyond, the public area distance prior to an electrical storm. There are several off the shelf solutions available (e.g., Campbell Scientific, Logan, Utah). Typically, these systems continuously monitor local electric fields and trigger warnings when there is the potential for lightning. These systems usually base their predictions on electric field measurements instead of lightning strikes; therefore, the system should detect lightning danger even when no other strikes have occurred. When a defined electric field threshold is met, a warning is issued and energizes aural warnings on the site.4 Depending on launch operator needs, the launch pad may include a pile-supported concrete platform with a steel gantry framing in addition to a concrete launcher track (supported by up to 3-feet-diameter piers), a flame trench, and a water retention tank that would be the principal supporting features for launch activities. Four lightning towers up to 250 feet tall each would be the major components of the lightning protection system. Liquid oxygen and rocket propellant-1 (RP-1) would be stored in dedicated propellant storage areas at the Vertical Launch Facility. Liquid oxygen tanks would store up to 50,000 to 100,000 gallons each and would be approximately 14 feet in diameter and 50 to 100 feet long. RP-1 tanks could be up to 50,000-gallon capacity each, approximately 12 feet in diameter and 60 feet long. Depending on the size of the tanks, up to six tanks for liquid oxygen and up to four tanks for RP-1 could be installed at the Vertical Launch Facility. Additional storage tanks would be provided for helium and nitrogen (both gaseous and liquefied), which are used as purge gases and tank pressurants. A total of approximately 10,000 to 15,000 gallons of helium could be stored in high-pressure tube banks, and a total of 25,000 to 50,000 gallons of nitrogen could be stored in up to two liquefied nitrogen storage tanks and four gaseous nitrogen storage tanks, each up to approximately 10 feet in diameter and 44 feet long. In addition to

4 Lightning warning system information (14 CFR 420.71) was added pursuant to FAA/AST (Randal Maday) request to Spaceport Camden (Andrew Nelson).

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1.2.2.2 Launch Control Center Complex The Launch Control Center Complex is to be constructed on approximately 2.4 acres (see Exhibit 4). As indicated in Exhibit 2, the Launch Control Center Complex would be located on an uplands area in the extreme western portion of the property approximately 2.3 miles from the launch pad at the Vertical Launch Facility and approximately 1 mile from the Mission Preparation Area. The Launch Control Center Complex would include a Launch Control Center Building housing a control room and related equipment and a Payload Processing Building. The Launch Control Center Building would be the control hub for launches and related operations. The Payload Processing Building would be the location for satellite and other related payload processing activities prior to integration onto launch vehicles. A first responder facility would be located within the Launch Control Center Building or the Payload Processing Building. In addition to these two structures, the Launch Control Center Complex could include two small storage buildings for payload propellants (satellite and special fuels) and miscellaneous maintenance equipment. Additional space for up to 1,000 cubic feet of helium storage and 3,000 cubic feet of nitrogen storage may be provided at the Launch Control Center Complex. Typically, these gases would be stored in six to eight tube banks or tanks, the tanks being approximately 2 feet in diameter and 40 feet long. In addition to these materials, ordnance may be stored at this facility for a short time before being inserted into the launch vehicle or payload, and/or transferred to the Vertical Launch Facility. The Launch Control Center Building and Payload Processing Building (the main buildings in this complex) would be up to 150 feet by 50 feet and 40 to 45 feet tall, with a high bay and/or a second floor for offices and conference spaces. The smaller storage buildings (20 feet by 20 feet and 15 feet tall), if used for storage of hazardous materials such as hydrazine (used sometimes as satellite fuel), would have appropriate environmental and safety equipment. The main buildings would be of environmentally controlled, pre-engineered metal construction on concrete foundations with footers. The smaller storage buildings would be of pre-engineered metal or cinder block construction. Both main buildings would be served by a backup generator with a fuel source (fuel storage tanks, up to 5,000 gallons each). Other features at the Launch Control Center Complex could include a parking lot, fencing, guard shack, gates, a septic system, and area lighting. Two retention ponds for storm water runoff control could be installed at the Launch Control Center Complex.

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Exhibit 6. Mission Preparation Area (Artist concept and layout schematic)

1.2.3 Types of Launch Vehicles at Each Launch Point Spaceport Camden is envisaged to have one primary launch point (the Vertical Launch Complex) as shown in Exhibit 2 and Exhibit 3. The primary launch point may accommodate small launch vehicles (e.g., RocketLab Electron, Vector R, ABL Launch Systems, FireFly Launch Systems, etc.).

1.2.4 Range of Launch Azimuths Planned from Each Launch Point As proposed, Spaceport Camden would accommodate up to 12 vertical launches per year. All vehicles would launch from the Launch Complex, generally to the east over the Intracoastal Waterway, Cumberland Island National Seashore, and the Atlantic Ocean. In addition, in support of the launches there would be up to 12 wet dress rehearsals and up to 12 static fire engine tests per year. The anticipated range of launch azimuths is from 83 degrees to 115 degrees. For the Vertical Launch Facility this is shown in Exhibit 7.

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1.2.5 Scheduled Operational Date Spaceport Camden aims to hold its first licensed launch in 2020 based on customer statements and indicated demand.

1.3 Foreign Ownership Within 14 CFR § 420.15(a)(3) it states the LSOL application must contain the following information regarding potential foreign ownership:

“Foreign ownership. Identify foreign ownership of the applicant, as follows:

(i) For a sole proprietorship or partnership, all foreign owners or partners; (ii) For a corporation, any foreign ownership interest of 10 percent or more; and (iii) For a joint venture, association, or other entity, any foreign entities participating in the entity.”

Spaceport Camden has no foreign ownership; therefore, these questions are not applicable.

2.0 Environmental Within 14 CFR § 420.15(b) it states the LSOL application must contain the following information regarding environmental analysis:

“(b) Environmental. An applicant shall provide the FAA with information for the FAA to analyze the environmental impacts associated with the operation of the proposed launch site. The information provided by an applicant must be sufficient to enable the FAA to comply with the requirements of the National Environment Policy Act, 42 U.S.C. 4321et seq. (NEPA), the Council on Environmental Quality Regulations for Implementing the Procedural Provisions of NEPA, 40 CFR parts 1500- 1508, and the FAA's Procedures for Considering Environmental Impacts, FAA Order 1050.1F. An applicant shall submit environmental information concerning a proposed launch site not covered by existing environmental documentation, and other factors as determined by the FAA.”

This environmental analysis prepared by FAA/AST for Spaceport Camden is found as Attachment 1 and meets the full requirements of 14 CFR § 420.15(b).

3.0 Launch Site Location Within 14 CFR § 420.15(c) it states the LSOL application must contain the following information regarding the launch site location review:

“(c) Launch site location. (1) Except as provided by paragraph (c)(2) of this section, an applicant shall provide the information necessary to demonstrate compliance with §§ 420.19-420.29. (2) An applicant who is proposing to locate a launch site at an existing launch point at a federal launch range is not required to comply with paragraph (c)(1) of this section if a

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launch vehicle of the same type and class as proposed for the launch point has been safely launched from the launch point.”

The launch site location review analysis for Spaceport Camden is found as Attachment 2 and meets the full requirements of 14 CFR § 420.15(c).

4.0 Explosive Site Plan Within 14 CFR § 420.15(d) it states the LSOL application must contain the following information regarding explosive site planning:

(d) Explosive site plan. (1) Except as provided by paragraph (d)(2) of this section, an applicant shall submit an explosive site plan that complies with §§ 420.63, 420.65, 420.67, and 420.69. (2) If an applicant plans to operate a launch site located on a federal launch range, and if the applicant is required by the federal launch range to comply with the federal launch range's explosive safety requirements, the applicant shall submit the explosive site plan submitted to the federal launch range.

The explosive site plan (and analysis) for Spaceport Camden is found as Attachment 6 and meets the full requirements of 14 CFR § 420.15(d) as it applies to planned operations at Spaceport Camden.

5.0 Launch Site Operations Within 14 CFR § 420.15(e) it states the LSOL application must contain the following information regarding launch site operations:

(e) Launch site operations. An applicant shall provide the information necessary to demonstrate compliance with the requirements of §§ 420.53, 420.55, 420.57, 420.59, 420.61, and 420.71.

These paragraphs are addressed below and in the following Attachments and meet the full requirements of 14 CFR § 420.15(e) as it applies to planned operations at Spaceport Camden.

§ 420.53 – Control of public access is addressed in Attachment 5. § 420.55 – Spaceport Camden requires that spaceport customers coordinate proposed

hazardous operations with the Launch Facility Operations Director (or designee). The Scheduling and Notification Plan is found as Attachment 12. An example of the Spaceport Camden Comprehensive Launch Plan (CLP) is provided in Attachment 9. The CLP development process is performed for each launch and ensures thorough coordination across the stakeholder community. The CLP process is also ICS-201 compliant (Incident Command System Form 201) and further conforms to the overarching Camden County Emergency Operations Procedures (Attachment 8).6

6 Modifications to the text addressing the requirements of § 420.55and the inclusion of Attachment 12 originate from two principle inquiries from FAA/AST to Spaceport Camden and are reflected within the revised text and the new Attachment 12. The first was an inquiry from FAA/AST (Karen Perez) regarding the Spaceport Camden

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§ 420.57 – Notifications are addressed in Attachment 12 (Scheduling and Notification Plan) and others referenced in Attachment 12.

§ 420.59 – Launch site accident investigation plan (AIP) is found as Attachment 7, with supporting information in Attachment 8 (enables the powers discussed in the AIP).

§ 420.61 – Records retention requirements are addressed as an integral part of the launch site accident investigation plan found as Attachment 7 and the supporting information in Attachment 8. With this application, it is confirmed that records shall be retained for a minimum of three (3) years, and these will made available to federal officials for inspection and copying as per federal regulations.

§ 420.71 – Lightning protection has been addressed in the core design practice of the Spaceport Camden project, including, but not exclusive of, provisions in explosive siting (Attachment 6) where no power lines are above or near fuel / pressurants tanks, meeting local code for buildings as it pertains to lightning protection / surge protection, and the inclusion of robust lightning protection at the Vertical Launch Facility (see Section 1.2.2.1 above). In addition to lightning protection systems, Spaceport Camden would utilize a lightning warning system to permit termination of operations and withdrawal of the public to the public area distance prior to an electrical storm, or for an explosive hazard facility containing explosives that cannot be initiated by lightning. The lightning warning system is described herein (see Section 1.2.2.1 above).7

N/A Population Monitoring and Management Plan – In addition to the requirements of 14 CFR § 420.53, FAA/AST has requested a population monitoring and management plan by Spaceport Camden for areas that currently are non-hazard areas, but are population dependent when it comes to their determination of being a potential future hazard area. This Population Monitoring and Management Plan is found as Attachment 10.8

Comprehensive Launch Plan (CLP) process and the USCG participation in the implementation of Safety Zones. Redlines proposed by Spaceport Camden were agreed with FAA/AST during a call and these redlines were subsequently delivered to FAA/AST by Spaceport Camden. The second set of revisions to this paragraph originated with an email from FAA/AST (Randy Maday) inquiring as to “the scheduling of hazardous activities at the site regardless of whether it’s a launch or routine ground activity.” Spaceport Camden (Andrew Nelson) initially responded with a follow up by FAA/AST, and a final proposed revision by Spaceport Camden that was accepted by FAA/AST. These two final accepted revisions are reflected in the revised response addressing § 420.55. 7 References to lightning warning systems included based on FAA/AST (Randal Maday) discussions with Spaceport Camden (Andrew Nelson). 8 The Population Monitoring and Management Plan (PMMP) originated from a verbal inquiry during a technical interchange meeting between FAA/AST and Spaceport Camden and a further inquiry by FAA/AST (Kenneth Wong) to Spaceport Camden. Through multiple evolving requests by FAA/AST for population related data a final set of estimated population data and a PMMP was prepared for FAA/AST by Spaceport Camden. FAA/AST (Kenneth Wong) sent further inquiries to Spaceport Camden about “Zone 4” of the PMMP and potential road monitoring and management in non-hazard areas of the County that may experience inconvenient traffic volumes by potential spectators (non-safety related impacts). Spaceport Camden (C N White) responded to FAA/AST (Kenneth Wong) addressing these inquiries.

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N/A Little Cumberland Island Fire Mitigation Plan – In addition to the requirements of 14 CFR part 420, FAA/AST has requested a fire mitigation plan for Little Cumberland Island, to the east of Spaceport Camden. This Little Cumberland Island Fire Mitigation Plan is found as Attachment 11.9

# # # # #

9 The Little Cumberland Island Fire Mitigation Plan (LCIFMP) originated from an inquiry by FAA/AST (Kenneth Wong). The LCIFMP (Attachment 11) was provided to FAA/AST (Kenneth Wong) by Spaceport Camden (Steve Howard and C N White). FAA/AST (Katherine Branham) had follow up inquiries about who prepared, reviewed, and approved the LCIFMP, their qualifications, and the standard used to prepare the LCIFMP. Full responses were provided by the County (Chairman James Starline) to FAA/AST (Kenneth Wong).

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Attachment 1

Spaceport Camden Draft Environmental Impact Statement

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Spaceport Camden – Draft Environmental Impact Statement

Page 1 of 1

DRAFT

Environmental Impact

StatementOn File with FAA

As of March 2018

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Attachment 2

Spaceport Camden Launch Site Location Review

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

22 U.S.C. 2778, as implemented in the International Traffic in Arms Regulations (ITAR), 22 CFR § 120 – 130 – NO PUBLIC RELEASE

Modified TRADE SECRETS / PROPRIETARY & REAL PROPERTY ACQ. EVAL DOCUMENT Page 1 of 28 14 January 2020 GORA/FOIA EXEMPT – MAY CONTAIN ITAR TECHNICAL DATA – NO PUBLIC RELEASE

Launch Site Location Review

As of 14 January 2020

FOIA EXEMPT – PROPRIETARY DATA

GORA EXEMPT – FEDERAL GOVERNMENT CONTROLLED DATA, SECURITY PLANNING INFORMATION, REAL PROPERTY ACQUISITION ANALYSIS DOCUMENT, CONTAINS TRADE SECRETS

ITAR RESTRICTED MAY CONTAIN ITAR TECHNICAL DATA OR CONTENTS MAY BE CONSIDERED A DEFENSE SERVICE

NO THIRD PARTY DISTRIBUTION ALLOWED

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

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Contents ATTACHMENT 2 – LAUNCH SITE LOCATION REVIEW .................................................................................... 3

1 14 CFR § 420.19 – Launch site location review—general. ................................................................ 3

1.1 Launch Site ................................................................................................................................ 4

1.2 Launch Vehicle .......................................................................................................................... 9

1.3 Range of Azimuths .................................................................................................................... 9

1.4 Heaviest Weight Class ............................................................................................................. 10

2 14 CFR § 420.21 – Launch site location review—launch site boundary. ........................................ 10

3 14 CFR § 420.23 – Launch site location review—flight corridor. .................................................... 12

3.1 Guided Orbital Expendable Launch Vehicle Flight Corridor [14 CFR §420.23(a)] ................... 12

3.2 Guided Sub-Orbital Expendable Launch Vehicle Flight Corridor [14 CFR §420.23(b)] ........... 12

3.3 Unguided Sub-Orbital Expendable Launch Vehicle Flight Corridor [14 CFR § 420.23(c)] ....... 13

3.4 Reusable Launch Vehicle Flight Corridor [14 CFR § 420.23(d)] ............................................... 13

4 14 CFR § 420.25 – Launch site location review—risk analysis. ....................................................... 14

4.1 Assumptions ............................................................................................................................ 15

4.1.1 Trajectory Data & Maps ...................................................................................................... 15

4.1.2 Winds Data .......................................................................................................................... 16

4.1.3 Population Data .................................................................................................................. 16

4.2 Expected Casualty (Ec) Data .................................................................................................... 19

4.3 Overflight Exclusion Zones / No Public Presence .................................................................... 23

5 14 CFR § 420.27 – Launch site location review—information requirements. ................................ 26

6 14 CFR § 420.29 – Launch site location review for unproven launch vehicles. .............................. 27

7 14 CFR §417.107(b)(2) – Flight safety, Public risk criteria, Individual risk ...................................... 27

7.1 Methodology – individual risk. ................................................................................................ 27

7.2 Assumptions ............................................................................................................................ 28

7.3 Outcomes / Results ................................................................................................................. 28

Revision History: 1/25/19 Initial Submittal. 01/14/20 Revisions include removal of medium-large launcher (only small launcher remains),

inclusion of enhanced (additional) population considerations, and additional minor edits. Changes agreed with FAA/AST between January – December 2019 also included.

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ATTACHMENT 2 – LAUNCH SITE LOCATION REVIEW This Launch Site Location Review (LSLR) for the Spaceport Camden Launch Site Operator License (LSOL) application is provided in accordance with the requirements of 14 CFR § 420.15(c)(1) (Information requirements, Launch site location) and 14 CFR § 420.17(a)(3) (Basis for issuance of a license), as amended. The last known amendment was published in the Federal Register, Volume 81, Number 139, on Wednesday, July 20, 2016 in the Rules and Regulations section, starting on page 47017, and became effective on 19 September 2016.1 Regarding the LSLR requirements, 14 CFR § 420.17(a)(3) states that:

(a) The FAA will issue a license under this part when the FAA determines that: … (3) The launch site location meets the requirements of §§420.19, 420.21, 420.23, 420.25, 420.27, and 420.29;

As such, this LSLR provides supporting information that is required by the referenced subparagraphs of 14 CFR part 420 for a representative small launch vehicle intended for small satellite launches. This LSLR is augmented by an analysis of individual risk (also referred to as “Pind” or individual probability) per 14 CFR § 417.107(b)(2) (Flight safety, Public risk criteria, Individual risk). The individual risk analysis is provided in Section 7.

1 14 CFR § 420.19 – Launch site location review—general.

Paragraph 420.19 states the following:

(a) To gain approval for a launch site location, an applicant shall demonstrate that for each launch point proposed for the launch site, at least one type of expendable or reusable launch vehicle can be flown from the launch point safely. For purposes of the launch site location review:

(1) A safe launch must possess a risk level estimated, in accordance with the requirements of this part, not to exceed an expected number of 1 x 10-4 casualties (Ec) to the collective member of the public exposed to hazards from the flight. (2) Types of launch vehicles include orbital expendable launch vehicles, guided suborbital expendable launch vehicles, unguided sub-orbital expendable launch vehicles, and reusable launch vehicles. Orbital expendable launch vehicles are further classified by weight class, based on the weight of payload the launch vehicle can place in a 100-nm orbit, as defined in table 1.

1 Federal Register, Vol. 81, No. 139, 20 July 2016, page 47017, “DEPARTMENT OF TRANSPORTATION, Federal Aviation Administration; 14 CFR Parts 417, 420, 431, and 435; [Docket No.: FAA–2014–0418; Amdt. Nos. 417–4, 420–7, 431–4 and 435–3]; RIN 2120–AK06; Changing the Collective Risk Limits for Launches and Reentries and Clarifying the Risk Limit Used To Establish Hazard Areas for Ships and Aircraft.”

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

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(b) If an applicant proposes to have more than one type of launch vehicle flown from a launch point, the applicant shall demonstrate that each type of expendable or reusable launch vehicle planned to be flown from the launch point can be flown from the launch point safely. (c) If an applicant proposes to have more than one weight class of orbital expendable launch vehicles flown from a launch point, the applicant shall demonstrate that the heaviest weight class planned to be flown from the launch point can be flown from the launch point safely.

Therefore, this Section 1 describes the launch site(s), launch vehicle(s), range of azimuths the launch vehicles may travel, and the heaviest weight class anticipated for the launch point. The Aerospace Corporation of El Segundo, California performed an extensive analysis of the expected casualty (Ec), also referred to as “cumulative risk”, and individual risk (Pind) from launches emanating from Spaceport Camden. There were trajectories evaluated from Spaceport Camden between 85 degrees and 120 degrees azimuth for a representative small launcher. All trajectories passed the Ec requirements of 14 CFR part 420 and individual risk requirements of 14 CFR part 417, given the assumptions within this report, including enhanced (additional) population stress test cases for Ec that went well beyond the anticipated worst case population on Little Cumberland and Cumberland Islands. Pursuant to the requirements of 14 CFR § 420.19, this document principally focuses on one reference trajectory, 100 degrees from true north, from the sole launch point planned for the site. This trajectory, with the assumptions described in this document, was significantly under the required Ec (cumulative risk) threshold of 14 CFR § 420.19. A stress test analysis for enhanced population scenarios also demonstrated the 100-degree trajectory to be resilient to added populations under the trajectory and nearby, both inside and just outside impact limit lines, while still meeting the cumulative risk (Ec) requirements of the CFR. Population data assumptions are pursuant to 14 CFR part 420 Appendix C requirements, utilizing the latest Camden County U.S. census and the worldwide LandScan / Oak Ridge National Laboratory (ORNL) database extrapolated forward to 2020. Additional local population on nearby barrier islands was added that are above and beyond the two referenced databases to reflect potential worst case (and beyond) conditions. For the 100-degree reference trajectory, this included population scenarios that are well beyond what is experienced today, or anticipated in the future, and are considered stress test cases. The analysis performed by The Aerospace Corporation is considered conservative for a number of reasons, including, among other conservative analysis parameters, the use of launch failure rates greater than required by Part 420. It is noted that anticipated public viewing areas for Spaceport Camden launches are outside the first stage analysis area of impacts, and hence do not impact Ec results, but are included in cumulative risk analysis for the enhanced population stress test analysis, as are “maximum” anticipated visitors to Cumberland Island National Seashore and greatly enlarged visitor populations to private habitable structures on Cumberland and Little Cumberland Island. Currently, the proposed Welcome Center at Spaceport Camden will not host visitors during launch operations. Further information regarding the analysis is found in this LSLR.

1.1 Launch Site

The proposed Spaceport Camden property is located in unincorporated Woodbine, in Camden County, approximately 11.5 miles due east of the town of Woodbine, Georgia. Access to the site is at the eastern terminus of Union Carbide Road, an extension of Harriett's Bluff Road (Exit 7 from I-95). The site is on the water, surrounded by salt marshes to the east and south, and the Satilla River to the north. The

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property comprises uplands, salt marshes and fresh water wetlands. The site was previously used for the manufacture of various chemicals. Most of the buildings, including all of the manufacturing facilities, have been demolished. Existing roads and other existing infrastructure – fiber optic communications, water, sewer and electrical power – may be reused, and potentially improved or extended. The remainder of the site, much of which is marshland, would be used as buffer. Offshore ship traffic is typical of the eastern seaboard; Andrews Sound has minimal traffic, while the Intracoastal Waterway and its various alternative pathways have some barge traffic. There is also recreational boating in the area but minimal impact due to the very low population density in the area. Exhibit 1 below shows the general location of the spaceport. Exhibit 2 shows a more detailed view of the proposed site.

Exhibit 1. General Location – Spaceport Camden County

Exhibit 2. Spaceport Camden County Location and Local Surroundings

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

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The proposed layout of Spaceport Camden has been developed to best use the geographical features of the site, considering the past uses, FAA requirements for rocket related operations, potential growth in the future, and lessons learned from other spaceport operations. Spaceport Camden includes a vertical launch site complex, a mission preparation area, a control center / payload integration complex and a welcome center / back up control center complex. Approximately 100 non-contiguous upland acres would be used for the four sets of facilities. Security and access control plans for these facilities and the 4,000 acres of uplands are provided in the Spaceport Camden Access Control Plan. An artist’s rendering of the site layout and launch and other facilities (with high level schematics) are shown in Exhibits 3 through 8. The distance between the Launch Pad Complex and the Main Gate / Welcome Center is over 2.2 miles, while the Launch Control Center / Payload Processing facility is approximately 2.3 miles. The distance between the Launch Control Center / Payload Processing facility and the Mission Preparation Area is about 1.3 miles, while the distance to the Main Gate / Welcome Center from the Mission Preparation Area is about 0.75 miles (~4,000 feet). At this time, the Welcome Center will not host the general public during launch operations. It is noted that Exhibit 3 through Exhibit 8 contain artist renderings. All explosive safety analysis has been performed and documented elsewhere in this LSOL application.

Exhibit 3. Proposed Site Plan – Spaceport Camden County

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Exhibit 4. Proposed Site Plan – Spaceport Camden County – View from East

Exhibit 5. Proposed Site Plan – Artist Rendering - Aerial View of Launch Pad Complex

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

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Exhibit 9. Range of Launch Azimuths Evaluated

1.4 Heaviest Weight Class

Pursuant to the requirements of 14 CFR § 420.19(c) the small launch vehicle weight class is proposed for orbital expendable launch vehicles from Spaceport Camden. A representative vehicle within this weight class was analyzed as part of this study.

2 14 CFR § 420.21 – Launch site location review—launch site boundary.

Paragraph 420.21 establishes the launch site boundary for proposed launch points on a spaceport. The requirements of 14 CFR §420.21 are found below:

(a) The distance from any proposed launch point to the closest launch site boundary must be at least as great as the debris dispersion radius of the largest launch vehicle type and weight class proposed for the launch point. (b) For a launch site supporting any expendable launch vehicle, an applicant shall use the largest distance provided by table 2 for the type and weight class of any launch vehicle proposed for the launch point. (c) For a launch site supporting any reusable launch vehicle, an applicant shall determine the debris dispersion radius that represents the maximum distance from a launch point that debris travels given a worst-case launch vehicle failure in the launch area. An applicant must clearly and convincingly demonstrate the validity of its proposed debris dispersion radius.

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In accordance with 14 CFR § 420.21, Table 2 minimum distance from the launch point to the launch site boundary, is 7,300 feet, unless an alternative method demonstrates another appropriate distance. Spaceport Camden will use the CFR defined minimum distance from launch point to launch site boundary as shown in Exhibit 10.

Exhibit 10. Minimum Distance to Launch Site Boundary (7,300 feet) for Small Representative Launch

Vehicle (14 CFR 420.21, Table 2)

The Spaceport Camden layout is such that the majority of the 7,300 feet radius circle is contained within the launch site boundary, or in the case of the Satilla River, controllable using USCG Safety Zone establishment procedures identified within the Access Control Plan and the Letter of Agreement (LOA) with the USCG and the County. This is shown in Exhibit 11 below.

Exhibit 11. Spaceport Camden Launch Site Boundary 7,300 Feet Radius (Yellow)

Pursuant to 14 CFR §§420.21, Table 2 versus Property Boundary Lines (White)

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3 14 CFR § 420.23 – Launch site location review—flight corridor. Paragraph 14 CFR § 420.23 requires the LSOL applicant to define a flight corridor that meets various requirements for a guided orbital expendable launch vehicle (14 CFR § 420.23(a)), reusable launch vehicle (14 CFR § 420.23(d)), and sub-orbital (guided and unguided) launch vehicles (14 CFR § 420.23(b) and § 420.23(c), respectively). This LSOL application principally addresses the representative guided orbital expendable first stage and second stage launch vehicle defined earlier in this LSLR; hence compliance with 14 CFR § 420.23(a) is demonstrated.

3.1 Guided Orbital Expendable Launch Vehicle Flight Corridor [14 CFR §420.23(a)] Section 420.23(a) requires the LSOL applicant to define a flight corridor that meets various requirements for a guided orbital expendable launch vehicle. Specifically, 14 CFR §420.23(a) states the following:

(a) Guided orbital expendable launch vehicle. For a guided orbital expendable launch vehicle, an applicant shall define a flight corridor that: (1) Encompasses an area that the applicant estimates, in accordance with the requirements of this part, to contain debris with a ballistic coefficient of ≥ 3 pounds per square foot, from any non-nominal flight of a guided orbital expendable launch vehicle from the launch point to a point 5000 nm downrange, or where the IIP leaves the surface of the Earth, whichever is shorter; (2) Includes an overflight exclusion zone where the public risk criteria of 1 x 10-4 would be exceeded if one person were present in the open; and (3) Uses one of the methodologies provided in appendix A or B of this part. The FAA will approve an alternate method if an applicant provides a clear and convincing demonstration that its proposed method provides an equivalent level of safety to that required by appendix A or B of this part.

Using the general methodologies of Appendix A and B of Part 420, as interpreted in The Aerospace Corporation’s Ec Tool / trajectory modeling software, the various trajectories with their overflight exclusion zones (OEZs) were evaluated for the Spaceport Camden site. The trajectory data is described in more detail in Section 4.1.1 and the OEZ, developed per 14 CFR §420.23(a)(2), is described in more detail in Section 4.3.

3.2 Guided Sub-Orbital Expendable Launch Vehicle Flight Corridor [14 CFR §420.23(b)] Paragraph 420.23(b) requires the LSOL applicant to define a flight corridor that meets various requirements for a guided sub-orbital expendable launch vehicle. These requirements are found below:

(b) Guided sub-orbital expendable launch vehicle. For a guided sub-orbital expendable launch vehicle, an applicant shall define a flight corridor that: (1) Encompasses an area that the applicant estimates, in accordance with the requirements of this part, to contain debris with a ballistic coefficient of ≥ 3 pounds per square foot, from any non-nominal flight of a guided sub-orbital expendable launch vehicle from the launch point to impact with the earth's surface;

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(2) Includes an impact dispersion area for the launch vehicle's last stage; (3) Includes an overflight exclusion zone where the public risk criteria of 1 x 10-4 would be exceeded if one person were present in the open; and (4) Uses one of the methodologies provided in appendices A or B to this part. The FAA will approve an alternate method if an applicant provides a clear and convincing demonstration that its proposed method provides an equivalent level of safety to that required by appendix A or B of this part.

Spaceport Camden is not requesting permissions for guided suborbital operations at this time; therefore, no analysis was performed. However, should such operations be requested in the future, Spaceport Camden is familiar with the processes and procedures for applying for such permissions.

3.3 Unguided Sub-Orbital Expendable Launch Vehicle Flight Corridor [14 CFR § 420.23(c)] Paragraph 420.23(c) requires the LSOL applicant to define a flight corridor that meets various requirements for an unguided sub-orbital expendable launch vehicle. These requirements are found below:

(c) Unguided sub-orbital expendable launch vehicle. (1) For an unguided sub-orbital expendable launch vehicle, an applicant shall define the following using the methodology provided by appendix D of this part:

(i) Impact dispersion areas that the applicant estimates, in accordance with the requirements of this part, to contain the impact of launch vehicle stages from nominal flight of an unguided sub-orbital expendable launch vehicle from the launch point to impact with the earth's surface; and (ii) An overflight exclusion zone where the public risk criteria of 1 x 10-4 would be exceeded if one person were present in the open.

(2) The FAA will approve an alternate method if an applicant provides a clear and convincing demonstration that its proposed method provides an equivalent level of safety to that required by appendix D of this part. (3) An applicant shall base its analysis on an unguided suborbital launch vehicle whose final launch vehicle stage apogee represents the intended use of the launch point.

Spaceport Camden is not requesting unguided suborbital operations at this time; therefore, no analysis was performed. However, should this type of operation be requested in the future, Spaceport Camden is familiar with the processes and procedures for applying for such permissions.

3.4 Reusable Launch Vehicle Flight Corridor [14 CFR § 420.23(d)] Paragraph 420.23(d) requires the LSOL applicant to define a flight corridor that meets various requirements for a reusable launch vehicle; as noted earlier, for the case of Spaceport Camden the reusable launch vehicle is a reusable first stage guided orbital launch vehicle with a guided expendable second stage and payload. Specifically, 14 CFR §420.23(d) states the following:

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(d) Reusable launch vehicle. For a reusable launch vehicle, an applicant shall define a flight corridor that contains the hazardous debris from nominal and non-nominal flight of a reusable launch vehicle. The applicant must provide a clear and convincing demonstration of the validity of its flight corridor.

Spaceport Camden is not requesting reusable operations at this time; therefore, no analysis was performed. However, should this type of operation be requested in the future, Spaceport Camden is familiar with the processes and procedures for applying for such permissions.

4 14 CFR § 420.25 – Launch site location review—risk analysis.

Paragraph 420.25 defines the risk analysis requirements for a flight corridor that contains a populated area in terms of casualty expectation associated with the flight corridor or impact dispersion area. The specific requirements are:

(a) If a flight corridor or impact dispersion area defined by section 420.23 contains a populated area, the applicant shall estimate the casualty expectation associated with the flight corridor or impact dispersion area. An applicant shall use the methodology provided in appendix C to this part for guided orbital or suborbital expendable launch vehicles and appendix D for unguided suborbital launch vehicles. The FAA will approve an alternate method if an applicant provides a clear and convincing demonstration that its proposed method provides an equivalent level of safety to that required by appendix C or D of this part. For a reusable launch vehicle, an applicant must provide a clear and convincing demonstration of the validity of its risk analysis.

(b) For licensed launches, the FAA will not approve the location of the proposed launch point if the estimated expected casualty exceeds 1 × 10−4.

The Aerospace Corporation analyzed the various trajectories from the Spaceport Camden launch point using their proprietary and trade secret algorithms that have been used in prior FAA, USAF and international analysis efforts of expected casualty for expendable and reusable launch vehicle operations and that conform to 14 CFR 420, Appendix C for guided orbital or suborbital expendable and reusable launch vehicles. Assumption for the risk analysis are provided in Section 4.4.1. For all small launch vehicle trajectories, The Aerospace Corporation analyzed from Spaceport Camden all trajectories had an estimated Ec that was significantly less than 1x10-4. Enhanced population cases of cumulative risk analysis (Ec) for the 100 degree azimuth (from true north) representative trajectory of a small launch vehicle demonstrated up to 40 people per structure could be accommodated. The results of these analyses are summarized below in Exhibit 12 and Exhibit 13.

Trajectory Azimuth

Mission Total (two phases of flight) Ec (x 10-4)*

85 0.01 100† 0.004 120 0.01

* These results are shown as two significant figures for clarity; however, 14 CFR Part 420 specifies Ec requirements with one significant figure. † The 100-degree azimuth trajectory has de minimis 2nd stage Ec contribution due to the entire 2nd stage trajectory being flown over water.

Exhibit 12. Spaceport Camden Small Trajectory Ec Analyses

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Exhibit 13. Spaceport Camden Small Launcher Enhanced Population 100-Degree Azimuth Ec Analysis

4.1 Assumptions The Aerospace Corporation’s analysis methodology of Ec included the assumptions summarized in Exhibit 14 and additional assumptions pursuant to 14 CFR part 420 and its appendices. Parameter Value Notes Total Probability of Failure (Pf) 20% First Stage Probability of Failure 10% Second Stage Probability of Failure 10% Catastrophic On-Trajectory (OT) Failure 30% Loss of Thrust (LOT) Failure 30% 50% intact and 50% explosive Malfunction Turn (MFT) 40% First Stage Casualty Area (Ac) 3,800 ft2 90 fragments Second Stage Ac 250 ft2 20 fragments OEZ Effective Casualty Area 3,800 ft2 Same as first stage casualty area Total Angle of Attach (Qα) >10,000 psf-deg Total Monte Carlo Simulations 300,000 100,000 per failure mode Impact Limit Line (ILL) delay 0.2 to 0.4 seconds Reference Launch Azimuth 100-degree Trajectory Data Varies See Section 4.1.2 Wind Data Varies See Section 4.1.2 Population Data Varies See Section 4.1.3

Exhibit 14. Summary of Key Assumptions for Ec Analysis

4.1.1 Trajectory Data & Maps

For the small representative launch vehicle’s 100-degree reference trajectory, the flight corridor that encompasses an area that is estimated to contain debris with a ballistic coefficient of ≥ 3 pounds per square foot, from any non-nominal flight of the guided orbital reusable launch vehicle, from the launch point to a point 5,000 nm downrange, or where the IIP leaves the surface of the Earth, whichever is shorter, was defined by The Aerospace Corporation as shown in Exhibit 15.

Camden County with Added Population Expected Casualty (/10,000) Persons per

CI/LCI Structure

CI Campers & Visitors

Launch Viewers Stage 1 Stage 2 Total

0 0 0 0.001 0.01 0.01 0 0 5350 0.014 0.01 0.02 0 380 0 0.016 0.01 0.03 2 0 0 0.068 0.01 0.08 2 380 5350 0.098 0.01 0.11

10 380 5350 0.37 0.01 0.38 20 380 5350 0.71 0.01 0.72 40 380 5350 1.39 0.01 1.40

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Exhibit 15. Flight Corridor (as per § 420.23(a)(1)) for Small Representative Reusable Launch Vehicle –

100-Degree (From True North) Azimuth Trajectory from Spaceport Camden

The trajectory and dispersion data that defines the flight paths and corridors of the representative launch vehicle used for this analysis were developed by The Aerospace Corporation based on representative small launch vehicles such as the RocketLab Electron, Vector R, and ABL RS0 launch vehicles, and is found in the Excel files included with the delivery of this report as part of the overall LSOL application. The mapping of the trajectories is shown in Exhibit 9. These data in the Excel files are considered proprietary and typically are ITAR controlled technical data.

4.1.2 Winds Data The winds data used by The Aerospace Corporation for this analysis are representative of coastal winds present in Southeastern Georgia and the Florida coastal community. The winds data is found in the Excel files included with this LSLR.

4.1.3 Population Data Population data used by The Aerospace Corporation for this analysis included three principle sources: the 14 CFR Part 420 recommended LandScan database from Oak Ridge National Laboratory (ORNL), with 0.5 x 0.5 arc-minute2 grid size extrapolated to 2020 for downrange overflight, the 2010 Camden County census tracks for local data, and assumed presence of persons at habitable structures on Cumberland Island and Little Cumberland Island that were close to potential flight corridors, but are not represented in the two official population databases. For the Ec analysis performed by The Aerospace Corporation, it was assumed that all population found in the population databases (LandScan / ORNL and Camden

2 It is noted that 14 CFR Part 420 requires 1 arc minute by 1 arc minute grid size, so this approach is more rigorous.

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

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Notes: LCI = Little Cumberland Island CI-N = North End, Cumberland Island CI-Squaw = Squaw Point, Cumberland Island CI-Plum = Plum Orchard, Cumberland Island

Exhibit 17. Habitable Structures on Cumberland Island and Little Cumberland Island Near the Flight Corridors Emanating from Spaceport Camden

The mapping of these habitable structures is shown in Exhibit 18 with a random example flyout (outbound) trace. Enhanced population assumptions for the 100-degree reference trajectory are shown in Exhibit 19 (table form) and Exhibit 20 (map form with notes).

Exhibit 18. Mapping of 55 Added Habitable Structures to Population Database (Base Case - 40 per Structure) Shown with Example Outbound Trajectory Line

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Exhibit 19. Enhanced Population Distributions and Latitude / Longitude Locations

Exhibit 20. Map of Enhanced Population Distributions and Latitude / Longitude Locations

4.2 Expected Casualty (Ec) Data The Ec analysis methodology used by The Aerospace Corporation contains trade secrets, is proprietary to Aerospace, is believed to contain ITAR controlled Technical Data, is considered to constitute a Defense Service under ITAR, and was performed in accordance with 14 CFR 420 and its appendices. The analysis is summarized in the following sub-sections: Assumptions, Operations, and Ec Results. The small representative launcher is presented.

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4.2.1 Methodology The Aerospace Corporation methodology for calculating Ec is implemented by multiplying the probability of impact (PI) by the casualty area (AC) of the debris, multiplied by the population density (DP) of the region of interest. The Aerospace Corporation’s Ec Tool utilizes gridded world population data (and other population sources and assumptions as appropriate) and sums the Ec over all the grid cells at risk and multiplies by the failure probability (PF).

The Aerospace Corporation’s Ec Tool uses as its base case the population density grid (as noted earlier in 4.3) of the LandScan database from Oak Ridge National Laboratory, with 0.5 x 0.5 arc-minute grid size. The Aerospace Corporation Ec Tool may be easily modified to reflect other population databases to enhance the analysis, as deemed appropriate. In the case of this Spaceport Camden analysis, the latest local Camden County U.S. census track data was used for local population density and it was assumed in the base case that additional visitors to permanent structures on Little Cumberland and Cumberland Island in the vicinity of the flight corridor were present (40 each at 55 habitable structures). For the enhanced population cases for the 100-degree reference trajectory additional populations were added, as described in paragraph 4.3, including the maximum allowable number of visitors, staff and campers to Cumberland Island (both CUIS and the Greyfield Inn), first responder populations, spectator populations, and additional guests at the habitable structures on Little Cumberland Island and Cumberland Island. In total between the two islands there were 2,580 people added near or underneath the flight trajectories. This is well beyond, by a factor of 5-times, any reasonable expectation of population anticipated on the two islands. It was assumed that the launch vehicle uses a highly-reliable, autonomous flight termination system (AFTS) using ordinance. The AFTS will be activated when the vehicle instantaneous impact point (IIP) crosses a limit line constructed to protect the surrounding region.5 The inert debris casualty area is the sum of the fragment areas with a human border. The probability of failure for Stage 1, and the failure mode allocation are scalable parameters; a conservative 10% failure rate was used to calculate Ec results per stage and phase of flight (i.e., for the small representative vehicle, Stage 1 is assumed to have a 10% failure rate and a 10% failure rate for the 2nd Stage, resulting in a 20% assumed failure rate for the entire mission).6 The impact distribution and analysis methodology used by The Aerospace Corporation

5 This condition is considered more conservative than in actual use, as certain anomalous conditions sensed by a typical AFTS would also terminate flight before its IIP reaches a limit line, thereby minimizing even further, debris distribution. 6 The failure rate used in the analysis is conservative given the mission failure rate requirement of 10% given in Appendix C to Part 420, paragraph (b)(3) and Table C-1.

(b) (4)

(b) (4)

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

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Exhibit 21. Spaceport Camden 100 Degree Azimuth Trajectory – 2nd Stage Ascent to Orbit With

Impact Probability Estimates (de minimis Ec Due to Over Water Flight)

4.2.3 Ec Results

The detailed Ec results for the small launcher trajectories are provided in Exhibit 22 and Exhibit 23, with additional details on second stage Ec calculations included.

Trajectory Azimuth

Mission Total (all three phases of flight) Ec (x 10-4)*

85 0.01 (rounds to 0) 100† 0.004 (rounds to 0) 120 0.01 (rounds to 0)

* These results are shown as two significant figures for clarity; however, 14 CFR Part 420 specifies Ec requirements with one significant figure. † The 100-degree azimuth trajectory has de minimis 2nd stage Ec contribution due to the entire 2nd stage trajectory being flown over water.

Exhibit 22. Spaceport Camden Small Trajectory Ec Analyses

Exhibit 23. Spaceport Camden Small Launcher Enhanced Population 100 Degree Azimuth Ec Analysis

Camden County with Added Population Expected Casualty (/10,000) Persons per

CI/LCI Structure

CI Campers & Visitors

Launch Viewers Stage 1 Stage 2 Total

0 0 0 0.001 0.01 0.01 0 0 5350 0.014 0.01 0.02 0 380 0 0.016 0.01 0.03 2 0 0 0.068 0.01 0.08 2 380 5350 0.098 0.01 0.11

10 380 5350 0.37 0.01 0.38 20 380 5350 0.71 0.01 0.72 40 380 5350 1.39 0.01 1.40

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Spaceport Camden – Launch Site Location Review GORA EXEMPT – PROPRIETARY & TRADE SECRETS – REAL PROPERTY ACQUISITION EVAL ANALYSIS – NO PUBLIC RELEASE FOIA & GORA EXEMPT – Contains Technical Data that may be controlled pursuant to the Arms Export Control Act (AECA),

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Exhibit 26. Simplified OEZ for the Small Representative Launch Vehicle – 100-Degrees Azimuth

(From True North) Trajectory from Spaceport Camden

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5 14 CFR § 420.27 – Launch site location review—information requirements.

Paragraph 420.27 defines the LSOL information requirements for the review of a launch site location. These information requirements are defined as follows:

An applicant shall provide the following launch site location review information in its application:

(a) A map or maps showing the location of each launch point proposed, and the flight azimuth, IIP, flight corridor, and each impact range and impact dispersion area for each launch point; (b) Each launch vehicle type and any launch vehicle class proposed for each launch point; (c) Trajectory data; (d) Wind data, including each month and any percent wind data used in the analysis; (e) Any launch vehicle apogee used in the analysis; (f) Each populated area located within a flight corridor or impact dispersion area; (g) The estimated casualty expectancy calculated for each populated area within a flight corridor or impact dispersion area; (h) The effective casualty areas used in the analysis; (i) The estimated casualty expectancy for each flight corridor or set of impact dispersion areas; and (j) If populated areas are located within an overflight exclusion zone, a demonstration that there are times when the public is not present or that the applicant has an agreement in place to evacuate the public from the overflight exclusion zone during a launch.

This information has been provided within this LSLR and its companion electronic files. Exhibit 27 (below) cross references these information requirements with the specific location within this LSLR where the information is found.

INFORMATION REQUIREMENT LOCATION IN LSLR (a) A map or maps showing the location of each launch point proposed, and the flight azimuth, IIP, flight corridor, and each impact range and impact dispersion area for each launch point;

1.1, 1.3, 2.4, 4.1.1, 4.2.2

(b) Each launch vehicle type and any launch vehicle class proposed for each launch point; 1.2, 1.4 (c) Trajectory data; 4.1.1, 4.2.2 (d) Wind data, including each month and any percent wind data used in the analysis; 4.1.2 (e) Any launch vehicle apogee used in the analysis; 4.1.1 (f) Each populated area located within a flight corridor or impact dispersion area; 4.1.3, 4.3 (g) The estimated casualty expectancy calculated for each populated area within a flight corridor or impact dispersion area;

4 , 4.2.3

(h) The effective casualty areas used in the analysis; 4.1, 4.2.1, 4.3 (i) The estimated casualty expectancy for each flight corridor or set of impact dispersion areas; and

4.2, 4.2.3

(j) If populated areas are located within an overflight exclusion zone, a demonstration that there are times when the public is not present or that the applicant has an agreement in place to evacuate the public from the overflight exclusion zone during a launch.

Not Applicable (see 4.3)

Exhibit 27. Cross Reference of 14 CFR § 420.27 Information Requirements vs Location in LSLR

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6 14 CFR § 420.29 – Launch site location review for unproven launch vehicles.

Paragraph 420.29 defines the launch site location review requirements for unproven launch vehicles. Specifically, the requirements are:

An applicant for a license to operate a launch site for an unproven launch vehicle shall provide a clear and convincing demonstration that its proposed launch site location provides an equivalent level of safety to that required by this part.

Spaceport Camden is not applying for these permissions in this application.

7 14 CFR §417.107(b)(2) – Flight safety, Public risk criteria, Individual risk

Although provisions of Part 417 are generally not required to be met by an applicant for a LSOL, Spaceport Camden had this analysis completed to demonstrate to potential launch operators that meeting this requirement was likely, given the assumptions made for the analysis. Only later after the initial submission of this information as supplemental in this Section 7 did FAA/AST require this information for the Spaceport Camden LSOL application (FAA/AST, Kenneth Wong, letter of 12 February 2019). Paragraph 417.107(b)(2) defines the requirement levied on launch operators to demonstrate the risk to any individual member of the public is highly remote for each hazard. Specifically, the requirements are:

A launch operator may initiate flight only if the risk to any individual member of the public does not exceed a casualty expectation of 1 x 10-6 for each hazard.12

This section includes a description of the methodology used in this analysis, the assumptions made, and the outcomes of the evaluations. This analysis was performed by The Aerospace Corporation using their Ec and individual risk tools that are proprietary, contain trade secrets, are believed to contain Technical Data that is controlled under ITAR, and is believed to constitute a Defense Service under the ITAR. It is considered that this methodology and the assumptions result in a conservative approach to individual risk evaluation, as described more fully below.

7.1 Methodology – individual risk. The individual risk calculation is used to determine the highest risk of casualty to any particular person. The Aerospace Corporation tool calculates the individual risk for a particular ith population grid cell as follows:

12 Revised as per Federal Register, Volume 81, Number 139, Wednesday July 20, 2016, pages 47017-47027.

(b) (4)

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Attachment 3

USCG / Spaceport Camden Draft Letter of Agreement (Signed)

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Spaceport Camden – United States Coast Guard Letter of Agreement

U.S. Coast Guard

Letter of AgreementSigned

As of 12 June 2019

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Attachment 4

FAA ATO / Spaceport Camden Letter of Agreement (Signed)

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Spaceport Camden – FAA Air Traffic (Multi-Party) Letter of Agreement

FAA

Air Traffic

(Multi-Party)

Letter of AgreementFINAL

Effective 12 February 2018

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Attachment 5

Access Control Plan

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Access Control Plan

As of 14 January 2020

FOIA EXEMPT – PROPRIETARY DATA

GORA EXEMPT – SECURITY PLANNING INFORMATION

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Contents

1.0 Introduction ...................................................................................................................................... 3 2.0 Access Control Background Information .......................................................................................... 3

2.1 Overview of Basic Security Concepts ............................................................................................ 3 2.1.1 The Asset Triangle ................................................................................................................. 3 2.1.2 The Threat Triangle ............................................................................................................... 4 2.1.3 The Security Triangle ............................................................................................................. 5

2.2 Security System Considerations .................................................................................................... 5 2.3 Major Elements / Functions Needed ............................................................................................ 6

2.3.1 Access Control System .......................................................................................................... 6 2.3.2 Intrusion Detection and Alarm System ................................................................................. 7

3.0 Access Control System Plan .................................................................................................................. 11 3.1 Review of existing Documentation ............................................................................................. 11 3.2 Access Control Security Checkpoints .......................................................................................... 12

3.2.1 Land-based Checkpoint Types ............................................................................................ 12 3.2.2 Waterborne Checkpoint Types ........................................................................................... 13 3.2.3 Typical Operational Checkpoints ........................................................................................ 13 3.2.4 Checkpoint Staffing Scenario By Operation Type ............................................................... 15 3.2.5 Operations – Routine Day to Day Access Control ............................................................... 16 3.2.6 Operations – Wet Dress Rehearsals / Static Firings Access Control ................................... 17 3.2.7 Operations – Launch ........................................................................................................... 18

3.3 Access Control System Features ................................................................................................. 19 3.3.1 Perimeter Fencing ............................................................................................................... 19 3.3.2 Clear Zone Along Fences ..................................................................................................... 20 3.3.3 Gates ................................................................................................................................... 20 3.3.4 Road to Main Gate & Speed Reduction .............................................................................. 20 3.3.5 Interior Roadways and Parking ........................................................................................... 21 3.3.6 Property Coastline............................................................................................................... 21 3.3.7 Waterborne Patrols............................................................................................................. 22 3.3.8 Dock .................................................................................................................................... 22 3.3.9 Lighting ................................................................................................................................ 23 3.3.10 Guard Houses ...................................................................................................................... 24 3.3.11 Signage ................................................................................................................................ 28 3.3.12 Crime Prevention Through Environmental Design (CPTED) ............................................... 28

3.4 Initial Plan – Camera Locations ................................................................................................... 28 Revision History: 1/25/19 Initial Submittal. 01/14/20 Revisions include removal of medium-large launcher (only small launcher remains) and

additional minor edits. Changes agreed with FAA/AST between January – December 2019 also included.

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1.0 Introduction

This Spaceport Camden Access Control Plan has been prepared to meet the requirements of 14 CFR § 420.53, the control of public access as it relates to physical security (surveillance systems, physical barriers, etc.) and personnel policy / procedures. Specifically, 14 CFR § 420.53 states:

§ 420.53 Control of public access. (a) A licensee shall prevent unauthorized access to the launch site, and unauthorized, unescorted access to explosive hazard facilities or other hazard areas not otherwise controlled by a launch operator, through the use of security personnel, surveillance systems, physical barriers, or other means approved as part of the licensing process. (b) A licensee shall notify anyone entering the launch site of safety rules and emergency and evacuation procedures prior to that person's entry unless that person has received a briefing on those rules and procedures within the previous year. (c) A licensee shall employ warning signals or alarms to notify any persons at the launch site of any emergency.

This document was largely prepared by Kimley-Horn with the coordination and assistance of Nelson Aerospace Consulting Associates for and on behalf of the Camden County Board of Commissioners. 2.0 Access Control Background Information

The following section reviews the general principles and overarching themes that were utilized to produce this Access Control Plan.

2.1 OVERVIEW OF BASIC SECURITY CONCEPTS

Three basic concepts of security were followed in developing the Spaceport Camden Access Control Plan including: the Asset Triangle, the Threat Triangle, and the Security Triangle.

2.1.1 THE ASSET TRIANGLE

The goal of security is to protect assets. An asset is anything owned or wholly controlled by the organization and contributes to the successful completion of the organization’s mission(s). Assets are best defined in three categories: infrastructure, information, and image. The Asset Triangle is shown in Figure 1.

Figure 1. Asset Triangle

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Infrastructure assets are tangible items that are part of the working structure of the organization – the things that make the organization’s mission(s) achievable. They include plant, property, equipment, and vehicles. Also included in this category are the persons who provide services to the organization – employees and contractors. Information assets are those that contain data that is relevant to the execution and outcome of the organization’s mission(s). They include strategic plans, customer lists, financial and accounting records, design drawings, personnel information, and any other data collected or held by the organization. Information assets are divided into electronic (computer-based) and hard (paper) records. Image assets are intangibles that influence the public and market perceptions of the value, reliability, and sustainability of the organization and its mission(s). Image assets include the public trust, market share, market capitalization, and competitive advantage. Asset criticality is determined by evaluating assets in each of these three categories from both the operational and agency mission viewpoints. Operational personnel must be involved in the determination of operational mission-critical assets, and senior management must be involved in the identification of agency mission-critical assets.

2.1.2 THE THREAT TRIANGLE

Every threat has three critical elements, all of which must be present before the crime or event can occur. These include: motive, means, and opportunity, as shown in the Threat Triangle in Figure 2.

Figure 2. Threat Triangle

Motive is the willingness to commit a criminal act. There are many reasons a person may commit a criminal act, ranging from personal vendetta to political statement, including every possible motive in between. The organization cannot control what motivates a criminal. Means refers to the capability of the person to perform an act. The means include such matters as equipment availability, time, the specific knowledge of the person, any available help from the inside of the organization, the person’s own native intelligence, and other resources. Once again, there is little that can be done to control the means available to a potential criminal or terrorist.

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Opportunity is the open window, both literally and figuratively, to commit a malevolent act. It is the unlocked door, the unobserved fence, the unalarmed building, and the unlit perimeter that makes it easier for a criminal to gain entry to a site and to achieve their objectives, to the detriment of the organization. Opportunity is the one element of the threat triangle over which the organization has a great deal of control, and it is therefore where security efforts must be concentrated.

2.1.3 THE SECURITY TRIANGLE

Security plans should have three objectives, each a step further into a criminal act than the previous: deter, detect, and delay. These three objectives are shown as the Security Triangle in Figure 3.

Figure 3. Security Triangle

Deter: The first objective of a site security plan is to deter, which is, in effect, reducing opportunity. The intention is to will the potential criminal to abandon their plan of attack. Detect: In the event that deterrence fails and the criminal proceeds with their plan of attack, it is desirable to ensure that the intrusion or other malevolent act is noted by the various components of the security system. In addition to the technology systems, detection also relies on the guards and the procedures and policies that are in place in order to note improper activities. Delay: Once the act has been detected, the next objective is to delay the intruder as much as possible. A number of barriers can be created that the intruder must overcome, each of which slows their progress in reaching their objectives. The delay needs to be significant enough to allow for a response, from whatever mechanism is in place to respond. Contract security, employees on site, and outside agencies all may play a role in response, depending on the level of the intrusion.

2.2 SECURITY SYSTEM CONSIDERATIONS

Electronic security systems should be designed and installed with deliberate consideration for their ultimate goals. Security systems should be integrated seamlessly with each other, allowing a simple and effective user understanding and response to critical situations identified by the systems. Integration is a central tenet of modern security design. Proper integration provides the end user with a greatly enhanced security capability, leading to a much higher level of comfort for the personnel that

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are protected by the system. Additionally, effective integration reduces training costs, enhances the ability to quickly troubleshoot a system, and provides a notably more effective response from security personnel. Integration is the interaction and sharing of information, features, and functionality between systems and people in order to effectively and efficiently perform a function. Strong integration will reduce the amount of interaction required between technology and people, which has two key benefits – the freeing up of personnel resources to perform other functions, and the reduction in possible points of failure in a system. Conventional contracting methods in security usually end up with several systems from several different vendors, each supplying a different component of the system. While a certain amount of this is inevitable, it can create extra cost for the owner in the areas of training, installation, and maintenance. Developing a commonality in the systems under design is the preferred choice. This commonality is a methodology by which differing components can function as one, reporting through the same interface to an operator. The advantages to the user are several. Functionally, this requires the operator to learn only one interface while operating multiple systems (e.g., CCTV, intrusion detection, access control, etc.). The cost of training is thus reduced while efficacy of operations is enhanced. Training or retraining processes on a single system is significantly easier and less costly than specialized training on each of the systems that are to be monitored and less complex systems enhances operational efficacy. The integrated approach also allows the use of a single workstation for the monitoring personnel, as opposed to the need for multiple computers and workstations for separate systems. The savings are not just in the cost of the extra computers and peripheral devices, but also in actual real estate (space), which can be used for other things. And again, a simpler system to monitor and operate improves operational efficacy. Integration has historically been performed by the firing of relays within a control panel or other device. This is a mechanical operation which, while effective, requires wiring of every integrated device to the control panel, in one form or another. On the other hand, software integration allows systems to interact at a software level. This means that wires are no longer needed for every contact that is part of the system. Now software can make the decisions, issue the commands, and invoke the necessary reactions from other systems. The savings in wiring alone from this capability at a large facility could be immense.

2.3 MAJOR ELEMENTS / FUNCTIONS NEEDED

The following are high level descriptions of the major elements / functions that are envisioned to be utilized at the Spaceport Camden site.

2.3.1 ACCESS CONTROL SYSTEM

The access control system will be the managing component of the entire security system. All gates, buildings, structures, and high priority areas of buildings will be equipped with a card access system to control entry and egress. Exceptions to this are anticipated for low priority storage sheds, and other

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non-critical structures. High priority assets will be protected with access control requiring something in addition to a card, such as a PIN or biometrics. An access control system provides a wealth of information that relates to both safety and security. The system should be able to provide reports that can be used as an investigative tool. The following matters, all of which can be determined via the software, should always be investigated:

Propped doors; Cards read in unauthorized areas; Cards read at unauthorized times; and Compliance with entry/exit procedures at gates.

The last point above relates to the problem of personnel not always properly carding into the site or a building or secure room / space. For example, when carpooling, there are often times when only the driver will read their card to gain entry, no one else will. This creates both security and safety issues, as no one can be sure who is on site. Personnel procedures will be put in place as appropriate to ensure accurate awareness of site presence by authorized staff, contractors, and visitors. Card access systems provide access via authentication (e.g., an access card) and authorization (where a given card is accepted). Authorization links authenticated individuals to the specific buildings or areas to which they are entitled to have access by establishing rules for each controlled access point. The authorization process is rightly in the hands of the access-system administrator and management. Authenticity can be provided via three factors:

Something you have (a card, a key); Something you know (a PIN number); and/or Something you are (biometrics).

The more factors required, the better the security. At the same time, there is a need to balance security requirements with operational efficiency. For the most part, using a card (something you have) as single factor authentication is strong enough security. However, for high priority assets multiple-factor authentications will be used, as appropriate.

2.3.2 INTRUSION DETECTION AND ALARM SYSTEM

The entire length of the perimeter should be equipped with intrusion detection devices that are integrated into the alarm system. All entry points into buildings and structures, including windows and roof hatches, as well as high priority areas within buildings, should be monitored as well.

2.3.2.1 Camera Systems Closed Circuit Television (CCTV) should be used for four purposes: alarming, assessment, surveillance, and investigation. For each secure facility, the entire length of the perimeter, clear zones, and high priority assets should be monitored by video surveillance. A combination of pan-tilt-zoom (PTZ) and fixed cameras should be used as necessary to provide the best possible coverage. The system should have a sophisticated video management system capable of geographic information system (GIS) integration, camera control, video distribution and analysis, sensor integration, and alarm notification.

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The CCTV component of the security plan should be viewed as an entire system that is greater than the sum of its parts. It is important not to attempt to consider the cameras separate from the management system, nor the reverse. Video cameras now have the video analytic capability to note motion in their field of view by several different technologies and can trigger an alarm situation when that occurs. CCTV cameras should also be used to provide assessment when the access control system or video analytic detection system creates an alarm. They should also be capable of filling a general surveillance role, being used for pre-programmed tours of the compound when not responding to alarms. Finally, the system should provide a high degree of investigative capability, with easy retrieval of stored video and assurance that the video was not tampered with, in the event that it is ever required as evidence. The system of cameras should include a combination of PTZ and fixed cameras. The PTZ cameras should be used for over-watch and alarm assessment, while the fixed cameras should be responsible for creating a recorded video record of the area for future investigations, as well as, real-time alarm assessment, general surveillance, and, in some cases, alarm detection.

2.3.2.2 Video Management System (VMS) The Video Management System (VMS) should provide a distributed, scalable set of technologies for detection, transmission, and notification of alarm events. The fundamental objectives of the technology are to be able to easily integrate with standard devices and sensors in the field, process the information from the devices, derive alarms based on significant changes in the devices’ state, and then annunciate the alarm through a set of open interfaces. This will require open architecture at the head end of the system so it can be easily integrated beneath more sophisticated command and control software. In particular, the system should include a suite of technologies for managing and analyzing digital video, controlling cameras, and interfacing to the perimeter intrusion detection and access control system. The VMS should be capable of working with a large number of different manufacturers’ PTZ cameras.

2.3.2.3 Camera and VMS Selection The camera selection process is simplified since cameras from most of the major manufacturers (Panasonic, Axis, Vicon, Pelco, Flir, Cohu and several others) are very similar in their optics and video streaming capabilities, but may differ significantly in their ability to support video analytic detection and/or ability to support low light or no light viewing of an area. In making a selection of the VMS and cameras, the following factors should be considered:

Manufacturer support; GIS integration; Camera control; Video distribution; Video analysis; Sensor integration; and Alarm notification.

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2.3.2.4 Geographic Information System (GIS) Integration The use of mapping technology to locate and position devices, cameras, and alarms within the real world provides several benefits, including enhanced situational awareness when identifying potential intrusions, incidents, and emergencies, and the response to these situations. The system should be able to associate latitude and longitude coordinates with objects and alarms. This allows the production of map displays of the location of devices, cameras, and alarms. The map displays can incorporate industry-standard GIS data files, such as aerial photographs, street names, critical building locations, etc. Users can zoom or pan maps to any level, and they can interact with the objects represented on the map. For example, clicking on a camera icon immediately causes video to be displayed from the corresponding camera. These capabilities should allow the operator to spatially associate and navigate video and alarm data and their locations in an intuitive manner, without requiring any special user interface programming on the part of the system integrator. GIS mapping capability should provide a high level of situational awareness for the operator. An additional benefit of having a native GIS capability is that the VMS could then automatically relate the sources of events with a means to evaluate or corroborate them. For example, if the system knows where each camera is and can determine where an alarm from an access control system is occurring, it can automatically position PTZ cameras to look directly at the point of intrusion without requiring any camera preset programming or relay contacts between the camera and the area of the detected intrusion. In the case of a large perimeter, this feature can save hundreds of hours of system integration time because the entire automated video surveillance response along a perimeter can be configured from a simple drawing that might take a few hours to produce.

2.3.2.5 Camera Control An important part of remote site surveillance is corroboration and assessment of alarm conditions. The use of PTZ video cameras is an efficient way to provide alarm assessment prior to a response team being dispatched. Automating the control of PTZ cameras reduces both the time required to perform an assessment, and the skill required of a human operator to track an object interactively. This can occur in two different ways. The two key capabilities of high-end camera control software are 1) providing remote control techniques that drastically reduce the effect of latency and bandwidth on camera positioning, and 2) using native GIS capabilities. This increased level of situational awareness should increase the capabilities of the monitoring personnel. Typical joystick camera control presents problems to operators when used with digital video. The problem is that the up/down, left/right, in/out control actions are all “relative” positioning commands. The operator depends on feedback from the video to determine when to stop moving the camera. If there is enough latency in the video feed (due to bandwidth limitations or streaming compression characteristics) then the operator will consistently overshoot their target. The problem is compounded if the operator is trying to track a moving target. If the VMS can position cameras using absolute coordinates, it would be able to support an alternate camera control methodology. Instead of moving the camera left/right or up/down, the operator would simply click on a spot on the video image where they would like to camera to point. The camera would

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automatically move so that this point becomes the center of its field of view. Within the constraints of the camera’s optics, the camera should automatically position and zoom to match the operator’s request. This point-and-click camera control capability would greatly reduce the effects of video latency and increase the ability of an operator to track a moving object, while reducing the manual skill required to control the camera. Another advanced feature of modern camera control technology is the ability to automatically direct a PTZ camera to track one or more objects in its field of view in an outdoor environment. The advantage of this is two-fold: it drastically reduces the need for a human operator to control the position of a camera, and since the control technology is based in an independent processor, it is independent of camera make and model.

2.3.2.6 Video Distribution The VMS should provide centralized access to all remote video camera feeds through a central server, eliminating the need for the user to figure out which remote device needs to be accessed in order to get video from a camera. The central server system (control and archive functions) should include both a local server within the secured site and a back-up server that is located at a remote location off site. Video should be distributed using standard IP networking protocols, so that it is available to any device that has an IP network connection, including web browsers and handheld devices. This capability can be important during a manned response to an alarm, where the responder can quickly view and take control of a PTZ camera before entering the subject location.

2.3.2.7 Video Analysis Most VMS manufacturers with network video recording (NVR) include some kind of video motion detection algorithms in their camera or VMS. Typically, these algorithms work well in indoor and outdoor environments. For this project, there is a need for the video processing and motion detection algorithms to work in the various lighting and weather conditions encountered in the outdoors, within reason.

2.3.2.8 Sensor Integration The VMS should be capable of integrating with third-party devices through RS-232/RS-422/RS-485 serial communications and Ethernet. The information provided by these devices can be used to generate alarm conditions, turn on programmed camera motion detection configurations, move one or more cameras to specified locations, or send a control signal to another type of device.

2.3.2.9 Alarm Notification The alarm notification system should be sophisticated and flexible in order to distribute alarm information both to monitoring personnel and to other systems. Alarm enunciation should be available through aural (speakers / horns), visual (lights / flags), e-mail, pagers, and voice telephone calls. In addition, there should be a graphical map-based console to provide operators with an intuitive view of a system by incorporating aerial photographs, Google Earth and other geographical contexts for alarms and video display.

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The notification system is intended to let users define a contact hierarchy, where each individual has designated methods of contact and a schedule for contact. The methods for contact may include e-mail, texting, voice telephone call, or any other contact method plug-in the system integrator supplies. The contact schedule specifies rules for when each contact method may be used, along with exceptions to those rules. Contacts can subscribe to different alarms either globally or on a per-site basis. More than one contact may subscribe to the same alarm. Each level in the hierarchy has a defined emergency contact that will be used if a designated contact for an alarm cannot be successfully reached. Each contact action taken for an alarm should be logged, along with an indication of acknowledgement.

2.3.2.10 Perimeter Intrusion Detection Systems (PIDS) In selecting a PIDS technology for each secure facility, there are typically four main factors to consider:

Probability of Detection: An ideal detector would have a perfect probability of one. However, there are no perfect detectors, so the closer the detection technology performs to an ideal condition (i.e., higher probability of detection) the better the PIDS will be. Nuisance alarm rate: A nuisance alarm (false alarm) occurs when an alarm is generated, but there is no target present. The ideal nuisance alarm rate would be zero. The most likely cause of nuisance alarms are environmental factors such as wildlife, vegetation, and weather conditions. Coverage Area and Tracking: The coverage area is the area in which the detection device can detect a target and track the movement of the target within the coverage area. In general, a larger the coverage area provides a longer duration for tracking a target’s movement. Larger coverage areas also provide the ability to define multiple electronic barrier limits within the coverage area and only trigger an alarm when the target crosses over a specific barrier limit. Visible Light Level: For this specific project, the ability to detect a target in areas where there is zero visible light is a critical technology selection factor in some site areas, since adding visible light is not a practical option along the outer most site perimeter.

3.0 Access Control System Plan

This section provides the Spaceport Camden Access Control System Plan. It includes an overview of the existing documentation; plans for the spaceport access control system elements; and those organizations that were part of the coordination group interviewed that influenced this plan.

3.1 REVIEW OF EXISTING DOCUMENTATION

In the development of this Access Control System Plan, the following documents were reviewed:

• Detailed Site Description for Spaceport Camden, • Draft Spaceport Camden potential safety zone charts, • US Coast Guard navigational charts for the region, • Various satellite and low altitude aerial photographs,

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• Publicly available maps, images, guides, and related material (e.g., National Park Service),

• Spaceport Camden County EIS DOPAA, and • Spaceport Camden County EIS Noise Study.

Preliminary client input for controlling the public access to Spaceport Camden included the following:

• Checkpoints along access roads, • Checkpoints for waterborne patrols, • Perimeter fencing along western boundary of property and each secure facility, • Appropriate clear zone on secure and unsecure side of fencing, • Existing and potential future security camera locations, and • Alternative surveillance systems (unmanned aerial systems, motion detection, etc.).

In addition to studying these materials and inputs, onsite visits, interviews with local experts (e.g., NPS staff, local first responders from the Sheriff’s Office and Camden Fire and Rescue, and residents) were held that included both on-land, and on-water investigations.

3.2 ACCESS CONTROL SECURITY CHECKPOINTS

Based on the activities and investigations discussed in Section 3.1, significant time was spent in identifying and confirming the location of security checkpoints and patrol areas that most efficiently and thoroughly provided controlled coverage of the critical launch areas for a representative launcher. Figures 4 through 6 later in this section and its subsections show and discuss these checkpoints including land and water-based check points for access control and management. Also discussed in the subsections below is Access Control for three operational scenarios: 1) Routine Day-to-Day Operations, 2) Static Test and Wet Dress Rehearsals, and 3) Launch Operations. All access control and notifications for a specific launch will be captured in a Comprehensive Launch Plan (CLP). Pursuant to 14 CFR §420.53(b), and as a matter of routine operations, all persons who enter the site will be briefed on safety / security rules, any special provisions required from the EIS mitigation measures, and emergency / evacuation procedures. Such briefing will be valid for one calendar year, unless updates dictate a shorter period. Pursuant to 14 CFR §420.53(c), during any emergency at the launch site, warning systems and alarms, as are described in section 2.3.2.9, will be employed. Each launch or test operation (e.g., wet dress rehearsal or static fire test) will have a defined set of warnings and alarms tailored to that operation. These warning systems and alarms will be captured and described in the CLP process, documented and rehearsed prior to the intended operation, as appropriate.

3.2.1 LAND-BASED CHECKPOINT TYPES

There are several land-based checkpoint types that are identified in the Spaceport Camden Access Control Plan including gate-entrance checkpoints, road / trail checkpoints, and various secure facility entrances with access control systems. These are briefly described below.

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Main Entrance – The main gate entrance is anticipated to be gated and manned 24/7. This is the primary entrance to the property. Secondary Entrance – The secondary entrance to the property has a typically unmanned guard house and may include a vestibule type aviation gate. During launch operations, this location will be manned. Road & Trail Checkpoints – These check points are established to control unauthorized access to the launch site and along the intended trajectory during launch operations. Secure Facility Entrances – Each secure facility such as the welcome center, vertical launch complex, launch control center complex, and mission preparation area will have a security gate and guard house. Depending on operations the entrances will either be manned or unmanned.

3.2.2 WATERBORNE CHECKPOINT TYPES

There are several waterborne checkpoint types that are identified in the Spaceport Camden Access Control Plan including fixed and roaming checkpoints and zones. It is assumed that the identified Safety Zones are approved and authorized pursuant to US Coast Guard standard operating procedures and established in accordance with 33 CFR §165. It is further assumed that this establishment procedure will include appropriate letters of authorization and agreement between US Coast Guard and local first responders such as the Camden County Sheriff’s Department. These are briefly described below.

Fixed Patrol Zones / Checkpoints – Several locations along the controlled access area require that a Sheriff’s boat (or other stakeholder first responder watercraft authorized by the US Coast Guard) patrol and remain essentially in a fixed location. These areas have an open field of view. Roaming Patrol Zone – Some locations along the controlled access area require that a Sheriff’s boat (or other stakeholder first responder watercraft authorized by the US Coast Guard, who is part of the official security team) roam and patrol a larger area that may be narrow and have a narrow field of view.

3.2.3 TYPICAL OPERATIONAL CHECKPOINTS

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Table 1 Typical Operational Checkpoints

(b) (7)(F)

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3.2.5 OPERATIONS – ROUTINE DAY TO DAY ACCESS CONTROL

During routine, day to day access control operations, the checkpoints shown in Figure 4 will be active as per the assignments shown in the table of section 3.2.4.

(b) (7)(F)

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3.2.6 OPERATIONS – WET DRESS REHEARSALS / STATIC FIRINGS ACCESS CONTROL

(b) (7)(F)

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3.2.7 OPERATIONS – LAUNCH (b) (7)(F)

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3.3 ACCESS CONTROL SYSTEM FEATURES

The Spaceport Camden Access Control Plan utilizes various physical and electronic features to ensure adequate security to meet FAA licensing and operational requirements. These are discussed below in the following subsections. These discussions take the form of the baseline plan for that system feature, and a potential added capability should the baseline feature be found to need augmentation.

3.3.1 PERIMETER FENCING

A barrier is often used as the initial line of defense in protecting a facility and thus is a critical element of the first security layer. The chain-link fence is the most common of these barriers, owing to its durability and relatively low cost. Security fencing as per FAA Airport requirements will be installed along the western boarder of the planned Spaceport Camden property and along the perimeter of each individual facility of the spaceport.

(b) (7)(F)

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3.3.2 CLEAR ZONE ALONG FENCES

All fenced areas will have clear zones with planted grass to enable enhanced electronic security systems to function properly.

3.3.3 GATES

Gates are a key part of any access control plan. Although a critical element of the perimeter, gates are also, typically, a weak point for entry. One of the major issues in gating is the strength of the gate when attacked or hit by a vehicle. Swing gates that join in the middle of the road provide minimal protection from this type of attack. The center point where the gates meet is the weakest area, and a vehicle attacking this point can easily breach the gate. The use of a sliding or rolling gate eliminates this weak point and establishes the quality of the gate material itself as the major variable in its ability to withstand attack. The following is planned for Spaceport Camden.

3.3.4 ROAD TO MAIN GATE & SPEED REDUCTION

Approaches to checkpoints are a critical element of securing a site. At Spaceport Camden, there is a (approximate) half mile straight section prior to the main gate that can enable a vehicle to gain significant speed. The following are plans for speed reduction.

(b) (7)(F)

(b) (7)(F)

(b) (7)(F)

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3.3.5 INTERIOR ROADWAYS AND PARKING

Should there be an anticipated increase in traffic causing congestion or concern with excessive speed on the Spaceport Camden site, interior road design may help alleviate these issues.

3.3.6 PROPERTY COASTLINE

The spaceport property is bounded on three sides by water and marshland. The ground elevation varies between 10-15 feet above the water level and provides a natural barrier to access. Warning signs exist along the whole of the property that note “Danger – Unexploded Ordnance – Keep Out.” New or additional signs will be installed, as appropriate. See signage subsection for additional plans. No additional security fence along the coastline is required, although electronic surveillance is envisioned.

Figure 8. Fallen Trees Along Bluff near Silo Site

(b) (7)(F)

(b) (7)(F)

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3.3.7 WATERBORNE PATROLS

During the day of launch or during wet dress rehearsals / static tests, at the direction and jurisdiction of the US Coast Guard pursuant to 33 CFR 165, Safety Zones will be established. The USCG’s designated first responder (e.g., the Camden County Sherriff’s Department (CCSD) and/or other affiliated first responders, as appropriate) will set up waterborne perimeter checkpoints / patrol areas in accordance with Figure 5 and Figure 6. Waterways between the checkpoints, within the controlled access area should be cleared of unauthorized vessels prior to launch / test and reopened following a successful launch / test. In the event of a mishap that results in debris in the controlled access area, the perimeter should be maintained in accordance with the launch site accident investigation plan.

3.3.8 DOCK

The dock on the property (see Figure 9 and 10) may present an access point onto the property that is easier than other waterborne points of entry, due to the old boat ramp on the south side of the dock. Access control here may be necessary. Should the dock be brought back into use, a ramp installed, and the structure appropriately permitted, additional measures (augmented plan) may be necessary for access control as described below.

(b) (7)(F)

(b) (7)(F)

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Figure 9. Dock along Floyd Creek

Figure 10. View from Dock looking North

3.3.9 LIGHTING

To facilitate night time access control and security, lighting will be necessary. (b) (7)(F)

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3.3.10 GUARD HOUSES

The Spaceport Camden site and individual facilities inside the property line will have several guard houses (e.g., main gate and a guard house at each facility). The guardhouses will consider the best practices of other government launch sites. Here is a brief discussion of these other guard houses. The main entrance to Wallops Flight Facility consists of a 2,500 sqft badging office and a 15’ x 20’ guard house at the main gate. These are shown in Figures 15 and 16. Kennedy Space Center has several guard houses that provide access to the large secure area “inside the fence”, and additional guard houses at each secure facility, such as Launch Complex 39A (LC-39A) and LC-39B. At the two main entrances to KSC, along NASA Parkway (SR-405) and North Courtney Parkway (SR-3), are vehicle checkpoints that consist of multiple lanes for badge check as well as a roughly 20’ x 40’ security building (See Figure 11 and Figure 12). The buildings have power, communications, and water. One 6,500 sqft badge office supports the center at the main entrance along SR-405. Both LC-39A and LC-39B have guard houses along the main roadways to the launch pads (see Figure 13) as well as guard houses at the entrance to each pad (see Figure 14). The guard house at each launch complex is approximately 20’ x 45’ with power, communications, and water. The facility is also equipped with Common Access Card technology allowing authorized personnel to scan their badge to gain access. The guard houses along Saturn Causeway and Beach Road are approximately 8’ x 10’ with power and communication only. Each guard house features a red warning light alerting traffic to upcoming launch/test.

(b) (7)(F)

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Figure 11. Kennedy Space Center Main Entrance at SR-405 (Source: Google Maps)

Figure 12. Kennedy Space Center Main Entrance at SR-3 (Source: Google Maps)

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Figure 13. Roadway Guard House (Source: Google Maps)

Figure 14. LC-39A Launch Site Guard House (Source: Google Maps)

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Figure 15. Wallops Flight Facility Main Entrance (Source: Google Maps)

Figure 16. Wallops Flight Facility Main Entrance (Source: Google Maps)

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3.3.11 SIGNAGE

Signage design should balance two critical needs: (1) to provide information to persons on the grounds, and more importantly to police, fire, or ambulance responders, and (2) to not provide so much information that they can aid intruders in their actions. Signs for public use should only detail areas the public is allowed to access, and not mission-critical or high-risk areas where the most damage can be achieved. The design approach to signage at the site should consider three types of signs: (1) Building-identifying; (2) Wayfinding; and (3) Regulatory/warning. Warning signs are of particular importance at a spaceport, which contains ample opportunity for someone to accidentally cause harm to themselves or others, particularly if they do not know their way around. This is not merely a security issue, but speaks directly to safety and liability as well.

3.3.12 CRIME PREVENTION THROUGH ENVIRONMENTAL DESIGN (CPTED)

In evaluating the landscape in terms of security, there are two main concerns to address. The first is whether any landscape feature would enable unauthorized entry into the property. This primarily addresses large trees or bushes that are adjacent to the perimeter fence, on either side, that facilitates access to the property. The second issue is whether the landscape provides screening or hiding areas for intruders. The type and placement of landscaping is also affected by the addition of proposed security devices. Security cameras need clear views of the perimeter fence around secure facility areas, unobstructed by large shrubs or trees. Sensing devices (i.e., video analytics) on perimeter fencing need clear space adjacent to the fence to avoid constant alarms caused by moving branches or tree limbs. The tree line along the outer most west perimeter fence and just beyond the clear zone will remain as a barrier to deter and delay a vehicle from breaching the fence line.

3.4 INITIAL PLAN – CAMERA LOCATIONS

The Spaceport Camden Access Control Plan has as its initial approach to install cameras as per Figure 17. Many camera technologies were evaluated including:

(b) (7)(F)

(b) (7)(F)

(b) (7)

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Tables 3 and 4 review these camera system possibilities. Figure 3 discusses the baseline plan and the augmented plan, as appropriate.

(b) (7)(F)

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(b) (7)(F)

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(b) (7)(F)

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Attachment 6

Explosive Site Plan

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Explosive Site Plan 14 January 2020

Prepared by: Kimley Horn

Denver, Colorado

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TABLE OF CONTENTS Acronyms & Abbreviations ............................................................................................................. 3

Section 1 – Introduction ................................................................................................................. 4

1.1 Description of Spaceport .................................................................................................. 4

1.2 Description of the Explosive Siting Regulations ............................................................... 4

Section 2 – Explosive Hazard Facilities ........................................................................................... 6

2.1 Introduction...................................................................................................................... 6

2.2 Vertical Launch Facility ..................................................................................................... 8

2.3 Mission Preparation Area ................................................................................................. 9

2.4 Launch Control Center Complex ...................................................................................... 9

Section 3 – Quantities of Propellants ........................................................................................... 10

3.1 Propellants Types at Spaceport...................................................................................... 10

3.2 Propellant Quantities at Explosive Hazard Facilities ...................................................... 11

3.3 Liquid Propellant Storage ............................................................................................... 13

3.4 HD 1.1 Storage ................................................................................................................ 13

3.5 HD 1.3 Storage ................................................................................................................ 13

3.6 Propellant Quantities at each Hazard Facility ................................................................ 13

3.7 Quantity Distance Calculations ...................................................................................... 13

Section 4 – Explosive Site Plan (Scaled Map) ................................................................................ 15

4.1 Explosive Site Plan Descriptions ..................................................................................... 15

4.2 Explosive Site Plans ........................................................................................................ 16

Revision History: 1/25/19 Initial Submittal. 01/14/20 Revisions include removal of medium-large launcher (only small launcher

remains) and additional minor edits. Changes agreed with FAA/AST between January – December 2019 also included.

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ACRONYMS & ABBREVIATIONS

CFR Code of Federal Regulations

DoD Department of Defense

DoDM Department of Defense Manual

ESP Explosive Site Plan

FAA Federal Aviation Administration

ft feet

FTS Flight Termination System

gal gallons

GSE Ground Support Equipment

HD Hazard Division

IBD Inhabited Building Distance

ILD Intraline Distance

lbs pounds

LOX Liquid Oxygen

MMH Monomethylhydrazine

NEW Net Equivalent Weight / Net Explosive Weight

NFPA National Fire Protection Association

NTO Nitrogen Tetroxide

OSHA Occupational Safety and Health Administration

PAD Public Area Distance

PTRD Public Traffic Route Distance

QD Quantity-Distance

RP-1 Rocket Propellant 1 (Kerosene)

TNT trinitrotoluene

UDMH Unsymmetrical Dimethyl Hydrazine

VIB Vehicle Integration Building

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SECTION 1 – INTRODUCTION

1.1 Description of Spaceport

The proposed spaceport is located in Camden County, Georgia. The property is approximately 11.5 miles due east of the town of Woodbine, Georgia. Access to the site is at the eastern termination of Union Carbide Road, an extension of Harriett’s Bluff Road (Exit 7 from I-95). The site is on the water, surrounded by salt marshes to the east and south, and the Satilla River to the north. Figure 1 shows a map of the spaceport location.

1.2 Description of the Explosive Siting Regulations

This Explosive Site Plan (ESP) addresses the explosive siting regulations outlined in 14 CFR § 420.63, § 420.65, § 420.66, § 420.67, § 420.69 and § 420.70. These regulations require that a launch site operator licensee develop an explosive site plan that includes the following key components:

• A scaled map showing the location of all explosive hazard facilities and a description of each activity to be conducted at the facilities (see Section 2)

• A list of the maximum quantity of propellants at each hazard facility (see Section 3) • A scaled map of the Explosive Site Plan (see Section 4)

The explosive site plan is required to ensure that appropriate separation distances are provided for handling co-located incompatible energetic liquids, co-located division 1.1 and 1.3 explosives, and the storage of energetic liquids and division 1.1 and 1.3 explosives. The following nomenclature is from the FAA regulations for determination of Hazard Facilities and separation distances. In some instances, Department of Defense (DoD) definitions are used to augment the description.

• Explosive Hazard Facility – A facility of location at a launch site where solid propellants, energetic liquids, or other explosives are stored or handled.

• Public Area – Any area outside a hazard area and is an area that is not in the possession, ownership or other control of a launch site operator or of a launch site customer who possesses, owns or otherwise controls that hazard area.

• Public Area Distance (PAD) – A minimum distance permitted between a public area and an explosive hazard facility. The DoD typically refers to this distance as an Inhabited Building Distance (IBD) and is the distance to be maintained between a potential explosive site and an inhabited building.

• Public Traffic Route Distance (PTRD) – The minimum distance permitted between a public highway or railroad line and an explosive hazard facility.

• Intraline Distance (ILD) – The minimum distance permitted between any two explosive hazard facilities in the ownership, possession, or control of one launch site customer.

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Figure 1. Spaceport Camden Location Map

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SECTION 2 – EXPLOSIVE HAZARD FACILITIES

2.1 Introduction

Spaceport Camden will have propellants storage and/or handling at the Explosive Hazard Facilities identified in Table 1 and Figure 2.

Table 1. List of Explosive Hazard Facilities

Explosive Hazard Facility Typical Operations Vertical Launch Facility

RP-1 Storage Area Storage and transfer of Kerosene (RP-1).

LOX Storage Area Storage and transfer of Liquid Oxygen (LOX).

Vehicle Integration Building Integration of launch vehicle and flight hardware components including flight ordnance and payload.

Launch Pad Vehicle propellant transfer (loading and offloading).

Mission Preparation Area

Mission Preparation Pad Storage and handling of flight hardware and ground support equipment, hazardous operations and testing.

Launch Control Center Complex

Payload Fuel Storage Area Storage and transfer of payload fuels.

Payload Oxidizer Storage Area Storage and transfer of payload oxidizers.

Payload Processing Facility Payload processing and propellant transfer (loading and unloading).

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Figure 2. Map of Explosive Hazard Facilities

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2.2 Vertical Launch Facility

The Vertical Launch Facility consists of various facilities and infrastructure to support the preparation and launch of a small class vertical launch vehicle. The Vertical Launch Facility is a secure facility that includes a vehicle integration building, offices, warehouse storage, commodity storage and distribution, lightning protection towers, flame deflection, launch vehicle erection, launch pad data/communications/lighting, and pad water systems. This facility is where the bulk of the propellants will be stored and handled. Propellant operations at the Vertical Launch Facility include propellant delivery, propellant storage, propellant transfer, launch vehicle propellant loading, cryogenic boil off venting and launch vehicle propellant offloading. The following explosive hazard facilities exist at the Vertical Launch Facility, 1) LOX Storage Area, 2) RP-1 Storage Area, 3) Vehicle Integration Building and 4) Launch Pad. 2.2.1. RP-1 Storage Area The RP-1 Storage Area contains Kerosene storage tanks, transfer connections, pumps, and control systems to transfer RP-1 to and from the pad for loading and offloading the launch vehicle. 2.2.2. LOX Storage Area The LOX Storage Area contains Liquid Oxygen (LOX) storage tanks, transfer connections, pumps, vents, and control systems to transfer LOX to and from the pad for loading and offloading the launch vehicle. 2.2.3. Vehicle Integration Building The Vehicle Integration Building (VIB) is where most launch vehicle integration and final checkout occurs. The activities include the following:

• Installation of flight ordnance o Stage separation o Flight Termination System (FTS)

• Integration of fueled payload • Loading and unloading of launch vehicle maneuvering propellants

2.2.4. Launch Pad The Launch Pad is where the launch vehicle is erected prior to final vehicle checkout and propellant loading. In the event that a mission is scrubbed, the primary liquid propellants on the launch vehicle will be offloaded, filtered, and returned to the storage tanks.

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2.3 Mission Preparation Area

The Mission Preparation Area consists of a 400 ft x 400 ft concrete pad that may support the following activities:

• Storage and handling of flight hardware and Ground Support Equipment (GSE) • Hazardous payload propellant handling operations • Ground-based testing of flight hardware or systems

Mission Preparation Pad Propellants, such as MMH, UDMH, and NTO, may be loaded onto the payload at the Mission Preparation Pad prior to transport to the VIB for final integration with the launch vehicle. Other hazardous testing may occur at the site and utilize LOX and RP-1.

2.4 Launch Control Center Complex

The Launch Control Center Complex includes facilities to support payload processing and propellant storage and transfer. The following explosive hazard facilities exist at the Launch Control Center Complex, 1) Payload Fuel Storage Area and 2) Payload Oxidizer Storage Area, and 3) Payload Processing Facility. 2.4.1. Payload Fuel Storage Area The Payload Fuel Storage Area provides an area for the storage of the payload fuels such as Monomethylhydrazine (MMH) and Unsymmetrical Dimethyl Hydrazine (UDMH). 2.4.2. Payload Oxidizer Storage Area The Payload Oxidizer Storage Area provides a storage area of the payload oxidizer storage such as Nitrogen Tetroxide (NTO). 2.4.3. Payload Processing Facility The Payload Process Facility is where the majority of the payload processing occurs. While most of the processing operations are nonhazardous, the loading of the propellants onto the payload is considered a hazardous operation. Propellants, such as NTO, may be loaded onto the payload and stored on the payload within the facility prior to transport to the other locations. Payload fuel (hydrazine) loading will occur elsewhere (e.g. at the Mission Preparation Area or Launch Pad Complex).

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SECTION 3 – QUANTITIES OF PROPELLANTS

3.1 Propellants Types at Spaceport

A variety of liquid propellants are considered for use and storage at the spaceport (see Table 2). This list includes fuels and oxidizers that are cryogenic, hypergolic, or hydrocarbon based.

Table 2. Liquid Propellants Considered at Spaceport Camden

In addition to standalone propellants, there are combinations and other explosives that are also stored and used at the spaceport (see Table 3). When rocket propellants (fuel and oxidizer) are combined, they can react similar to a Hazard Division 1.1 (HD 1.1) high explosive such as TNT. The Net Equivalent Weight (NEW) of HD 1.1 for the combined propellant is typically determined based on a percentage of the total propellant mass.

(b) (7)(F)

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Table 3. Propellant Combinations and Other Explosives

3.2 Propellant Quantities at Explosive Hazard Facilities

Table 4 lists the maximum quantities of propellants and other explosives expected to be stored or utilized at each Explosive Hazard Facility. Table 5 includes their associated separation distances, and the maximum allowable quantities for those distances.

(b) (7)(F)

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(b) (7)(F)

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3.3 Liquid Propellant Storage

Liquid propellants are stored at both the Vertical Launch Facility and the Launch Control Center Complex. In some instances, mobile propellant vehicles may be used to prevent boil off of large storage tanks’ chill down processes.

3.4 HD 1.1 Storage

3.5 HD 1.3 Storage

3.6 Propellant Quantities at each Hazard Facility

Table 4 lists the quantities of propellants at each of the hazard facilities.

3.7 Quantity Distance Calculations

The Quantity Distance (QD) calculations provided in this explosive site plan are based on guidance provided in 14 CFR Part 420 Appendix E and DoD Ammunition and Explosive Safety Standards (DoDM 6055.09). The separation distances displayed in the explosive site plan figures are measured from the closest hazard source and along straight lines, in accordance with 14 CFR §420.70. For each hazard facility and its associated propellants/explosives, a QD is calculated based on the anticipated maximum quantity of propellants located at the facility. The separation distances are only in affect when propellants/explosives are stored or handled at the facility. During times when no propellants/explosives are present the QD values do not apply.

(b) (7)(F)

(b) (7)(F)

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For each hazard facility, the Public Area Distance (PAD), Public Traffic Route Distance (PTRD), and Intraline Distance (ILD) are calculated and shown in Table 5. It should be noted that DoDM 6055.09 was utilized when determining the structure/protected/barricaded QD distances for the FTS stored within the VIB and the MMH/UDMH stored at the Payload Fuel Storage Area. DoDM 6055.09 provides an equivalent level of safety as the explosive siting regulations in 14 CFR Part 420 and is therefore in compliance with 14 CFR §420.63(d).

Table 5 QD for Hazard Facilities (b) (7)(F)

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SECTION 4 – EXPLOSIVE SITE PLAN (SCALED MAP)

4.1 Explosive Site Plan Descriptions

4.1.1. Vertical Launch Facility

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(b) (7)(F)

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4.1.3. Launch Control Center Complex

4.2 Explosive Site Plans

It should be noted that the PADs for all explosive hazard facilities are within the proposed overall property boundary. In instances where the PADs extend into the waterways adjacent to the explosive hazard facilities, the waterways will be controlled in accordance with the Control of Public Access Plan.

(b) (7)(F)

(b) (7)(F)

(b) (7)(F)

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Attachment 7

Accident Investigation Plan

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TABLE OF CONTENTS

1 GENERAL ..................................................................................................................................................... 3

1.1 Launch Site Accident Investigation Plan ............................................................................................. 3

1.2 Definitions........................................................................................................................................... 3

2 REPORTING REQUIREMENTS ...................................................................................................................... 4

2.1 Reports ............................................................................................................................................... 4

3 RESPONSE PLAN .......................................................................................................................................... 5

3.1 Responsibilities ................................................................................................................................... 5

3.2 Contain and Minimize Consequences of the Accident ....................................................................... 6

3.3 Investigation Leader / Preserve Data and Physical Evidence ............................................................. 7

3.4 Reporting and Cooperation ................................................................................................................ 8

3.5 Preventive Measures to Avoid Recurrence of Accident ..................................................................... 9

4 INVESTIGATION PLAN ................................................................................................................................. 9

4.1 Preliminary Investigation .................................................................................................................... 9

4.2 Completion of Investigation ............................................................................................................. 10

4.3 Responsibilities of AIB Participants & Witnesses ............................................................................. 11

APPENDIX A – MISHAP NOTIFICATION FORM – 2 PAGES ................................................................................. 12

APPENDIX B – KEY PERSONNEL CHECK LISTS .................................................................................................... 14

B.1 Range Director or Designee Check List ............................................................................................. 14

B.2 Launch Director Check List ............................................................................................................... 14

B.3 Incident Commander Check List ....................................................................................................... 15

B.4 Range Operations Check List ............................................................................................................ 15

B.5 Investigation Leader Check List ........................................................................................................ 16

B.6 Evidence Custodian Check List ......................................................................................................... 16

Revision History: 1/25/19 Initial Submittal. 01/14/20 Revisions include a clarification agreed with FAA/AST regarding the reference to

Attachment 8 (Camden County Emergency Operations Plan Chapter 22 Excerpt) to the Spaceport Camden LSOL application and minor editorial updates.

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1 GENERAL

1.1 Launch Site Accident Investigation Plan

The Launch Site Operator License (LSOL) for Spaceport Camden requires a Federal Aviation Administration (FAA) approved launch site accident investigation plan (AIP) to be in place before the license is issued. Within 14 CFR § 420.59 it states, “A licensee shall develop and implement a launch site accident investigation plan that contains the licensee's procedures for reporting, responding to, and investigating launch site accidents, as defined by § 420.5, and for cooperating with federal officials in case of a launch accident.”

Camden County has in place an overall county-wide Emergency Operations Plan that includes the requirements for accident and incident investigations and response procedures in Chapter 22 (found as Attachment 8 to the Spaceport Camden LSOL application). This AIP for spaceport launch operations is intended to fall within the overall scope and authority of the county-wide approved plans and procedures.

Within 14 CFR § 420.59(e) it states that the launch site accident investigation plans shall also address launch accidents, i.e., accidents that occur after liftoff. If such an accident occurs, all procedures in this launch site accident investigation plan that are applicable to the launch accident will be applied. Also, Spaceport Camden will cooperate with the FAA or National Transportation Safety Board (NTSB) investigations of a launch accident for launches launched from a launch site at Spaceport Camden. Therefore, the procedures in this document will apply to both launch site accidents and launch accidents.

Also, within 14 CFR § 420.59 it also states that “The launch site accident investigation plan must be signed by an individual authorized to sign and certify the application in accordance with §413.7(c) of this chapter.” This document is signed and certified by Jimmy Starline, Chairman of the Camden County Board of Commissioners, who is authorized to sign for Spaceport Camden.

1.2 Definitions

Within 14 CFR § 420.5 it defines a launch site accident as follows:

Launch site accident means an unplanned event occurring during a ground activity at a launch site resulting in a fatality or serious injury (as defined in 49 CFR 830.2) to any person who is not associated with the activity, or any damage estimated to exceed $25,000 to property not associated with the activity.

Also, 14 CFR § 401.5 defines a launch accident as follows:

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Launch accident means:

(1) An event that causes a fatality or serious injury (as defined in 49 CFR 830.2) to any person who is not associated with the flight;

(2) An event that causes damage estimated to exceed $25,000 to property not associated with the flight that is not located at the launch site or designated recovery area;

(3) An unplanned event occurring during the flight of a launch vehicle resulting in the impact

of a launch vehicle, its payload or any component thereof:

(i) For an expendable launch vehicle, outside designated impact limit lines; and

(ii) For a reusable launch vehicle, outside a designated landing site.

(4) For a launch that takes place with a person on board, a fatality or serious injury to a space flight participant or crew member.

Within 49 CFR § 830.2 it defines fatality and serious injury as follows:

Fatal injury means any injury which results in death within 30 days of the accident.

Serious injury means any injury which: (1) Requires hospitalization for more than 48 hours, commencing within 7 days from the date of the injury was received; (2) results in a fracture of any bone (except simple fractures of fingers, toes, or nose); (3) causes severe hemorrhages, nerve, muscle, or tendon damage; (4) involves any internal organ; or (5) involves second- or third-degree burns, or any burns affecting more than 5 percent of the body surface.

Hazardous Materials are defined by OSHA as chemicals present in the workplace which are capable of causing harm. Tables of hazardous materials as defined by OSHA are provided in 49 CFR 172.101 which lists these materials alphabetically with information on hazard class or division, identification and labels, packaging, quantity limitations, and storage requirements

2 REPORTING REQUIREMENTS

2.1 Reports

The following reporting requirements as specified in 14 CFR § 420.59 will be followed:

• In the event of a launch site accident, the Federal Aviation Administration (FAA) Washington Operations Center (Phone +1-202-267-3333) will be notified immediately of the accident by the Range Director or their designee. A “Mishap Notification Form” (see Appendix A to this AIP for an example) will be prepared and submitted.

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• Launch Director: Has the primary responsibility for directing and managing all launch

vehicle related activities. This person has go/no go authority for the launch vehicle only.

• Range Operations: Has the primary responsibility for directing and managing all range operations related activities. This person has go/no go authority for range systems only.

• Incident Commander: Has primary emergency operations, evacuation, and recovery

responsibilities. Also is responsible for emergency communications and notifications.

• Investigation Leader: Has primary responsibility for the investigation of the accident, producing the initial and final accident reports, coordinating with FAA and NTSB incident / accident investigation personnel, Leads the investigation team, leads the Accident investigation board (AIB) and assigns the Evidence Custodian.

• Evidence Custodian: Responsible for all evidence.

3.2 Contain and Minimize Consequences of the Accident

The Incident Commander will coordinate immediately to respond to the accident and be responsible for execution of the procedures below and in accordance with the unique launch aspects captured within the Comprehensive Launch Plan (CLP) for the specific launch. The CLP will define all of the anticipated assets and personnel needed for an accident of the specific launch vehicle being launched. For example, fire suppression, hazardous materials, and emergency medical response teams will stand by at a safe location within the larger launch site or elsewhere as deemed appropriate. Pursuant to the CLP, launches and certain other types of hazardous operations (e.g., static engine firings) will require the presence of emergency response teams. These teams will respond to downrange accidents as appropriate pursuant to the CLP. On-site teams will be supplemented by nearby municipal and county service providers if they have insufficient capacity to deal with an accident that is beyond the scope anticipated during the CLP development process.

The following actions will occur, as appropriate, upon an accident occurring:

(1) The Range Director, Range Operations and Launch Director will immediately ascertain to the extent possible the nature of the accident and coordinate with the Incident Commander.

(2) Depending on the type of accident, the Incident Commander will direct personnel on site to be evacuated immediately to a safe distance to avoid further exposure to possible explosive events or release of hazardous materials.

(3) The Incident Commander will, if the accident has caused personal injuries, or has the potential to cause injuries, to direct trained emergency medical personnel and equipment to be moved from their standby locations to the launch site or elsewhere as appropriate. These trained personnel, in

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consultation with the Incident Commander, will determine the action to treat injuries and move injured persons to a medical facility. If injured persons are moved, their exact locations before and after the accident will be recorded as evidence.

(4) If the accident has caused a fire, or has the potential to cause a fire, the Incident Commander will direct trained fire suppression personnel and equipment to be moved from their standby locations to the launch site or elsewhere, as appropriate. These trained personnel, in consultation with the Incident Commander (as appropriate), will determine the action to be taken to suppress the fire or prevent a fire from occurring.

(5) Toxic materials released during an accident would typically come from the payload, smaller thruster engine fuel pods on the vehicle, or result from secondary emissions, e.g. toxic gases resulting from combustion of composite materials that make up parts of the launch vehicle. If the accident has caused release of hazardous materials, or has the potential to cause release of hazardous materials, trained HazMat personnel and equipment will be moved to the launch site or elsewhere as appropriate. These trained personnel, in consultation with the two lead personnel, will determine the action to be taken to protect persons from actual or potential hazardous materials. This would include measures to contain hazardous materials that are being released or have the potential to be released.

(6) Once all non-essential persons have been evacuated from the accident site and the site has been made safe, the area containing the accident will be cordoned off with clearly marked tape and/or barriers to prevent access prior to the investigation of the accident.

(7) A security guard or responsible person will be stationed at the site to prevent access to the accident area.

(8) Security measures will be taken to prevent the public from entering the general launch site area; such measures would include posting a guard and/or conducting surveillance of the area within 1,250 feet of the launch site.

(9) Launch site activities, other than those required for the response plan and accident investigation, will not be permitted until the final accident report is finished (see Section 4.2) and preventive measures and corrective actions to avoid recurrence of the accident are implemented.

3.3 Investigation Leader / Preserve Data and Physical Evidence

Spaceport Camden will designate an individual to lead and complete the investigation of the launch site accident. This individual, the Investigation Leader, will work with the personnel defined in Section 3.1. It may be that the Investigation Leader is the same person as the Range or Launch Director. These persons are designated as the Investigation Team. The Investigation Team will work with the concerned parties including launch operator personnel to execute the procedures in this section. The Investigation Leader may be augmented by trained investigative personnel from the Camden County Sheriff’s Office, Camden Emergency Management and/or the Camden County Safety Officer. The Investigation Leader will have final decision-making authority for all aspects of the investigation. The following activities will

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occur:

(1) Photographs and videos will be taken at the launch/accident site and any other location relevant to the accident to preserve a visual record of the scene after the accident.

(2) The Investigation Team will be responsible for verifying that potential evidence is not removed from the area or tampered with prior to the investigation. If materials are moved to a secure location, the Investigation Team will observe the move to verify the chain of custody. A chain-of-custody form will be used to list the items moved and be signed by the Investigation Leader.

(3) All data, physical evidence, and other materials at the launch site relevant to the launch site accident will be preserved for the investigation. This may be accomplished by preventing access to the launch site or moving the materials to a secure location. The data and materials to be preserved may include computers, digital storage devices, hardcopies, cameras, handwritten notes, Material Safety Data Sheets (MSDSs), and other items deemed relevant by the Investigation Team. Physical evidence to be preserved may include buildings, launch vehicle components, explosive storage containers, generators, vehicles, and other items deemed relevant by the Investigation Team.

(4) If persons were injured, the record of their locations before and after the accident (recorded immediately after the accident) will be considered evidence and stored in a secure location.

3.4 Reporting and Cooperation

The Spaceport Camden Range Director defined in Section 3.1 will perform the following:

(1) Notify the FAA Washington Operations Center immediately of the accident and cooperate with the FAA in whatever actions they require to investigate the accident.

(2) If requested by the FAA Washington Operations Center, notify the NTSB within the specified time period after the accident and cooperate with their investigations of the accident. (3) Designate the Range Director as the initial point of contact for the FAA and, if required, the NTSB.

Once appointed, the Investigation Leader becomes the primary point of contact with Federal investigative bodies. When that happens, the FAA and NTSB (if required) will be notified of this additional point of contact.

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3.5 Preventive Measures to Avoid Recurrence of Accident

The Accident Investigation Board (AIB) is responsible for implementing corrective measures to avoid the recurrence of incidents and accidents. Membership in the AIB is discussed in Section 4. The following will be performed:

(1) The AIB investigation will identify preventive measures and corrective actions (see next section) to avoid recurrence of the accident. The AIB will approve those measures and actions it deems sufficient to prevent a similar accident. These measures and actions will be incorporated into the Spaceport Camden and launch operator procedure and safety documents where appropriate and become standards of policies and/or procedures to be followed in the future. The AIB may consult with employees of the Spaceport Camden, the launch operator, other launch operators at Spaceport Camden, and/or outside experts in formulating its list of preventive measures and corrective actions.

(2) The approved preventive measures and corrective actions will be reviewed with all affected personnel, whose job tasks are relevant to the accident findings, including contract employees.

4 INVESTIGATION PLAN

The Accident Investigation Board (AIB) is responsible for implementing these procedures. The members of the AIB will include the Investigation Team and at least two other persons with appropriate knowledge and experience to thoroughly investigate and analyze the accident. The other board members will be selected cooperatively by the Investigation Team. The Investigation Leader will lead the AIB.

4.1 Preliminary Investigation The following preliminary investigation activities will be performed, as appropriate:

(1) The AIB will convene as soon as the accident site is safe and evidence has been preserved. This should occur promptly, but not later than 48 hours following the accident, as possible.

(2) The AIB will conduct recorded interviews with witnesses with knowledge of the accident to preserve as evidence their observations before, during, and after the accident.

(3) The AIB will analyze all available evidence to form a preliminary conclusion as to the cause of the accident. Evidence will include all of the types discussed in Section 3.3 to include data, physical evidence, written materials, witness reports, photographs, videos, and any other type of evidence that the AIB deems as relevant. Personnel with direct knowledge of certain evidence, or with appropriate knowledge and experience of certain types of evidence, will be asked to provide analyses and conclusions based on the evidence to the AIB.

(4) Based on the preliminary conclusion as to the cause of the accident, the AIB will prepare and submit a written preliminary report to the FAA-AST. This report will be submitted within five days of

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the accident and will contain the information listed in Section 2.1.

4.2 Completion of Investigation To complete the investigation, the following activities will occur, as appropriate:

(1) After the preliminary investigation, the AIB will continue to interview witnesses and analyze evidence (as described above). These investigations will continue until the AIB reaches a firm conclusion as to the cause of the accident or determines that a firm conclusion is not possible and that continued investigations are not practicable. The cause of the accident may be a single event, or multiple events whose combination resulted in the accident. If a firm conclusion is not reached, the most likely event(s) that caused the accident will be identified.

(2) The AIB investigation will identify to the extent possible the preventive measures and corrective actions necessary to avoid recurrence of the accident. These measures and actions will be included in the final report. They will also be incorporated in safety documents and reviewed with affected personnel, as described in Section 3.5.

(3) The AIB will amend the preliminary report to prepare a final written report. This report will contain the information listed in Section 2.1 as well as a summary of the evidence, the conclusions as to the cause(s) of the accident, and the preventive measures and corrective actions necessary to avoid recurrence of the accident. It may also contain dissenting opinions. The report will be signed by the AIB members.

(4) The final accident investigation report will be submitted by the Investigation Leader to the FAA-AST and the NSTB (if required) promptly once it is completed.

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4.3 Responsibilities of AIB Participants & Witnesses

The responsibilities of personnel participating in the accident investigation are as follows:

Investigation Leader: This person has overall responsibility for preserving the accident site, conducting the investigation, leading the AIB, preparing the preliminary and final accident reports, and submitting the reports to the FAA and NSTB (if required). The Investigation Leader may also retain outside persons to assist in conducting and participating in the investigation. The Investigation Leader will be designated by Spaceport Camden and have final decision-making authority in all matters of the investigation.

Range Director and Launch Director: These two personnel are the lead individuals representing the Spaceport Camden and the launch operator. These positions are defined in Section 3.1. These two personnel will initially be responsible for containing and minimizing the consequences of the accident (Section 3.2) if the Incident Commander is not in place and standing by at the time of the accident. They will also be members of the Investigation Team. Prior to the designation of the Investigation Leader, the lead person representing Spaceport Camden (Range Director) will have final decision-making authority.

Investigation Team: This team consists of the Investigation Leader and the personnel defined in 3.1. It may be that the Investigation Leader is the same person as the Range Director or Launch Director, in which case the Investigation Team would have less members. This team is responsible for preserving the accident site, conducting the investigation, preparing the preliminary and final accident reports, and submitting the reports to the FAA and NSTB (if required). The Investigation Leader will have final decision-making authority.

Accident Investigation Board (AIB): The members of the AIB will include the Investigation Team and at least two other persons with appropriate knowledge and experience to thoroughly investigate and analyze the accident. The AIB will convene within 48 hours of the accident, as possible. The AIB is responsible for carrying out the investigation plan defined in section 4. The Investigation Leader will lead the AIB.

Witnesses: Witnesses to the accident may be Spaceport Camden, launch operator, and contractor personnel; they may also be visitors and other members of the public if they have substantive information related to the accident. They are responsible for providing the AIB with accurate and complete information on what they witnessed that is relevant to the accident. Public communication prior to and after launch will be augmented by the County Emergency Operations Plan “Mass Notification System.” The Mass Notification System would directly support investigative efforts by allowing for defined geographical based communications that would be used to reach all personnel within the affected area in support of information gathering from witnesses.

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APPENDIX A – MISHAP NOTIFICATION FORM – 2 PAGES

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APPENDIX B – KEY PERSONNEL CHECK LISTS

B.1 Range Director or Designee Check List

a. Notify the FAA Washington Operations Center per Section 2 and Appendix A. b. Designate / authorize the Investigation Leader. c. Inform FAA and as appropriate NTSB, of Investigation Leader appointment and contacts d. Provide periodic updates to FAA on the status of the investigation. e. If not leading the Investigation Team, contribute as a member. f. Submit final Accident Investigation Report to FAA upon completion. g. Lead appropriate actions to implement corrective action / lessons learned from accident.

B.2 Launch Director Check List

a. Immediately inform and require all launch and payload system leads and personnel to lock down and preserve all data from systems for the Investigation Team.

b. Determine if any range operations team members are injured. Inform the Incident Commander of their location and status if known.

c. Assess the accident from known data streams and knowledge of the launch vehicle and payload of the accident location, debris patterns based on status of the vehicle at time of accident and weather conditions, potential toxins, fire hazard, or emissions.

d. Inform the Incident Commander of the launch team’s assessment to determine appropriate immediate response, as information becomes known in the immediate aftermath of the accident, and as appropriate later.

e. Commence initial launch operator assessment of accident cause(s). f. Participate as a member of the Investigative Team. g. Participate as a member of the AIB. h. Support clean up/recovery operations. As appropriate, lead these efforts. i. Support Evidence Custodian to ensure data and physical evidence is preserved and turned

over to the Evidence Coordinator.

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B.3 Incident Commander Check List

a. Ensure personnel and/or others impacted by the accident are evacuated from the accident site to the appropriate recovery / treatment location pursuant to advanced planning contained in the Comprehensive Launch Plan (CLP) document for the launch or operation. Ensure personnel are interviewed by the Investigation Leader or designee.

b. Coordinate with the Range and Launch Directors to determine extent of emergency and the need for various hazard response teams (e.g., fire, toxics, medical, forestry, and/or waterborne vessel response teams) and direct those assets on standby to the appropriate location.

c. Determine the need for Spaceport Camden personnel, tenants, visitors, the public, regional officials, and other stakeholders for information notification and act upon those determinations. As necessary activate the Mass Notification System operated by the Camden County Emergency Operations Center.

d. Participate as a member of the Investigation Team. e. Participate as a member of the AIB. f. Support clean up/recovery operations. As appropriate, lead efforts. g. Support Evidence Custodian to ensure data and physical evidence is preserved and turned

over to the Evidence Coordinator.

B.4 Range Operations Check List

a. Immediately inform and require all range operations system leads and personnel to lock down and preserve all data from systems for the Investigation Team.

b. Determine if any range operations team members are injured. Inform the Incident Commander of their location and status if known.

c. Assess the accident from known data streams and knowledge of the launch vehicle and payload tracking systems, potential debris patterns based on status of the vehicle at time of accident and weather conditions.

d. Inform the Incident Commander of the range operations team’s assessment to determine appropriate immediate response, as information becomes known in the immediate aftermath of the accident, and as appropriate later.

e. Commence initial range operator assessment of accident cause(s). f. Participate as a member of the Investigative Team. g. Participate as a member of the AIB. h. Support clean up/recovery operations. i. Support Evidence Custodian to ensure data and physical evidence is preserved and turned

over to the Evidence Coordinator.

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B.5 Investigation Leader Check List

a. Lead the Accident Investigation Team that consists of the Investigation Leader, Incident Commander, Range Operations, Range Director, Launch Director and the Evidence Custodian.

b. Designate an appropriate member of the Camden County staff to perform the duties of the Evidence Custodian.

c. Conduct initial interviews of witnesses and collect witness data. d. Designate additional roles as needed. e. Establish role as primary point of contact for FAA and, if required, the NTSB. f. Initiate or delegate collecting interview statements from staff involved in the accident or

evacuated from the accident site. g. Initiate or delegate collecting the locations of injured persons and secure the data with the

Evidence Custodian. h. Provide all interview data to Evidence Custodian. i. Provide periodic updates on the status of the investigation to the Range Director to share

with FAA, and the Camden County Administrator and Board of Commissioners to keep them informed.

j. Lead and schedule all meetings for the AIB. k. Submit preliminary written report prepared by the AIB within five days of the accident to

FAA.

B.6 Evidence Custodian Check List

a. Collect photographs and videos of the launch/accident site and any other locations relevant to the accident. The location (coordinates) should be recorded when taking photos and video.

b. Document and secure evidence as required. c. Verify that potential evidence is not removed from the secure area or tampered with. d. Develop a chain of custody form to be used if evidence is moved. e. In the event of adverse weather, protect weather sensitive debris from the effects of

weather. f. If persons were injured, the record of their locations before and after the accident

(recorded immediately after the accident) will be considered evidence and stored in a secure location.

g. In accordance with 420.61(a) collect all records, data, and other materials needed to verify that the operations were conducted in accordance with representations contain in the license application.

h. Retain all records for a minimum of 3 years.

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Attachment 8

Camden County Emergency Operations Plan

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Office of the County Clerk P.O. Box 99/200 East 4th Street Woodbine, GA 31569

Phone: (912) 576.5601 Fax: (912) 576.5647 www.camdencountyga.gov

“Award-Winning Government”

STEVE L. HOWARD JOHN S. MYERS County Administrator County Attorney

LANNIE BRANT CHUCK CLARK JIMMY STARLINE GARY BLOUNT BEN L. CASEY Commissioner, District 1 Commissioner, District 2 Commissioner, District 3 Commissioner, District 4 Commissioner, District 5

December 21, 2017

To whom it may concern:

I, Kathryn A. Bishop, County Clerk, Camden County Board of County Commissioners, hereby certify the

attached copy of the Official Code of Ordinances, Chapter 22, Civil Emergencies as amended and

approved in lawful assembly during the regularly scheduled Board of County Commissioners meeting

held on March 1, 2005.

Kathryn A. Bishop,

County Clerk

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Chapter 22

CIVIL EMERGENCIES

Article I. In GeneralSec. 22-1. Definitions.Secs. 22-2--22-35. Reserved.

Article II. Emergency ManagementSec. 22-36. Emergency management policy.Sec. 22-37. Definitions.Sec. 22-38. Enforcement.Sec. 22-39. Organization.Sec. 22-40. Emergency powers.Sec. 22-41. Regulations.Sec. 22-42. Penalty.Secs. 22-43--22-60. Reserved.

Article III. State of Emergency

Division 1. GenerallySec. 22-61. Definitions.Sec. 22-62. Overcharging prohibited.Sec. 22-63. Unlawful acts during emergencies.Secs. 22-64--22-80. Reserved.

Division 2. Suspension of Ordinances, FormalitiesSec. 22-81. Definitions.Sec. 22-82. Meetings.Sec. 22-83. Purchasing and public works contracts.Sec. 22-84. Code enforcement.Sec. 22-85. Fees.Sec. 22-86. Temporary dwellings.Secs. 22-87--22-100. Reserved.

Division 3. Registration of Building ContractorsSec. 22-101. Required.Sec. 22-102. Penalties.Sec. 22-103. Application.Sec. 22-104. Fees.Sec. 22-105. Transferability.Sec. 22-106. Display of registration certification.Sec. 22-107. Revocation, suspension.Secs. 22-108--22-120. Reserved.

Division 4. Curfew During Emergency or DisasterSec. 22-121. Definitions.Sec. 22-122. Institution.Sec. 22-123. Prohibition.

ARTICLE I.

IN GENERAL

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Sec. 22-1. Definitions.

The following words, terms and phrases, when used in this chapter, shall have the meanings ascribed to them in this section, except where the context clearly indicates a different meaning:

Emergency management means the preparation for the carrying out of all emergency functions, other than functions for which military forces are primarily responsible; to prevent, minimize and repair injury and damage resulting from emergencies, energy emergencies, disasters or their imminent threat, of manmade or natural origin caused by enemy attack, sabotage, civil disturbance, fire, flood, earthquake, wind, storm, wave action, oil spill or other water contamination requiring emergency action to avert danger or damage, epidemic, air contamination, blight, drought, infestation, explosion, riot or other hostile action, or other causes. These functions include, without limitation:

(1) Firefighting services;

(2) Police services;

(3) Medical and health services;

(4) Rescue;

(5) Engineering;

(6) Warning services;

(7) Communications;

(8) Defense from radiological, chemical and other special weapons;

(9) Evacuation of persons from stricken areas;

(10) Emergency welfare services;

(11) Emergency transportation;

(12) Plant protection;

(13) Temporary restoration of public utility services; and

(14) Other functions related to civilian protection;

together with all other activities necessary or incidental to the preparation for and carrying out of these functions.

Cross References: Definitions generally, § 1-2.

Secs. 22-2--22-35. Reserved.

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ARTICLE II.

EMERGENCY MANAGEMENT* __________ * Editors Note: Ord. No. 2005-4, adopted March 1, 2005, amended art. II in its entirety to read as herein set out. Former art. II,§§ 22-36--22-42, pertained to emergency management agency.__________

Sec. 22-36. Emergency management policy.

Because of the existing and increasing possibility of the occurrence of emergencies or disasters resulting from man-made or natural causes; in order to ensure that preparations in Camden County (including the cities of Kingsland, Woodbine, and St. Marys, if adopted by the mayor and city councils of the cities of Kingsland, Woodbine, and St. Marys) will be adequate to deal with such emergencies or disasters; generally to protect the public peace, health and safety; and to preserve the lives and property of the people in Camden County, it is found and declared necessary:

(1) To create an emergency management agency for emergency management in Camden County.

(2) To confer upon the board of commissioners of Camden County and the chairman of the board ofcommissioners the emergency powers provided for in this article.

(3) To authorize the establishment of an emergency management agency and the taking of such stepsas are reasonable and necessary to implement the provisions of this article.

(Ord. of 3-1-2005(1))

Sec. 22-37. Definitions.

As used in this article, the terms:

Agency means the emergency management agency enacted by the board of commissioners of Camden County.

Emergency management means the preparation for the carrying out of all emergency functions to prevent, minimize and repair injury and damage resulting from emergencies, disasters or imminent threat thereof, of man-made or natural origin caused by civil disturbance, fire, flood, earthquake, wind, storm, wave action or similar physical conditions. These functions include without limitation, firefighting services, police services, medical and health services, rescue, engineering, warning services, communications, evacuation of persons from stricken areas, emergency welfare services, emergency transportation, plant protection, temporary restoration of public utility services and other functions related to civilian protection, together with all other activities necessary or incidental to the preparation for and carrying out of the foregoing functions.

State of emergency means the conditions declared by chairman of the commissioners when after conferring with the mayors of Kingsland, St. Marys and Woodbine, and in their judgment, the threat or actual occurrence of a disaster or emergency is sufficient severity and magnitude to warrant extra ordinary action to prevent or alleviate the loss of human life or damage to public or private property. (Ord. of 3-1-2005(1))

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Sec. 22-38. Enforcement.

The law enforcement authorities of the State of Georgia, the Camden County sheriff's department, and the Cities of Kingsland and St. Marys police department shall enforce the orders, rules and regulations issued pursuant to the terms and conditions of this article. During a declared state of emergency, the Camden County sheriff and the chiefs of police in Kingsland and St. Marys, Georgia shall have the authority and power to increase the number of and swear in additional police officers during the declared state of emergency. Such officers' tenure shall expire at the conclusion of the state of emergency. (Ord. of 3-1-2005(1))

Sec. 22-39. Organization.

(a) There is hereby established pursuant to the provisions of this article an agency which shall beknown as the Camden County Emergency Management Agency, hereinafter called the emergency management agency, with a director of emergency management who shall be the head thereof.

(b) The board of commissioners of Camden County shall nominate a director of emergencymanagement who shall be appointed in accordance with the provisions of O.C.G.A. § 38-3-27. The director shall be subject to the direction and control of the board of commissioners, through the county manager and shall be responsible for the carrying out of the programs for emergency management in Camden County. The county manager shall act as the acting director of emergency management in the event of the absence or disability of the director for any reason. The compensation of the director shall be fixed by the board of commissioners and the director shall hold the office at the pleasure of the board of commissioners.

(c) The director may employ such technical, clerical, stenographic and other personnel, may fix theircompensation and may make such expenditures with the appropriations therefor, or from other funds made available to him for the purpose of emergency management as may be necessary to carry out the purposes of this article.

(d) The director, subject to the direction and control of the board of commissioners, shall beresponsible for carrying out the programs for emergency management in Camden County. He shall coordinate the activities of all organizations called upon to assist in a state of emergency in Camden County, shall maintain liaison with and cooperate with the emergency management agency of the State of Georgia and that of the federal government.

(e) The sheriff, the police chiefs and fire chiefs shall be the disaster coordinators and shall act for thechairman of the board of commissioners when requested to do so by the chairman of the board of commissioners or the vice chairman in the chairman's absence. (Ord. of 3-1-2005(1))

Sec. 22-40. Emergency powers.

(a) Prior to declaring any state of emergency within the geographical boundaries of Camden County,the chairman of the board of commissioners after advice and council with the other members of the board, the mayor of Kingsland, the mayor of St. Marys and the mayor of Woodbine and with concurrence with the

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Georgia Emergency Management Agency shall be vested the sole authority to declare a state of emergency. (b) A declaration of a state of emergency or disaster shall activate the emergency and disaster response and recovery aspects of the local emergency operation plans applicable to Camden County and shall be the authority for the development and use of force to which the plans apply and for the use or distribution or any supplies, equipment and materials and facilities assembled, stockpiled or arranged to be made available pursuant to provisions of this article. (c) The chairman of the board of commissioners shall have and may exercise for such periods as the state of emergency or disaster exists or continues the following emergency powers: (1) Command or utilize any private property if he finds this necessary to cope with the emergency or

disaster; (2) Direct and compel the evacuation of all or a part of the population from any stricken or

threatened area within Camden County if he deems this action necessary for the preservation of life or other disaster mitigation or response;

(3) Prescribe routes, modes of transportation and destinations in connection with the evacuation; (4) Control ingress and egress to and from the disaster area and the occupancy of premises therein; (5) Suspend or limit the sale, dispensing or transportation of alcoholic beverages, firearms,

explosives or combustibles; (6) Make provision for the availability and use of temporary emergency housing; (7) Suspend any regulatory ordinance prescribing the procedure for conduct of county business, or

the orders, rules and regulations of any county agency, if strict compliance with any ordinance, order, rule, or regulation would in any way prevent, hinder or delay necessary action in coping with the emergency or disaster;

(8) Utilize all available resources of Camden County as may be reasonably necessary to cope with

the emergency or disaster; (9) To perform and exercise such other functions, powers and duties as may be necessary to promote

and secure the safety and protection of the public; (10) To ensure all laws, rules and regulations relating to emergency management and to assume direct

operational control of all civil forces and helpers in Camden County; and (11) To seize or take for temporary use, property for the protection of the public. (d) Any power or authority granted to the chairman of the board of commissioners by this article may be exercised by the vice chairman of the board of commissioners so long as the chairman of the board of commissioners is absent from Camden County or otherwise unable to perform the duties of the office of the

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chairman. If the chairman and vice chairman of the board of commissioners are both absent from Camden County or otherwise unable to perform the duties of the office of chairman, any power or authority granted to the chairman of the board of commissioners by this article may be exercised by the member of the board of commissioners designated by the chairman of the commission. The chairman, during the committee appointments, shall designate a line of authority setting forth the order of succession of the commissioners for exercising the powers and duties until either the chairman or vice chairman are able to exercise those powers and duties. (Ord. of 3-1-2005(1)) Sec. 22-41. Regulations. (a) The director of the agency is authorized and empowered to make orders, rules and regulations as may be necessary for emergency management purposes, provided such orders, rules and regulations are non-inconsistent with any orders, rules or regulations promulgated by the governor of the State of Georgia or by any state agency exercising power delegated to it by him. (b) All such orders, rules and regulations shall be approved by the board of commissioners prior to their effective date and copy, as approved, shall be filed with the clerk of the board of commissioners. (c) All such orders, rules and regulations promulgated by the board of commissioners shall have the full force and effect of law. (Ord. of 3-1-2005(1)) Sec. 22-42. Penalty.

Any person who violates any provision of this article or any rule, order or regulation made pursuant to this article shall be guilty of a misdemeanor. (Ord. of 3-1-2005(1)) Secs. 22-43--22-60. Reserved.

ARTICLE III.

STATE OF EMERGENCY

DIVISION 1.

GENERALLY

Sec. 22-61. Definitions.

The following words, terms and phrases, when used in this article, shall have the meanings ascribed to them in this section, except where the context clearly indicates a different meaning:

Building contractor means any person engaging in, undertaking or carrying on any business consisting

of or relating to building construction, repair, renovation or making improvements to real property including

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dwellings, homes, buildings, structures, or fixtures attached thereto. Doing business means any building contractor shall be deemed to be doing business subject to the

requirements of this article if:

(1) He has or operates an office, agency, project site or placeof business located in the unincorporated areas of thecounty, whether permanently, temporarily, periodically,or otherwise, that provides the following activities in theunincorporated areas of the county expressly including,but not limited to, the construction, renovation or repair, ofdwellings or buildings or the making of improvements toreal property or any fixtures attached thereto; or

(2) He performs the following activities or services in the unincorporated areas of the county

expressly including, but not limited to, the construction, renovation or repair of dwellings or buildings or the making of improvements to real property or any fixtures attached thereto regardless of the location of the principal office.

Overcharging means charging prices for goods, materials, services, or housing which are substantially in

excess of the customary charges or in applicable cases substantially in excess of the supplier's or provider's costs for such goods, materials, services or housing. The existence of overcharging shall be presumed from a substantial increase in the price at which the goods, materials, services, or housing was offered in the usual course of business immediately prior to the onset of the emergency, but shall not include increases in costs to the supplier directly attributable to higher costs of materials, supplies, and labor costs resulting from the emergency.

State of emergency, as defined by O.C.G.A. § 38-3-3(5), means a condition declared by the governor

when, in his judgment, the threat or actual occurrence of a disaster, emergency, or energy emergency is of sufficient severity and magnitude as to warrant extraordinary efforts in preventing or alleviating the damage, loss, hardship or suffering threatened or caused thereby.

Subsequent recovery period means the period of time that the disaster or emergency continues to cause

disruptions in the area by the disaster or emergency. The "subsequent recovery period" shall not exceed six months after the state of emergency declaration by the governor is terminated unless extended by official action of the board of commissioners. (Ord. of 7-20-1999(2), § 2; Ord. of 7-20-1999(3), § 2; Ord. of 7-20-1999(4), § 2; Ord. of 7-20-1999(5), § 2) Cross References: Definitions generally, § 1-2. Sec. 22-62. Overcharging prohibited.

In order to preserve, protect, or sustain the life, health, or safety of persons or their property, it shall be unlawful during the duration of a state of emergency, or subsequent recovery period in which the county has been designated as a disaster area, for any person located or doing business in the county to overcharge for any goods, materials, services or housing sold within the county. (Ord. of 7-20-1999(3), § 1) Sec. 22-63. Unlawful acts during emergencies.

It shall be unlawful for any person to commit any of the following acts during an emergency:

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(1) To wilfully obstruct, hinder or delay any member of theemergency management corps in the

enforcement of anylawful rule or regulation issued pursuant to this article or in the performance of any duty imposed by virtue of this article.

(2) To do any act forbidden by any lawful rules or regulations issued pursuant to this article if such

act is of such a nature as to give assistance to the enemy, imperil the life or property of any inhabitant of this county, or prevent, hinder or delay the defense or protection of this county.

(3) To wear or carry or display without authority any mark or identification specified by the

emergency management agency. Secs. 22-64--22-80. Reserved.

DIVISION 2.

SUSPENSION OF ORDINANCES, FORMALITIES

Sec. 22-81. Definitions.

The following words, terms and phrases, when used in this division, shall have the meanings ascribed to them in this section, except where the context clearly indicates a different meaning:

Fees means any fee or rate charged by the county for building permits, land disturbance permits, zoning

applications, special land use permits, temporary land use permits, and other fees relating to the reconstruction, repair and clean up of areas impacted by the disaster or emergency. "Fees" shall not include those fees collected by the county on behalf of the federal or state government or those fees charged by the county pursuant to a federal or state statute or regulation.

Temporary dwelling means any mobile or easily movable home, trailer, recreational vehicle or structure

not otherwise permitted by the zoning regulations in a particular zoning district. (Ord. of 7-20-1999(5), § 2) Cross References: Definitions generally, § 1-2. Sec. 22-82. Meetings.

Upon proclamation by the appropriate state official of an emergency or disaster of manmade or natural causes or enemy attack impending on or affecting the state or the United States, the affairs and business of the county may be conducted at places other than the regular or usual place thereof, within or outside of the county, when it is not prudent, expedient or possible to conduct business at the regular location. When such meetings occur outside of the county, all actions taken by the board of commissioners shall be as valid and binding as if performed within the county. Such meetings may be called by the presiding officer or any two members of the board of commissioners without regard to or compliance with time-consuming procedures and formalities otherwise required by law. (Ord. of 7-20-1999(5), § 1(1)) Sec. 22-83. Purchasing and public works contracts.

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Upon the declaration of a state of emergency by the governor, or upon the determination by the board of

commissioners, or its designee, of the existence of an emergency or disaster, the board of commissioners, its designee or the emergency interim successor may contract for public works without letting such contract out to the lowest, responsible bidder and without advertising and posting notification of such contract for four weeks; however, any public works contract entered into pursuant to this section shall be entered on the minutes of the county as soon as practical and the nature of the emergency described therein. (Ord. of 7-20-1999(5), § 1(2)) Sec. 22-84. Code enforcement.

Upon the declaration of a state of emergency by the governor, or upon the determination by the board of commissioners, or its designee, of the existence of an emergency or disaster, the board of commissioners, its designee or the emergency interim successor may temporarily suspend the enforcement of the Camden County Code, or any portion thereof, where:

(1) The emergency or disaster is of such nature that immediate action outside the Code is required; (2) Such suspension is consistent with the protection of the public health, safety and welfare; and (3) Such suspension is not inconsistent with any federal or state statutes or regulations. (Ord. of 7-20-1999(5), § 1(3)) Sec. 22-85. Fees.

Upon the declaration of a state of emergency by the governor, or upon the determination by the board of commissioners, or its designee, of the existence of an emergency or disaster, the board of commissioners, its designee or the emergency interim successor may temporarily reduce or suspend any permit fees, application fees or other rate structures as necessary to encourage the rebuilding of the area impacted by the disaster or emergency. (Ord. of 7-20-1999(5), § 1(4)) Sec. 22-86. Temporary dwellings.

Upon the declaration of a state of emergency by the governor, or upon the determination by the board of commissioners, or its designee, of the existence of an emergency or disaster, the board of commissioners, its designee or the emergency interim successor may issue temporary mobile home, trailer, recreational vehicle or other temporary dwelling structures or parks in any zoning district while the primary dwelling is being repaired provided that such temporary dwellings or parks are designed by an engineer and the plans are approved by the county health department and building and inspections department. The temporary permit shall not exceed six months in duration. In the case of continuing hardship and in the discretion of the board of commissioners or its designee, the permit may be extended for a period for an additional six months. Upon expiration of the temporary permit or an extension, the temporary dwelling shall be removed. (Ord. of 7-20-1999(5), § 1(5)) Secs. 22-87--22-100. Reserved.

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DIVISION 3.

REGISTRATION OF BUILDING CONTRACTORS

Sec. 22-101. Required.

No person shall engage in, undertake or carry on any business, in whole or in part, within the unincorporated areas of the county, consisting of or relating to building, constructing, repairing, renovating or making improvements to real property including dwellings, homes, buildings, structures, or fixtures attached thereto without having registered the name of the business with the board of commissioners and having paid fees as provided by the schedule of fees and charges on file in the office of the county clerk. (Ord. of 7-20-1999(4), § 1) Sec. 22-102. Penalties.

Any building contractor required by this division to pay a registration fee who engages in business without first registering and receiving a registration certification from the county as required shall be in violation of this division and punished as provided in section 1-19. Each day a building contractor does business in the unincorporated areas of the county without complying with this division shall constitute a separate offense. (Ord. of 7-20-1999(4), § 5) Sec. 22-103. Application.

All building contractors doing business or proposing to do business in the unincorporated areas of the county during a state of emergency or the subsequent recovery period shall register and file applications with the clerk of the board of commissioners or such other person designated by the board of commissionersat the county courthouse, or such other place designated by the county. The building contractor shall, under oath, provide the board of commissioners with a statement describing the general nature of the business to be conducted and give true and correct information as may be called for on the registration form, application or certificate provided by the county. (Ord. of 7-20-1999(4), § 3) Sec. 22-104. Fees.

Registration fees shall be as set forth in the schedule of fees and charges on file in the office of the county clerk and paid in full at the time of issuance of the registration certification. (Ord. of 7-20-1999(4), § 4) Sec. 22-105. Transferability.

Each certification issued under this division is granted to, and shall be accepted by, the building contractor under the condition that the same is not transferable and after issuance no such certification shall be transferred by the county or the building contractor to another individual or entity. (Ord. of 7-20-1999(4), § 6)

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Sec. 22-106. Display of registration certification.

Each certification issued under this division shall be postedconspicuously by the building contractor in the place of business of the building contractor or shall be carried on his person or vehicle used in such business. Such certification shall be exhibited to any authorized enforcement officer when so requested. (Ord. of 7-20-1999(4), § 7) Sec. 22-107. Revocation, suspension.

Each certification granted under this division is a mere permit to engage in the business only so long as such business is conducted in a lawful manner. The board of commissioners reserves the right to revoke or suspend any certification granted hereunder, if the building contractor, or the building contractor's agent or employee acting within the scope of his employment, violates this division or any other county, state or federal law. If after issuance of a certification, the county desires to revoke such certification, written notice shall be given to the building contractor, which notice shall specify the violation with which the building contractor is charged and a date, time and place at which a hearing shall be held with regard to the violation. The building contractor shall have an opportunity to be heard at such hearing, shall have the right to be represented by counsel and shall have the right to introduce and submit evidence in opposition to such revocation. (Ord. of 7-20-1999(4), § 8) Secs. 22-108--22-120. Reserved.

DIVISION 4.

CURFEW DURING EMERGENCY OR DISASTER

Sec. 22-121. Definitions.

The following words, terms and phrases, when used in this division, shall have the meanings ascribed to them in this section, except where the context clearly indicates a different meaning:

Curfew means a regulation requiring the withdrawal from any person not otherwise exempt from this

division from appearing in certain public areas during specified hours. Exempt individuals, unless otherwise specified in the resolution implementing the curfew, means those

individuals engaged in the provision of designated, essential services, such as fire, law enforcement, emergency medical services and hospital services, military services, utility emergency repairs. The resolution may, in the discretion of the board of commissioners, also exempt regular employees of local industries traveling to and from their jobs with appropriate identification, news media employees, building and repair contractors, properly registered according to division 3 of this article, performing activities related to construction, repair, renovation or improvement of buildings and other structures damaged during the disaster or emergency. (Ord. of 7-20-1999(2), § 2) Cross References: Definitions generally, § 1-2. Sec. 22-122. Institution.

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(a) Upon the declaration of a state of emergency by the governor, or upon the determination by the board of commissioners, or its designee, of the existence of an emergency or disaster, the board of commissioners, its designee or the emergency in-terim successor may adopt a resolution instituting a curfew when it is determined necessary to protect and safeguard the people and the property of the county. (b) All of the territory of the unincorporated county shall be subject to the terms of the curfew, unless otherwise specified in the resolution. (c) The resolution instituting the curfew shall include the dates and hours that the curfew shall be in effect. (Ord. of 7-20-1999(2), § 1) Sec. 22-123. Prohibition.

It shall be prohibited for any person, other than exempt individuals, to appear in public in the territory subject to the curfew including, not limited to, streets, highways, alleys, sidewalks, vacant lots, parks, public buildings or any other public places in all or a delineated part of the unincorporated county during the stated hours of the curfew. (Ord. of 7-20-1999(2), § 3)

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Spaceport Camden – Launch Site Operator License Application

14 January 2020 FOIA EXEMPT – PROPRIETARY DATA GORA EXEMPT – SECURITY INFORMATION

Attachment 9

Spaceport Camden Comprehensive Launch Plan (Example)

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SPACEPORT CAMDEN FINAL-V1.1 GEORGIA OPEN RECORDS ACT (GORA) SECURITY PLANNING DOCUMENT EXEMPT – NO PUBLIC RELEASE

COMPREHENSIVE LAUNCH PLAN (CLP) FINAL – V1.1 Page 4 of 12 GORA EXEMPT – NO PUBLIC RECORDS RELEASE Last Updated – 31 July 2017

COMPREHENSIVE LAUNCH PLAN (IAW ICS 201), Adapted CAMDEN EMA

1. Launch Customer / Launcher:VECTOR LAUNCH / B0.002

2. Launch Number (if applicable):SCC-2017-001

3. Estimated Date/Time:Date: 8/3/2017 Time: 0800 hrs local (TBD)

7. Current and Planned Objectives:

The objectives of this launch activity are several, and include, but are not limited to, the following:

1. VECTOR – Development and technical shakedown test of rocket, operations, and crew training.2. CAMDEN – Initial development and exercise of processes and procedures for working with launch operators,

local stakeholders, and other officials on a launch3. ALL - Protect the health and safety of the public and responders.4. CAMDEN - Ensure Site security is maintained from the air, land, and waterside to prevent unauthorized entry.5. ALL (AS APPROPRIATE) - Provide accurate information to news media and the public pre/post launch.6. ALL - Ensure fires or other hazards are eliminated.7. ALL - Ensure HAZMAT(s) are safely handled and removed prior to demobilization.

8. Current and Planned Actions, Strategies, and Tactics:Time: Actions:

SEE SECTION 9 FOR INDIVIDUAL ORGANIZATION’S PLANNED ACTIONS, ETC.

6. Prepared by: Name: Position/Title: Signature:

ICS 201, Page N/A Date/Time: Updated by FDA 2/2011

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SPACEPORT CAMDEN FINAL-V1.1 GEORGIA OPEN RECORDS ACT (GORA) SECURITY PLANNING DOCUMENT EXEMPT – NO PUBLIC RELEASE

COMPREHENSIVE LAUNCH PLAN (CLP) FINAL – V1.1 Page 5 of 12 GORA EXEMPT – NO PUBLIC RECORDS RELEASE Last Updated – 31 July 2017

COMPREHENSIVE LAUNCH PLAN (IAW ICS 201), Adapted for CAMDEN EMA

1. Launch Customer / Launcher: VECTOR LAUNCH / B0.002

2. Launch Number (if applicable): SCC-2017-001

3. Estimated Date/Time: Date: 8/3/2017 Time: 0800 hrs local (TBD)

9. Organizations 9.1 VECTOR LAUNCH SYSTEMS (Radio ID: VECTOR) 9.1.1 CONTACTS 9.1.1.1 Primary Point of Contact John Garvey, CTO, +1-562-234-1760, [email protected] (also, Mr. Garvey is the FAA Designated “Launch Control Officer” – LCO or his designee) 9.1.1.2 Other Contacts Alex Rodriguez, VP Gov / External Relations, +1-520-275-0519, [email protected]

George Regrutto, Onsite Logistics (starting Friday, 7/28), +1-520-444-0102 9.1.2 ROLE – Launch operator 9.1.3 RESPONSIBILITIES Vector Launch Systems (VLS) is the launch operator solely responsible for all aspects of safe handling (arrival, set up, clean up and removal), operating / launching (including fueling, defueling, launching, and any data collection, to name a few actions), and recovering the launch system under test, except as otherwise defined in this CLP that will be performed by other organizations. VLS is responsible for holding a Launch Readiness Review to include Camden County officials, between 48 and 24 hours prior to the proposed launch. VLS is fully responsible for their customers, other guests and personnel on the launch site and elsewhere. VLS is responsible for all interface with FAA and US Navy points of contact identified in the 27 June 2017 FAA Part 101 authorization, and its addendums, to launch the Vector-R experimental low altitude rocket in accordance with any and all requirements of the FAA or other government entities that regulate launch activities pursuant to the authorizations received. VLS is responsible for coordinating with Spaceport Camden POCs as defined in this CLP. VLS is responsible for executing an agreement with Camden County, and a site access agreement with the current owner of the property, Bayer Crop Science (BCS), with Camden County’s facilitation. VLS is responsible for all media and media relations pertaining to this launch activity. 9.1.4 PRIMARY RESOURCES AND PLACEMENT Placement of the following VECTOR equipment will be as per the map in Section 4. The primary resources from VECTOR include:

Launch Vehicle and Launch Support Equipment Communications Vehicle with Equipment Launch Control Center with Equipment Observers Station and Support Equipment

9.1.5 ACTIONS / CONTINGENCIES (a) Arrival / Set up / Check Out (b) Oversee Launch Readiness Review (c) Perform site and flight familiarization discussions with observers and visitors, as appropriate and available. (d) Launch and Recovery Operations, including all necessary VLS-specific communications IAW required FAA conditions of launch. (e) Media relations and guest relations. (f) Business operations, contracts, and related matters. (g) Complete operations, clean up, & depart.

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SPACEPORT CAMDEN FINAL-V1.1 GEORGIA OPEN RECORDS ACT (GORA) SECURITY PLANNING DOCUMENT EXEMPT – NO PUBLIC RELEASE

COMPREHENSIVE LAUNCH PLAN (CLP) FINAL – V1.1 Page 6 of 12 GORA EXEMPT – NO PUBLIC RECORDS RELEASE Last Updated – 31 July 2017

1. Launch Customer / Launcher:VECTOR LAUNCH / B0.002

2. Launch Number (if applicable):SCC-2017-001

3. Estimated Date/Time:Date: 8/3/2017 Time: 0800 hrs local (TBD)

9.2 CAMDEN COUNTY – COUNTY ADMINISTRATOR / SPACEPORT CAMDEN (Radio ID: SPACEPORT) 9.2.1 CONTACTS 9.2.1.1 Primary Point of Contact

Steve Howard, County Administrator, +1-912-552-3788, [email protected] Andrew Nelson, Spaceport Consultant, +1-617-899-8873, [email protected]

9.2.1.2 Other Contacts Charles White, Emergency Response, +1-912-510-5993, [email protected] William Brunson, Parks Administration, +1-912-552-2904 (c), [email protected]

9.2.2 ROLE – Launch site coordination

9.2.3 RESPONSIBILITIES Camden County’s Office of County Administrator is the primary focal point for the development and initial operation of Spaceport Camden County (SCC) on behalf of the Camden County Board of Commissioners. SCC is responsible for facilitating site access for all parties with the current owners of the properties that may be directly impacted by this activity (Bayer Crop Sciences (BCS) and Union Carbide Corporation (UCC)). SCC is responsible for facilitating the participation of other Camden County first responder units from the Camden County Sheriff’s Department, and the Camden County Fire and Rescue Department. SCC will facilitate communications with the local US Navy presence in Camden County, as appropriate and necessary. SCC is responsible for providing other assets and support as agreed from time to time with VLS. SCC is responsible for any of their guests, employees, and/or contractors, who shall be on site and supporting or observing the launch operation.

9.2.4 PRIMARY RESOURCES AND PLACEMENT

Camden County / Spaceport team members will provide the following resources: Two (2) county owned ATVs, fuels / consumables, maintenance & support, initially at Main Gate. Informational graphics, support equipment and staff at the Main Gate and Observation Area. Observation Area equipment, forms of shelter, hygienic facilities, and staff. Basic essentials given the time of year (e.g., water, sunscreen, bug spray, etc.) Other consumables, hardware, support equipment, etc., as agreed to leading up to the operation.

9.2.5 ACTIONS / CONTINGENCIES (a) Arrival / Set up / Check Out(b) Coordination between other Camden personnel / resources, Vector, and any other necessary entities (e.g., Navy,land owners, abutters, invited guests, etc.)(c) On site oversight of Camden and other visitors at Observation area.(d) Participation in Launch Readiness Review.(e) Ensure all equipment is in good working order, provide all consumables, fuel, and ensure personnel are equippedfor principal safety measures while on duty.(f) Clean up and removal of all items brought on to property.

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SPACEPORT CAMDEN FINAL-V1.1 GEORGIA OPEN RECORDS ACT (GORA) SECURITY PLANNING DOCUMENT EXEMPT – NO PUBLIC RELEASE

COMPREHENSIVE LAUNCH PLAN (CLP) FINAL – V1.1 Page 7 of 12 GORA EXEMPT – NO PUBLIC RECORDS RELEASE Last Updated – 31 July 2017

1. Launch Customer / Launcher:VECTOR LAUNCH / B0.002

2. Launch Number (if applicable):SCC-2017-001

3. Estimated Date/Time:Date: 8/3/2017 Time: 0800 hrs local (TBD)

9.3 CAMDEN COUNTY SHERIFF’S OFFICE (Radio ID: SHERIFF) 9.3.1 CONTACTS 9.3.1.1 Primary Point of Contact

Kevin Chaney, Captain, +1-912-552-4213, [email protected] 9.3.1.2 Other Contacts

Chris Sears, Lieutenant, +1-912-552-3714, [email protected] Chuck Byerly, Chief Deputy, +1-202-590-6760, [email protected]

9.3.2 ROLE – Site & Perimeter Monitoring and Security / Intervention

9.3.5 ACTIONS / CONTINGENCIES

(a) Arrival / Set up / Check Out(b) Participate in Launch Readiness Review(c) Ensure all equipment is in good working order, provide all consumables, fuel, and ensure personnel are equippedfor principal safety measures while on duty.(d) Perform monitoring / intervention duties on land and water as necessary, and report waterways “clear” or “not-clear”at time of launch.(e) Lead establishment of first responder communications network, coordinate with other necessary entities (fire,rescue, forestry, US Navy, Camden County / Spaceport).(f) Clean up and removal of all items brought on to property, and return watercraft to their original locations.

(b) (7)(F)

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1. Launch Customer / Launcher:VECTOR LAUNCH / B0.002

2. Launch Number (if applicable):SCC-2017-001

3. Estimated Date/Time:Date: 8/3/2017 Time: 0800 hrs local (TBD)

9.4 CAMDEN COUNTY FIRE & RESCUE w/ GEORGIA FORESTRY SUPPORT (Radio ID: FIRE) 9.4.1 CONTACTS 9.4.1.1 Primary Point of Contact

Mark Crews, Chief, +1-912-552-3810, [email protected] Frank Allen, Chief Ranger, +1-912-390-1150, [email protected]

9.4.1.2 Other Contacts Charles Lowther, Assistant Chief Mark Lain, Operations Captain Tina Ingles, Shift Supervisor / Battalion Captain

9.4.2 ROLE – Onsite Fire, Paramedic, and Forestry Support

9.4.3 RESPONSIBILITIES The Camden County Fire & Rescue Department, with Georgia Forestry (CAMDEN FIRE) will provide support for safety and intervention, should an accident, fire, or other incident occur. With Georgia Forestry support, CAMDEN FIRE will assist VECTOR in retrieving the launch vehicle should it fall into a heavily forested area, using the Georgia Forestry tractor plow. CAMDEN FIRE will also participate in coordination, facilitation and review meetings prior to and after the launch operation. CAMDEN FIRE will work with CAMDEN SHERIFF to ensure the first responder communications system is operating correctly from and on the launch site property. (This does not include the VECTOR launch operations communication system. As part of the development of this CLP it will be investigated if these two systems should or could be connected so all first responders could monitor launch operations communications in real time).

9.4.4 PRIMARY RESOURCES AND PLACEMENT

The primary resources will be placed as defined on the map in Section 4. These primary resources to be utilized by CAMDEN FIRE include the following:

1- Fire Engine with 2 firefighters1-Tanker-off Road capable, with 2 firefighters1- Advance Life Support ambulance with 1 Paramedic and 1 EMT1- Georgia Forestry tractor plow with operator1-Fire Incident Commander1-Military HUMVEE with a water tank, pump and hose line reel with 2 personnel assigned1-Georgia Forestry Support Truck

Should the need arise to Air-Evac a person, the Harrietts Bluff First Baptist Church is a predetermined landing zone for Camden County air ambulances out of Jacksonville.

9.4.5 ACTIONS / CONTINGENCIES (a) Arrival / Set up / Check Out(b) Participate in Launch Readiness Review(c) Ensure all equipment is in good working order, provide all consumables, fuel, and ensure personnel are equippedfor principal safety measures while on duty.(d) Perform fire, rescue, paramedic, and forestry related duties as necessary, and report “ready” or “not-ready” at timeof launch. Also, assist Vector, using the Forestry plow, with retrieval of rocket if it lands in trees.(e) Coordinate with Sheriff’s office on first responder communications network establishment and operation.(f) Clean up and removal of all items brought on to property.

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1. Launch Customer / Launcher:VECTOR LAUNCH / B0.002

2. Launch Number (if applicable):SCC-2017-001

3. Estimated Date/Time:Date: 8/3/2017 Time: 0800 hrs local (TBD)

9.5 OTHER ORGANIZATIONS

9.5.1 OFFICIAL NOTIFICATIONS PER FAA PART 101 WAIVER BY VECTOR LAUNCH

9.5.1.1 ONE TO THREE DAYS PRIOR TO LAUNCH

LEIDOS Flight Service Station, +1-877-487-6867, to issue NOTAM (Notice to Airmen)

9.5.1.2 ONE HOUR, AND 15 MINUTES PRIOR TO, & UPON TERIMINATION, OF LAUNCH

SUBASE KINGS BAY – ROBERT TIGHE, +1-912-573-9694 (o), +1-912-674-6822 (c) [email protected] Alternate Contact: On Duty Watch Commander +1-912-674-6831 (c) (no email avail for ODWC)

SWFLANT – CDR GEORGE PORTER, +1-912-573-4174 (o), +1-912-409-5707 (c), [email protected]

FACSFAC JAX – LCDR O.L. CHAMBERS, +1-904-542-2027, [email protected] (Fleet Area Control & Surveillance Facility Jacksonville)

FAA JACKSONVILLE ARTCC, +1-904-845-1537 (no name or email provided)

FAA JACKSONVILLE TERMINAL RADAR APPROACH CONTROL, +1-904-741-0767 (no name or email provided)

9.5.2 SITE OWNERS 9.5.2.1 BAYER CROP SCIENCES (BCS)

A representative(s) of BCS will be onsite to observe and ensure compliance with access agreements put in place for this activity. BCS currently has third party security on site 24/7 and will continue to provide this during this activity. The primary POC for BCS is: David Pitman, +1-912-222-7967, [email protected]

9.5.2.2 UNION CARBIDE CORPORATION (UCC) / DOW CHEMICAL A representative(s) of UCC may be onsite to observe and ensure compliance with access agreements put in place prior to, and potentially for, this activity. The primary POC for UCC is: Tim King, +1-304-389-2371, [email protected]

9.5.3 OTHER INTERESTED PERSONS 9.5.3.1 US NAVY

Captain Dan Rochford, Commanding Officer, SWFLANT, +1-912-573-4173 (o), +1-912-674-9556 (c), [email protected] Mr. Mark Rector, Public Affairs, SWFLANT, +1-912-573-2623 (o), +1-912-409-5834 (c), [email protected] Mr. Russell Byrd, CPLO Kings Bay, +1-912-573-1675 (o), [email protected]

IN NOTES: SEE ADDITIONAL USN/USMC CONTACTS FOR GENERAL INFORMATION

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1. Launch Customer / Launcher:VECTOR LAUNCH / B0.002

2. Launch Number (if applicable):SCC-2017-001

3. Estimated Date/Time:Date: 8/3/2017 Time: 0800 hrs local (TBD)

9.6 CROSS ORGANIZATION COMMUNICATIONS This section defines the real time data and voice communications capabilities that will be utilized during the activity. In addition, Vector may have a real time video link via the internet that persons can monitor online. This is being worked on, and if it is realized, will be included in this CLP. For general communications the US Navy will be connected to the site via cell phone between Vector Launch Control and SWFLANT (CDR George Porter or his designee), who will then communicate on to other Sub Base personnel.

9.6.1 ORGANIZATION’S RADIO IDENTIFICATIONS Each Organization will have radio identifiers as described below.

9.6.2 COUNTY RADIO FREQUENCY / RADIO COMMUNICATIONS PLAN – VOICE

9.6.3 VECTOR RADIO FREQUENCY / RADIO COMMUNICATIONS PLAN – VOICE / DATA / VIDEO / OTHER The Vector voice, data and video communications frequency usage is planned as follows:

6. Prepared by: Name: Position/Title: Signature:

ICS 201, Page N/A Date/Time: Updated by FDA 2/2011

Organization Voice Comms Identifier Example Functions

Vector Launch System Vector <function> Vector Launch Control

Camden Spaceport Spaceport <function> Spaceport Administrator

Camden Fire Fire <function> Fire Tanker

Camden Paramedics Paramedic <function> Paramedic Observer Site

Camden Sheriff Sheriff <function> Sheriff North Boat

Georgia Forestry Forestry <function> Forestry Plow

System/Cache Channel Function Frequency/Tone Assignment Remarks

(b) (7)(F)

(b) (7)(F)

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COMPREHENSIVE LAUNCH PLAN (IAW ICS 201), Adapted CAMDEN EMA

1. Launch Customer / Launcher:VECTOR LAUNCH / B0.002

2. Launch Number (if applicable):SCC-2017-001

3. Estimated Date/Time:Date: 8/3/2017 Time: 0800 hrs local (TBD)

6. Prepared by: Name: Position/Title: Signature:

ICS 201, Page N/A Date/Time: Updated by FDA 2/2011

(b) (7)(F)

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NOTES:

FROM SECTION 5: Safety Message/Expanded Safety Message, Safety Plan, Site Safety Plan: All personnel must receive initial briefing morning of operations regarding overall operation and specific mission they are

assigned. Upon assuming physical posting, test communications and assess surrounding areas for hazards. Identify /report hazards

(likely to result in negative impacts) All personnel will remain aware of launch cycle, paying attention to equipment or debris falling via canopy, or other debris

from overhead, taking any necessary protective actions. Radio communications will be conducted for Go / No-Go status aswell alert to final countdown for launch.

Remain aware and report location of any debris observed from assigned post, monitoring for fire or other hazard. HAZMAT will be handled by trained personnel, using proper PPE. Keep hydrated; ensure adequate supply of water is available (drink enough water). If drinking Gatorade or similar products

use a 2:1 ratio (2 quarts water to 1 quart of Gatorade). Officers should bring a meal with them and or snacks that are small enough to fit into a cargo pocket Maintain communications with adjoining teams, and supervisors. Traffic vests should be used when operating on or near roadways for added visibility. Officers should bring tick and bug spray. A product containing DEET is recommended. Make a supervisor aware of tick bites. Snakes, poisonous and non-poisonous, are known to the area as well as alligators. Look before walking or placing your hand

into an area. Consider all aspects of current and future situations

WEATHER TBD: Weather forecast will be provided prior to final IAP dissemination, and should be used as a guide for protective clothing or

measures.

From 9.5.3.1 – Additional USN / USMC CONTACTS: LtCol Martinez [email protected] 912-409-0906

LCDR Foster [email protected] 912-409-1455

Maj Juarez [email protected] 912-674-5630

Maj Fletcher [email protected] 912-409-5000

Capt Martin [email protected] 912-409-9393

LT Fogel [email protected] 912-409-9376

Capt Angel [email protected] 912-409-1151

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Attachment 10

Population Monitoring and Management Plan

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Population Monitoring and Management Plan

14 January 2020

GORA EXEMPT – SECURITY INFORMATION FOIA EXEMPT – SECURITY INFORMATION

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TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................. 2

Section 1 – Introduction ........................................................................................................ 3

1.1 FAA/AST Request for PMMP ............................................................................................ 3

1.2 Regulatory Justification for Request (14 CFR § 413.13) ................................................... 3

Section 2 – Population Management and Monitoring............................................................. 4

2.1 Generation of Population Threshold Data by Launch ...................................................... 4

2.2 Population Monitoring and Management (M/M) ........................................................... 4

2.2.1. ZONE 1 – Water......................................................................................................... 5

2.2.2. ZONE 2 – Cumberland Island .................................................................................... 6

2.2.3. ZONE 3 – Little Cumberland Island ........................................................................... 7

2.2.4. ZONE 4 – Rest of Areas (ROA) ................................................................................... 7

Section 3 – Conclusions ......................................................................................................... 9

Revision History: 1/14/20 Original issue of this document. Material previously contained within the LSOL

application of 1/25/2019, submissions to FAA/AST and additional material developed in response to FAA/AST inquiries between January and December 2019.

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SECTION 1 – INTRODUCTION

Spaceport Camden has prepared this Population Monitoring and Management Plan (PMMP) for use in and around Spaceport Camden during hazardous operations. The resultant data generated by this plan on day-of-launch will inform the Launch Facility Operations Director (also known as the “launch director”) or a designee, if pre-determined population related thresholds are exceeded. These pre-determined population thresholds are identified to maintain safe cumulative risk limits (also known as “expected casualty” or “public risk limits”) during hazardous launch site operations in accordance with Title 14 of the Code of Federal Regulations (CFR) Part 420 for a Launch Site Operator License (LSOL) and Parts 415/417 for a Launch License. The following paragraphs describe how Camden County will account for and manage the process to determine day-of-launch populations on Little Cumberland Island (LCI), Cumberland Island (CI), and the waters surrounding these islands, to ensure that cumulative risk limits are not exceeded.

1.1 FAA/AST Request for PMMP

This PMMP is required to address the concerns expressed by FAA/AST regarding the active monitoring and management of population that may be present on, and migrate to and from, Little Cumberland Island (LCI) and Cumberland Island (CI), during hazardous launch operations at Spaceport Camden. The original inquiry from FAA/AST stated:

“We need information on how the number of people on LCI and Cumberland Island would be accounted for and managed to ensure that the public risk limits are not exceeded.”

1.2 Regulatory Justification for Request (14 CFR § 413.13)

Although a PMMP is not a required submission under the LSOL regulations of 14 CFR Part 420 (or Parts 415/417), the FAA may request, pursuant to 14 CFR § 413.13 “additional information necessary for a determination that public health and safety, safety of property, and national security and foreign policy interests of the United States are protected during the conduct of a licensed or permitted activity.” This PMMP is one such request.

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SECTION 2 – POPULATION MANAGEMENT AND MONITORING

2.1 Generation of Population Threshold Data by Launch

For every launch at Spaceport Camden there is an Incident Command System (ICS) Form 201 compliant document prepared by the launch stakeholders (led by Spaceport Camden) called the Comprehensive Launch Plan (CLP).1 Within the CLP, one of the analysis products for an orbital launch will be a launch operator generated, and FAA/AST approved, determination of the maximum population that may be accommodated on LCI and CI, given appropriate characteristics for the launch vehicle, payload, trajectory, weather, and other factors included in an FAA/AST approved launch license. These maximum population determinations will serve as the basis for the maximum allowable populations on LCI, CI and the surrounding waters for day-of-launch. Should population estimates exceed these allowable limits, a launch hold would be implemented until populations have been reduced below the agreed upon limits.

2.2 Population Monitoring and Management (M/M)

The following is the description of the process to be used to monitor and manage populations that enter LCI, CI and the surrounding waters. For ease of understanding and considering various regulatory frameworks and necessary working arrangements, the M/M of population is broken down into four (4) zones: 1) Water, 2) Cumberland Island, 3) Little Cumberland Island, and the 4) Rest of the Area (ROA). These zones are shown in Exhibit 1 and are described in the following paragraphs based on their characteristics, lead-agency, supporting organizations, and the methods used to perform M/M operations.

1 See Spaceport Camden’s Launch Site Operator License (LSOL) application, Attachment 9, for an example of a CLP used in a suborbital launch performed at Spaceport Camden under Part 101.

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Guard regulations (33 CFR § 165.20) and further addressed within the Spaceport Camden-USCG LOA (Attachment 3 to the Spaceport Camden LSOL application). All craft who wish to proceed through or within the Safety Zone must present appropriate credentials or otherwise be authorized by a launch official or the COTP’s representative on the USCG-authorized water craft. Craft and their population will be reported to a central launch population M/M desk that will be the point of contact for up-to-date population counts to the launch director. Assisting in the monitoring of the water areas will be other authorized first responder craft, video surveillance from Spaceport Camden property, and launch-day staff pre-positioned on CI, LCI, and Jekyll Island. If needed, fixed wing and/or drone aircraft (appropriately authorized under FAA rules) will also be utilized. These supporting elements will report observed (and if necessary, estimated) populations to the central launch population M/M desk so they are accounted for and managed, as appropriate. 2.2.2. ZONE 2 – Cumberland Island Cumberland Island is managed and controlled by the National Park Service (NPS), Cumberland Island National Seashore (CUIS) staff. Currently, CUIS utilizes Camden County (CC) first responders (FRs) for enforcement purposes, including the pre-positioning of equipment, vehicles and material on CI. This existing mutual aid arrangement will be utilized for day-of-launch support where NPS/CUIS will be the lead agency supported by CC FRs. The primary method of population M/M will rely on CUIS’s existing monitoring systems and the fact that there is a limit of 300 visitors allowed on Cumberland Island per day and an overwhelming majority uses the paid ferry system to the island. The number of overnight campers (who also use the ferry system) is known through the reservation and check-in system used by the CUIS staff. The number of ferry passengers is known by the ticket sales and boarding counts taken on the ferry. It is noted the 300 per day limit includes visitors who arrive by private boat and are not one of the limited number of residents or guests of the only inn on the island. Private arrivals on the island will be monitored by CC FRs and NPS/CUIS rangers. These observations will be augmented by CC FR and Ranger patrols prior to launch, launch-day staff pre-positioned at CPs between Plum Orchard, Yankee Paradise Campground and the beach in the central-north section of the island, and if necessary, fixed wing and drone aircraft operating under FAA regulations. From these various sources of data, population will be reported to a central launch population M/M desk that will be the point of contact for up to date population counts to the launch director.

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2.2.3. ZONE 3 – Little Cumberland Island The only access to LCI is by boat. For boats of a typical monohull draft design, access to LCI is achieved around high tide to the only boat dock3 on the island. For shallow hulled watercraft access may be achieved at any time to the LCI dock or the northern and eastern beaches of LCI across shallow flats. The lead government agency for LCI is the Georgia Forestry Commission’s (GFC’s) southeast regional command. The GFC has entered into an agreement with LCI Home Association (LCIHA), for emergency services, safety, rescue, and monitoring of population that is documented in a Letter of Coordination (LOC). The LCIHA employed caretaker(s) will serve as the primary point of contact for regular and emergency contact procedures developed under the LOC. Through established mutual aid agreement(s), Camden County supports GFC in this activity and others. Through the LOC the regular reports of current population (owners and visitors) on LCI will be made to GFC and the CC Emergency Management Agency. Augmenting this reporting will be data from the planned day-of-launch USCG Safety Zone and shore-based video surveillance (and if employed, drone and/or fixed wing aircraft) operations described above for Zone 1. In order to travel to LCI through the Safety Zone, a watercraft and its occupants will need to show pre-authorization as a property owner or registered guests of an owner. A tertiary M/M strategy may include CC FRs presence on LCI who will make additional independent population observations. From these various sources of data, population will be reported to a central launch population M/M desk that will be the point of contact for up-to-date population counts to the launch director. 2.2.4. ZONE 4 – Rest of Areas (ROA) There is little anticipated impact from the ROA on the public risk limits as these areas are well outside of the widest anticipated impact limit lines of a launch from Spaceport Camden. There is no anticipated plan to estimate or report Zone 4 populations on day-of-launch. However, M/M of spectator populations in non-hazardous operation areas is an important public service function included as part of a larger overall population M/M plan that helps to prevent inconvenient traffic patterns that may be created on the day of launch.

3 LCI boat dock access is via the Cumberland River (Intracoastal Waterway) from the western side of the island through a shallow channel that winds its way through the marsh.

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The Director of the CC Emergency Management Agency (CCEMA) is responsible for developing and implementing CC local emergency operations plans. Through implementation of a unified command structure, the Director of CCEMA centrally coordinates all events and incidents that may impact public safety, including those where multiple jurisdictions are involved. Zone 4 encompasses all land and water outside of the area directly affected by Zones 1 – 3. The CCEMA director delegates the M/M of road flow and potential congestion during launch operations in Zone 4 during day of launch operations to the county sheriff’s office pursuant to National Incident Management System (NIMS) doctrine. NIMS provides a common, nationwide framework that enables the whole community to work together to manage all threats and hazards. NIMS applies to all incidents, regardless of cause, size, location, or complexity. The NIMS utilizes the Incident Command System (ICS) approach that defines all aspects of incident / event management through use of standardized ICS approved forms. The ICS is scalable and modular, allowing Camden County to collapse or expand, as necessary, to manage complex events. Spaceport Camden launches are organized and planned utilizing the ICS-compliant CLP process. Methods of M/M are anticipated to include common tactics employed today for events and incidents including: road flow changes, CPs, and FR monitoring and interdiction, as necessary. The CLP process incorporates and utilizes common practices already in place across all local and regional first responders and government agencies to manage issues such as road flow and potential congestion. Anticipated participating agencies and their agreed upon roles and responsibilities for Zone 4 are provided in the following exhibit.

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Agency Roles and Responsibilities

Camden County Sheriff’s Office Road Closure on Union Carbide Road near Spaceport Camden’s main gate and any identified flow control issues elsewhere in the county

Camden County Fire & Rescue Staged for response Georgia Forestry Commission Staged for response NPS/CUIS Notification / Awareness Naval Submarine Base Kings Base Notification / Awareness Strategic Weapons Facility Atlantic Notification / Awareness Georgia Department of Natural Resources (includes Crooked River State Park)

Notification / Awareness

Glynn County Emergency Management Agency Notification / Awareness Georgia Emergency Management Agency – State Operations Center Duty Officer

Notification / Awareness

Georgia State Patrol Notification / Awareness Georgia Department of Transportation Notification / Awareness

Exhibit 2. Zone 4 Anticipated Participating Agencies & Agreed Upon Roles / Responsibilities SECTION 3 – CONCLUSIONS The processes described above for M/M of populations on day-of-launch will be pre-coordinated through the ICS-201 compliant CLP process employed by Spaceport Camden. The provisions of this population M/M plan will be integrated into the overall CLP and executed. Through the utilization of the USCG Safety Zone and the concomitant enforcement provisions there under, unauthorized vessels will be kept from LCI and CI and Zone 1 waterborne craft (and persons) will be accounted for on day-of-launch. For Zone 2, and augmenting the USCG CPs, on CI there will be NPS/CUIS’s robust daily data on campers, ferry passengers, and private boats who visit the CUIS docks, which will be further augmented by ranger / FR patrols and land CPs. For Zone 3, on LCI, those vessels authorized to carry pre-registered visitors and property owners will go through the appropriate water CP and be counted. Augmenting this data will be information received under the GFC’s LOC agreement with LCIHA. If needed, CC FRs on LCI may also monitor population, as needed. All of these data will be reported to launch control for use in determining if cumulative (public) risk limits have been exceeded.

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Attachment 11

Little Cumberland Island Fire Mitigation Plan

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TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................. 2

Section 1 – Introduction ........................................................................................................ 3

1.1 FAA/AST Request for LCI FMP .......................................................................................... 3

1.2 Regulatory Justification for Request (14 CFR § 413.13) ................................................... 3

Section 2 – Background Regarding LCI and Fire....................................................................... 3

2.1 LCI and the National Park Service (NPS)........................................................................... 3

2.2 Existing Conditions, Fire Fighting Capability & GFC/CC Ability to Fight Fires on LCI ....... 5

Section 3 – LCI / CI Launch Related Fire Risk Assessment ........................................................ 7

3.1 Weather Related Risk Factors and Fire ............................................................................ 7

3.2 Launch Related Fire Risk in Good Weather on LCI / CI ................................................ 7

Section 4 – Fire Impact Mitigation Strategies ......................................................................... 9

4.1 Fire Fighting Equipment ................................................................................................... 9

4.2 Fire Mitigation Mutual Aid & Support ........................................................................ 11

4.3 Fire Response ................................................................................................................ 11

4.4 Coordination and Dispatching ..................................................................................... 13

Section 5 - Summary Conclusions and Information ............................................................... 13

Revision History: 1/14/20 Original issue of this document. Material previously contained within the LSOL

application of 1/25/2019, submissions to FAA/AST and additional material developed in response to FAA/AST inquiries between January and December 2019.

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SECTION 1 – INTRODUCTION

Spaceport Camden has prepared this Little Cumberland Island (LCI) Fire Mitigation Plan (FMP) for use during Spaceport Camden launch operations.

1.1 FAA/AST Request for LCI FMP

This LCI FMP is required to address the concerns expressed by FAA/AST regarding risk from fire on Little Cumberland Island (LCI) during liquid rocket engine powered launch operations from Spaceport Camden. The original inquiry from FAA/AST stated:

“As a result of our application review, and a site visit conducted by AST personnel, it was determined the risk from fire should be included in the LSOL risk analysis. Little Cumberland Island (LCI) is heavily lined with saw palmetto underbrush, and firebreaks are difficult to maintain. If a fire were to start due to a mishap or incident, it could quickly spread and would be difficult to contain. LCI’s existing firefighting capability is limited. Also, island egress from LCI is a concern as the only access to the island is by boat and LCI’s dock is located in a tidal stream. The Dock cannot be accessed two-hours before or after low tide. This creates a situation in which evacuation and emergency services may not be feasible.”

1.2 Regulatory Justification for Request (14 CFR § 413.13)

Although a FMP is not a required submission under the LSOL regulations of 14 CFR Part 420 (or Parts 415/417), the FAA may request, pursuant to 14 CFR § 413.13 “additional information necessary for a determination that public health and safety, safety of property, and national security and foreign policy interests of the United States are protected during the conduct of a licensed or permitted activity.” This LCI FMP is one such request. SECTION 2 – BACKGROUND REGARDING LCI AND FIRE

2.1 LCI and the National Park Service (NPS)

During the creation of Cumberland Island National Seashore (CUIS), Little Cumberland Island was incorporated into the lands of the new national park by the formation legislation. However, owners of cottages on Little Cumberland Island negotiated the continued occupation of the properties pursuant to an agreement entered into in 1975. The agreement between the Little Cumberland Island Homes Association (LCIHA) and the United States of America, acting by and through the Secretary of the Department of the Interior, requires LCIHA to perform mitigation activities for “Fire and Fire Control” and “Timber” by employing certain forest management practices, including prescribed burning

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and removal of timber impacted by disease, insects or natural causes (e.g., severe weather). 1 LCI has been identified by NPS/CUIS as Fire Management Unit (FMU) #3 in their Fire Management Plan (see Exhibit 1). 2 As seen in Exhibit 1, LCI is located north of the larger Cumberland Island, with Christmas Creek and marsh separating the two. While LCI is within the Cumberland Island National Seashore boundaries, it is privately owned throughout and is managed by its own homeowners’ association, the aforementioned LCIHA. In consideration of its ownership, management, and jurisdiction, LCI has been designated by the NPS as a distinct FMU, encompassing approximately 3,437 acres (see Exhibit 1). The boundaries of the LCI FMU are Christmas Creek and marsh to the south, Cumberland River to the west, St. Andrews Sound to the north, and the Atlantic Ocean to the east. The NPS is considered a cooperator with Camden County and the Georgia Forestry Commission (GFC) as lead agency, for fire management of this FMU.

Exhibit 1. FMU #3, Little Cumberland Island (Source: NPS, CUIS FMP, 2015)

1 Agreement between the LCIHA, Inc. and the USA (Department of Interior), in lieu of taking by imminent domain by the USA, 30 pages (1975). 2 “Cumberland Island National Seashore Fire Management Plan,” National Park Service, 88 pages (2015).

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2.2 Existing Conditions, Fire Fighting Capability & GFC/CC Ability to Fight Fires on LCI

Camden County has assessed LCI’s indigenous firefighting capability and Camden County generally concurs with the FAA assessment that existing capability to fight fire is limited, noting that the limitations have existed throughout the years, back to the original signing of the 1975 agreement. Camden County recognizes fire on LCI from lightning strikes and or man-made causes has occurred in the past, as documented by NPS/CUIS in their analysis shown as Exhibit 2, and may occur in the future. The NPS exhibit indicates two fires occurred on LCI between 1977 and 2013 while over 60 fires occurred on Cumberland Island in the same period. Camden County also recognizes that the risk of fire on LCI may be greater due to a lack of prescribed (controlled) burns since the 1975 agreement. Although the benefits achieved via controlled burns within the mostly Maritime Forest (oak tree canopy and various groundcover (vegetation) that includes saw palmettos) found on LCI may be less than for pine forests that are more common to South East Georgia, such burns are beneficial.3

Exhibit 2. Historic Fires on LCI and CI 1977-2013 (Source: NPS, CUIS FMP, 2015)

3 Fire conditions (fuel), may vary to some degree, depending on moisture content, height of vegetation, type of vegetation and trees, and other atmospheric conditions. Fire danger ratings are calculated on a day-to-day basis and are subject to change with weather conditions.

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Camden County works in partnership with the GFC, who is recognized as the lead agency within Camden County for all woodland wildfire response, as well as public awareness, education and mitigation efforts. During the all-hazards assessment and response planning efforts carried out by Camden County Emergency Management, Camden County Fire Rescue, with GFC consultation, it was concluded that although fuel loading in some areas of LCI is considered high, fire incidents on LCI would in all likelihood be slow moving due to the nature of the Maritime Forest. Where ground firefighters are deployed on the Island in a timely manner with appropriate equipment (i.e., wheeled water ‘buffalo’ carriers [see Exhibit 3] with access to artesian wells), attack/ defense strategies would have a high probability of success. Relatively flat terrain, expansive beach access via landing craft, coupled with no natural gas pipelines and limited on-grid electric utilities, further decreases the fire hazard, while enhancing response effectiveness.

Exhibit 3. Current Type of Water Buffalo on LCI

LCI has a water buffalo permanently stationed on the island, but it has been inoperable (pump / motor). The LCI water buffalo is being repaired at County expense for re-deployment to LCI.

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SECTION 3 – LCI / CI LAUNCH RELATED FIRE RISK ASSESSMENT This section addresses risk factors on LCI and CI related to launch from Spaceport Camden.

3.1 Weather Related Risk Factors and Fire

Lightning and wind are the primary weather concerns contributing to naturally occurring fires on LCI and CI. Strong wind is also a principle concern to man-made fires. These same weather factors are assessed for risk to the rocket and payload during launch operations. Inclement weather (rain, ice, snow, lightning or the presence of static electrical buildup prior to lightning) is the cause of rocket launch abort. So when there is a danger of lightning in the vicinity of a launch pad (and in the presence of sensitive electronics/fuel and an increased probability of strike during launch) rockets are not launched. Therefore, the risk of fire on LCI / CI from a rocket launch is reduced in the presence of inclement weather. The greater concern for LCI / CI is from lightning itself. The presence of strong low and high altitude winds (that cause high aerodynamic loads), with or without other weather affects (rain, lightning, etc.) is also a danger to launch operations. Low level (altitude) winds are also a principle cause of concern for the spread of fire. Since launch operations cannot occur in strong winds, the risk of fire from a launch incident is also reduced due to the lack of strong winds. Therefore, the probability of a launch failure in inclement weather or high winds is remote because the probability of a launch in such conditions is de minimis.

3.2 Launch Related Fire Risk in Good Weather on LCI / CI

The probability of a launch failure in good weather conditions causing a fire on LCI / CI is also considered remote, given the nature of liquid rocket engine powered vehicle failures (both probability and how rockets fail along the trajectory) and the trajectory these vehicles fly. The limitation of operations to small launch vehicles with relatively low fuel loads also causes the probability of fire due to an incident to fall dramatically versus larger rockets. A typical trajectory starts with a nearly vertical climb for 45-75 seconds, and then slowly tips horizontally, continuing to gain altitude until it achieves orbit. At the proposed Spaceport Camden, when the rocket approaches Cumberland Island or LCI, it should be between 70,000 and 100,000 feet above the Island and take between 6-10 seconds to cross the island. The instantaneous impact point (IIP) also clears the island from west to east in about 5-7 seconds of dwell time. The IIP is the projected landing spot of the rocket should thrust be terminated at that instant.

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The nature of liquid-fueled rocket failures also limits the risk of fire caused by an accident. The most probable cause of a fire from a rocket failure is an intact impact – the entire rocket falls onto the land as one piece and the remaining fuel ignites. Given the distance from the launch pad (between 5-7 miles) and the height of the rocket along the trajectory in order to make the island in the case of a failure, it is highly unlikely the rocket will fall all the way to the Earth without breaking up due to atmospheric stresses or a triggered range destruct signal from the automatic flight termination system. Such intact impacts typically only occur very near the launch pad. In the 300,000 Monte Carlo cases evaluated by The Aerospace Corporation, for each trajectory evaluated in the Spaceport Camden flight safety analysis, there was no intact impacts experienced on the islands. All failures resulted in mid-air breakup due to high loads exceeding the structural limits (Qα – “que-alpha”) of the automatic flight termination system destroying the rocket in flight. To be clear, in no case was there an intact impact on LCI or CI in the flight safety analysis. Therefore, this most likely failure scenario limits the probability of fire from launch accidents on the island(s) to near zero. As communicated by the FAA at the December meeting in Washington D.C. to Spaceport Camden representatives, FAA/AST have further confirmed these results in their own flight safety analysis of launch failures, with no intact impacts from launch occurring on LCI or CI.

SECTION 4 – FIRE IMPACT MITIGATION STRATEGIES

The following addresses fire impact mitigation strategies to be followed by Spaceport Camden.

4.1 Fire Fighting Equipment

As noted earlier, Camden County’s initial assessment of LCI fire risk and response capability revealed that the current fire-fighting apparatus, i.e., water buffalo (Exhibit 3) stationed on LCI did not work due to an inoperable pump and motor. Camden County agreed to assist the GFC in bringing this apparatus back online to support potential firefighting response. As of this writing, Camden County has agreed in writing with the GFC to assume cost for all apparatus repairs, with GFC responsible for work completion and return to service on LCI. . Camden County is also assessing the need to procure and strategically deploy a second water buffalo on LCI, should the GFC make this recommendation. Launch day planning would include pre-staging firefighters/EMTs with equipment, to include fire-fighting All-Terrain Vehicles (ATVs) on stand-by ready marine landing craft (see Exhibits 5, 6 and 7).

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Exhibit 5. Fire Fighting ATV

Exhibit 6. Rescue ATV

Exhibit 7. Shallow Bottom Landing Craft Enables Beach Access

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4.2 Fire Mitigation Mutual Aid & Support

Camden County is providing mutual aid to GFC for fire response support, with Camden County leading all evacuation, medical, and/or law enforcement response. Actions and resources supporting a fire incident are outlined in the Camden County Local Emergency Operations Plan, Camden Fire Standard Operating Guides, Memorandums of Understanding (MOUs) and the “Launch Day” Incident Action Plan (IAP) called the Comprehensive Launch Plan (CLP) in our LSOL application (example at Attachment 9 of the Spaceport Camden LSOL Application). The CLP outlines the following: command and control, communications, resources, and response to all hazards and cascading events, including safety zone security under a Unified Command structure. Camden County recognizes that although considered unlikely, Spaceport Camden must plan for the possibility of a launch incident that could impact LCI. Planning efforts include draft development of Launch Day CLP that establishes USCG safety zone controls and supporting contingency plans for potential incidents that may occur. Camden County, Camden County Emergency Management Agency, Camden Fire Rescue, Camden County Sheriff’s Office along with Naval Submarine Base Kings Bay, NPS/CUIS, and Glynn County Emergency Management maintain robust communications and mutual aid agreements that further mitigate fire danger on LCI. This enhanced coordination process amplifies mutual aid agreements and further strengthens the response capability, while outlining authorities, roles, and responsibility. This was highly evident during the Vector R Part 101 launch from Spaceport Camden in August 2017. Additional supporting agencies during this successful operation included the US Navy (Kings Bay), U.S. Coast Guard and Georgia Department of Natural Resources.

4.3 Fire Response

In the Cumberland Island National Seashore Fire Management Plan (FMP) Fire Management Unit (FMU) #3 operational guidance identifies the GFC and Camden County Fire and Rescue as the lead agencies for fire management on LCI. The NPS will assist Camden County and the GFC according to annual operating plans and requests from the lead agencies. A unified command structure is to be established for incidents within this FMU pursuant to the Spaceport Camden CLP process. Camden County concurs with the FAA assessment regarding the limited access to LCI based on tidal restrictions. During low tide periods, access to the LCIHA’s Shell Creek dock (latitude N 30.95040, longitude W 81.42110) is not feasible for deeper drafted boats, and this limitation may delay emergency response efforts which include firefighting, search and rescue, and/or evacuation. Based on this limitation, Camden County would not rely solely on the existing tidal creek or traditional boats, opting instead to utilize alternative

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4.4 Coordination and Dispatching

The NPS is dependent on other federal agencies and local cooperating agencies for fire management activities, due to the lack of staffing of qualified personnel at the Cumberland Island Seashore (CUIS). The NPS has MOUs, Annual Operating Plans (AOPs), and/or other agreements with multiple agencies to enhance the capabilities of the park to manage fire. The NPS has a central MOU with the GFC at the regional level and an AOP at the local level. These agreements provide for the sharing of resources and equipment during an emerging incident. The NPS also has a MOU with Camden County, which is updated annually. The NPS is a partner in the Tri-Agency Agreement with Okefenokee National Wildlife Refuge, Osceola National Forest, and Timucuan Ecological & Historic Preserve that streamlines the sharing of resources and equipment between local federal agencies. This agreement requires annual updates and signatures of agency administrators. Dispatching and ordering of CUIS resources is currently completed by the Georgia Interagency Coordination Center (GICC) in Gainesville, Georgia. Coordination with the Southern Area Coordination Center (SACC) is necessary for off-unit and NPS specific orders. In the event of an incident in the park, a dispatch center will be established either on the mainland or at the Captain’s House on the Island and it will be staffed with an initial attack dispatcher. The initial attack dispatcher will coordinate the fire management officer (FMO)/incident commander’s needs with local agencies and the GICC as well as keeping a communication log. If a wildfire is reported on LCI FMU #3, Camden County and GFC must be notified as they are the lead agency for response to this FMU. Mandatory notifications of a wildfire at CUIS include:

Camden County 911 GFC Camden Unit (912) 576-5387 GICC (770) 297-3036 SACC (678) 320-3000

SECTION 5 - SUMMARY CONCLUSIONS AND INFORMATION

The low number and impact of historical wildfires on LCI provides a direct assessment dimension in assessing future occurrences from all-sources. Georgia ranks in the top 20 states experiencing the highest number of thunderstorms per year and leads the nation in lightning strike related insurance claims. Lightning strikes are considered frequent occurrences in Camden County and can reach temperatures beyond 50,000 degrees Fahrenheit. Typically, humans are a key source of fires, but given the limited human activity on LCI, lightning is considered to be the highest threat vector for fuel ignition. This fact is considered in assessing both ignition and fire spread, indicating

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that the LCI Maritime Forest has experienced lightning strikes, without significant rapid spread of fire occurring. Ongoing efforts by the GFC to build stand-off areas, i.e., defensible spaces on LCI, and the low density of structures on LCI also reduces the risk of propagation via exposure, spread and intensity from fires. For all launches, pursuant to the launch specific CLP, Camden County Fire/Rescue and Law Enforcement will utilize marine landing craft that will ensure uninterrupted ingress/egress to LCI, day and night in support of all First Responders. . Additional investments in restoring the existing water buffalo to an operational status and adding a new water buffalo, with ATV deployment capability for use by GFC, or Camden County Fire, EMS and or Law Enforcement will ensure a timely response onto LCI in support of all-hazards threats, e.g., fire, medical, evacuation, search and rescue. Camden County was recently recognized in 2019 by the State of Georgia and Georgia Emergency Management Agency (GEMA), for achieving a high level of readiness and compliance in all-hazards planning and operational readiness. Camden County maintains highly effective and robust communications with our local, state and federal partners, to include multi-agency drills and exercises. Camden County operates in a well-established incident command system, in partnership with the GFC and the NPS/CUIS under established agreements that outline fire planning for LCI. It should also be noted that Camden County retains emergency authority throughout Camden County, to include privately owned property on LCI as defined in the Local Emergency Operations Plan (LEOP) Sec. 22-40 (Attachment 8 to the Spaceport Camden LSOL Application). Emergency powers as defined in the Camden County LEOP states that the Camden County Chairman of the Board of Commissioners shall have and may exercise for such periods as the state of emergency or disaster exists or continues the following emergency powers: (1) Command or utilize any private property if he finds this necessary to cope with the emergency or disaster; (2) Direct and compel the evacuation of all or a part of the population from any stricken or threatened area within Camden County if he deems this action necessary for the preservation of life or other disaster mitigation or response; (3) Prescribe routes, modes of transportation and destinations in connection with the evacuation; (4) Control ingress and egress to and from the disaster area and the occupancy of premises therein. Additional authorities are contained in the Camden LEOP previously provided as attachment 8 to the Spaceport Camden LSOL application. Camden County is acutely aware of the future responsibilities in carrying-out safe launch operations to include mitigation and response in an all-hazards environment should an incident occur on LCI. Safety of First Responders and the public will be the first priority during any incident.

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Attachment 12 Scheduling and Notification Plan

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Scheduling and Notification Plan

14 January 2020

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TABLE OF CONTENTS Acronyms & Abbreviations ............................................................................................................. 3

Section 1 – Introduction ................................................................................................................. 4

1.1 Description of Scheduling Regulations (§ 420.55) ........................................................... 4

1.2 Description of Notifications Regulations (§ 420.57) ........................................................ 4

Section 2 – Scheduling of Launch Site Operations ......................................................................... 5

2.1 Scheduling Launch Site Operations .................................................................................. 5

2.2 Comprehensive Launch Plan ............................................................................................ 5

Section 3 – Notifications ................................................................................................................. 6

3.1 Notifications to Launch Operators and Other Customers ............................................... 6

3.2 Notifications to United States Coast Guard ..................................................................... 6

3.3 Notifications to FAA Air Traffic Control ............................................................................ 6

3.4 Notifications to Adjacent Land Owners and Other Agencies........................................... 6

Revision History: 1/14/20 Original issue of this document. Material previously contained within the LSOL

application of 1/25/2019 and additional material developed in response to FAA/AST inquiries between January and December 2019.

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ACRONYMS & ABBREVIATIONS

ATC Air Traffic Control

CFR Code of Federal Regulations

CLP Comprehensive Launch Plan

EIS Environmental Impact Statement

FAA Federal Aviation Administration

ICS Incident Command System

LSOL Launch Site Operator License

NOTAM Notice to Airman

NOTMAR Notice to Mariners

USCG United States Coast Guard

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SECTION 1 – INTRODUCTION

Spaceport Camden has prepared this plan to coordinate the scheduling and notification of hazardous launch site operations consistent with Title 14 of the Code of Federal Regulations (CFR) Part 420 for a Launch Site Operator License (LSOL). This plan requires that launch site operations between various site users be scheduled with Spaceport Camden and appropriate notifications issued to other launch site users, adjacent property owners, and key stakeholders.

1.1 Description of Scheduling Regulations (§ 420.55)

This Scheduling and Notification Plan is required to addresses the scheduling regulations provided in 14 CFR § 420.55 as quoted below: § 420.55 Scheduling and Notification Plan

(a) A licensee shall develop and implement procedures to schedule operations to ensure that each operation carried out by a customer at the launch site does not create the potential for a mishap that could result in harm to the public because of the proximity of the operations, in time or place, to operations of any other customer. A customer includes any launch operator, and any contractor, subcontractor or customer of the launch site operator's customer at the launch site. (b) A licensee shall provide its launch site scheduling requirements to each customer before the customer begins operations at the launch site.

1.2 Description of Notifications Regulations (§ 420.57)

This Scheduling and Notification Plan is required to addresses the notification regulations provided in 14 CFR § 420.57 as quoted below: § 420.57 Notifications

(a) A licensee shall notify each launch operator and any other customer of any limitations on the use of the launch site. A licensee shall also communicate limitations on the use of facilities provided to customers by the launch site operator. (b) A licensee shall maintain its agreement, made in accordance with § 420.31(a), with the local U.S. Coast Guard district. (c) A licensee shall maintain its agreement, made in accordance with § 420.31(b), with the FAA ATC office having jurisdiction over the airspace through which launches will take place. (d) At least two days prior to flight of a launch vehicle, the licensee shall notify local officials and all owners of land adjacent to the launch site of the flight schedule.

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SECTION 2 – SCHEDULING OF LAUNCH SITE OPERATIONS

2.1 Scheduling Launch Site Operations

In general, potential hazardous operations should be scheduled as far in advance as possible. A monthly scheduling meeting with the Launch Facility Operations Director (or designee) and active spaceport customers will be used to identify potential upcoming hazardous operations and to ensure that the proposed operations are on the Spaceport’s master schedule. The Launch Facility Operations Director (or designee) will maintain a master schedule that includes all requested, tentative, and firmly scheduled events. The master schedule will be used to prevent scheduling issues among customers and will be available to spaceport customers upon request. A weekly scheduling meeting will be held with representatives of the spaceport and active spaceport customers at the direction of the Launch Facility Operations Director (or designee) to discuss the potential hazardous operations that are on the master schedule. The purpose of the meeting is to review the schedule for the week and to ensure coordination and de-confliction of potential hazardous operations. The weekly scheduling meeting will be the primary forum in which spaceport customers can raise concerns about potential hazardous operations to be conducted by other customers.

2.2 Comprehensive Launch Plan

When hazardous operations include launch activity, spaceport customers must submit a Comprehensive Launch Plan (CLP) in advance of their launch operations. For clarity, a spaceport customer includes any launch operator, and any contractor, subcontractor or customer of the launch site operator's customer at the launch site. The CLP development process is performed for each launch and ensures thorough coordination across the stakeholder community. The CLP process is also ICS-201 compliant (Incident Command System Form 201) and further conforms to the overarching Camden County Emergency Operations Procedures (Attachment 8 of the LSOL Application). The CLP has been developed to ensure each operation carried out by a customer at Spaceport Camden does not create the potential for a mishap that could result in harm to the public because of the proximity of the operations, in time or place, or to operations of any other spaceport customer or local entity such as the US Navy at Submarine Base Kings Bay. An example CLP was provided to the FAA as Attachment 9 of the LSOL Application and was from a FAA Part 101 launch at Spaceport Camden that did not require waterway closures or monitoring by the United States Coast Guard (USCG). Future CLPs for orbital launches will include the USCG implementation of an appropriate safety zone pursuant to 33 CFR § 165.20 and Attachment 3 of the LSOL Application.

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SECTION 3 – NOTIFICATIONS Compliance with § 420.57 Notifications is provided below.

3.1 Notifications to Launch Operators and Other Customers

Following the weekly scheduling meeting identified in Section 2.1, the Launch Facility Operations Director (or designee) will send out a schedule of the potential hazardous operations that are occurring within the week to all spaceport customers. If changes are made regarding the potentially hazardous operation after the weekly schedule is distributed, the Launch Facility Operations Director (or designee) will immediately contact all spaceport customers to notify them of the amended schedule. The notifications will identify unique launch requirements, schedule of operations, and any limitations on the use of launch site facilities

3.2 Notifications to United States Coast Guard

Camden County Board of County Commissioners maintains an agreement with the USCG, in accordance with § 420.31(a). Notifications to the USCG will be completed according to the agreement for the issuance of a Notice to Mariners (NOTMAR). The agreement was provided to the FAA as Attachment 3 of the LSOL Application.

3.3 Notifications to FAA Air Traffic Control

Camden County Board of County Commissioners maintains an agreement with the FAA Air Traffic Control (ATC) office having jurisdiction of the airspace through which launches would occur from Spaceport Camden. The agreement is in accordance with § 420.31(b) and notifications to the FAA will be completed according to the agreement for the issuance of a Notice to Airmen (NOTAM). The agreement was provided to the FAA as Attachment 4 of the LSOL Application.

3.4 Notifications to Adjacent Land Owners and Other Agencies

Spaceport Camden will maintain an email list of adjacent land owners, local officials, other agencies, appropriate media outlets, and the general public. At least two days prior to each launch, Spaceport Camden will notify adjacent land owners and other agencies in accordance with the launch specific CLP. The CLP process, identified in Section 2.2, includes notification contacts and procedures for each launch related operation. Such notifications will also be in accordance with any special notification requirements defined in the mitigation section of the Spaceport Camden Environmental Impact Statement (EIS).