Stop the SpaceX Raid On Rio Grande Valley National Wildlife Refuge

Dear US Fish and Wildlife Service: Under the Draft Environmental Assessment (EA) prepared by the U.S. Fish and Wildlife Service (Service) for the proposed Boca Chica Land Exchange, approximately 712 acres of lands within the Lower Rio Grande Valley National Wildlife Refuge (LRGVNWR) would be exchanged for some 692 acres of land owned by Space Exploration Technologies Corp. (SpaceX) in Cameron County, Texas, After reviewing the EA and considering the environmental setting of the Lower Rio Grande Valley, it is clear that the proposed action raises substantial environmental, ecological, cultural, and policy concerns. I am opposed to the proposed exchange of lands but also believe that before any decision is made, the proposed exchange warrants preparation of a full Environmental Impact Statement (EIS) under the National Environmental Policy Act (NEPA), 42 U.S.C. §4332. FWS should not only do an EIS, but also a consistency analysis (as the Refuge Act requires) to determine whether the future uses of the divested lands will be compatible with the Refuges, including not only from noise and light, but also explosions and debris from testing and launching rockets. Indeed, FWS continues to ignore prior harm to Refuge lands from explosions and debris at the launch site as well as the Massey test site, which have caused significant harm. FWS should: Analyze how this proposal will destroy and degrade the Palmito Battlefield National Historic Landmark and National Register of Historic Places and its landscape. Analyze how this proposal will destroy and degrade ancient grasslands (old growth prairies) that are pristine and like those that existed in 1865. Analyze how this proposal will dismantle and degrade residents’ use of Boca Chica Beach and other nearby public lands. Analyze how this proposal will destroy or degrade important wildlife lands and landscapes for endangered and threatened species which currently are and should remain preserved. Analyse the coastal wetlands and floodplain systems that perform important ecological functions including storm buffering, habitat support, and migratory bird use Analyze the environmental impacts that hurricanes, storms, and heavy rainfalls will have on proposed land exchange lands. Analyze how development of the current property that is currently part of the FWS would impact the culture, environment and health of nearby communities; Analyze the ongoing expansion of SpaceX operations in the area. Treating the exchange as a stand-alone administrative transaction fails to acknowledge the broader context in which the action occurs, and an EIS must also assess this development. Analyze how this proposal will affect the accelerated decline of North American bird populations in the Valley. Consider how the proposed exchange of public lands that are currently utilized by peoples of South Texas including native people will impact public enjoyment of those lands. More fully analyze the proposed transfer of land known as the Starbase Unit - the small parcel that FWS proposes to give up directly adjacent to the launch area. That area is currently a vegetative buffer for the adjacent tidal flats that migratory birds rely on (including critical habitat for piping plovers), which will be lost if SpaceX expands into the area. For NEPA purposes, an alternative that does not include the Starbase Unit should be considered. Ensure that all impacts have been fully mitigated before even considering this proposed landswap, and/or should require a much higher ratio of land to offset impacts, such as 3:1 or 4:1. Analyze increased traffic that will ensue from further development of the area by SpaceX, which will lead to more collisions with wildlife and undermine the public's access to the area.