View the Lower Rio Grande Valley Sierra Club's Comment on SpaceX's Draft PEA (Sent 11/01/2021)

• View FAA PEA
• View Original EIS and Written Re-Evaluations
   

View the Lower Rio Grande Valley Sierra Club's Comment on SpaceX's US Army Corps of Engineers Application (April 5, 2021)

• View USACE Application

Programmatic Environmental Assessment:

View Our Programmatic Environamental Assessment Factsheet (tinyurl.com/spacex-pea-factsheet)

SpaceX proposes to conduct Starship/Super Heavy launch operations from the Boca Chica Launch Site in Cameron County, Texas. SpaceX must apply for and obtain an experimental permit(s) and/or a vehicle operator license from the FAA Office of Commercial Space Transportation to operate the Starship/Super Heavy launch vehicle. The FAA's evaluation of a permit or license application includes a review of 1) public safety issues (such as overflight of populated areas and payload contents); 2) national security or foreign policy concerns; 3) insurance requirements for the launch operator; and 4) potential environmental impact.

The FAA has released the Draft Programmatic Environmental Assessment for the SpaceX Starship/Super Heavy Launch Vehicle Program (Draft PEA) for review and comment deadlines in November 2021. The PEA is still under review by the FAA. 

Helpful Resources:

Starship User Guide

Everday Astronaut “Starship v Falcon 9”

SpaceX Starship

Background

• SpaceX went through the regulatory processes to construct a site for  launching the Falcon 9 and Falcon Heavy; 4 to 12 launches a year.

• Since 2014, SpaceX has made 8 changes to expand their site design and operations,which had to be evaluated and approved by the Federal Aviation Administration. They have never launched a Falcon 9 or Falcon Heavy from Boca Chica.

• SpaceX no longer plans to conduct launches of its Falcon launch vehicles at the Boca Chica Launch Site and has instead decided to use the launch site to develop, fabricate, test, and launch the Starship, a much larger vehicle than either the Falcon 9 and Falcon Heavy.  Starship + Super Heavy will be the largest rocket ever built.

• SpaceX currently holds a license for testing Starship prototypes at the launch site. This involves static fire engine tests and a series of suborbital launches ("hops") from just a few inches to up to 18 miles off the ground.

• SpaceX is currently drafting a Programmatic Environmental Assessement. The FAA is accepting public comments until November 1, 2021

Comparing Falcon and Falcon Heavy to Super Heavy/Starship

The Vehicles

• Falcon 9: a single rocket for light payloads

• Falcon Heavy: a Falcon 9 boosted with two other Falcon 9 engine cores for heavier payloads

• Super Heavy: the booster (bottom part for lift-off for the Starship)

• Starship: the spacecraft 

A New Environmental Impact Statement (EIS) Is Needed

• SpaceX’s new plans for Boca Chica mean vastly greater environmental impacts.  An Environmental Impact Statement (EIS) rather than an Environmental Assessment (EA) is needed. Federal Aviation Administration (FAA) must make that decision, not SpaceX (SpaceX was allowed to choose). That is a National Environmental Protection Agency requirement and is stated in FAA’s own regulations. An EIS  is more comprehensive and allows for more public input and participation.

• SpaceX is proposing to construct and operate a power plant, liquefied natural gas plant, a desalination plant, and a solar farm. These infrastructures and operations are not detailed in the Programmitic Environmental Assessment. Details lacking include, but are not limited to, source of natural gas for liquefaction, source of gas for the power plant, pipelines for delivery of gas, design of infrastructures, location of infrastructures, and infrastructure typical of these operations including flares, thermal oxidizers, and ammonia storage tanks.

• The Programmtic Environmental Assessment is an approach to avoid identifying cummulative impacts and consequently bypasses the minimization and mitigation of intended and unintended consequences.
• The Programmatic Environmental Assessment also does not address or include a launch failure analysis of potential impacts to proposed LNG export terminals at the Port of Brownsville, and the Jupiter MLP condensate upgrader facility and export terminals.

Alternatives

FAA should consider not just the “proposed project” and “no action” alternatives, but also other alternatives that include launches of Starship from an offshore platform, an alternative that Elon Musk has publicly mentioned and for which 2 job openings were posted early in 2020.  Another alternative is moving Starship launches to Cape Canaveral, for which the necessary infrastructure already exists and is situated further away from national wildlife refuge and/or state park land.

Cumulative Analysis

• A 3rd party launch failure analysis needs to be conducted due to the proximity of Port Isabel, Long Island Village and potentially three LNG export terminals within 5 miles of the launch site.  Public safety must be the first and foremost consideration.

• An analysis of the potential impacts to the proposed Jupiter LLC project, a crude upgrading, processing and export facility which includes an offshore loading facility 6 miles offshore. 

Mitigation

• SpaceX leasing/buying the Loma Ecological Preserve and other nearby lomas from the Port of Brownsville could serve as a measure of mitigation for the many increased impacts to the public, environment, and wildlife.

Environmental Impacts

• Construction and operational impacts include, but not limited to light, sound, vibration impacts, sonic booms, and air pollution.

• Impacts from testing, launching, and failures thereof, include but are not limited to explosions, debis fields, debris left in the ocean, fire, smoke, and release of hazardous fuels & vapors.  The launch site is adjacent to and surrounded by national wildlife refuge land, state park land, tidal flats that host many wading bird species, and public beach.

• A new Environmental Impact Statement is needed to anticipate impacts of all proposed infrastructures and operations. Development of the Starship has led to unanticipated impacts that have included explosions, debris, and brush fire, all of which impact wildlife, particularly nesting birds. Compared to the Starship, the Super Heavy will have 27-33 raptor engines, is much larger, and carries much more propellant. Testing and launching of the much larger Super Heavy booster will have much more impact.

Sea Turtle Nesting & Other Wildlife Impacts

• Development of a larger spacecraft, increased testing, and increased launches will increase impact on wildlife and habitat.

• 5 species of turtles nest on Boca Chica: Loggerhead, Green, Leatherback, Hawksbill, and the most critically endangered of all, the Kemp’s Ridley. Unlike the others, the Kemp’s Ridley comes ashore to nest during the day.

• Other endangered and threatened species in the region of SpaceX operations include ocelot, Gulf coast jaguarundi, piping plover, alpomado falcon, and red knot. 

• Increased beach closures increase the potential for sea turtle nests not to be found and relocated. Vibrations from testing and launches may disorient or prevent turtles from coming ashore to nest, and may have potential to harm incubating eggs that are not found or relocated.

• Light, for night-time construction or operations, impact nocturnal wildlife and sea turtles. Light impacts have been greater than anticipated particularly due to prolonged construction.

• Nighttime construction and activities have not conformed to the 2014 Final Environmental Impact Statement. A schedule of nighttime construction should be included in the new Environmental Impact Statement along with a new Biological Opinion for the Starship program.

• Modifications and adjustments to the Lighting Management Plan for Space X’s Starship program. Light affects nocturnal wildlife, particularly of concern are hatchlings from nests that are not relocated could potentially be disoriented by any lights from the launch facility. 

• Increase/prolonged  traffic due to construction, increase in employees, and visitors pose increased chances to traffic collisions resulting in wildlife injuries or mortalities.

Beach Closures & Other Impacts to Public Lands

• SpaceX is proposing to increase road closures to up to 500 hours per year and an additional 300 for response from failed launches or landings. The original 180 hours of closure has been routinely exceeded and not enforced.

• Most closures will occur during the day limiting public access to Lower Rio Grande Valley NWR, Palmito Hill Battlefield, and Boca Chica State Park, including the 7 miles of public beach. The public’s right to access all Texas beaches is written into the Texas Constitution As per The Texas Bill of Rights, Article 1, Section 33.

Methane and Emissions

• The Starship is powered by sub-cooled methane and oxygen.  Methane is highly explosive. The storage and use of large quantities of methane was not part of the 2014 EIS.

• Methane is a greenhouse gas and is 84 times more potent in its first two decades after release than carbon dioxide. Methane is the primary component of natural gas, with some emitted to the atmosphere during its production, processing, storage, transmission, distribution, and use. It is estimated that around 3% of total worldwide natural gas production is lost annually to venting, leakage, and flaring, resulting in substantial economic and environmental costs.

• What/where is the source for SpaceX’s gasses? Is the methane sourced from fracked gas? SpaceX should account for and mitigate for it’s full value chain of its operations, including the sourcing, escaping, and burning of gasses, especially fossil fuels like natural gas. Fracking is especially harmful to the environment, if SpaceX’s natural gas is sourced from fracking, it should be accounted for and mitigated.

• Starship testing is outlined in the November 2019 WR. Estimated testing emissions are as follows.

Climate Change

According to Texas A&M study:

• The number of 100-degree days could nearly double again by 2036.

• Extreme rainfall has become more frequent and severe and is expected to worsen.

• Hurricane intensity is expected to increase significantly. 

• The state has gotten drier despite increased precipitation.

All of the above have consequences to tax dollars, public health, and public safety.  Impacts from expected sea level rise should be part of the analysis.

Prepared by members of LRGV Sierra Club and Save RGV