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A U.S. Fish and Wildlife Service report sent to the Federal Aviation Administration for the FAA’s ongoing Programmatic Environmental Assessment (PEA) of SpaceX’s expansion plans for Boca Chica predicts the impact on endangered species in the surrounding area, though the report concludes that mitigation measures can help counter the impact.

CNBC first reported that the USFWS’s draft Biological and Conference Opinion (BCO) had been submitted to the FAA, having obtained the 141-page document through a Freedom of Information Act request. SpaceX is awaiting the results of the long-delayed PEA before it can conduct its first orbital launch from Boca Chica of a Starship/Super Heavy prototype. May 31 is the latest target date set by the FAA for the study’s release.

Over a two-year construction period, SpaceX has proposed expanding the solar farm at its production complex and adding parking lots, a liquid natural gas pre-treatment system, liquefier, payload processing facility, and pull-offs along SH 4, according to the BCO. At the Vertical Launch Area (VLA) closer to Boca Chica Beach, the company is proposing a redundant launch and landing pads, a second integration/launch tower, tank structural test stands, additional support buildings and a 15-megawatt power plan on 5.4 acres.

It appears the biggest losers in all this are shorebirds, specifically the piping plover and red knot, according to USFWS.

The BCO focuses on an “action area” of a 13-mile radius around the SpaceX site. Within that area, USFWS identified more than 903 acres of “unconsolidated shore, bare land, water and estuarine aquatic bed” that makes up critical habitat supporting foraging, roosting and sheltering that could be impacted by SpaceX’s proposed construction and operations.

Within the 903 acres is more than 446 acres of piping plover critical habitat that “will be directly impacted and result in loss of habitat,” according to the BCO. Red knot critical habitat covers the same 903 acres and the same portion is expected to be directly impacted, said USFWS in its report.

“Impacts would occur due to construction and stormwater runoff from impervious surfaces that would cause vegetation to grow within the wind tidal flats or reduce available piping plover and red knot food and roosting habitat,” said the agency. “Loss and degradation of foraging and roosting habitat could result in decreased fitness and survivorship of wintering piping plovers.”

Despite these impacts, and taking into consideration the amount of critical habitat and proposed critical habitat for these birds across the United States, losing 446 acres around Boca Chica “would not represent an adverse modification” of such habitat in general, the BCO concluded. In order to minimize potential impacts to listed species and critical habitat, SpaceX will implement certain “terms and conditions” contained in the BCO, according to USFWS.

“SpaceX agrees to continue to work with (USFWS and Texas Parks and Wildlife Department) to select appropriate native plant species to revegetate temporarily disturbed areas,” said the agency. “SpaceX will reduce impacts to vegetated wetlands and wind tidal flats, include locating the parking area predominately in uplands and locating installing, and siting payload and processing facilities away from wetlands.”

Further, SpaceX’s Spill Prevention, Control and Countermeasure Plan and Hazardous Material Management Program, plus conservation measures to “avoid and minimize erosion and sedimentation and to control the spread of invasive species will be implemented to help reduce potential adverse impacts,” according to the BCO.

In addition to plovers and red knots, USFWS looked at anticipated impacts on two species of endangered wildcats, the ocelot and the jagurundi, the northern Aplomado falcon, and five species of sea turtle: Kemp’s ridley, loggerhead, hawksbill, green and leatherback. USFWS said that if SpaceX proceeds with its expansion, the risks to all the species can be mitigated by basic measures.

In a cover letter accompanying the BCO, the agency said it has determined that the proposed expansion “is not likely to jeopardize the continued existence of the species listed above. The action area encompasses a relative small portion of the rangewide habitat of each of the species addressed in this opinion and small portion of each species’ population.”

Regarding Aplomado falcons as outlined in the BCO’s terms and conditions, SpaceX will continue working with the Peregrine Fund to identify suitable areas for reintroducing the birds and nests boxes, and will also continue work on a solar-powered Starlink system to provide round-the-clock video coverage of the falcons and their habitats, USFWS said.

“Starlink video would help understand predators, habitat, diet and ways to promote and protect the Aplomado falcons,” according to the report.

The BCO noted that SpaceX’s rocket manufacturing and associated development activities all take place on private land, don’t require federal approval, and are planned to continue whether or not the FAA gives the company a launch license for its first orbital Starship flight or subsequent flights, orbital and non-orbital. The FAA considers manufacturing etc. to be useful independent of whether it issues the licenses, according to the report.

“For example, the components manufactured and processed in Boca Chica could be shipped to support launch and test activities at any of SpaceX’s facilities, including Vandenberg Air Force Base, McGregor, Texas, or Cape Canaveral Air Force Station,” said the USFWS.

SpaceX founder and CEO Elon Musk said during a Feb. 10 presentation at the Boca Chica launch area that the first Starship/Super Heavy orbital flight would have to launch from Florida rather than Boca Chica if the FAA’s final PEA determines that a more comprehensive, time-consuming Environmental Impact Statement is required for its proposed expansion, which would preclude a license being issued anytime soon.

At the same time, Boca Chica would continue as the advanced research-and-development center for the Starship development program, he said. Meanwhile, SpaceX has developed a more powerful and reliable version of its Raptor rocket engine, dubbed Raptor 2, which will power the first Starship/Super Heavy test flight. Elon Musk, the company’s founder and CEO, tweeted on March 31 that he hoped to launch the first orbital flight this month from Boca Chica.

“We’ll have 39 flightworthy engines built by next (April), then another month to integrate, so hopefully May for orbital flight test,” he tweeted.

With the release of the PEA not scheduled until May 31,however, that flight will have to wait a little longer.