The Federal Aviation Administration has plenty to consider from the many public comments regarding SpaceX’s Starship-Super Heavy development program at Boca Chica.
On Nov. 15 the FAA released transcripts of comments from virtual hearings held Oct. 18 and 20 to solicit feedback on the agency’s draft Programmatic Environmental Assessment (PEA) of SpaceX’s proposed activities at the site. The FAA received 121 verbal comments during the two hearings, some from people who spoke during both hearings. The agency received 17,000 written comments during the comment period, which ended Nov. 1.
Commenters were sharply divided over SpaceX activities at Boca Chica, some accusing the FAA of not going far enough in reviewing the Starship program and calling for a full Environment Impact Statement, more rigorous than the PEA. Some predicted catastrophic effects on Boca Chica’s wildlife and environment, while others applauded the Starship program as a major advancement toward interplanetary travel with probablyminimal impact on the environment.
Among those arguing during the hearings that the FAA should conduct the more stringent EIS was Jim Chapman, president of Friends of the Wildlife Corridor, who said that according to the FAA’s own regulations covering the National Environmental Policy Act, SpaceX’s “massive expansion” at Boca Chica clearly meets the criteria for the agency to conduct an EIS rather than a PEA. The agency violated NEPA by allowing SpaceX to determine whether a PEA or EIS was warranted, when NEPA stipulates that it is the FAA’s decision, he said.
Neither does the draft PEA contain a launch-failure analysis of the worst-case scenario in the event Starship-Super Heavy explodes on or above the launch pad at Boca Chica, Chapman said. Starship is the six-engine spacecraft to be mounted atop the massive, 29-engine Super Heavy booster, both of which SpaceX is readying for the first orbital flight.
“The FAA is also required to do a safety-risk analysis, a hazard risk analysis, and they’re — those are absent in the EA as well,” Chapman said. “There are also ten other documents that are missing from the draft EA that are referred to but are missing from the EA.”
He added that SpaceX’s construction of a 450-foot launch tower at Boca Chica is a blatant violation of the NEPA requirement that a project under environmental review cannot commence “irretrievable and irreversibly commitment of resources” until completion of that review. Chapman also argued that the FAA should be considering alternatives such as moving testing of the Super Heavy to a designated large rocket testing facility such as that located at Stennis Air Force Base in Mississippi.
Joyce Hamilton, who described herself as a South Texas resident and frequent visitor to Boca Chica, also argued in favor of an EIS and said her “most passionate concern” is to protect and conserve Boca Chica’s wildlife and habitat.
“I would also like to speak up for the rights of the local community, the fishermen, the sea turtle rescue volunteers, the naturalists and birders and the families from the surrounding area who lost their right to regular access to the beach on a regular basis,” she said.
Frequent closing of Boca Chica Beach and S.H. 4 leading to it during “launch activities” is a frequent criticism among many opponents of SpaceX’s current and proposed activitiesin Cameron County. Sharon Almaguer, a Port Isabel property owner and resident, also called for a full EIS for a project she said “will fundamentally transform this area.”
Almaguer said beach access has been cut off because of SpaceX and that the company had violated agreements with the county regarding beach access.
“They have regularly closed off the beach when they were not authorized to do so and have basically just … run roughshod over locals in the area,” she said. “And that’s been wrong and their heavy-handed tactics have not gone unnoticed, and they are inappropriate.”
Almaguer said her house shakes every time SpaceX launched a Starship by itself, with no more than three engines, and predicted widespread property damage if the company launches the much more powerful Super Heavy in combination.
On the other side of the opinion divide were commenters such as Michael O’Halloran, who said it appears that SpaceX has a good plan for mitigating “the vast majority of environmental effects from the build and test sites” at Boca Chica.
“I feel this is to a degree that more than satisfies me, as a member of the public and someone who cares a lot about the environment,” he said.
O’Halloran said a number of academic studies indicate that space materials within the inner solar system are worth “quadrillions of dollars” and that being able to access such resources and move industries off Earth could benefit the planet environmentally. SpaceX’s Starship-Super Heavy launch architecture could provide the technology that makes such advancements possible, he said.
“In the very long term, small environmental effects at Boca Chica may end up allowing for drastically less environmental damage worldwide,” O’Halloran said. “Starship and Super Heavy are clearly worth the gamble, so to speak. As far as the economy, I’d like to point out that space technology will likely be the next sector that will revolutionize the way we live.”
He said it’s important that the United States leads the world in this pursuit in order to “set the tone” for the utilization of space resources and exploration over the next century.
“Starship is our clearest path towards remaining a leading voice for responsible space travel,” he said.
Zachary Parker, a resident of Georgia, said SpaceX’s Starship program deserves the country’s support but called on the company to work with community members, local and federal government and others “to ensure that the environmental costs associated with such an ambitious launching are minimized, mitigated and contained.”
“SpaceX has a social responsibility to fulfill, and that entails making sure the ecological footprint of this important exploration is sustainable,” he said.
The FAA released its hearing transcripts three days after SpaceX’s first ever static-fire test of six engines simultaneously, installed in Starship SN20, which the company plans to send on the program’s first orbital mission pending FAA approval. The agency may issue a “Finding of No Significant Impact” upon conclusion of the PEA and grant the experimental launch permit to SpaceX for its first orbital Starship flight, or it may deem an EIS necessary after all, which would mean substantial delays for the program.
The agency has set a Dec. 31 deadline for completing the PEA.