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OPEN LETTER YOU ARE FREE TO SUBMIT TO THE FAA AS MEMBER OF OUR COMMUNITY Re: Draft Environment Assessment of the Boca Chica Operations of SpaceX.
🕑 Added 2021-10-14 18:03:54 +0000 UTCTo: Stacey Zee, Environmental Protection Specialist, FAA
James Repcheck, Manager Safety Authorization Division, FAA
From: The YouTube Channel ‘Common Sense Skeptic’
Dated: October 13th, 2021
Re: Transcript of attached video: https://youtu.be/7bdkcoiFaN0
To Whom It May Concern,
This is an open letter to the FAA, addressed to Stacey Zee Environmental Protection Specialist, and James Repcheck, Manager Safety Authorization Division, in response to their September 17th 2021 posting on Twitter and the FAA website asking for public input regarding the Draft Programmatic Environmental Assessment of SpaceX StarShip/SuperHeavy launch vehicle Program.
We are writing on behalf of our 31,000-member strong online community - our channel The Common Sense Skeptic has been following the activities of Elon Musk and SpaceX for several years now, and producing video content based largely on Musk’s various claims made starting in July of 2020.
We had intended to go through the 150+ page document point-by-point with our concerns, but we note that this document was not created by the FAA. This document was prepared by three environmental engineers who are SpaceX employees, and one employee named Brian Pownell, who is a transportation engineer working for a consulting firm named Kimley Horn & Associates. That firm seems to specialize in large city-scale infrastructure projects rather than anything remotely environmentally friendly.
Upon completion, this document was submitted to Recheck at the FAA for consideration; and, as part of that consideration, your agency is now asking for input on this document outlining SpaceXs continued sprawl across the general Boca Chica area.
To set the tone of this letter, we - our channel, and our online community - are space enthusiasts, but we do not support Elon Musk’s unsanctioned, reckless and destructive activities in the Boca Chica area.
Neither should the FAA, because the activities being conducted here do not resemble whatsoever the original intended, declared, permitted purpose of this site.
A bit of history here,
In the beginning, when SpaceX was shopping for launch sites and Texas threw their hat in the ring along with the city of Brownsville, Musk’s declared intention was to establish a single launch pad and infrastructure for variations of the Falcon rocket, which was commissioned and endorsed by NASA to service the International Space Station as part of a $1.6billion contract. This was how the proposed facility was to be built.
To attract Musk and SpaceX to Brownsville, a list of incentives was presented to Musk, including $2.3 million from the Texas Enterprise fund, and another $13 million through the Cameron County Spaceport Development Corp, a private-public business which would quickly be turned against the residents of Boca Chica Village to force them out of their homes on Musk’s orders.
As part of this incentive package, Texas also changed state laws to allow Musk to launch one rocket per month, on weekdays between 7am and 7pm, Monday to Friday, excluding holidays. This state law also prevents SpaceX from being sued for noise complaints as a result of those launches - which were supposed to be of Falcon9 or Falcon Heavy launch vehicles.
Since accepting the state’s invitation and money, Musk has been operating in the Boca Chica area as if he has absolutely no oversight.
Instead of building a single launch facility similar to SpaceX leases in Cape Canaveral and Vandenberg Space Force Base, Musk has instead constructed a massive industrial complex and launch operations centre in an area that is situated between no less than four separate ecologically important and sensitive areas.
They are Boca Chica State Park. Brazos Island State Park, the Las Palomas Wildlife management area, and Boca Chica Beach. Musk’s Launch centre is directly adjacent to every single one of those protected areas.
AND, Musk has built a completely separate industrial manufacturing complex that was never accounted for in any other assessment!
In 2014, your office - the Federal Aviation Administration - released an EIS report commissioned in 2013 to evaluate the impact this launch complex would have on the surrounding environment and wildlife, with special emphasis on federally-protected species. That assessment was conducted using the following parameters:
A) That the site would be a single launch platform, for
A rocket system known as the Falcon, that was
C) Launching NASA-endorsed missions in support of the International Space Station.
In fact, it’s right there in your cover artwork!
The Falcon rocket, which carries capsules called Dragons (Cargo Dragon, Crew Dragon) is now a proven system - the Falcon being a 70m-tall multi-stage rocket requiring a propellant load of 395 tons in the first stage, and another 92 tons in the second stage, for a total of around 500 tons. According to the SpaceX user’s guide for Falcon, the noise rating inside the fairing of the vehicle is 131.4dB.
With those parameters and logistics in mind, the FAA conducted their initial environmental assessment and at the time the FAA indicated concerns surrounding the federally-protected and critically endangered mammal, bird and reptile species, naming the ocelot and jaguarundi; the Aplomado Falcon, piping plovers, and red knots; and the Kemp’s Ridley, hawksbill, leatherback, loggerhead and green sea turtles. They are all named in the December 18, 2013 Final Biological and Conference Opinion Consultation number 02ETCC00-2012-F-0186.
Your final report published in May of 2014 also noted the following state-protected species of flora and fauna in the area, including birds such as:
The White-Faced Ibis
Texas Botteri’s Sparrow
Sooty Tern
This site is also part of a migration corridor for over 500 species of birds making annual migrations. The Rio Grande Valley Birding festival celebrates this site, and this single event brings in $463 million to the region each year.
Additional mammals that were listed include:
The West Indian Manatee
Southern Yellow Bat
White-Nosed Coati
And, the following reptiles were noted:
Sheep Frog
Black-Striped Snake
Northern Cat-Eyed Snake
Speckled Racer
Texas Indigo Snake
Texas scarlet snake
Texas Horned Lizard
Texas Tortoise
Black-Spotted Newt
Mexican Tree Frog
South Texas Siren
And the White-Lipped Frog
There are also three types of plants on the state and federal endangered list that were noted:
South Texas Ambrosia
Texas Ayenia, and
The Star Cactus.
Both of these papers were drawn up using the parameters of the Falcon launch systems, which would be landing their boosters either in the Atlantic Ocean or on barges for recovery. Not on site. There is no ‘re-landing pad’ in the original diagrams.
But Musk isn’t launching Falcons into orbit from this site. He’s destructively testing a much bigger, unproven launch vehicle that is more powerful, more destructive and far louder than the vehicle this site was considered for.
And there is absolutely no chance the above-noted endangered creatures and plant-life are not being adversely affected by the Spacex expansionist and testing activities happening at Boca Chica.
The 100-acre wildfire caused by Musk at this site in 2019 is proof that SpaceX cannot be trusted with this biologically and ecologically sensitive area. In fact, Musk is quoted as telling the press, “We’ve got a lot of land with nobody around, so if it blows up, it’s cool.”
It is important to recognize the difference between The Falcon 9 and the Starship, because these two vehicles bear no resemblance to each other.
The Falcon9 with a Dragon capsule or fairing stands up to 70 meters tall.
The StarShip, atop its superheavy booster stands 120 meters tall
The Falcon 9 requires a combined propellant load of RP1 refined kerosene and LOX totalling 500 tons, firing 9 proven Merlin engines at launch
The StarShip Super Heavy combined vehicle requires 4600 tons of liquid methane and LOX, firing up to 37 unproven Raptor engines at launch, as per SpaceXs submitted documents.
The RP1 propellant used by Falcon9 is more stable at room temperature, stored at 20 degrees celsius and presents less of an explosion hazard than liquid methane which has to be kept stored at -161 Celsius as a cryogenic fuel. This is what happens when one of those tanks ruptures.
The Falcon 9 has a noise rating of 131.4 db inside the fairing, a result up the 1.7 million pounds of thrust it produces.
The Saturn V was measured at up to 220dB at the launch site, a result of the 7.6 million pounds of thrust it produces.
And the SuperHeavy booster is expected to produce twice the power of a Saturn V with over 16 million pounds of thrust, potentially doubling the volume of the SaturnV vehicle at Launch.
Decibels are measured on a logarithmic scale. For every 10 decibels, you are measuring double the energy being produced by this device. Let’s call the volume of the Falcon 9 130db, rounded down. At 140 it is double that volume. At 150 it has quadrupled. 160, factor of 8. 170, factor of 16. 180, factor of 32. 190, factor of 64. 200, factor of 128. 210, factor of 256. Making the Saturn V at 220db 512x louder than then Falcon 9. And since the SuperHeavy booster promises double the thrust, we should expect it to be up to twice at loud as the Saturn V, making it 1024x louder than a Falcon 9.
This level of energy isn’t experienced as noise. Above 194dB sound is converted into a shock wave, and that shock wave will kill every living thing in the direct vicinity of the launch pad, and blast the eardrums out of every creature until that shock wave drops below 140dB. The destruction of hearing is often a fatal injury for animals.
The Falcon9, at 131.4db was below the permanent hearing damage threshold. The SuperHeavy at a possible 230dB would be 1000x times greater.
So, the entire Appendix B of this document regarding the effects of noise, referred to throughout this document, is sheer, unmitigated nonsense, since they use 150dB as the SPL in the immediate area of the launch site on their diagrams on Page 11 of Appendix B.
KBR has embarrassed themselves in this assessment by ignoring such obvious historical parallels using other known launch platforms ie: the Saturn V and Space Shuttle launches.
Assuming their modelling is correct, and their numbers were just low we can swap out the 150 they used with the known 220db of a SaturnV launch and show that South Padre Island can expect to be blasted with 180-190 dBs of sonic energy. And every living thing in the Boca Chica area will be deafened or destroyed.
These are demonstrable facts.
So, too, is the destructive potential of the StarShip and SuperHeavy booster.
In 2016, a Falcon9 such as the one Musk said would be launching from Boca Chica exploded on pad SLC40 at Cape Canaveral during propellant loading - meaning, this vehicle was not yet filled. Yet, this explosion was felt several miles away and destroyed SLC40, taking almost a year to rebuild.
If this vehicle had been fully fuelled, it would have contained only 10% of a combined StarShip/SuperHeavy stack. It was not fully fuelled.
In 1969, the Soviet Union launched a series of rockets known as N1s. N1-L5 was the second such launch, and it crashed on the launch pad after clearing the tower. That explosion was measured in kilotons, estimates ranging from one to seven kilotons. It decimated the launch complex and surrounding area, throwing debris ten kilometres from the site and raining burning fuel for half an hour.
N1 was fuelled using RP1 and LOX, with a total load of propellant around 2300 tons.
StarShip atop SuperHeavy carries twice this amount of methane and LOX, total of 4600 tons.
Meaning, a loss of vehicle on the Boca Chica pad will be even larger with a greater degree of damage than the N1 catastrophe.
At Cape Canaveral’s Launch Pad 39A, where the Space Shuttle launched from, the closest civilian homes are 20 kilometres away in Titusville.
At SpaceXs launch complex, the closest civilian homes are the remaining citizens of Boca Chica Village, only 2.4 kilometres away.
The larger communities of Port Isabel and South Padre Island are only 8kms away.
Populated areas of Mexico are about 12 kms away.
And the Rio Grande, which acts at the Mexican/US border in this area, is only 4kms away.
If operations at Boca Chica were being conducted with the same safeguards as the distance between Titusville and pad 39A, THIS is what that safety radius would look like, extending well into Mexico.
Just out of curiosity, has anybody bothered to ask Mexico what they think about ICBMs being launched two miles from their territory? What agreements are in place with Mexico with regards to this launch site? What happens if one of these rockets lands In Mexico?
And while we are on the topic of location, has it occurred to the FAA that if Musk’s intention is to launch orbital rockets from this site, that the site is quite possibly the most ridiculous location imaginable? From Cape Canaveral, launches can take off in a wide swing of azimuths, but from Boca Chica the corridors available for launches are extremely limited.
When this process began, you gave Musk what he wanted based on what he promised and he took ten times more. If the FAA continues down this path, he will never stop taking more than you agree to. In fact, despite the plans he outlines in this report bearing his company’s name, these are not his end goals by any stretch of the imagination.
This PEA submitted by SpaceX shows the next level of expansion he intends to pursue - doubling the size of the current launch facility. AND, he intends to build a five acre natural gas plant to power this expansion, complete with chimneys 150 ft tall. But he won’t stop there.
In April 2021, the Dallas Morning News questioned whether or not Musk could create his own city, which went hand in hand with Musk sending out a general hiring call for people to move to StarBase USA, as he now calls the area.
In June 2021, Texas Monthly declared Elon Musk is turning Boca Chica into a space-travel hub.
This is NOT what was proposed in 2012. If it had been, it would have been shot down immediately. But Musk has snuck in under your noses and created this situation that you have not halted, and now you need to step up and shut it down before it gets any further out of hand.
You, the FAA, began conducting this new environmental assessment a year ago, announced on November 23 of 2020. You, the FAA, began taking public input on this topic at that time.
Yet, since then:
You have breached your own EIS and agreements with SpaceX by authorizing StarShip launches known as ‘hops’ for reasons unknown with no safety assurances from SpaceX.
On December 8th, 2020, the FAA authorized the hop of SN8. This vehicle exploded on impact while landing.
Despite SpaceX breaching their license with the FAA with the SN8 launch, and despite Musk attacking you on Twitter for holding up their ‘progress’, and despite Musk fuelling up the SN9 craft in defiance of a do not fly order while you conducted ‘an investigation’, the FAA then went on to authorize the launch of SN9 on February 2, 2021. This craft also exploded on impact while landing.
A month later, on March 3rd, you authorized SN10 to hop. This machine exploded 8 minutes after a hard landing.
The same month, SN11 launched with your misguided approval, through an impossibly foggy morning that should have grounded all craft. That machine never even made back to Earth in one piece, and contaminated many square kilometres of the protected sanctuaries surrounding the Boca Chica area, spreading fields of stainless steel shrapnel across the landscape due to a mid-air explosion. Debris was flung 8 kilometres away from that explosion.
THIS ALL HAPPENED WHILE YOUR NEW EIS ASSESSMENT WAS TAKING PLACE.
Now, without FAA authorization and in defiance of warning letters from your office, Musk continues to build a 480ft/145m tall launch tower on the very edge of their launch site, right next to the fence. Media reports you, the FAA, telling Musk he is building this structure at their own risk, but Musk has in sheer defiance your warnings continued to build - right at the very edge of the complex.
In fact, it is reported that Musk lied to your federal agency about this tower in May of 2021, declaring an environmental review was not necessary because this tower was not meant for launches and that they are only going to use it as an “integration tower for production, research and development purposes and not for FAA-licensed or -permitted launches.”
Meanwhile Musk and his company president Gwynne Shotwell were both telling SpaceX fans, employees and investors in June of 2021 that Musk was planning to launch the first orbital StarShip in July of 21, landing in the waters off Hawaii.
That launch would have required a tower.
There is no other launch tower on the Boca Chica site.
Musk lied.
Shotwell lied.
And now SpaceX is installing arms on that same tower to catch the super heavy booster when it comes back to land - which is another unproven and highly dangerous maneuver not covered in the 2014 FAA EIS.
In your original EIS from 2013/2014 there were no re-landings of craft at this site. Boosters from falcon 9 were to be dumped in the Atlantic or recovered from landing barges - not landing back at this site and creating a second chance for a loss of vehicle with catastrophic effect.
These actions and changes of paradigm prove that no matter what conditions you place on Musk and SpaceX after reviewing this new draft programmatic environmental assessment, Musk will continue to do as he pleases until somebody eventually is forced to shut the entire complex down.
In addition to the May 2014 Final EIS, there have been a number of WRs, or written re-evaluations. The FAA website summarizes that the contents of the 2014 EIS remain current and substantially valid - despite the fact the vehicle at the centre of this development is nine times larger, 1000x louder, and twice the height and width of the vehicle at the centre of the 2014 assessment while ignoring the sprawling industrial complex eating up real estate two kilometres away.
In short, these written re-evaluations are pure nonsense, and the authors of those papers were in serious denial about the changes being made to the launch vehicle systems and the supporting infrastructure.
And now, we are going to dive into a section of the PEA submitted by SpaceX, where Musk outlines the new infrastructure he intends to build to service his grand vision.
There are several points we need to elaborate upon:
The proposed expansion of the Boca Chica launch complex pictured on page 28, expanding it to more than twice the size it currently is, which is already far larger than what Musk originally proposed for this area. This is cause for great concern, extending and backfilling further and further out into the salt plains and marshlands. Orbital Launch Mount B at the 5 o’clock position is once again right at the very edge of the facility. At no other facility in Vandenberg or at Cape Canaveral is a launch platform constructed in such a way. Launch towers are located at the centre of a well-cleared, normally circular complex, giving a much-needed buffer between launch blast zones and the perimeter of the site.
Page 32, article 2.1.4.7 describes a proposed 5.4acre, 250 megawatt natural-gas-powered power station with structures standing 150 feet, 50m tall is of even greater concern. If such a facility was located at the intersection of Eichorn Blvd and State Hwy 4, this would be the massive footprint required for this facility. And this is just for the power plant. Additional infrastructure being introduced in this paper include an expansion of the solar farm to double its size, a natural gas pretreatment facility, liquefier, and desalination plant - as listed quietly on page 9.
A twitter personality known as ESG Hound who is an environmental engineer specializing in compliance has been gracious enough to share these slides demonstrating our points. Such a facility will require a pipeline to feed 50,000,000 cubic feet of natural gas to it daily. Constructing that pipeline across these tidal wetlands will be devastating to them. To obtain 50 million cubic feet of natural gas daily, this will require the output of 300 new wells, and all the associated energy required to drill and operate those wells.
Those wells, according to ESG Hound, will be located at least 70 miles away from Boca Chica, because that’s where the nearest natural gas producing fields are. This is backed up by this map from the Texas Commission on Environmental Quality. On this map each red dot is a gas well, each blue dot is an oil well. This power plant will require the output from 300 more red dots.
Additionally, if they are processing the gas on this site, there will be byproducts from that refinement that will need to be disposed of and carted away. Using SpaceXs 250megawatt station as the starting point, ESG Hound uses their numbers to determine such a facility would require a non-stop array of tanker trucks to haul away 1.2 million gallons of waste water, 6 million gallons of condensate, and 105 million pounds of gas co-product annually from processing field gas into the refined gas used by the power plant.
And this, in no way shape or form, addresses the fuel requirements for these launch vehicles. This is just for the power plant that will be running 24/7, every day of the year. As will all the support facilities for this power plant.
CONCLUSION:
In 2014, the FAA believed they were authorizing a single launch complex, for a small rocket system that was endorsed by and created for NASA, that would launch monthly resupply and crew missions for the ISS, on weekdays between 7am and 7pm according to Texas state law.
What you’ve allowed Musk to build in Boca Chica though non-intervention, without county, state or federal authorization, is his own private community, industrial rocket complex, private destructive testing range that pollutes protected sanctuaries, and multi-pad launch site for a completely different vehicle more akin to an ICBM that is unproven, a thousand times louder, with ten times the amount of explosive potential than the machine he promised - one that is a threat to everyone and everything in the area even if it doesn’t explode.
To recap some bullet points:
Musk told federal and state authorities this site would become a single, typical launch platform similar to Cape Canaveral launch pads.
He lied.
This facility has become Musk’s own personal destructive rocket testing range and 24/7 industrial manufacturing facility.
Musk told federal and state authorities this site would be used to launch variations of Falcon in support of the ISS.
He lied.
Neither the Falcon, Falcon 9, nor Falcon Heavy have ever launched from Boca Chica, nor are there any plans to do so.
Musk told federal and state these operations would take place from 7am to 7pm from Monday to Friday, not on weekends or on holidays.
He lied.
He has conducted tests at all hours of the day and night, and the manufacturing facility runs 24/7.
Musk told state authorities he would honour an annual cap of 300 hours for blocking state Highway 4 to conduct launch operations.
He lied.
His security force in the area has in fact closed Hwy 4 in excess of 1,000 hours per year, telling those people they are redirecting they have authority from the county for the closures.
They also lied.
And, they are being charged with impersonating law enforcement as a result.
Musk constructed a 50-storey launch tower without FAA authorization.
You told him to stop.
He didn’t.
In fact, he told you in writing this wasn’t even a launch tower.
He lied, and he is daring you to tell him to remove it.
That is the pattern of Elon Musk. He lies. He takes. He forces his way in. And he challenges you to oppose him because if you do, “you’re against him and his mission to save humanity.” Which is all nonsense.
You have the authority to stop this in its tracks and make Musk honour the original agreements.
Let’s reword that. You have the obligation to stop this in its tracks and make Musk honour the original agreements.
You are, in fact, bound by your office’s mandate to enforce these laws and shut down Boca Chica operations for non-compliance, to remove all unauthorized structures, and demand this site be returned to its natural state at Musk’s expense.
You, the FAA do not get to pick and choose which laws signatory parties have to obey based on their celebrity status. By doing so, you become complicit in the disasters to come, and they will eventually include human fatalities.
From the FAA website:
FAA ENDURING MISSION
Our enduring mission is to provide the safest, most efficient aviation system in the world.
FAA VISION
We strive to reach the next level of safety and efficiency and to demonstrate global leadership in how we safely integrate new users and technologies into our aviation system. We are accountable to the American public and our aviation stakeholders.
The FAA enduring mission statement is “to provide the safest, most efficient aviation system in the world.
To reach the next level of safety and efficiency and to demonstrate global leadership in how we safely integrate new users and technologies into our aviation system.”
By ignoring your own declared mantra you are failing the residents, wildlife and populated areas around Boca Chica, allowing an eccentric billionaire with a terrible environmental and operational record to continue to operate in defiance of your orders, in breach of your agreements, in violation of state and federal laws, who will embarrass you through his 60 million twitter followers if he doesn’t get his way.
This document is an environmental assessment. The only conclusion the FAA can reach with regards to its contents is that there is no environmental benefit associated with this proposal, and if it is allowed to proceed will irreparably further harm the delicate unique ecosystems of Boca Chica.
Accordingly, as a federal agency entrusted with the public good, the FAA must reject this proposal.
We expect you to do your duty.
Sincerely,
The Common Sense Skeptic And YouTube Community.
Comments
underserf
Yeah, Phineas Freak's unacknowledged grandson's encouragement was just the stimulus I needed to add my support. Keep up the awesome work, here's to 56^2 and more supporters in the future!
Common Sense Skeptic
Thunderf00t is a great friend to the channel, and got us on the map :) Hoping to one day do a collaboration with him.
