The commercial rocket launch company Space X is considering 3 possible locations for a launch pad for rockets that would place commercial and NASA payloads in space. A parcel of private land just off of Boca Chica beach, near the mouth of the Rio Grande, is the top contender. The LRGV Sierra group has submitted scoping comments regarding Spare X’s proposed rocket launch site. You can read the comments we submitted below.
The recent public scoping meeting in Brownsville and the scoping comments that we submitted are part of the process, established by the National Environmental Policy Act (NEPA), for preparing an Environmental Impact Statement (EIS). Because Space X needs the approval of a federal agency, in this case the Federal Aviation Administration, NEPA requires that they examine the potential impacts of the project on human communities and the natural environment. The scoping process is meant to solicit advice about the impacts that should be studied. Once the initial studies have been carried out a draft EIS will be released, followed by another chance for comments on its findings, and then a final EIS will be crafted. The EIS is meant to give federal decision makers the information needed to weigh the pros and cons of a project.
The Federal Aviation Administration page devoted to the SpaceX proposal is here
Sierra Club Scoping Comments Regarding Space X Launch Site
Please accept these scoping comments on behalf of the Sierra Club for the Environmental Impact Statement that is being prepared for the proposed SpaceX launch site near Boca Chica Beach in South Texas’ Cameron County. We appreciate the opportunity to participate in the National Environmental Policy Act process. The Sierra Club is concerned about a range of environmental impacts that construction of infrastructure and launches could have on fragile local ecosystems and sensitive species. These comments are intended to identify some of the potential impacts that we believe must be fully explored and addressed in the Environmental Impact Statement before this project can be approved.
At the heart of the Sierra Club’s concerns is the location chosen for the launch site. The project will be just off of Boca Chica beach, near the mouth of the Rio Grande on land surrounded by US Fish and Wildlife tracts which are part of the Lower Rio Grande Valley National Wildlife Refuge. The Lower Rio Grande Valley National Wildlife Refuge (LRGVNWR) preserves habitat along the final stretch of the Rio Grande, which is one of the most biologically diverse areas in North America. Here subtropical climate, gulf coast, great plains and Chihuahuan desert come together to create a series of unique ecosystems. The LRGVNWR is home to over 1,100 plant species and 700 vertebrate species (including 484 bird species), 20 of which are listed as federally threatened and endangered. During fall and spring migrations millions of birds from the Central and Mississippi flyways funnel through the area on their way to and from Central and South America, as do migratory bats and butterflies. Of the original habitat that once supported this enormous diversity, less than 5% currently remains, so every acre that is lost is important.
While the launch site will be built on privately owned land, it is “currently undeveloped” according to the handout provided at the May 15, 2012 public scoping meeting in Brownsville.[i] This would indicate that the land is currently in use by plant and animal species which are unaware of the difference between federal and private ownership. The proposed launch site would be surrounded by the 10,680 acre Boca Chica tract of the Lower Rio Grande Valley National Wildlife Refuge. The LRGVNWR was envisioned as a wildlife corridor, linking tracts of land for use by terrestrial animals, especially the ocelot and jaguarundi, which are listed under the Endangered Species Act. Both are small wild cats with fewer than 100 individuals believed to survive in the United States. According to US Fish and Wildlife, “Boca Chica is an important link of the Lower Rio Grande Valley ‘Wildlife Corridor.’ It connects habitat along the Gulf Coast to the Rio Grande River and allows wildlife to travel unimpeded.”[ii] The EIS should examine the impact of the project on this “link,” via the fencing off of the site and the resulting blocked access to ocelots, jaguarundi, and other wildlife. To what extent will the development of this site impact the viability of the coastal refuge tracts and the riparian tracts that follow the Rio Grande? Ocelot and jaguarundi are typically unwilling to cross open areas cleared of vegetation, as one would assume a rocket launch pad would be. If the passage from coastal to riparian habitat is restricted by the development of the site and launch activities, is it possible to mitigate these impacts through the purchase of lands that would create alternative wildlife passages, or are these impacts on endangered species irremediable?
Another threat faced by the ocelot, jaguarundi, and many other nocturnal species is the impact of flood lights. This was an important component of a successful lawsuit brought by the Sierra Club, Audubon Society, and Defenders of Wildlife against the Border Patrol’s Operation Rio Grande in 2001. Specifically, the illumination of brush prevents the regular nocturnal habits of animals, which in the case of the ocelot and jaguarundi includes hunting. This makes otherwise vital habitat of limited value in sustaining their populations. They are also disturbed by, and will avoid, intense lights and loud noises, both of which would be associated with the launching of rockets. The EIS should thoroughly examine the impacts on these (and other) endangered species.
Boca Chica beach, adjacent to the launch site, is also one of the few places where Kemp’s Ridley Sea Turtles, one of the world’s most critically endangered sea turtles, come ashore to nest in the spring and summer (April through July). Launches could potentially have a number of negative impacts on the Kemp’s Ridley, and the EIS should fully examine impacts on their coastal habitat as well as their behavior. In particular, if launches coincide with nesting will sea turtles be driven back by the noise and commotion? If eggs are successfully laid, will they be impacted during incubation or if hatching coincides with a launch?
This site is also in the heart of critical bird habitat. As mentioned above, it is a funnel for millions of migrating birds, as well as bats, each fall and spring. Many follow the coast, while others cross the Gulf of Mexico and “fall out” en masse once they reach shore. The loss of habitat in the middle of their flyway means a loss of places to rest and refuel, reducing the chance of a successful migration. Many birds that are seen rarely or not at all in the rest of the nation, some of which are listed under the Endangered Species Act, are found in the vicinity. These include brown pelicans, peregrine falcons, piping plovers, reddish egrets, northern gannet, American oystercatchers, and mangrove warblers. All could suffer from a reduction of available habitat. If towers are built using an open latticed construction, as is depicted in photographs of launches on the Space X website,[iii] birds could perch or nest on the structures, only to be blown off and killed when a launch occurs. Additionally, there is a great deal of literature regarding the impacts of vertical structures such as radio and cell towers upon birds and bats, which collide with the structures or their supporting wires. The number of impacts, and resulting mortality, could be dramatic in an area such as this though which so many migratory birds pass each year, making the specific design of the towers of critical importance. Many birds could also be negatively impacted by lighting: nocturnal birds such as owls and paraque may be unable to hunt, while birds that are active during the day may be unable to nest and sleep. The impacts on birds and bats should be thoroughly studied in the EIS.
The site selected by Space X is also adjacent to mangrove marshes and wetlands, which may be impacted directly or via runoff into the nearby Rio Grande. These are important habitats which are home to numerous species and act as nurseries for fish and shrimp. They are also highly sensitive to sedimentary runoff and chemical pollutants. The EIS should lay out the chemicals that will be used and/or stored on site, and how these would impact local ecosystems if/when they enter the ground or water. For example, what chemicals will be present in the “propellant storage and handling areas” mentioned in the public scoping meeting handout?[iv] The 2011 Environmental Assessment for Issuing an Experimental Permit to SpaceX for Operation of the Grasshopper Vehicle at the McGregor Test Site, Texas states that
“SpaceX produces approximately 10,000 pounds of hazardous waste annually at the McGregor test site. Hazardous waste is generally produced by engine testing and cleaning or dismantling of the engines. Hazardous wastes produced at the McGregor test site include acetone, oily rags, paint-related wastes, and hypergol waste in the form of water mixed with either monomethylhydrazine or nitrogen tetroxide in small amounts.”
Will these chemicals, or others, be present at the Boca Chica launch site, in similar or greater quantities? What impacts might such chemicals have on soil and water, marshes and wetlands and the Rio Grande, if they escape into the environment? How will they be stored to ensure that they do not leak or spill, and what measures will be in place to immediately clean up any inadvertent spills that may occur? What is the potential for them to ignite, and how would such an unintended fire be handled, how would it be cleaned up afterwards, and what would the anticipated environmental impacts of such a fire be?
The chemicals that will be released during successful launches should also be fully catalogued and quantified, and their potential to pass into the soil and water described in the EIS. This information should be broken down by the different types of launch vehicles that would be used – the “Falcon 9, Falcon Heavy (up to two per year), and a variety of smaller reusable suborbital launch vehicles” according to the public scoping meeting handout[v] – and expanded out to cover the twelve proposed annual launches. The accumulation of these chemicals in the soil and water, and their ability or inability to persist in the environment, should be discussed for the expected lifetime of the launch site.
Carbon dioxide emissions, which contribute to global climate change, should also be quantified and discussed in the EIS. The Environmental Assessment for Issuing an Experimental Permit to SpaceX for Operation of the Grasshopper Vehicle at the McGregor Test Site, Texas did this for Grasshopper RLV launches, which the Brownsville public hearing materials list as a “smaller” alternative which may at times be used instead of the Falcon 9 and Falcon Heavy launch vehicles. The 2011 EA shows that each launch of the Grasshopper RLV would release 23,752 pounds of carbon dioxide into the atmosphere. Similar numbers should be extrapolated for the Falcon 9 and Falcon Heavy.
There should also be a detailed discussion of the potential impacts of, and measures taken after, a catastrophic event such as the explosion of a rocket during or shortly after launch. This possibility was touched on very briefly in the Environmental Assessment for Issuing an Experimental Permit to SpaceX for Operation of the Grasshopper Vehicle at the McGregor Test Site, Texas. The relevant section (188.8.131.52 Impacts from Launch Failures) was a scant two paragraphs, however, and dealt solely with CO2 emissions. The EIS now being prepared should discuss the full range of impacts in detail, including the types and quantities of chemicals that might be released, the impact of falling debris and its persistence in the environment, and the risk of associated fires. This location is also periodically hit by tropical storms and hurricanes. The EIS should discuss measures that would be taken in the event of such a storm to ensure that stored chemicals, as well as solid structures, are not torn apart by high winds or swept offsite by flooding and thereby thrust into adjacent ecosystems.
The EIS must also discuss impacts upon the human environment. The project area is in the vicinity of some of the last battles of the Civil War – the Palmito Ranch Battlefield, site of the war’s last major battle, is also off of Highway 4 – and the area should be surveyed for archaeological remains before any construction commences. Boca Chica beach, where the Rio Grande empties into the Gulf of Mexico, is adjacent to the proposed launch site. The EIS should describe the impacts of launches on public access to the beach. Will the beach or other nearby lands be closed to the public during launches? Will the water just offshore be closed to boaters? Or will these areas be filled with sightseers, with the resulting increase in litter and the potential trampling of sea turtle nests and mangrove marshes?
Again, the Sierra Club appreciates the opportunity to participate in the NEPA process, and looks forward to continuing to provide input and insight as the Environmental Impact Statement is prepared. The Sierra Club should be considered a stakeholder in this process, and we hope that SpaceX will respond fully to these scoping comments in the draft and final EIS documents.