"Free the Sky" Comments on Draft Environmental Assessment (EA) for SpaceX Starship/SuperHeavy Increased Cadence

Guest Post by Nina Beety, Free the Sky. Comments re: A Poorly Publicized Proceeding and the FAA's patently false conclusion of “no significant environmental impacts" and now: Vandenberg

Californians have a lot going on right now, yet Nina Beety was still able to post comments about issues with increased launches in Boca Chica by the deadline to comment, which was January 17. PDF here.

There is another proceeding now underway “Study to examine environmental impacts of increased SpaceX launches from Vandenberg” with a deadline of January 27 for written comments. Information about submitting is at bottom of this post. You can help your CA neighbors by commenting on this proceeding to oppose increased launches. (The Dept of Defense has become involved, and instead of investigating environmental concerns, is defending increased launches.)

Re: Boca Chica

January 17, 2025

To the FAA Comments regarding Docket No. FAA-2024-2006:

Draft Environmental Assessment (EA) for SpaceX Starship/SuperHeavy Increased Cadence

I oppose Increased Cadence and ask the FAA to halt SpaceX Starship/SuperHeavy launches as destructive to the environment.

SpaceX, a private, for-profit company, is conducting business in the United States with widespread environmental, human health, public safety, and economic impacts, costs, and hazards on an international scale.

Despite this, only one in-person hearing was held locally in Brownsville, Texas. With AI, virtual and online comments can't be guaranteed to originate from actual persons, and AI and bots can skew comment numbers. Another in-person hearing was canceled and not rescheduled. No hearings are scheduled in the other states impacted including the Gulf states, Hawai'i, and California. No hearings are scheduled in other countries including Mexico, Chile, Peru, Cuba, the Caribbean islands, Indonesia, Madagasgar, and all the countries in the Indian Ocean. Instead, the FAA fast-tracked this poorly publicized proceeding.

The existing launches cause extensive environmental damage. This proposal is for a rapid accelerating increase: SpaceX wants to increase SuperHeavy launches and landings from 5 to 25, and Starship landings from 10 to 25, in just two years' time. The proposal also changed the word “disposed” to “expended”, but what SpaceX actually wants is the option to “dump” Starship and SuperHeavy rockets in the Indian Ocean, Pacific Ocean, and Caribbean/Atlantic Ocean.

A full Environmental Impact Statement by the FAA is a requirement to more thoroughly assess the impacts from current operations and future impacts.

The FAA's patently false conclusion of “no significant environmental impacts” in the categories it examined is arbitrary and capricious, not reasoned decision making., and frankly, embarrassing. The FAA's conclusion rests on wishful thinking and stands in stark contrast to all the data available on negative impacts from rocket launches and from SpaceX in particular including as recently as Thursday, January 16. On Thursday, a SpaceX rocket blew up, exploding repeatedly, filled the sky with fiery debris, showered Turks and Caicos and the surrounding ocean with fallout. Injuries or deaths have not been reported so far – a miracle if it bears out. Property damage could be considerable. Exposing the public to danger is unacceptable, and this also posed a hazard to airplanes and air traffic from the explosion and debris shower, which is very grave, in addition to grounding flights due to the danger. https://abcnews.go.com/WNT/video/faa-orders-spacex-investigate-starship-explosion117814482

https://www.nbcnews.com/science/space/spacex-starshipdebris-littered-islands-turks-caicos-rcna188223

Air Quality

All successful and failed SpaceX rocket launches put pollutants into the sky and air, from ground level to the stratosphere, reducing the air quality for all living beings. Five times the present launches, means five times the present contamination. With less time between launches for the air to clear. These are vapor/gases and particulate matter. And when there is an explosion like the SuperHeavy launch in April 2023, which as you know destroyed the launch pad, dust, debris, and chunks of concrete, rebar, and other materials filled the air in a great cloud which traveled miles. https://www.popularmechanics.com/space/rockets/a43729691/spacex-starship-launch-failurefallout-fire/ Oops, SpaceX Blew Up Its Own Launch Pad and Started a Fire in a State Park

The stratospheric changes are severe and threaten life on Earth by impacting climate and the ozone layer. Rockets destroy ozone by multiple mechanisms. The rockets' radical emissions cause immediate and total ozone destruction as they transit through the sky, creating huge ozone voids. Second, the exhaust, water vapor, and chemicals rockets inject in the stratosphere persist for years and interact with ozone, destroying it over the long term. Third, when rockets and satellites de-orbit, the shockwave creates nitric oxide which destroys ozone. Finally, the sun's rays interact with oxygen in the stratosphere and replenish the ozone layer. However, the exhaust, water vapor, black carbon, and fuel components such as alumina which rockets put into the stratosphere, block the sun’s rays, reducing the sun’s creation of ozone, and reducing ozone layer repair and replenishment. Because rocket byproducts are long-lived and persist in the stratosphere for 3-5 years, accumulating with every rocket launch, each launch decreases ozone regeneration.

https://freethesky.org/2022/02/03/rockets-destroy-ozone-and-cause-climate-changeaerospace-programs-deadly-impacts/

Climate

Rockets especially SpaceX cause climate change. The exhaust, water vapor, black carbon, alumina, and other chemicals that remain and accumulate in the stratosphere creating a growing blanket that traps the heat emitted from Earth, keeping it from venting into space. That causes global warming, and it increases with each launch.

Coastal Resources

SpaceX's launch site closes the highway and public access to local public lands, beaches, and recreation facilities, impairing public access. Increasing launches and tests increases those closures. In addition, scenic resources and viewsheds are part of the coastal resources, and this industrial site that explodes into fire and noise damages the homeostasis and serenity of this beautiful coastal area.

When rockets blow up, when debris is strewn over the mud flats, and when fires are caused by SpaceX and wastewater allowed to flood out, this results in disturbance and recovery operations over the entire area. This has been extensively covered by the media and environmental organizations.

Water (Wetlands, Floodplains, Surface Waters, Groundwater, Ocean Waters)

SpaceX has degraded the quality of the water resources at Boca Chica. The run-off from the launch site can be seen by the FAA's overhead visual of the site. SpaceX hasn't complied with wastewater regulations in the past until there was a lawsuit. How will the inundation system impact the surrounding parkland and nature refuge, or is the state giving up control for this to be maintained as public space and for wildlife protection?

Hazardous Materials

I have already covered this issue. That includes fuel and debris contamination harming the public Biological Resources Wildlife and bird deaths https://freethesky.org/2022/07/18/new-mexico-hundreds-of-thousands-if-not-millions-of-birdsdied-during-2020-usaf-spacex-5g-exercise/

Public Safety and Noise

Explosions are not mere noise, and they are harming the public, with explosive re-entries and fallout harming the public, and endangering aircraft. These launches add fire danger, in part due to hot fallout and debris, and the explosions that have caused wildfires.

Marine Resources

The ocean is a living being. At present, it is overstressed by human actions. This SpaceX proposal worsens the ocean's situation, using ocean dumping of rockets. “Some vehicles may not be reused and would be disposed in the ocean.” If weather balloons are also employed, this adds more debris with risk of entanglement.

This ignores the fundamental fact that ocean health is the foundation of the health of planet Earth. Yet Elon Musk's enterprise seems to be governed by the principle of “Why worry about the ocean, if you're planning to live on some other planet?” What's frightening is that the FAA, USFW, NOAA, and other regulatory agencies seem to buy into this philosophy and are willing to treat the ocean as a toilet or a sewer.

Department of Transportation Section 4(f) Resources

which include public parks, recreation areas, wildlife or waterfowl refuges of national, state or local significance, and land of a historic site of national, state, or local significance. SpaceX is already causing destruction and damage to state land, including fires, wastewater runoff, and debris dumping, as well as vehicle impacts and damage to land, mud flats, habitat for endangered species

These issues are not listed:

Atmospheric Impacts

SpaceX launches are ripping holes in the ionosphere, affecting ham radio communication and GPS, with unknown health and environmental effects https://www.spaceweather.com/archive.php?view=1&day=21&month=07&year=2023

The cost of SpaceX falls on the public, the Earth, and the future

All this is governed by an ethos that shows disrespect for his workers' safety, disrespect for Earth and the universe, and seems to celebrate ecocide.

2023 SuperHeavy explosion

SpaceX is turning the ocean and marine environment, the sky, and the Earth, along with everyone who lives on it, into a vast sacrifice zone. Wake up now, and stop this assault. Wildlife and habitat and sky and ocean are being harmed and destroyed right now. That destruction must stop. That is not negotiable. To do otherwise is to stand by and let your children and grandchildren's future be jeopardized by Elon Musk and SpaceX.

2023 SuperHeavy explosion

Do not allow any further SuperHeavy launches for the Earth's sake.

Sincerely, Nina Beety Monterey, California www.freethesky.org

Submit comment by January 27 re: “Study to examine environmental impacts of increased SpaceX launches from Vandenberg”

(The Dept of Defense has become involved, and instead of investigating environmental concerns, is defending increased launches.)

News article/explanation Study to examine environmental impacts of increased SpaceX launches from Vandenberg https://spacenews.com/study-to-examine-environmental-impacts-of-increased-spacex-launches-from-vandenberg/

An environmental study getting underway would allow even more launches from Vandenberg. The Department of the Air Force announced Dec. 13 it would carry out an environmental impact statement (EIS) covering both an increase in SpaceX launches at Vandenberg as well as use of a second launch pad. [] The EIS would also allow SpaceX to conduct up to 100 launches annually between SLC-6 and its existing launch pad at Vandenberg, SLC-4. That includes booster landings at both launch sites as well as droneships downrange.

The Department of the Air Force is planning three in-person public meetings Jan. 14 through 16 in Ventura, Santa Barbara and Lompoc, California, as well as an online public meeting Jan. 23 to discuss the planned EIS and receive comments on what should be included in the scope of the study. Those comments can also be submitted through Jan. 27.- Source

From the EIS Dedicated Website: Public Comments

The public is encouraged to submit comments during the scoping period from Dec. 13, 2024, through Jan. 27, 2025. To ensure DAF has sufficient time to consider public input in the Draft EIS, comments must be postmarked or received electronically by Jan. 27, 2025. Public scoping comments can be submitted in English or Spanish in the following ways:

• In-person at one of the three public scoping meetings

• Via online comment form here: Vandenberg Space Force Base Launch EIS - Home scroll down

• Email to: info@VSFBFalconLaunchEIS.com, with the subject line “Falcon EIS”

• Mail to: ATTN: VSFB Falcon Launch EIS
  c/o ManTech International Corporation
  420 Stevens Avenue, Suite 100 - Source

Previous testimony to the California Coastal Commission (a different agency which opposed the increased launches) (October 2024) about this issue can be viewed here: Th9a-10-2024-corresp.pdf 34 pages

Surfrider Foundation and Audubon California: we must proceed with caution. Potential impacts to coastal avian species are particularly concerning. For example, according to the staff report, “The USFWS also found that the proposed project is likely to adversely affect but would not likely jeopardize the continued existence of California Red-Legged Frog (Rana draytonii) and threatened Western Snowy Plover (Charadrius nivosus nivosus))” (from page 22). Given the disturbing potential for population level impacts and the great uncertainty, more frequent launches are not appropriate at this time. []s, “During the terrestrial sonic boom events plovers exhibit stress responses such as hunkering down over the nest or abandoning the nest, which may have resulted in damage to eggs and embryos.” Increased nest abandonment was documented in 2023 and trends showed abandonment was higher for sites closer to rocket launches [] n August, DAF was required to submit monitoring and mitigation plans under conditional concurrence. The Commission should not consider more frequent launches until more robust and complete data from those plans is collected and analyzed, especially for impacts to coastal species including threatened snowy Plovers and endangered CA Least Terns

Santa Lucia Chapter of the Sierra Club: We ask the California Coastal Commission to ensure, prior to further launch expansion, there is sufficient time to collect the data necessary to establish a current baseline for impacts from launch disturbance, which is currently lacking. Given the short duration before the scheduled ramp up to 100 launches per year, during which time the multi-agency working group comprised of Commission staff and federal resource management agencies are tasked with implementing biological monitoring, discussing monitoring results and identifying appropriate response measures, how does the Commission propose to ensure there is a sufficient amount of time to collect enough data to establish a current launch disturbance baseline?

Gaviota Coast Conservancy (GCC) When the Commission previously considered the proposed increase to 36 annual SpaceX launches, we raised concerns about the proposal’s impact on public access and recreation, marine debris, commercial fishing, and wildlife. Through the diligent efforts of the Commission and its staff, conditions were identified and strengthened to mitigate many of these impacts. Impacts to wildlife from frequent exposure to rocket launch noise and sonic booms however went largely unaddressed. We were pleased to learn that the Space Force and SpaceX have now agreed to comply with the biological and acoustic monitoring conditions that the Commission required at the August hearing. Those monitoring conditions are critical to understanding how sensitive species on VSFB and in surrounding areas respond to regular disturbance from launch noise and sonic booms, and importantly, how they can be protected from adverse consequences. It is premature to increase the number of annual SpaceX launches from 36 to 50 when this monitoring effort is only just beginning. []this threatened species are in place, it would be reckless to further increase launch activity. USFWS has also determined that adverse effects are likely for other threatened and endangered species including California least tern, southwestern pond turtle1, and California red-legged frog

California Native Plant Society Channel Islands Chapter While I understand and support efforts to manage invasive species and enhance local ecosystems, there are significant concerns that require addressing before approval of this project. The report accompanying the Consistency Determination outlines plans for the removal of nonnative vegetation, particularly around Spring Canyon, and the replacement of this vegetation with native species. In particular, the plan includes a wetland habitat enhancement project to offset the removal of non-native species such as Tasmanian bluegum eucalyptus, proposing a 2:1 ratio of enhancement area to managed area. The project highlights the restoration and enhancement of native vegetation, such as arroyo willow, which will be critical to reestablishing natural habitats and maintaining ecological balance in riparian and coastal wetland areas. However, the exact locations of the proposed native vegetation replacement efforts remain insufficiently detailed.[] The presence of the federally endangered Gaviota tarplant (Deinandra increscens ssp. villosa), found in several locations west and northwest of Lompoc, does not appear to be documented or addressed or mitigated for in the provided project document. It could well occur on the project site. Another concerning issue is the release of heated water used in the cooling procedures. It is well known that even a slight increase in water temperature can adversely impact riparian/wetland native plants and other aquatic organisms. Given the ecological importance of the site and the potential for significant environmental impacts, I urge the Commission to withhold approval of the project until a thorough vegetation restoration plan is submitted.

Some citizen science:

Sonic boom effects on human and non-human inhabitants in the local area -

Chemicals released as satellites burn in the atmosphere leading to damage to Earth’s protective ozone layer:

The effects of rocket crashes on the marine environment are largely unknown:

California needs to be a good neighbor on our one planet -

Lack of baseline data on environmental impacts -

Additionally, I must register my skepticism with the claim by the DAF that commercial space launches are critical to national defense. The project should not be characterized as a federal agency activity, as it involves commercial space launch activities carried out by SpaceX.

There is no evidence of any attempt to understand, much less mitigate, the GLOBAL issues raised by multiple commenters when this massive increase in launches was before you in August.

The proliferation of electromagnetically emissive satellites, including toxic materials, in low Earth orbit, subject to collisions and to orbital decay and re-entry through the ionosphere into the Earth's biosphere, in the thousands leading to tens of thousands leading to hundreds of thousands, constitute a massive experiment to which most of the people and other life forms placed at risk have not given informed consent. Until a process for obtaining such consent is devised (no idea what it could look like, especially relative to non-human subjects of the experiment), the LACK of consent must be assumed, and you have a moral responsibility to act accordingly, even if it means testing the limit of your powers.

The mission creep is excessive; 36/yr. current launches to 50/yr. launches by year-end followed by the expected requested of 100 launches next year. This says nothing of the developing capacity to accommodate re-entry boosters and their cascading BOOM

These proposed increase in rocket launches have a significant impact on Ventura County people and wildlife. They should be reduced, not increased.

The sonic boom from the launch on Tuesday for Starlink shook my apartment and rattled windows the windows. I live on Carpinteria a mile from the seal sanctuary. If it was that loud in Carp I can only imagine how loud it was closer to Vandenberg. SpaceX needs to show a little more accountability for the effects of its private enterprise before increasing the launch schedule

Thank you for all you do.