[mark212]

What I can’t seem to find the answer to in this very long and stream-of-consciousness style series of posts is why the author thinks the FAA is the only relevant federal agency. They complain constantly about violating NEPA and accuse the FAA of just waiving this through … but there’s no way someone can operate a point-source emitter (e.g., large 250mw power station, let alone the natural gas processing facility) without getting a permit from the relevant air quality regulator.

Might be the EPA but I’m guessing it’ll be TCEQ; most states, especially the large ones, have their own state agencies and so long as the standard exceeds what the federal minimums are, then they issue the permits. This is the scheme set up by the Clean Water Act and Clean Air Act. (I practice in California and we have two separate state agencies, one for air and one for water. It seems like Texas Comm’n on Enviro Quality does both per their website.) The EPA doesn’t get involved in permit issuing and the state agencies even have authority over other federal agencies’ operations and issue permits to them.

So if the FAA is asleep at the switch, who really cares? There’s a whole second governmental regulator out there and a host of environmental non-profits and local governments with standing to sue if they think that regulator has made a decision they don’t like.

It’s like complaining that the plumbing inspector hasn’t given proper consideration to the minimum set-backs and architectural character of the neighborhood and signs off on the new toilets and showers for a house renovation. Like, who cares? You can’t move in without getting the final permit from the City and even if you did get that permit, the neighbors can sue and stop construction if they think the City made the wrong decision.

What am I missing? Why is this author so obviously emotionally distraught?

[ChuckMcM]

It's a valid question. I am surprised (as I am usually) at the emotional content of these sorts of things.

[wolverine876]

> I am surprised (as I am usually) at the emotional content of these sorts of things.

You're surprised by emotional content of politicized issues, such as the environment and anything Elon Musk?

[ChuckMcM]

Yes I am. Contextually Texas has a huge methane problem[1] and there is every indication that SpaceX will run their facility in a responsible way. What people "get" for SpaceX running that activity is a space capability that is superior to every other nation on the planet.

I do understand being emotional about the environment and a desire to preserve it in the presence of people and the activities that we have to do to survive. So I understand being emotional about an administration rolling back EPA restrictions on coal power waste water release[2] (for example).

Analogy: I don't understand a co-worker being "mad" at you for driving 10 miles to the office because they ride their bike that same distance and are therefore doing more for the environment than you are. Proud of their own efforts? Sure. Mad because not everyone can do what they do? No, I don't understand that.

[1] https://www.texasobserver.org/methane-abandoned-oil-wells/

[2] https://www.ewg.org/news-insights/news-release/trump-epa-rol...

[wolverine876]

I think we're stretching the meaning of 'surprised' past the breaking point, but I get your point. Tangentially:

> What people "get" for SpaceX running that activity is a space capability that is superior to every other nation on the planet.

The US already has had that for 50 years, and SpaceX is nowhere near the pinnacle of space capability. NASA has a helicopter flying around Mars, will soon have a new telescope out at (L2?), is operating in interstellar space, put humans on the moon 50 years ago, etc. etc.

SpaceX is good at launches to orbit, but being a private business they can sell that to any country. The US public doesn't own that capability like they do for NASA, any more than they own the new Ford truck line.

[gpm]

> The US public doesn't own that capability like they do for NASA, any more than they own the new Ford truck line.

They do, because ITAR means that SpaceX can't ship that capability overseas without the US governments approval, but ford can ship their truck line overseas (and has in fact been known to do so).

They aren't directly entitled to control it (beyond their ability to pass new laws that effect it, like taxes if they want to capture the profit, or laws forbidding SpaceX sell services to foreign entities they dislike, or so on), but the capability is very much tied down to the nation.

[korantu]

I understand it is specifically about _space launch_ capability. No other state can launch as efficiently as spaceX. And private citizens get tangible benefits from it, such as internet in remote areas

[dragontamer]

> and there is every indication that SpaceX will run their facility in a responsible way.

Wouldn't a "responsible way" include applying for a NEPA permit correctly?

A big problem with this PEA is this pipeline + fracking hypothesis. The pipeline, and the wells, are completely missing from the document.

The document has clearly made assumptions: they assume that a pipeline has built, and they seem to assume raw natural gas. But there's literally no disclosure about the infrastructure.

As such: SpaceX is already making an irresponsible move. A responsible company would disclose the details of their planned pipeline and/or mining operations.

[ChuckMcM]

I don't know what the "correct" way to apply for a NEPA permit is, and I don't have access to or know how many agencies SpaceX is communicating with. I don't know if they talked to NEPA who said, "get this permit first then we'll issue ours" or if there is a completely separate permit process rolling along with less visibility.

What I do know is that SpaceX wants to launch rockets from Starbase and they want to have the infrastructure to do that. I know they have a lot of experience operating out of Cape Canaveral and are familiar with the infrastructure NASA put there to support NASA's launching activities. And I know that even though it annoys them that agencies like the FAA aren't really equipped yet with processes to deal with companies like SpaceX, they do follow the existing rules.

As a result, it would surprise me if they hadn't aligned all of the respective agencies on what they were doing and jumping through the hoops that were put there by those agencies to get to the other side.

[dragontamer]

NEPA is the environmental law stating that everyone needs to disclose environmental effects ahead-of-time, before you build stuff. There's no NEPA agency, its simply the law.

FAA, being a government agency, is required to follow NEPA.

-------

The accusation, from ESG_Hound on this matter, is that FAA is rubber stamping the approval process and that SpaceX is on the path to making environmental changes without disclosure. There were many blog-posts about the deficiencies in this NEPA / disclosure document.

The one this topic is dealing with, is that the emission numbers simply don't make sense: SpaceX seems to have described Starbase as some kind of fracking operation. The estimated emissions are way too high.

--------

The problem is, if we let this approval go through, then SpaceX would be allowed to do fracking-related operations on Starbase (or at least, they seem to be doing substantial upstream / midstream operations. Maybe not fracking specifically, but... there's a lot of missing details in their disclosure).

There's two ways to think about this:

1. SpaceX's NEPA request is "correct" -- Which means they're really trying to do upstream/midstream natural gas operations (a well known dirty industry) in a federal reserve property.

2. SpaceX's NEPA request is "incorrect" -- Which means they filed their paperwork horribly incorrectly.

I think we're all hoping for #2. Because if #1 is true, then SpaceX is basically trying to become a fossil fuel company all of a sudden. In which case, we need to send the document back to SpaceX and ask them: hey, is this really what you're trying to do here? I thought you were just trying to launch rockets at Boca Chica? What's all this crap about VOC emissions and NOx emissions per year doing in this nominally "rocket ship base" ???

[XorNot]

Having read the whole blog post series I agree.

I can't figure out what the issue actually is meant to be here: the strongest argument is that the emissions SpaceX will have from the Starbase site itself will be higher then are being reported because the assumptions about the facility they're building are not accurate.

This might be significant, although it's certainly an argument I have a hard time worrying about in Texas, for this one facility, unless it would actually have a deleterious local impact (or be unmitigateable) - but it is a reasonable point of concern and a good use of public comment - though as noted in the series, the NEPA process is more about documentation then prevention. SpaceX can it seems, just update the numbers now and say "yeah so anyway it'll be that".

Where I'm much less clear is the argument about the gas wells or the gas pipeline - which are presented separately but seem to be necessarily together in order to link them as an issue associated with the Starbase site's operations itself, and I'm really not able to connect the dots here: it's implicitly obvious that Starbase is going to use some quantity of hydrocarbons to operate, but I'm not clear - once the site itself is accounted for - why its a problem that the pipeline and wells they'll necessarily build not being initially included matter?

Is the NEPA process somehow going to grant approval to construct fracking wells that will not be on the Starbase site, or approval for the pipeline construction? The pipeline argument in particular seems to be the weakest because if the existing decommissioned pipeline (who's run length I imagine SpaceX intend to use) was denied, based on the map coloring as presented in the post there's very obviously another path which doesn't cross any shaded regions...through which another pipeline already runs. If it does that seems like a problem, but I'm having a tough time figuring out how the FAA approving rocket launches would in any jurisidiction translate automatically into "and so we also are totally approved for this subsidiary company's fracked natural gas well many miles away and a pipeline".

There seems to be a weird implicit assumption that the FAA approving what it has would somehow approve it with every other agency - which, can it? Does it? As things stand "we're going to build a 250MW gas power plant" maybe shouldn't happen on the site seems to be my takeaway, but since they haven't built it yet and since it's existence doesn't seem to of major impact beyond land-clearing and emissions, surely whether it could be built is one question compared to whether SpaceX can get approval to do everything else they'd need to run it? At the moment they've launched zero rockets, but it seems like they'll be able to launch some without any of this and everything else is a question for the future - and surely the point of other regulatory processes particularly if it's not happening on the site itself?

[rspeed]

All of those would need to get approval by the Texas DOE.