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Starship at Boca Chica
An FAA environmental review cleared launches of SpaceX’s Starship/Super Heavy vehicle from Boca Chica, but with dozens of mitigations, large and small, required. (credit: SpaceX)

A step closer for Starship

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For months, Starship advocates, opponents, and those simply interested in SpaceX’s heavy-lift launch vehicle have been circling dates on their calendars, only to cross them off.

The FAA review concluded that, with mitigations, Starship launches from Boca Chica “would not significantly affect the quality of the human environment.”

Last fall, the FAA’s Office of Commercial Space Transportation projected it would complete the environmental assessment for Starship/Super Heavy launches from SpaceX’s Boca Chica, Texas, test site—aka Starbase—by the end of the year. But in late December, the agency said it was moving the completion date to the end of February, citing work needed to review some 18,000 public comments and coordinate with other agencies.

That date slipped again to late March, then again to late April, and again to the end of May. On May 31, the FAA said the date for completing the environmental assessment had slipped again, but by only two weeks, to June 13. After months of month-for-month delays, a two-week delay was a hopeful sign to some that the review was almost complete. Perhaps this would be the last delay.

It was. On the afternoon of June 13, the FAA released that final report, formally known as a Programmatic Environmental Assessment (PEA). Along with it came the “Record of Decision,” the FAA document that concluded whether, on an environmental basis, Starship launches could proceed.

The answer was a qualified yes. The FAA’s decision was what it called a modified Finding of No Significant Impact (FONSI), which allows SpaceX to conduct Starship orbital launches from Boca Chica but only after making dozens of changes to its operations there. “After reviewing and analyzing all available data and information on existing conditions and potential impacts, as well as the mitigation identified in the PEA which SpaceX must implement, the FAA has determined the Proposed Action would not significantly affect the quality of the human environment,” the FAA concluded in its Record of Decision. That avoids a more thorough, and lengthy, environmental impact statement.

The mitigations that SpaceX must implement, though, are lengthy. In a statement, the FAA said SpaceX must take “more than 75 actions” to comply with the modified FONSI determination. Depending on how one counts all the items and sub-items in the Record of Decision, the number of conditions exceeds 100.

While there are many conditions, most are not particularly difficult for SpaceX to implement. The FAA, for example, requires SpaceX to limit lighting at the site and minimize their impact on sea turtles. SpaceX will also have to introduce an employee shuttle to transport employees t between Brownsville and Starbase to limit traffic, but simply “encourage” use of it and only mandate workers take it “as practicable.” SpaceX will also clean up trash along the side of Highway 4, the road that leads from Brownsville to Boca Chica, but only on a quarterly basis.

Some of the conditions are unusual. SpaceX will have to write “a historical context report (i.e., historical narrative) of the historic events and activities of the Mexican War (1846–1848) and the Civil War (1861–1865) that took place in the geographic area” around Boca Chica.” SpaceX will donate $5,000 annually to a program run by the Texas Parks and Wildlife Department to purchase fishing equipment that is loaned out to the public (“You can borrow fishing equipment as easily as you borrow books at a library!” states the website of that program.) Other $5,000/year donations will go to the Peregrine Fund for monitoring those birds and the Friends of Laguna Atascosa National Wildlife Refuge Adopt‐an‐Ocelot Program—enough to adopt 20 ocelot dens, according to that group’s site.

SpaceX will donate $5,000 annually to a program run by the Texas Parks and Wildlife Department to purchase fishing equipment that is loaned out to the public (“You can borrow fishing equipment as easily as you borrow books at a library!” the program’s website states.)

A far more significant condition, though, involves road closures. Closing off Highway 4 for Starship launches and other tests also cuts off the only route to Boca Chica Beach, a public beach adjacent to Starbase. The frequency of those closures irritated some residents, prompting a lawsuit by one local group against state and county officials (but not SpaceX itself) for approving those closures, arguing they violated state law guaranteeing “free and unrestricted access” to public beaches like Boca Chica.

The Record of Decision places stronger restrictions on highway closures. SpaceX will have to provide a forecast of planned closures one to two weeks in advance to the county government to disclose publicly. SpaceX won’t be able to close the highway on more than a dozen holidays or holiday weekends. SpaceX will also be limited to five weekend closures a year.

The PEA itself states that SpaceX will be limited to 500 hours of access restrictions per year for “nominal operations.” SpaceX would also be able to close access for an additional 300 hours “to address anomalies.” That is not a particularly long time: 500 hours works out to just under 21 days.

The PEA notes that SpaceX does not plan many launches from Boca Chica, at least under the conditions of this environmental assessment. The company would be able to perform no more than five suborbital Starship launches and five Starship/Super Heavy launches, as well as associated landings, per year. That may be suitable for testing, but not for operational missions where SpaceX envisions a far higher flight rate.

SpaceX CEO Elon Musk already suggested Boca Chica will be more of a test site than an operational spaceport. At an event there in February, he said Starbase is “well-suited to be our advanced R&D location” where the company would test new versions of the vehicle. The Kennedy Space Center “would be our main operational launch site,” he said (see “Starship status check”, The Space Review, February 14, 2022.) Last week, SpaceX installed the first section of a launch tower for Starship launches at KSC’s Launch Complex 39A, near the existing pad now used for Falcon 9 and Falcon Heavy launches.

The completion of the environmental assessment and the FAA’s Record of Decision does not necessarily mean Starship orbital launches are imminent from Boca Chica. SpaceX still needs an FAA launch license, and it’s not clear if all the mitigations listed need to be completed, or simply in progress, before the FAA issues a launch license. SpaceX will need to satisfy other technical, policy, and financial aspects of the launch licensing process, although traditionally the environmental review was often the longest to complete.

The review could be headed to the courts as well. Environmental groups made it clear they were unhappy with the modified FONSI ruling by the FAA, arguing instead that the FAA should perform the more thorough environmental impact statement.

“SpaceX has shown a blatant disregard for Boca Chica’s natural habitats. The area here is not just empty space for fuselage debris and waste,” said EJ Williams of the American Bird Conservancy, a group that is concerned about the impacts of Starship launches on endangered and threatened species. It was among the groups that lobbied for an environmental impact statement.

“One step closer to the first orbital flight test of Starship,” SpaceX tweeted.

Last December, FAA concluded an environmental assessment for the proposed Spaceport Camden in Georgia and awarded a license despite opposition from environmental groups and local residents. Last month, several environmental groups filed suit against the FAA in federal court in Washington, arguing the agency did not properly follow its procedures when it awarded that spaceport license. It seeks to vacate the license and related documents.

Even without legal action, there’s the question of when SpaceX will be ready. In tweets last week, Musk said Starship “will be ready to fly next month,” with a second Starship/Super Heavy vehicle ready in August “and then monthly thereafter.”

However, based on his record, one should be careful about taking Musk’s schedule comments literally. At the February event, he showed off a fully stacked Starship/Shoer Heavy vehicle, suggesting it would be the vehicle that makes the first orbital launch attempt. But both Booster 4 and Ship 20 have been retired, with Booster 7 and Ship 24 now the ones being prepared for a potential launch—at least for now.

Those uncertainties may be why SpaceX was relatively muted in its reaction to the FAA decision. “One step closer to the first orbital flight test of Starship,” the company tweeted in its only formal comment on the decision. Perhaps because they realize that step is not the final step, nor is it guaranteed all the steps will be moving forward.

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