If SpaceX’s Starship doesn’t go orbital this year, this report will be why

SpaceX has been steamrolling towards their orbital Starship attempt out of Boca Chica since the SN15 launch. However, we are still months away from a possible attempt. The reason? Darn FAA Environmental Reviews.

All launch sites and launch vehicles that operate within the U.S. have to undergo an Environmental Review process. This is due to the National Environmental Policy Act (NEPA), signed into law by President Nixon on January 1, 1970. Without an Environmental Review process, you will not be issued a launch license or permit. Federal agencies developed NEPA procedures that best addressed the agency’s role. The general NEPA process is as follows:

  1. Initial identification of issues and concerns
  2. Coordination with other Federal, state, or local agencies to determine which entities should be included in the NEPA process
  3. Identification of the appropriate type of environmental review (see The Types of Commercial Space Transportation Environmental Review, below)
  4. Preparation of the draft NEPA document, and public involvement, as appropriate
  5. Preparation of the final NEPA document
  6. Issuance of the environmental determination

NEPA Process outline provided by the FAA

Environmental Reviews – EA and EIS

There are 2 main reviews the FAA utilizes for Commercial Space Transportation: Environmental Assessments (EAs) and Environmental Impact Statements (EISs). There is a third called Categorical Exclusions, but those generally do not apply to Commercial Space Transportation licensing. Thus, we won’t cover it unless it becomes a part of the Starship/Super Heavy licensing.

Environmental Assessment (EA)

An Environmental Assessment is conducted for any licensing carried out. As stated by the FAA,

An EA defines the purpose and need for the project, analyzes the potential impacts of the project and alternatives; demonstrates compliance with other Executive Orders and environmental laws; and allows for public participation, when applicable.

FAA Commercial Space Office

EAs are generally developed by the company/organization responsible for the project with oversight from the FAA. The amount of public involvement can vary from assessment to assessment but is generally determined by public interest. We are expecting to see more public involvement with the Starship/Super Heavy EA. This is due to the FAA conducting “scoping” before work could begin on the draft EA.

Scoping is conducted in some environmental assessments to allow the public to help determine the scope of issues to be analyzed in the EA. The Starship/Super Heavy scoping period ended on January 22, 2021, and the FAA received 321 comments. Work should be well underway on the draft EA for Starship/Super Heavy, and we could see the draft released for public comment in the near future. The public comment period will be open for at least 30 days. The comments received during this period will be reviewed, and the FAA may ask SpaceX to revise sections of the EA to address the comments. This is around the time one of two things is expected to occur. A FONSI, or an NOI to Prepare an EIS.

EA Process | Image Credit: FAA

FONSI or NOI to Prepare an EIS?

If the environmental assessment can demonstrate that the project’s effects on the environment would not be significant, the FAA would issue a Finding Of No Significant Impact (FONSI). This would clear the way for the FAA to issue a permit or license. However, a FONSI does not mean a permit or license will be issued.

There is another option for the FAA. If the FAA determines that the project will result in significant environmental impacts that cannot be mitigated by actions described in the EA, the FAA would issue a Notice of Intent to Prepare an EIS.

Environmental Impact Statement (EIS)

The biggest differences between an EA and an EIS are the following: The FAA prepares the EIS, the amount of public involvement, and EISs are much more detailed. The FAA states that an NOI for an EIS can be issued at any time, including before and after the draft EA is released for public comment.

This is the biggest concern for the orbital Starship attempt timeline. Should the FAA require an EIS (it is my opinion they will, I’ll explain why later), the time frame for the steps on their own is 105 days at a minimum. That does not even include the time to prepare the draft and final EIS.

Why do I believe that the FAA will require an EIS for Starship/Super Heavy operations? It’s simple: they made one for Falcon 9 and Falcon Heavy. For those who may not know, SpaceX initially planned on using Boca Chica to launch the Falcon 9 and Falcon Heavy rockets. Back in 2014, the FAA released the final EIS. The 392 page PDF can be viewed on the FAAs website, and it details all the effects and impacts of SpaceX operating out of Boca Chica. It also describes measures that can be taken to reduce the effects of the project.

If operating Falcon 9s and Heavys out of Boca Chica resulted in the need for an EIS, there appears to be no way that Starship/Super Heavy operations will not need one.

EIS Process | Image Credit: FAA
Header Page for the 2014 SpaceX EIS | Image Credit: FAA

What about the testing that has occurred?

As SpaceX evolved its plans for the Boca Chica site, the FAA re-evaluated the 2014 EIS multiple times. This was done to determine whether the operations SpaceX intended to conduct fell within the scope of the EIS that had already been prepared. Every flight and test that has occurred thus far has been found to fall under the scope of the 2014 EIS. This has been challenged by some groups in the area, but the FAA has still authorized most of the testing.

Preparations for orbit, whether they’re approved or not…

Orbital Integration Tower and Orbital launch Mount (Pad A) | Image Credit: Austin Barnard

SpaceX has focused all their effort on preparing the orbital launch mount and supporting infrastructure since the success of SN15. The most notable of which is the integration tower. This tower, which will be around 480 feet tall, is expected to support the integration of Super Heavy and Starship. It may also be involved in the recovery of Super Heavy in the future.

CNBC reported the FAA notified SpaceX that the tower is not yet approved 2 months ago. SpaceX had attempted to get the tower approved under the 2014 EIS, but the FAA held firm. They stated that “A 480-foot-tall integration tower is substantially taller than the water and lightning towers assessed in the 2014 Environmental Impact Statement (EIS) and requires further environmental review under NEPA”. They also mentioned that the use of the integration tower would fall outside the scope of the 2014 EIS. While unlikely, the FAA also warned that the environmental reviews could determine that the tower be removed.

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