A LINK TO ESG HOUND, ENVIRONMENTAL SCIENTIST BLOGGER, AN EXPERT ON IMPACT OF A PROJECT LIKE SPACEX

 

I'm trying to sort through the very technical jargon of a science blog, ESG Hound.

Hound makes plain he has no financial interest in SpaceX failing, loves rockets and space.

He states that the NEPA, the National Environmental Policy Act, now being used to vet SpaceX is antiquated, made effective January 1, 1970, and its enforcement will not protect our region.

This scientist, an environmental specialist, has written 14 highly technical chapters on the dangers to our area of the SpaceX project.

Here is the link to ESG Hound:  

https://substack.com/profile/16083964-esg-hound

The format is difficult to navigate as he uses a black background, but the technical info will blow you away.

Just a few points from the introduction:

I think that the Boca Chica expansion project proposed by SpaceX and the FAA is ill conceived, rushed and catastrophic for both the local ecosystem and the credibility of a well functioning regulatory state. That it erodes trust in our society and is a case study in regulatory capture and crony capitalism. I believe that this project should be halted until a compliant and complete Environmental Assessment is complete.

NEPA doesn’t require the agency to mitigate all environmental risks, they simply must be disclosed. DOT/PHMSA could determine that a pipeline kills an entire population of endangered species, but could still proceed as long as that risk is disclosed. NEPA disagreements almost always occur through interested parties (Such as Greenpeace, Sierra Club, etc) suing the Federal Agency.

Regarding SpaceX specifically, they completed an EIA for initial operations in Boca Chica back in 2014. Full EIAs take years to complete, so if the FAA/SpaceX wanted to add a few launches per year, for example, they could simply update the existing authorization using a PEA. All they have to demonstrate that the proposed change meets the scope and impact of the initial EIA; all environmental impact changes must be minimal.

The problem here is that, a prima facie, this project is NOT a minimal change. Elon Musk is calling it STARBASE for crying out loud. The rockets they’re launching are like 10 times bigger than initially authorized. They’re building a very large power plant, and they’re doing physical separation of natural gas! It’s patently absurd to even non environmental law nerds like me.

The scope of the assessment must include, by law, all associated operations. The FAA cannot just examine impacts from the rocket launches in a vacuum. Since the natural gas and power infrastructure included for this project are critical to the launches by SpaceX’s own admission, they are very much in scope to the proposed action. Musk and the media have focused on the rockets, while the massive industrial operation supporting the launches themselves have gone unnoticed. I suspect this is by design, but I’m here to pull the curtain back.

While NEPA doesn’t require specific mitigation, it does mandate full disclosure and it requires response to public comment. This is where I come in. I live in Texas, I’m an environmental compliance professional. This project is in my back yard, and frankly it’s an affront to my profession. In my view, if approved and unchallenged, it would invalidate NEPA as a process.