Letter to stop SpaceX in Boca Chica Wildlife Refuge - copy and send

 Ms. Stacey Zee, RE: SpaceX PEA

c/o ICF, 9300 Lee Highway, Fairfax, VA 22031

To: E-mail: spacexbocachica@icf.com,

Stacey.Zee@faa.gov

CC: <lesli_gray@fws.gov>

Dear Ms Zee,

I am writing to provide comment on the FAA’s Draft Programmatic Environmental Assessment for the SpaceX Starship Super Heavy Project at the Boca Chica Launch Site.I am very concerned about the current state of development and activities which have already had major negative impacts and which were never evaluated in the original EIS, making this new plan to EXPAND that activity and infrastructure even more alarming.  The Boca Chica area, including the Lower Rio Grande Valley National Wildlife Refuge, several Texas State Parks and the South Bay Coastal Preserve – is an ecological gem, yet it is being treated by SpaceX as if it were a wasteland. This expansion plan essentially seeks to sacrifice a publicly-owned natural resource area of hemispheric importance for a private company.  I just read an informative article by the American Bird Conservancy, and the following quote is quite alarming: 

“The American Bird Conservancy (ABC) is deeply concerned about the facility's impacts on wildlife habitat and species listed under the Endangered Species Act (ESA), including the federally Threatened Piping Plover and Red Knot, and the Endangered Northern Aplomado Falcon…The SpaceX facility in Boca Chica is surrounded by federal and state public lands used by hundreds of thousands of individual birds of many different species throughout the year…”

Boca Chica is an especially vital place for migratory birds that pass through there to rest and refuel so they can successfully continue and complete their migratory journeys. Also, the area contains all five seagrass species that occur in Texas, mostly fringed by dense and probably the most well-established stands of black mangrove in the state. These stands of mangrove also have considerable importance to nesting waterbirds, such as the Roseate Spoonbill. The Piping Plover, listed as Threatened under the Endangered Species Act, is one of the many species being negatively impacted by the ongoing construction of the SpaceX Starship Super Heavy Project and launch site. According to a recent analysis, the population of Piping Plovers has declined by over 50% at the site in only three years since the onset of testing and launch activities. This is an alarmingly rapid decline for a species that is already under increasing risk of extinction.

An objective Environmental Impact Assessment should be made:

• To address cumulative impacts that have yet to be recognized by the Federal Aviation Administration and SpaceX, such as fuel transport and storage at the facility, as well as massive proposed infrastructure projects including a 250 MW power plant, a natural gas plant and liquefier, and a desalination plant.

• A launch failure analysis should be part of the Environmental Impact Statement (EIS) to assess the risks to public safety and risks to the proposed infrastructure and operations at the Port of Brownsville and off-shore.

• The Federal Aviation Administration should examine more alternatives, rather than just the “all or nothing” alternatives.  One of the other alternatives that should be included is moving the testing of Super Heavy to a designated large rocket testing site, such as Provo, Utah or Stennis AFB in Mississippi.  The latter is where the Saturn V rocket was tested, and where the Space Launch Systems (SLS) rocket is currently being tested.  Another alternative should include launching Super Heavy offshore or from Cape Canaveral.

• The Clean Water Act, Section 404 specifies the consideration of alternatives to the proposed action of filling or dredging of wetlands. SpaceX has provided no alternatives or other measures necessary to protect public health and safety.

• Construction is anticipated to permanently fill 17.16 acres of wetlands, and the filling of 25.8 acres of floodplain. No alternatives or mitigation has been provided by SpaceX. 

• The Draft Programmatic Environmental Assessment mentions that noise and shock waves (far-field overpressure) may break windows on SPI and Port Isabel.  If that can happen 5 miles away from the launch site, what will be the effects on birds, reptiles & small mammals that are a half mile or less from the launch site?  The launch site is surrounded by national wildlife refuge and state park land.

With these and many other serious concerns in mind, I therefore must ask why is the SpaceX Starship Super Heavy Project and launch site being expanded, even though some of the infrastructure has yet to be approved by the Federal Aviation Administration (FAA). This is not a suitable site for such a volatile and damaging industry to operate. Now that this site is no longer out of sight and out of mind, I ask that the FAA NOT approve this proposed SpaceX expansion scheme. Instead, I ask that the FAA move to better regulate and greatly reduce operations there so that they abide by the original approval stipulations which SpaceX has sadly repeatedly violated without sufficient repercussions.

Awaiting Your Prompt Response,

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