The Planetary SocietyMay 12, 2023

Why has SpaceX's Starship sparked an environmental controversy?

A conversation with environmental policy expert Eric Roesch

Prior to the inaugural launch of SpaceX’s Starship spacecraft aboard its enormous Super Heavy rocket, environmental policy expert Eric Roesch was outspoken about the likelihood of significant environmental damage.

As the rocket launched on April 20, 2023, from Boca Chica, Texas, it kicked up massive clouds of dust and destroyed its launchpad, scattering large chunks of concrete into delicate marine and coastal sanctuaries nearby. SpaceX CEO Elon Musk called it a “human-made sandstorm” that they want to avoid in the future, and acknowledged they need an improved flame deflection system for future launches.

Roesch blames both SpaceX and its regulatory body, the Federal Aviation Administration (FAA), for allowing the company to skirt environmental regulations and for not working hard enough to mitigate its impact on the delicate wilderness surrounding Boca Chica. He’s not alone; days after the launch, a consortium of environmental groups sued the FAA to prevent further launches of Starship.

Roesch joined the May 5, 2023 episode of Planetary Radio: Space Policy Edition to talk with host Casey Dreier about where he thinks SpaceX and the FAA went wrong in their approach to environmental protections, the tensions between progress and conservancy, and how NASA’s Kennedy Space Center is an example of the right way to approach environmentally responsible spaceflight.

The original transcript has been condensed and edited for clarity.

SpaceX's 2023 Starship test launch
SpaceX's 2023 Starship test launch Starship taking off from Boca Chica, TX, on April 20, 2023.Image: SpaceX

Casey Dreier: Eric, thank you for joining me on the Space Policy Edition today.

Eric Roesch: Thanks for having me, Casey.

Casey Dreier: A few weeks ago you published a piece called “SpaceX's Texas Rocket is going to cause a lot more damage than anyone thinks.” And congratulations, your analysis was proven true I suppose. You've been following this for a few years.

Eric Roesch: Right.

Casey Dreier: You had called this out in advance, but to most observers it seemed to be a surprise. I'd like to hear a little bit about Boca Chica — what makes it unique from a protected standpoint, and why is this something that we should care about from an environmental perspective?

Eric Roesch: I want to start off by saying that the environmental disciplines are really wide-ranging, and I have to be careful when I'm talking about endangered habitats because endangered species are not my specialty.

But generally speaking, Boca Chica is home to both state and federally owned lands that serve as a refuge to various endangered and protected species. So on that really basic level, I think that's where a lot of the primary concern stems from. We have this really unique habitat — low tidal flats — essentially an offshore barrier that prevents large waves from crashing up and protects from hurricanes. It also exists at the base of the Rio Grande river. It has some really unique physical and geological characteristics that make it a stopping point where a lot of wintering birds will spend half the year before they go up to the Great Plains. It's land that's owned by government agencies that exist primarily to maintain the lands as they are.

Casey Dreier: The key thing here is NEPA, the National Environmental Policy Act. Can you tell me more about that?

Eric Roesch: NEPA was actually the bedrock environmental law. Basically, we had this massive post-World War II expansion of our economy, which involved a lot of highway building, industry building, rail building. We cut highways through the middle of cities. And people were suddenly paying attention to environmental issues. NEPA said, okay, if we're going to do a big government sponsored project, at the very least we should go through and tell people what the impacts of it will be.

And so NEPA exists primarily as a disclosure law, and it was actually intended to be not super overbearing, which is what, in fairness, it has become. It's become a lot of paperwork. I think some of it's really important and some of it is probably not the best use of resources, if we're speaking purely objectively. But it existed to say, for example, if I want to go to the Everglades and dig a pit, throw a bunch of tires in there, light them on fire, and just have that burn 24/7/365, NEPA doesn't actually prohibit you from doing that as long as the impacts are disclosed. But it became a way for people to stop projects because of the disclosure.

I think some of it's been very good. I'm not going to just defend everything about it, but it puts the burden on government agencies that if they're going to go in and do a big project that can change a community, that at the very least they have to disclose the impacts. I think it's really fair to put that in comparison with the later environmental laws — the Clean Air Act and the Clean Water Act in particular.

Those laws tend to be based more on how many pounds of emissions are being put out, or how many particles of this type of discharge are being put in the water, and so it's easier to track. Whereas with NEPA rules, in particular with things like endangered species, you have to extrapolate into the future; what is the wildlife habitat going to look at 30 years from now? We may not know, the results aren't necessarily as tangible. But NEPA was really our first attempt as a nation to get some of this stuff under control so we don't just ruin our entire planet or our communities.

Casey Dreier: What's so interesting to me from a policy perspective is that this is, in a sense, the public imposing friction on purpose in order to direct the outcome of certain types of activities of industry. And these environmental laws were placed on industries that were already pretty well established at the time, but when you are talking about something like SpaceX with Starship, it's very rapid, it's very experimental, and in a sense it's much smaller of an impact than the oil industry or the auto industry. Is it appropriate to apply these types of high friction regulatory systems to an experimental developmental project? Or will that just unnecessarily slow it down and prevent the development of transformational launch access to space? Where's the appropriate balance here? Because I think that's what people are arguing about.

Eric Roesch: Let's actually look specifically at the project in Boca Chica. SpaceX proposed to build a small launch site, and after considering a few other sites they settled upon Boca Chica. They did some community outreach, they hired some PR firms, they went and gave presentations. And they actually got an initial environmental impact statement, which I think was issued in 2015.

This launch site was intended for a handful of Falcon 9 launches per year. That was the original intent of the site. And there were people complaining because of a Falcon 9 that exploded on the pad in 2016 at the Kennedy Space Center in Florida. But I think besides that, the Falcon 9 is rock solid. They can turn them around really quickly, they can reuse them, and they rarely have to scrub or cancel flights if it's not because of an outside factor. It's an incredibly good platform. So the intent at the Boca Chica site was to do one-off launches of a fully developed rocket.

And what happened instead is that over the course of the next four or five years as they were starting to test some of the early Starship prototypes, they were going back to the FAA and saying, “Hey, can you do a written reevaluation saying the impacts won't be that much more?” And they didn't propose to reopen this NEPA.

SpaceX Boca Chica launch site
SpaceX Boca Chica launch site A Google Maps view of the location of the SpaceX launch facility in Boca Chica, TX, and the surrounding nature preserves.Image: Google Maps

So the question to ask is whether Boca Chica was the best site for this new rocket development. Is there more land they could've bought? Could they have done offsets with the Department of Interior and converted another portion of the Texas shoreline into a different refuge that would offset these impacts? I guess what I'm saying is that we talk about iterating fast and I get it, but they actually did have plenty of time to go through and do these processes the right way. And that includes picking out maybe a different site, maybe working with the Kennedy Space Center to develop something else. Or if they wanted to keep it there, to really engage the community and say, how do we offset this? It feels to me like they just wanted the public and the regulators to go along with it and they've been pretty successful with that.

I know one of the critiques about the idea that they should just be launching from Kennedy Space Center is that there's too much traffic there. And to give credit to that point, yeah, we should have developed another space port. Absolutely we should have. But is the right way to do it to have a private company come in, buy 20 acres and say, “Deal with the consequences”? I don't think so. But that's basically what the FAA has allowed in my view.

SpaceX did an environmental assessment, which is basically just a mini version of an environmental impact assessment where the impacts would be below what we call a significant level. That's what SpaceX proposed, along with the FAA. They proposed this in order to take this site from the small launchpad it is to a large launch facility with development, tests, landings, all the stuff that they wanted to do, with a process that takes less time, that has less requirements.

Casey Dreier: I see. So if I can restate this to make sure I understand, basically SpaceX went this easier route years ago and then have gone back and modified it without having to redo the full heavy-handed environmental impact assessment?

Eric Roesch: Well actually no. The original in 2015 was a full environmental impact assessment, but they did what they called written reevaluations because the original assessment did not have exploding tiny little prototype Starships included in it. So the FAA had to go through and say, “Here's why it's acceptable.” You keep adding more and more of those until at some point you've ratcheted from what the site was into something different, and you'd have to start a brand new process over. That's what we hit in that 2020-21 period, when they were permitting the site as a Starship test, development, and launch facility as compared to what it was before, which was a Falcon 9 occasional launch facility.

Casey Dreier: This is the period that you really reserve for your harshest critique. Is that correct? This period where suddenly the fundamental need and use of this site changes. And I think if I understand you correctly, NEPA just requires full disclosure about the full impact of what was going to be done to an existing space. And your claim is that SpaceX has not been doing that, that instead they've been diminishing what they've been doing in order to avoid the harsher or longer term reevaluations. But they've also been getting approval from the FAA, which is what controls the ability of SpaceX to launch. I think I have a quote from you here that you'd said that SpaceX and the FAA hired contractors to help evaluate these applications, who appear to have been actively complicit in greenwashing and minimizing the impacts from a very public operation run by the richest and arguably most famous man in the world. And so what are the failings in your perspective of the FAA in this situation?

Eric Roesch: I want to be clear that I have plenty of critiques about the culture of SpaceX, which I think is probably the reason that they move so fast as well. I understand the upsides there, a little bit of that tech “move fast and break things” ethos. But really at the end of the day the onus for this does come down to the FAA. They are the sponsors of the program. They're required to certify it. If we're talking about it from a business perspective, if the agency is going to let you get away with it, you may as well.

I'm going to bring up Kennedy Space Center again, because if you actually look at their requirements under NEPA, my suspicion is that the FAA may have gotten complacent because NASA is a very, very cautious agency and that goes through to all their departments. They do almost all the work that goes into the NEPA documents, which then goes into the launch licenses that are granted out of Kennedy Space Center. And so it's really easy if you have a partner that's doing most of these with you that is conservative almost to a fault, that it's easy for the FAA to get locked into just trusting their launch partners.

Casey Dreier: Interesting that they've gotten too credulous based on their past experience with a well-intentioned partner.

We saw the launch, and it basically blew apart the launchpad area and threw debris everywhere. It looks like small fires were started, along with a big dust cloud and more destruction than anyone anticipated. From a regulatory standpoint, is it too late? I know that the FAA is doing a mishap investigation, but that's because a rocket blew up. What is the proper responsibility, do you think? Or is Boca Chica incompatible with the type of exploratory rocketry that SpaceX wants to do, from an environmental regulatory perspective?

Eric Roesch: I really honestly do believe it's the latter. The orbital launchpad in Boca Chica, their full property, is something like 20 acres. If you go to launchpad 39A at Kennedy Space Center, one of the large rocket launchpads, it's something like 175 acres. So you're talking about an eightfold or so increase in area. And so just on that really basic level, if you have land around there that is not owned by them, that is also protected habitat, I don't don't see how it works fundamentally in the long term. And to be frank with you, it's struck me that I think SpaceX realizes this as well. I think the initial vision that was pitched has been ratcheted back. They have not outright said that, but that's been my take reading between the lines.

Casey Dreier: A lot seems to hinge on the interpretation of the word ‘significant’ in terms of significant impact and SpaceX having to operate below the threshold of significant impact to the environment or to mitigate significant impact. How do you define significance for something so broad as the environment?

Eric Roesch: Well, there's 40 or 50 years of case law that talks about some of these very specific issues. There is the Council on Environmental Quality, that's part of the Executive Branch. The courts will look at those, they'll look at previous case law. The FAA also has their own guidebook for what they consider significant.

But on a more basic level, I think the big thing is the dust cloud we saw. The actual spread of debris was not really described at all in the documents they did produce, even for an incident where the rocket itself blew up on the pad. If we have evidence in hand that you've not foreseen a consequence that many people would say is obvious, then that itself demonstrates that there was a problem with the process.

Starship Test Flight Launch
Starship Test Flight Launch A view of the 2023 Starship launch from Boca Chica, TX.Image: SpaceX

Casey Dreier: The Washington Post had a great piece that showed the video as the rocket was taking off, with all this debris splashing into the ocean miles away. And it just was shocking. Elon Musk was saying just the other day that, "The debris is basically just sand and rock and it's not toxic at all or anything." He said it's just like a sandstorm — a human-made sandstorm. He was downplaying it. Is that accurate or are there real issues here to consider from a broader community health and environmental perspective?

Eric Roesch: I would say the characterization of “just sand” is at the minimum too early to tell. I think it's pretty disingenuous. I think Musk's true genius is how he deploys language. I think this is a perfect example of that, right? Because he chooses “non-toxic” and he specifically mentioned the plume. And yes, by hazard laws and how we think about toxicity, yeah, methane and oxygen combusted together don’t make a toxic chemical. It's not bio-persistent, doesn't bio-accumulate, and it's not immediately carcinogenic. If you get stuck in the middle of a methane cloud, could you run out of oxygen and die? Yes. But that's not what we think of as toxic. And so there's some truth there to it. And I think that's the genius portion of it. But the environmental impact, it isn't just whether something's toxic. It is whether you've altered an environment to an extent that it causes more damage than either people would expect or is allowed.

The thing that surprised me the most was that dust cloud coming in. I wrote my master's thesis on plume modeling. I love talking about air events and all this stuff. But I didn't think people would be as viscerally struck by it as they were. I think it was just that visual reminder that this is something that could cause a lot of problems. We don't know the actual chemical composition of things that were shredded by a 2,400 degree Fahrenheit flame. And I can write a billion words about how they did a bad job of assessing risk or predicting this, that, and the other, or not following the process. But when you see an image like the ones of the plume, even if someone doesn't understand the rules, there's this intuitive feeling that it doesn't quite look right. The powerful images of rockets going off, that awe and wonder you feel, I get that. I love that. But just know that our emotional response to big things happening visually isn't always going to be one of wonder. Sometimes it'll be horror or fear or disgust. And I think that's important to recognize.

Casey Dreier: I think that's a really important point. As people know, I am very pro-space. I want space exploration to happen. I want Starship. NASA's going to land on the moon because of Starship. I want this to succeed. My frustration with SpaceX and Musk's approach to this was that they were taking, at best, a cavalier attitude toward the possibility that it blows up or something goes wrong. But if and when something does go wrong, when that visual reaches people who aren't big space fans like me, it will look ominous at best. And if there's a lack of trust or if, as in Musk's case, if he's gone and almost purposely cultivated a very polarizing public persona, then there's not going to be this assumption of honest actions or mistakes or trying to do better. By ignoring the environmental regulatory process, or let's say dismissing it or not taking it seriously, they're running a huge risk in terms of overall public opinion that eventually will filter out to political response.

Eric Roesch: I think that's an amazing point. When you're doing these types of projects, it is 50% knowing the rules, doing the work to get approval, and 50% just PR. And there are plenty of PR snafus, but in general these projects happen because they spend money on PR, they spend time on it. Good or bad, that's what you have to do. And it seems to me that Musk has been able to get away with not doing that. But I think in particular with the current climate and how he's portraying himself to the public, those foibles or things he didn't deal with before are catching up to him all at once. That's my perception about it.

Casey Dreier: I've always thought this is one of the big long-term risks of privatization of space, that you start to have individuals and all their idiosyncrasies and strange character quirks and so forth start to be associated with what had, up until very recently, been this stately government program that was publicly run. With people like Musk and Jeff Bezos and others, you start to carry the baggage of a single person representing this era, with all of the attendant positives and negatives that come with it. And Musk especially is really leaning into being Twitter's character of the day over and over again. So that's one of my long-term fears, that he personally is polarizing the broader public's attitude about SpaceX's success or failure.

One more question before we close this up here. We've talked about SpaceX, we've talked about the FAA. Where do you see NASA's responsibility in this whole situation? Do you think they should impose more stringent environmental requirements on their contractors from the top? Do you think NASA has an ethical or just social responsibility here that they're not exercising?

Eric Roesch: I think it actually is more on NASA, because I think they've got the ability to do it. If you look at how many lawsuits get filed against the Kennedy Space Center, it’s almost none because they have a world-class environmental health and safety program. Their documentation is always up-to-date. You can go through their whole NEPA library going back decades. You can actually see every single project, every single decision they make, every single comment they make to a person asking, “What if this rocket lands and kills a blue whale?” I think NASA is more than equipped to do this from a cultural standpoint; having the right culture is a huge part of complying with the laws. I would love to see them be a part of keeping SpaceX in line. But at the end of the day, because the FAA licenses commercial space ports, it’s on them.

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