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> and there is every indication that SpaceX will run their facility in a responsible way.

Wouldn't a "responsible way" include applying for a NEPA permit correctly?

A big problem with this PEA is this pipeline + fracking hypothesis. The pipeline, and the wells, are completely missing from the document.

The document has clearly made assumptions: they assume that a pipeline has built, and they seem to assume raw natural gas. But there's literally no disclosure about the infrastructure.

As such: SpaceX is already making an irresponsible move. A responsible company would disclose the details of their planned pipeline and/or mining operations.




I don't know what the "correct" way to apply for a NEPA permit is, and I don't have access to or know how many agencies SpaceX is communicating with. I don't know if they talked to NEPA who said, "get this permit first then we'll issue ours" or if there is a completely separate permit process rolling along with less visibility.

What I do know is that SpaceX wants to launch rockets from Starbase and they want to have the infrastructure to do that. I know they have a lot of experience operating out of Cape Canaveral and are familiar with the infrastructure NASA put there to support NASA's launching activities. And I know that even though it annoys them that agencies like the FAA aren't really equipped yet with processes to deal with companies like SpaceX, they do follow the existing rules.

As a result, it would surprise me if they hadn't aligned all of the respective agencies on what they were doing and jumping through the hoops that were put there by those agencies to get to the other side.


NEPA is the environmental law stating that everyone needs to disclose environmental effects ahead-of-time, before you build stuff. There's no NEPA agency, its simply the law.

FAA, being a government agency, is required to follow NEPA.

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The accusation, from ESG_Hound on this matter, is that FAA is rubber stamping the approval process and that SpaceX is on the path to making environmental changes without disclosure. There were many blog-posts about the deficiencies in this NEPA / disclosure document.

The one this topic is dealing with, is that the emission numbers simply don't make sense: SpaceX seems to have described Starbase as some kind of fracking operation. The estimated emissions are way too high.

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The problem is, if we let this approval go through, then SpaceX would be allowed to do fracking-related operations on Starbase (or at least, they seem to be doing substantial upstream / midstream operations. Maybe not fracking specifically, but... there's a lot of missing details in their disclosure).

There's two ways to think about this:

1. SpaceX's NEPA request is "correct" -- Which means they're really trying to do upstream/midstream natural gas operations (a well known dirty industry) in a federal reserve property.

2. SpaceX's NEPA request is "incorrect" -- Which means they filed their paperwork horribly incorrectly.

I think we're all hoping for #2. Because if #1 is true, then SpaceX is basically trying to become a fossil fuel company all of a sudden. In which case, we need to send the document back to SpaceX and ask them: hey, is this really what you're trying to do here? I thought you were just trying to launch rockets at Boca Chica? What's all this crap about VOC emissions and NOx emissions per year doing in this nominally "rocket ship base" ???


So ESG_Hound here has an issue with the FAA that they should not approve this application because it is missing data?

If so, the FAA has a pretty functional portal for public comments on applications. I'm sure they have made their concerns known to the FAA?

Given how "by the book" the FAA has been on their test flights and their stated concern of risk to public safety I am not sure I would be persuaded by an argument that the FAA was "rubber stamping" anything here. Is that your impression?


> So ESG_Hound here has an issue with the FAA that they should not approve this application because it is missing data?

I don't speak on behalf of him. But... it seems that yes, the FAA is complicit in this thus far.

> If so, the FAA has a pretty functional portal for public comments on applications. I'm sure they have made their concerns known to the FAA?

The FAA public stakeholder hearing is tomorrow at 5pm. Yes. The idea is to drum up support before the public hearing.

https://www.faa.gov/space/stakeholder_engagement/spacex_star...

> The FAA will hold two virtual public hearings to solicit comments from the public concerning the scope and content of the Draft PEA. The hearings have been moved to October 18 and October 20, 2021 at 5:00 p.m. Central Time. The FAA invites all interested parties to attend the meeting. Register to attend here.

By publishing the qualms of the PEA document SpaceX submitted, people will have the precise, technical arguments needed to ensure that the meeting tomorrow can go more smoothly.

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ESG_Hound seems focused on the natural gas issue. There's a few other groups who have studied the rocket-launch assessment side and have also come up with concerns.

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The process was _SUPPOSED_ to be SpaceX preparing a comprehensive PEA for the public to discuss. However, all sorts of details with regards to natural gas seem to be missing, which means that SpaceX has either purposefully, or inadvertently, sabotaged the conversation and the environmental assessment process.

All we'll be able to do tomorrow is point out how inadequate some of these calculations are on the PEA.




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