The Environmental Impacts of SpaceX's Oil and Gas Gambit
A Guide for the Public
I’m not a journalist. Or, at least, I wasn’t one.
In the four weeks since SpaceX and the FAA dropped the Programmatic Environmental Assessment (PEA) for the proposed expansion to Starbase in Boca Chica, I appear to be the only person on the internet actually digging into and writing about all the stuff in the document. Stuff, of course, being everything besides the rockets.
I wanted to write about the details, the stuff deep in the weeds, to my audience. That ship has long sailed. I’ve written 17 posts on the topic. I have no copy editor and I was writing as I discovered new, and sometimes shocking, revelations that were either explicitly mentioned or obviously missing but implied elsewhere. The narrative structure of my series doesn’t exist because there isn’t one. I started writing about everything I could the second I realized how massive of a story this is and haven’t stopped since. It’s time to take a step back and summarize, to the best of my ability.
The construction of SpaceX’s facility in Texas was initially authorized in 2014, following an extensive Environmental review and release of an Environmental Impact Statement (EIS), commissioned by the FAA as a required under the National Environmental Policy Act (NEPA). NEPA requires full disclosure of all environmental impacts related to a project that receives government funding or utilizes government land. Whichever agency is granting approval for these resources is responsible for the EIS and compliance with NEPA. If you’re building an interstate pipeline, FERC is the lead agency under NEPA. A DOE grant for a power plant makes them the lead agency, and so on.
The 2014 EIS authorized a handful of Falcon 9 launches annually by SpaceX along with the construction of a small support facility.
The full Assessment and EIS process is lengthy, and can take 5 or more years to complete. Because it is such a burdensome and exhaustive process, small or incremental changes can be authorized using the Programmatic Environmental Assessment (PEA) process. This is a mini EIS, that looks at proposed changes under the federal action, and determines if there is a significant change to the potential Environmental Impact of a project.
The FAA has used 8 written revisions (minor changes) to authorize the expansion of SpaceX’s operations, to the point that it looks like this today:
It doesn’t take a NEPA expert to see that the scope of the project is already well beyond the 2014 approval. This fact alone is concerning, since EPA and CEQ have repeatedly warned against “permitting by increment.” A lot of small changes can add up to a project that looks nothing like the original document. What’s happening this year, however, is a completely new ballgame.
While SpaceX charged forward with plans for Starship development, the public finally had enough after a series of explosions and mishaps, culminating in the explosion of test craft SN11 in March of this year, which spread debris across miles of a sensitive wildlife habitat. FAA ordered SpaceX to knock it off until the environmental stuff could be dealt with.
On September 17th, the FAA released a draft PEA to authorize the Starship program. The document was penned by SpaceX themselves, with the help of 11 Independent Reviewers, hired by the FAA from government consulting firm ICF specifically for their expertise in NEPA. The takeaway was that environmental impacts would be insignificantly different from the 2014 EIS.
I don’t know enough about rocketry to really talk about the launches themselves, nor do I know enough about wildlife range management or beach access law in Texas to add meaningfully to the discourse on these. But this was the supposed focus of the PEA: rockets, wildlife and beach closures.
Here’s the scope of the federal action, in their own words.
Remember, all environmental impacts (direct, indirect and cumulative) must be considered for items in the proposed action. Don’t take my word for it, here’s what the FAA’s policy document says:
3-1.3: Under NEPA, the FAA must prepare an EIS for actions significantly affecting the quality of the human environment (see Chapter 4 for additional information regarding significance of impacts). An EIS is a detailed written statement required under Section 102(2)(C) of NEPA when one or more environmental impacts would be significant and mitigation measures cannot reduce the impact(s) below significant levels. Direct, indirect, and cumulative impacts must be considered when determining significance
My interest was piqued by the stuff in the “Related Infrastructure Construction” box. I have made public comment on several federal projects and TCEQ (Texas’ environmental regulator) permitting actions over the years, in particular those related to development of new industrial activity in regions of the gulf that aren’t already impacted. I’m not broadly opposed to every single oil and gas project, but I find the industrial creep into every undeveloped mile of coast troubling. These projects in particular deserve, at the very least, a full and comprehensive review.
No one is talking about the oil and gas stuff
The rockets and the beach closures were all anyone talked about before, during, and after the Draft PEA process. Meanwhile, SpaceX and FAA had snuck a rather large industrial operation into this document. I noticed this nearly immediately and realized something very, very bad was going on. As I stated from day 1, construction of this kind of industrial operation constitutes a prima facie significant environmental impact.
A utility sized 250 megawatt power plant, a natural gas treatment facility, and a methane liquefier (eg a LNG process) is no small thing. TechCrunch, after some minor prodding from yours truly, covered the power plant and gas supply last week in context of NEPA.
Failing to mention this in the PEA is unusual, and possibly contravenes the federal National Environmental Policy Act (NEPA), says Pat Parenteau, professor of law and senior counsel in the Environmental Advocacy Clinic at Vermont Law School.
“NEPA is what we call the look-before-you-leap law,” Parenteau said. “It’s designed to inform federal decision-makers about the environmental impacts of their actions and ways to avoid them.”
Parenteau is one of the top legal scholars on environmental impact review. I finally had some heavy hitter support for my assertion that this whole thing stunk to the high heavens.
“More than 50 years after NEPA [was enacted], I’m pretty surprised to see an agency doing this,” Parenteau said. “Perhaps they’re hoping that nobody notices?”
If you know lawyers, they choose words carefully. I can’t claim such restraint, but the above quote couldn’t be more damning for the entire process.
As a professional in the field of environmental review, permitting and risk management, I have four main points on the whole mess:
The document itself is inadequate and contains numerous egregious technical errors
There are lots of direct, indirect and cumulative impacts completely missing
NEPA is a public disclosure law, and one month on, the fact is that the public remains in the dark about the industrial stuff
That the document itself was released in the first place is a troubling sign of how tech culture, monopolies and regulatory indifference has shaped society as we know it (and it’s not getting better)
The Worst NEPA document I have ever seen
As stated before, I’m not on some mission funded by Jeff Bezos to stop Elon Musk from saving humanity. I’ve been poking around in these sorts of projects for years, providing comment where I can. As a former regulator and corporate auditor, I enjoy it. Typically, my comments on NEPA or TCEQ permitting actions are dry, technical and minor. I’ll spend a few hours combing through an EIS, be it a LNG terminal, a pipeline or an industrial complex, looking at the laws I know best. I’ll find 1-2 things, usually minor technical quibbles, submit my comment and follow up a few months later.
As a way of comparison, I have a findings list, already 109 items deep, complete with calculations and regulatory citations on this project. There are so many things that are flat out incorrect, many of them complete showstoppers. Here are a couple of highlights:
Neither SpaceX nor the independent reviewers identified that a 250 Megawatt power plant would be only one of 28 source types (to go along with things like smelters and refineries) specifically named as “Major Sources of Emissions” under the Clean Air Act amendments of 1977, and subject to extra scrutiny. The justification for using a de minimus determination under the General Conformity Rule is flat out incorrect, legally and technically. This is Air Permitting 101 stuff.
A cooling tower is mentioned twice in passing in the PEA for condensing steam generated in the combined cycle power plant. A cooling tower this size would consume hundreds of millions of gallons per year. The PEA claims the entire project will consume only 5.4 million gallons per year.
The emissions calculations are very bad across the board. This one is really hard to describe for a lay person, but I think the CO2 calculations for the power plant is a great illustration, which were off by a factor of nearly 100x, and this is hardly all of the errors.A thread about CO2 emissions from cogen steam Natural Gas fired turbines, as it relates to Boca Chica (I am doing your work for you, journalists) SpaceX claimed that they would emit 9,858 Tons of CO2/year from a 250 MW power plant 1/
ESG Hound @ESGhoundThis "oopsie" might be something that the SEC's climate and ESG task force may want to look into https://t.co/t1wEPvJ4ac
All the Missing Stuff
In addition to the glaring technical errors, the items missing in this document are truly incredible. This has been the focus of much of my writing, so check out the links for analysis and discussion.
The Missing Pipeline: A 250 Megawatt power plant alone will consume over 100 trucks worth of compressed natural gas per day. These types of power plants cannot just stop and start and need constant access to fuel. Sudden shutdowns create major emissions events and can cause serious damage to the hundreds of millions of dollars worth of equipment. The idea that you’d even attempt to operate such a facility (or the Gas plant for that matter) without a pipeline is absurd. SpaceX clearly intends to build a pipeline, and TechCrunch even cited a federal official who said that SpaceX tried to recommission an old low pressure pipe that was abandoned in 2016 and repurposed as a data line conduit. Yet, the PEA does not discuss exactly how tens or hundreds of millions of standard cubic feet of gas per day will get to the facility.
The idea that such an item would not be in scope given that NEPA requires evaluation of all impacts, direct and indirect, is absurd. It’s all but certainly a deliberate omission, but that’s for future reporting and disclosure to determine definitively.
Any information whatsoever about the Gas Plant. The PEA discusses a “natural gas pretreatment process” that includes a 200 foot tall, 16 foot diameter deethanizer and “smaller cylinders approximately 6 feet tall.” This is a full on natural gas plant, and a rather big one at that, at least 50 million scf per day and all but certainly 200 mmscfd or larger. There is no information on the design capacity of the plant, nor is there any discussion on the flares, thermal oxidizers and NGL (natural gas liquids) handling and storage operations required for such a facility.
The plant itself, covered again in part 16, was what finally got this story to go viral. Thank you Hacker News!
The Implied Oil and Gas Production needed: Remembering that NEPA requires a full analysis of “direct, indirect and cumulative” environmental impacts, the Gas plant itself is a clear indication that SpaceX intends to treat and process field natural gas, the stuff that comes from newly drilled or re-fracked wells. The problem is that there are no wells near the facility. This is a very low activity part of Texas. The logic is outlined in this chart:
The Stuff the Public Doesn’t Know
This topic is important in the Historical Context of NEPA. The law itself revolves around public disclosure and addressing public comment. As I posted here:
And it's a testament to Elon Musk's true brilliance. If we don't mention the pipeline, it doesn't exist. 30 days is all we need. Report on it after then, fine. By that time the FAA has rubber stamped the PEA.
When we find out 6 months from now that, yes, a pipeline was, in fact, needed, the story changes. As a result, the Texas RRC and US Department of Fish and Wildlife is forced to permit the needed pipeline regardless, despite the fact that it was illegally omitted from environmental review. They've already poured the foundation for the gas plant after all.
The fact that no one, not the press, not the FAA and certainly not SpaceX are discussing the missing but required stuff is a clear indication that NEPA has been violated. It’s a public disclosure document, after all. That’s the issue I want to push and has been the focus of much of my writing.
It’s also important to note that what we call things matters. NEPA requires plain language so the public understands what’s going on. Renaming standard industrial processes and units to things that sound different is an insidious form of greenwashing, as discussed here:
The Musk Reality Distortion field allows someone to call Pipeline spec Natural Gas “Pure Methane.” Behind the Distortion Field, a generic Gas Plant is now a “Natural Gas Pretreatment Process” and an LNG processing plant is a “Rocket fuel Liquifier.” Throw on some Tesla Solar Panels and his squealing fans on Reddit breathlessly decree that STARBASE is GigaEden on Earth.
What all this stuff implies about Corporate Oversight
This is the most fascinating part of the whole saga to me. That SpaceX, FAA and the FAA’s hired contractors appear to have all 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 is incredible.
It’s almost as if the rich and powerful, especially the tech variety know they can get away with whatever they want:
I keep getting asked by people “Why do you care so much about this?” I hope I’ve made it clear up to this point that the level of sloppiness and lack of professionalism displayed by the Environmental Specialists at FAA and SpaceX is insulting to me personally. I take pride in my work, and would be embarrassed to sign my name to this dreck.
It’s also symptomatic of Monopoly power. SpaceX has done a tremendous job up to this point developing a space program, I won’t ever deny that. Forget unit economics of landing rockets or gimmicks or Elon Musk antics, they are now *the* Big Fish in the US space program. Right or wrong, they have become a necessity for NASA. This leads towards a troubling dynamic you see with monopolies or near-monopolies. Doubly so if they rely on government money.
SpaceX owns the FAA. This Draft Programmatic Environmental Assessment (PEA) is all the evidence you need. Construction of a large, 250 MW power plant and a gas plant alone is clearly not an insignificant environmental impact. The PEA process is to expedite minor changes to a full EIA.
Separating Fact From Opinion
Keep in mind, I’m not a journalist. I have my biases and they are laid out for all to see. This is an op-ed kind of Substack, not the investigative journalism variety. I shouldn’t have to report breaking news, but since no one else is, it kind of falls on me out of necessity.
I was, and still am, concerned about the process being rushed through approval without disclosure. So if you go back and look through my writing, I think it’s clear that it is very upsetting to me, personally and professionally.
That being said, I am absolutely guilty of meandering between opinion and fact and analysis. No doubt about that. I wish, truly, that it wasn’t up to me to be the person reporting on all this, well… stuff.
Let the reporters do their jobs. I’ll keep on keeping on. That way if you don’t like my world view or personal feelings about Elon Musk you can just continue to ignore my writing (which is 100% ok with me) and not be in the dark about real facts. I’d indeed prefer it that way.
PART 1 - NEPA Primer / FAA has no business permitting oil and gas facilities
PART 2 - Elon Musk’s Natural Gas Treatment Plant
PART 3 - SpaceX is building a pipeline and doesn’t feel the need to mention it
PART 4 - SpaceX dreams of drilling for a sh*tload of oil
PART 5 - A discussion on the hugeness of the project, a parade of tankers and a reality check about the Oil and Gas biz
PART 6 - The Facility would be a Major Source of Pollution under the PSD Rules in the Clean Air Act, which by statutory definition would exclude it from fast track approval under NEPA
PART 7 - The GHG and CO2 emissions are plainly nonsense
PART 8 - ESG Hound drops the gauntlet and explains why this is a massive fraud happening in plain sight.
PART 9 - The End of NEPA as we know it
PART 10 - ELON MUSK REALITY DISTORTION FIELD
PART 11 - Pipeline Plans Confirmed!
PART 12 - It turns out drilling for oil and gas has some negative environmental impacts
PART 13 - I found the Modular Gas Plant; the clue that got me there will leave you stiff with shock
PART 14 - The wildlife toll of industry, told through my personal experiences
PART 15 - SpaceX is building an LNG, does anyone care?
PART 16 - First Principles and gas processing plants