South Texas Chapter

Public Comment on SpaceX Starship / Super Heavy Project

SpaceX’s Starship / Super Heavy Project at Boca Chica

Speak Up on SpaceX’s Boca Chica Project!

However you may feel about the future of space travel and exploration and the project in concept, SpaceX’s Starship / Super Heavy project will certainly affect our local communities in a very real way, so it’s important for us as community members to be aware of what’s being proposed and to speak up to represent our interests.  Below is a summary of planned and potential impacts resulting from the SpaceX Starship / Super Heavy project at Boca Chica as characterized in the draft Programmatic Environmental Assessment (“PEA”) written by SpaceX:

What we know about the project:

  • Project description: SpaceX’s proposed Starship/Super Heavy program consists of suborbital launches and orbital launches from its facilities at Boca Chica. SpaceX’s proposal also includes launch-related activities at the Boca Chica Launch Site, such as tank tests, static fire engine tests, expansion of the vertical launch area (VLA) and solar farm, and construction of additional infrastructure including parking lots, a liquid natural gas pretreatment system, a natural gas liquefier, a payload processing facility, a power plant, a desalination plant, and trenching and pull-offs along State Highway 4.
  • Beach access closures: For this project, SpaceX proposes to close State Highway 4–the only public roadway connecting Brownsville and surrounding communities to Boca Chica Beach, state park land, and the National Wildlife Refuge–for up to 800 hours annually.  This is 500 additional hours above the 300 hours currently permitted.  800 hours of closure would be akin to closing Highway 4 for 5 hrs per day, Monday through Friday, for 32 weeks of the year.  This runs afoul of the provisions of the Texas Open Beaches Act which protects Texans’ rights to access state beaches.
  • Air pollution mitigation: The project and its components are expected to emit enough carbon monoxide (102 U.S. tons per year) to qualify it as a “major source” of pollution by U.S. EPA.  Because of that, the FAA needs to conduct a conformity determination to comply with air pollution laws, which it has not done yet.
  • The PEA acknowledges that there will very likely be additional future explosions, which it refers to as anomaly events, and further acknowledges that these events may cause glass breakage and debris. There is also no proposed mitigation to prevent harm to habitat or wildlife from the anomaly events caused by debris, sound, or shock waves.
  • Sonic booms and overpressure / Public safety and property damage:  The PEA notes that predicted overpressure levels for a Super Heavy landing range from 2.5 pressure per square foot (psf) to 15 psf. Brazos Island State Park, Boca Chica Bay, Boca Chica State Park, portions of the NWR, Boca Chica Village, and Tamaulipas, Mexico would experience levels up to 15 pressure per square foot. Boca Chica Beach and the southern tip of South Padre Island are within the 6.0 psf contour. South Padre Island, including residences, Port Isabel, and the Port of Brownsville ship channel are included in the 4.0 psf contour.  The potential damage that can occur at 4-6 psf includes damage to glass, plaster, roofs, and outside walls. The potential damage that can occur at 10+ psf is more severe.
  • Noise: The Center for Disease Control notes that immediate hearing loss can occur at sound intensity levels of 120 dB.  The Noise addendum to the PEA shows that portions of South Padre Island and Port Isabel will likely be exposed to sounds at 120 dB during Starship Orbital launches and landings.  
  • Power plant:  The proposed gas-fired 250-megawatt power plant will be about 5.4 acres in size, have structures up to 150 feet tall, and operate continuously year-round, day and night.  A power plant this big typically serves over 100,000 homes. SpaceX needs the gas power station to run a new desalination plant that will produce the millions of gallons of fresh water needed annually for sound and fire suppression during launches. Large amounts of electricity will also be used to make liquid oxygen from the air.  A 250-megawatt power station would normally qualify as a major new source of air pollution under the Clean Air Act; thus, the impacts of this plant need to be fully disclosed, analyzed, and mitigated to properly comply with NEPA.
  • Wildlife: The project area is immediately adjacent to state parks lands, beaches, and a national wildlife refuge.  The project will affect listed and endangered species through impacts associated with noise, overpressure, construction, industrialization, traffic, explosions, lighting, habitat displacement and habitat disturbance. 
  • Social justice issues: The negative impacts associated with loss of beach access, access to park and refuge lands, potential for property damage, and public health and safety concerns will disproportionately impact low-income communities and communities of color, which are the communities in closest driving proximity to the project area.
  • Community exclusion from this process: The Carrizo/Comecrudo Tribe of Texas, the ancestral lands of which are being developed by this project, have not been consulted at any point by SpaceX.  Project analysis materials and notices have not properly been distributed in Spanish.  It is unknown whether the governments or communities in Tamaulipas, MX have been made aware of the project or invited to comment.


What we DON’T know about the project:

  • Brownsville Ship Channel closures: We do know that there will be times when travel through the ship channel is restricted. However, although the PEA notes that such restrictions would occur during orbital and some suborbital launches (= up to 23 annually), as well as potentially after unplanned explosions/ “anomaly” events, it does not define for how long these closures are expected to occur.  If the shipping channel restrictions are managed similar to roadway restrictions (i.e. a closure is scheduled and the public is notified of the closure, only for the closure to later be cancelled), the increased in de facto closures could exacerbate economic impacts to charter fishing operations that rely on bookings, dock workers, and the shipping industry.
  • Natural gas: It is unclear how the tens of millions of cubic feet of gas required daily will get to SpaceX’s remote facility near the Mexican border.  Potential methods could include reusing a defunct natural gas pipeline running through the Lower Rio Grande Valley National Wildlife Refuge, drilling/fracking onsite, or trucking in natural gas, which would require thousands of tanker deliveries every year. NONE OF THESE are included in the PEA analysis, meaning that there are potentially significant impacts that are undefined and unmitigated.
  • Desalination: The project proposes to construct a 4300 square foot desalination plant, which would treat water from two new source wells and the existing well, and which would inject brine into an injection well ~2900 ft deep. Further details about how the injection well will work and the impacts of injecting brine into the aquifer are not included in the PEA. The PEA also does not describe if or how aquifer drawdown will impact connected water resources or other water rights holders/water users reliant on this aquifer. There is no information about how much energy will be required to run the desalination plant other than “the desalination process requires substantial quantities of energy”.
  • Financial responsibility for sustained property damage:  The PEA notes that “SpaceX will be responsible” for damages sustained from future explosions and overpressure events, yet it does not outline or propose any actual process for property owners to seek reimbursement for property damage caused by anomaly events.  
  • Despite indications from Elon Musk about his intentions to turn Boca Chica into the city of “Starbase,” the full extent of the project has not yet been defined for environmental review. SpaceX and the FAA intend to take a piecemeal approach to review as opposed to the FAA requiring SpaceX to better define the full project so that it can be studied all at once. This kind of approach deprives affected communities from fully understanding the full, long-term consequences of all pieces of this project.

Key Conclusions:

  • The analysis is deficient and does not include a sufficient level of detail about the project or its potential impacts.
  • The project as proposed does not comply with the National Environmental Policy Act, as there are likely significant environmental effects for which proper mitigation has not been proposed.
  • A comprehensive Environmental Impact Statement (EIS) is needed to understand the full extent of impacts that this project may cause, and this EIS needs to include and fully analyze all planned components of the project.

Opportunities to make your voice heard:

  • Monday, October 18 and Wednesday, October 20 – online hearing and oral comments –> visit this page for specific details about participation in the hearings
  • Through November 1 – written comments about the draft PEA can be addressed to Ms. Stacey Zee, SpaceX PEA, c/o ICF, 9300 Lee Highway, Fairfax, VA 22031 or submitted by email to
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