Public Comments on SpaceX Starship Launch Facility at LC-39A Highlight Environmental and Safety Concerns

Kennedy Space Center, Florida — SpaceX’s ambitious plans to repurpose Launch Complex 39A (LC-39A) at the Kennedy Space Center for its Starship/Super Heavy launch vehicle program have sparked a wide array of concerns from various public and private stakeholders.

A public comment period was held as part of a required Environmental Impact Study held earlier this month. The FAA has now placed the received comments online at Regulations.gov. Numerous organizations, as well as private citizens, voiced their concerns and recommendations. The hearings held both in nearby Titusville, Fl. and online, resulted in a mix of highlighting potential environmental impacts, safety issues, operational considerations, and quality of life impacts.

Local citizens have been concerned about the environmental impacts of launches from NASA and the Cape Canaveral Space Force Station long before Starship was even a thought.

In the past, back in Apollo, the normal disposal of the solvent cleaning was down the drain … out the back door,” Rosaly Santos-Ebaugh, Kennedy’s remediation program manager and the person responsible for leading the cleanup told USA Today. According to documents obtained under the Freedom of Information Act, there are roughly 2 square miles of chemically contaminated soil and groundwater around Kennedy Space Center.

USA Today Report – 2011

In 2011, NASA reported that the pollution from Space Shuttle launches at Kennedy Space Center in Florida would cost the government $96 million to clean up and would take 30 years to complete. NASA officially ended the Space Shuttle Program on July 21st, 2011, when the Space Shuttle Atlantis touched down for the final time at Kennedy Space Center. The plumes of smoke from the 135 shuttle launches had caused toxic chemicals to seep into the sandy soil around the space center. Additionally, the Air Force announced they would allocate $50 million to address a similar environmental issue at Cape Canaveral.

The last shuttle mission launched from LC39A in July 2011. Photo: NASA

As far as pollution of the type caused by the shuttle goes, the effects of Starship chemical deposits remain to be seen. The Space Shuttle utilized solid rocket boosters (SRBs). Starship, on the other hand, does not use SRBs but a much cleaner burning Methane / Liquid Oxygen combination.

Airline Pilots Express Safety and Efficiency Concerns

The Air Line Pilots Association, International (ALPA), representing over 78,000 pilots, emphasized the importance of a safe and efficient National Airspace System (NAS). ALPA pointed out gaps in previous Environmental Assessments (EAs) and called for a more comprehensive Environmental Impact Statement (EIS). Their key concerns included:

  • Airspace Closures: There is a need to evaluate the environmental and operational impacts of airspace closures, such as longer flight routes, increased fuel burn, additional carbon emissions, longer flight durations, and delays in accessing airports.
  • Safety Impacts: It is necessary to consider the impacts on traditional NAS stakeholders above 10,000 feet, including the collection of additional information to review flight profiles and speeds at altitudes where commercial space vehicles encounter commercial airline traffic.
  • Launch Frequency: ALPA suggested analyzing the number of projected launches per year to ensure they do not exceed the operational limits defined in the Acceptable Level of Risk (ALR) concept​​.
Environmental Groups Highlight Ecological Concerns

Several environmental organizations, including the Merritt Island Wildlife Association (MIWA), Audubon Florida, and the National Wildlife Refuge Association, provided detailed comments focusing on the potential environmental impacts of the proposed project. Their concerns covered a wide range of issues:

  • Artificial Lighting: The impact of high-intensity lighting on nocturnal wildlife, nesting sea turtles, and migrating birds. The EIS must address mitigations to prevent hazards from artificial lighting​​​​​​.
  • Noise and Vibration: The potential for high noise levels to disrupt wildlife, particularly birds incubating eggs. The EIS should assess both short- and long-term consequences​​.
  • Stormwater Management: Recommendations for advanced stormwater treatment systems to protect water quality and manage runoff effectively​​​​.
  • Ozone Layer Damage: There are concerns about potential damage to the stratospheric ozone layer due to frequent launches, which require updated studies and assessments​​​​.
  • Cumulative Impacts: The cumulative effects of multiple space-related activities on water quality, air quality, habitat destruction, and carbon emissions​​​​must be considered.
Environmental Concerns

As you might expect, environmental concerns were also prominent in the feedback:

  • Containment of Industrial Discharges: The importance of containing and treating industrial discharges and stormwater on-site to prevent contamination of adjacent wetlands and habitats​​.
  • Sea Level Rise and Storm Resilience: The design of infrastructure at LC-39A should account for predicted sea level rise and increased storm frequency, ensuring long-term resilience​​.
  • Wildlife Habitat Management: The potential impact on prescribed fire management for habitat conservation, particularly for federally threatened species like the Florida Scrub Jay and Gopher Tortoise. SpaceX may need to provide financial support to ensure these management practices can continue despite the launch schedule​​.
Public Access and Economic Impact

The potential impact on public access to the Merritt Island National Wildlife Refuge and Canaveral National Seashore was another significant concern. One issue voiced by many citizens is the single road leading to Playalinda Beach in the Canaveral National Seashore. The beach is in itself a popular local destination, and is a favorite among launch watchers. With an anticipated 44 launches per year, the possibility of frequent closures of these areas could affect over 2.1 million annual visitors, impacting local businesses reliant on tourism and outdoor recreation. The EIS should analyze the economic impact of such closures and explore alternative strategies to minimize disruption​​.

Playalinda beachgoers watch a Falcon 9 lift off from Pad 39A. Photo: Charles Boyer/FMN
Playalinda beachgoers watch a Falcon 9 lift off from Pad 39A. Photo: Charles Boyer/FMN
Concerns from Local Residents and Organizations

Local residents and organizations have also raised several critical issues. Lewis Kontnik, a Brevard County resident, emphasized the need to manage and mitigate the cumulative and indirect impacts of the project to protect the Indian River Lagoon and maintain the quality of life in Brevard County. Kontnik called for a comprehensive analysis and mitigation plans for the full range of impacts associated with the proposed action and other foreseeable developments​​.

General Public and Community Comments

Comments from the general public highlighted various concerns about the environmental and community impact of the proposed launch facility. Issues raised included:

  • Public Facility Closures: The impact of SpaceX’s heavy-lift vehicle operations on public access to facilities like Playalinda Beach, which is often closed during launches. Concerns were expressed about the frequency of these closures and the need for alternative access routes​​.
  • Environmental Impact: The detrimental effects on Florida’s delicate ecosystem, including noise and light pollution affecting wildlife and nesting habitats. There were also concerns about the potential for rocket debris to harm marine life and coral reefs​​.
  • Economic and Social Impact: SpaceX must be accountable for any damage caused and contribute to the local community through taxes and environmental preservation efforts​​.

Overall, there is general support for repurposing LC-39A for SpaceX’s Starship program due to its lesser environmental impact compared to building new launch sites. The public’s comments do, however, underscore the necessity for a thorough and comprehensive EIS. Addressing the multifaceted environmental, safety, and operational concerns will be crucial for balancing the advancement of space technology with the preservation of the surrounding natural and human environments. As SpaceX and NASA move forward, collaboration with stakeholders and adherence to rigorous environmental standards will be essential to ensure the project’s success and sustainability.

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