Earlier this week, the FAA issued its Final Programmatic Environmental Assessment and Mitigated Finding of No Significant Impact/Record of Decision for SpaceX’s Starship program, which involves the Starship Spacecraft and Super Heavy Rocket. SpaceX plans to launch its planned Starship missions from its South Texas Launch Site, also called the Boca Chica Launch Site, near Brownsville, Texas.
What does this assessment mean?
Conditional upon the fulfillment of 75 conditions within the assessment report, the company is on track to successfully complete the environmental permitting process in time for its planned tests later this summer. So although this assessment is not technically an “approval,” it’s good news for SpaceX, and is something akin to a conditional approval.
What is the Starship program?
SpaceX completed its fifth high-altitude test for a Starship prototype on May 5th, 2022. The Starship is “a fully reusable transportation system designed to carry both crew and cargo to Earth orbit, the Moon, Mars and beyond. Starship will be the world’s most powerful launch vehicle ever developed, with the ability to carry in excess of 100 metric tonnes to Earth orbit.” This program will allow larger payloads than ever before to enter Earth orbit, and is a major step towards the future of space exploration.
Although this approval is good news for innovation and the future of private space activities, it does tell something of an alarming story about environmental approvals in general, and in the energy and aerospace sectors in particular.
Any development of innovative technologies now comes not only with its own costs, but with extensive permitting costs, as well as a whole host of accompanying costs that developers must accept in order to proceed with projects.
This project is no different.
Many of the required actions fall into two broad categories: historic preservation and ecosystem protection. Some of the proposed requirements seem to accommodate the melding of purposes of the area reasonably, protecting historic sites from destruction and requiring measures to avoid destruction of the ecosystem and its endangered and threatened species. But, some of the measures go beyond the realm of reasonableness and are indicative of what makes it so difficult to build and do big things.
One example is the requirement for “Preparing a historical context report (i.e., historical narrative) of the historic events and activities of the Mexican War (1846–1848) and the Civil War (1861–1865) that took place in the geographic area associated with and including the APE.” There are several other requirements relating to the creation of historical markers and the study of area history that seem similarly to go beyond the logical scope of what this company should be working on.
As Alec Stapp, Co-Founder of the Institute for Progress, pointed out on Twitter, “Each request may seem minor on its own, but it’s death by a thousand cuts for many projects.” Just because SpaceX is a big company that will almost certainly be willing and able to pay the fees and take the actions that the FAA and other agencies require, does not mean that these requirements are good policy. They contribute to an unpredictable and expensive permitting process that unnecessarily serves to discourage the sort of development that is necessary for a nation that purports to prize innovation and development.
Some commentators have pointed out that many of these requirements could be avoided by refusing to take any federal money in the first place, because Section 106 of the National Historic Preservation Act of 1966, which is responsible for many of the more eyebrow raising requirements, only applies to companies that do so.
But in my view, policies like this one, even when they are directed toward companies that receive government funds, can be frivolous and wasteful. It would be even worse to apply these restrictions to purely private activities, but it is still an anti-development policy to require such a litany of giveaways for pet causes and unrelated issues. It is also worth noting that although most companies in this area work in partnership with NASA and the U.S. government, and accept government funding in various ways, industry is far and away less government centric than it was years ago. Current space activities are much more free market than even some of the most ardent libertarians would have imagined 10 years ago.
These requirements take time and money to comply with, and those costs can be absorbed by a large organization like SpaceX, but may serve to keep smaller entrants into the aerospace industry from entering and providing competition in the sector.
On the whole, this Final Programmatic Assessment is good news. After the various adjustments are made and side costs absorbed, SpaceX will be able to go ahead with its plans to launch both vehicle programs on schedule.
This piece was produced by Paige Lambermont, a Policy Associate at IER