Ss-SH operations are expected to have a greater environmental impact than any other launch system currently operating at KSC or CCSFS. Ss-SH can hold up to an unprecedented 5,200 metric tons of liquid methane for propulsion, resulting in Qualified Distances for safety margins that potentially overlap the operational sites of other companies, the Government, and the public. The data quantifying these Qualified Distances has not been published, but given the anticipated Ss-SH launch rate and vehicle impact, the impact of Ss-SH operations at KSC may be even greater than at Starbase.
Accordingly, the EIS should thoroughly evaluate the considerable risks, alternatives, mitigations, and resources listed below. The issues raised herein are reasonably foreseeable.
Mitigations
Mitigation measures not currently included in the Proposed Action should be considered, including but not limited to:
• Capping the rate of Ss-SH launch, landing, and other operations, including but not limited to test firings, transport operations, and fueling, to a number that has a minimal impact on the local environment, locally operating personnel, and the local community, in consideration of all risks and impacts, including but not limited to anomaly risks, air toxin and hazardous materials dispersion, road closures, and heat and noise generation.
• Government investment in additional launch infrastructure that would make more launchpads available to other entities in a manner that deconflicts Ss-SH operations from other launch providers at KSC and CCSFS to preserve the health and safety of their personnel and Assets.
• Government investment in additional infrastructure for KSC and CCSFS that would reduce the risk to other launch providers at KSC and CCSFS in order to preserve the health and safety of their personnel and Assets by diverting traffic from the Proposed Action area, including but not limited to improving the Roy D. Bridges Bridge to accommodate transport of large Assets.
• Limiting Ss-SH operations to particular, limited times to minimize and make predictable their impact on the local community, and allotting other launch providers the right-of-first-refusal or schedule priority for certain conflicting launch or other operational opportunities.
• Mitigating the effects of Ss-SH that would require evacuation or other operational pauses at other launch providers' launch sites through infrastructure improvements or other operational changes.
• Require SpaceX and/or the Government to indemnify third parties for any losses caused by or related to Ss-SH operations, including commercial disruption incurred due to the operation of Ss-SH.
• Institute independent mandatory penalties for SpaceX for conducting operations not included in an active EIS or other environmental restriction, violating a launch license, or any other laws, regulations, or other rules for operating.
Resources
No. 23-1204 (D. D.C. filed Dec. 15, 2023) available at