FWS Says SpaceX Boca Chica Operations Have Severely Impacted Wildlife Refuge, Criticizes FAA Environmental Assessment as Inadequate

Debris from a Starship MK1 pressure test explosion in November 2019 with arrows showing how the pieces were removed from the marshland. (Credit: SpaceX)

by Douglas Messier
Managing Editor

SpaceX’s operations at its Boca Chica test site in Texas have severely impacted the adjacent Lower Rio Grande Valley National Wildlife Refuge and its wildlife due to rocket explosions, wildfires and excessive road and beach closings, according to a letter from the U.S. Fish and Wildlife Service to the Federation Aviation Administration (FAA).

“Frequent closures of the Refuge caused by SpaceX activities are already substantially impairing both the Refuge’s ability to adequately manage the Refuge and the public’s enjoyment of the Boca Chica Beach area for wildlife-dependent recreation. There are both ‘adverse’ and ‘severe’ impacts to Refuge public use, management, wildlife, and habitat from the SpaceX activities,” the letter said.

The letter to FAA Safety Division manager Daniel P. Murray was signed by Manuel Perez III, manager of the South Texas Refuges Complex, and Charles Ardizzone, project leader of the Texas Coastal Ecological Services Office.

The Jan. 22 letter said that SpaceX’s plans to significant expand its operations and physical footprint to include launches of the Super Heavy and Starship rockets will further exacerbate the impacts on the sensitive wetlands and the endangered species that reside there. FWS officials urged the FAA to conduct a much more rigorous environmental review of the plans than it is currently performing.

FAA has issued a preliminary environmental assessment (PEA) with the preferred option of approving the expanded operations. The agency held two public hearings on the project last month. The deadline for public comments was Nov. 1.

Debris is removed from marshland after an explosion at SpaceX’s Boca Chica test site. (Credit: SpaceX)

FWS said the impacts of SpaceX’s operations have been much greater than anticipated when the federal government approved the Boca Chica facility in 2014. The FAA conducted an environmental impact statement (EIS) that included a FWS analysis of the impact on the operations on the local area.

At the time, SpaceX planned to launch 12 Falcon 9 and Falcon Heavy rockets from the facility just north of the Mexican border. However, Elon Musk’s company abandoned those plans in 2018, electing to develop and flight test the much larger Starship and Super Heavy launchers.

Although the original approval allowed SpaceX to fly experimental vehicles at Boca Chica, the impacts of those activities were not analyzed in the original EIS, the FWS letter said.

“Since 2014, SpaceX has undertaken activities not covered in FAA’s 2014 EIS which addressed
only 12 launches per year, not continual experimentation related to the Starship/Super Heavy
proposal as is currently being carried out. SpaceX activities not covered include a higher
frequency of road closures extending well beyond 180 hours, large explosions from reported
anomalies, the appearance of significantly large staffing, 24/7 operations, traffic, and construction activities not analyzed in the 2014 EIS,” the letter said.

Under the 2014 approval, SpaceX was limited to closing access to the wildlife preserve and beach for 180 hours annually. FWS said it recorded that access was closed for more than 1,000 hours in 2019. SpaceX disputed that claim, claiming it only closed access for 158 hours, the letter said. The company now wants to expand closings to 300 hours per year.

Ruts in the marshland created by removal of debris from a November 2019 explosion. (Credit: SpaceX)

“In addition, SpaceX rocket debris falling onto the Refuge has damaged the sensitive wind tidal flats. And, the vehicles or machinery used to retrieve rocket debris have created ruts and caused other damage that interrupts water sheet flow across these flats. Two SpaceX incidents on July 25, 2019 and again in August 2019 resulted in wildfires of 130-acres and 10-acres respectively burned through coastal prairie and dune habitats on refuge managed land. Anomalies resulting in explosions on November 20, 2019, February 28, 2020, and December 9, 2020 resulted in debris scattered onto refuge managed lands. Retrieval methods damaged the sensitive alkaline flat and refuge cable fencing installed to protect the area from disturbance,” the FWS letter said.

The FWS letter was included in comments sent the FAA by group of 11 environmental organizations opposing SpaceX’s planned expansion. The submission included internal FWS emails, one of which chronicled the impacts SpaceX has had on the local environment. [Emphasis added]

Example of damages by/from Space-X:

Traffic volume, road closures, wildlife mortality
Impacts to habitat: tidal flats, dunes, coastal prairie – debris, fires, rutting, wetland filling
Fires – 2 fires in 2019
Explosions (Debris scattered) – several since 2019
Development – conversion to industrial development/testing area
Residential Eviction – Kopernik Shores
Loss of public access to refuge, state park, beach and no reliable access or land management

Important Dates:

Nov 2018 – during Federal Government Shutdown/Furlough – Space X announces they will change activity from launch facility to a testing facility
April 21,22 -2019 – Space X employee(s) get stuck with 2 vehicles and a forklift in tidal flats. Causes significant damage to tidal flats. Space X employees did not have permission to be on the refuge.
July 25, 2019 – 130-acre fire caused from Space-X test that sent fire/embers into the coastal prairie
August 2019 – second 15-acre fire, mostly in the dunes
November 20, 2019 – MK 1 explosion; Nose cone north of HW 4; cable fence damaged (never fixed)
February 28, 2020 – explosion – SN1 – Big debris north of HW4
Dec 9, 2020 – explosion of SN8 – Big debris (LE managed); Space-X still dragged/damaged flats

In its letter, FWS said SpaceX’s activities have “significantly diminished” the service’s ability to maintain the health of the wildlife refuge and protect its endangered species.

“This occurs by preventing or constraining public access year-round, hampering biological and monitoring studies including sea turtle patrols, sea turtle cold-stunning responses, hampering refuge management and law enforcement patrol, increased observations of road mortality of wildlife at all hours of daytime and nighttime, damage to sensitive habitats such as the wind tidal flats and to the salt prairie from explosions and fires, as well as adversely impacting nesting habitat for sensitive species. According to the Coastal Bend Bays and Estuaries Program, Wilson’s and Snowy Plovers, have essentially stopped nesting near the SpaceX site in the last two years,” the FWS letter said.

SpaceX’s plans to launch Starship and Super Heavy rockets from Boca Chica involve a significant expansion of the facility, including the filling in of 17 acres of marshland and the construction of a power plant.

Instead of conducting another EIS, which would take years, the FAA has elected to conduct a less rigorous and faster environmental assessment (EA) of the expansion plans. FWS officials recommended FAA conduct a new EIS given the inadequacy of the original statement and the substantial impacts expected under SpaceX’s expanded operation. They said it is required under the National Environmental Policy Act (NEPA).

“The FWS believes that an EIS may be the more appropriate NEPA pathway for this proposed action if significant effects cannot be avoided. The FWS requests that you give adequate consideration to and objective analysis of our NEPA concerns; that you adequately comply with the [Endangered Species Act]; and, that you conduct an alternative action analysis per Section 4(f) of the Transportation Act of 1966,” the letter said.

Critics have made the same arguments. They claim that FAA’s decision to use an EA is an improper attempt to fast track approval of SpaceX’s expansion plans.


Comments on SPACEX Draft Programmatic Environmental Assessment for
Starship/Super Heavy Program
(includes FWS letter to FAA, FWS internal emails and SpaceX email with pictures of November 2019 cleanup following explosion)

Submitted to FAA by: Defenders of Wildlife, Environment Texas, Sierra Club Lone Star Chapter, Coastal Bend Audubon Society, Endangered Species Coalition, Surfrider Foundation, American Bird Conservancy, Friends of the Wildlife Corridor, Save RGV, Texas Campaign for the Environment, Center for Biological Diversity

Comments on FAA’s Draft Programmatic Environmental Assessment and Biological Assessment for SpaceX

Submitted to FAA by: Center for Biological Diversity