With SpaceX quickly building necessary infrastructure at sites like LC-39A in Florida, eventual Starship launches are not far away. SpaceX and Elon have expressed in the past that while Boca Chica is a great test site and facility, the future of the vehicle likely lies in Florida. Even new reports suggest that SpaceX wants the capability to launch Starship 120 times a year from that state.
With this being said, some companies in the area are not too fond of what this could mean. Both Blue Origin and United Launch Alliance have submitted comments on the FAA’s EIS of Starship in the area. Their comments include concern of Starship’s impact on their employees, general operations, noise, health, etc. Here I will go more in-depth into what both companies had to say, the significance of these comments, future plans, and more.
Blue Origin & ULA Comments
These comments from both companies are related to an EIS or Environmental Impact Statement which was issued by the FAA and is active right now. The proposed action involves issuing a Vehicle Operator License to SpaceX, as well as potential future renewals or modifications to the Vehicle Operator License for operations that would be within the scope analyzed in the EIS. Put simply, it impacts both the ability to launch a vehicle like Starship from LC-39A and especially the frequency at which is launches.
With this comes the opportunity for companies or those possibly impacted by the decision to submit comments and concerns for the FAA to consider in their decision. This is what we are seeing from both Blue Origin and United Launch Alliance.
Starting with Blue Origin, they submitted a 3-page document listing a wide variety of concerns with future Starship operations at the Cape. Within the mitigation section, they were quoted saying, “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” they said.
Another interesting mitigation was “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.” In other words, compensate Blue Origin for any disruptions with their work related to launching Starship at LC-39A. For reference, Blue Origin operates a facility nearby.
The rest of the comment mainly included general factors like health and safety, transportation, airspace, and many others. What’s arguably even more interesting are comments from ULA and even CEO Tory Bruno.
In ULA’s case, they created a 22-page letter outlining 17 major concerns with SpaceX’s future Starship plans in Florida. In one long quote, they said, “SpaceX does not intend to limit its operations to LC39-A. It also proposes to
build infrastructure and launch multiple Starships from the nearby Space Launch Complex 37 (SLC-37) at CCSFS. The Department of the Air Force is currently preparing an EIS to assess the environmental impacts at SLC-37. The EIS notice for SLC-37 provides little detail about the proposed scope of operations, simply stating that “SpaceX would modify, reuse, or demolish the existing . . . infrastructure at CCSFS to support Starship-Super Heavy launch and landing operations.”
“The FAA’s EIS should evaluate SpaceX’s proposed operations at LC-39A in conjunction with SpaceX’s proposed operations at SLC-37. This should further include an assessment of national security space capabilities and the associated vulnerabilities presented by the consolidation of these operations at adjacent launch complexes within a six-mile area. This also potentially increases the threat to other national security space launch providers located in the same six-mile area. SpaceX seeks to frequently launch the largest rocket ever from two launch sites within a six-mile area. Just one Starship launch site is likely to disrupt other launch operations in the area and cause significant environmental impacts, as discussed in detail below.”
“The impacts are certain to be amplified if coming from two launch sites in such close proximity. For example, SpaceX intends to conduct up to 44 launches per year from LC-39A. If SpaceX aims for a comparable number at SLC-37, that would lead to nearly 100 launches per year—or one every three days or so. The FAA should also consider the cumulative impacts of SpaceX operations from LC-39A and SLC-37 on air quality, noise, water quality, public safety, other launch operators, and the ability to maintain assured access to space” they said.
In regard to ULA’s comment, the 100 launch estimate is not far off. A new report revealed the exact number of launches SpaceX would be targeting at both sites. 44 from LC-39A and 76 from SLC-37, combining to a total of 120 a year.
Interestingly, beyond comments within the letter, ULA CEO Tory Bruno also had quite a bit to say in regard to this entire process. In one reply he said, “The total launch capacity of the Cape will go down if other providers are forced to evacuate their facilities whenever a vehicle is fueled. Nor will it be practical to require class A hearing protection across and beyond the Base.” When someone asked if what ULA was doing was uncompetitive he replied, “Indeed it could be, but not the way you might think. The application suggests explosive arcs that force other people to evac their facilities at sound levels that are impractical and beyond the Cape, which is not intended to be a single provider facility. The other providers have been asked how they are impacted. The Gov will evaluate.”
In one final tweet, he said, “It’s a very, very large rocket, and getting bigger. That quantity of propellant requires an evacuation zone whenever fueled that includes other people’s facilities. A (weekly) Launch has injurious sound levels all the way into town. The Cape isn’t meant for a monopoly.” It’s clear based on these comments that Tory and ULA are genuinely concerned about what Starship’s future in Florida could look like.
Focusing back on the letter, ULA also pointed out plans to make Starship much bigger and more powerful over time. Here the statement said, “As a threshold matter, the EIS must acknowledge that Starship is still in its experimental stages and that SpaceX’s planned operations at the LC-39A have evolved and continue to evolve. Starship is the largest rocket ever built, and it is currently tested at SpaceX’s private base in Boca Chica, Texas. In prior test flights, SpaceX has experienced several technical accidents. In addition, SpaceX has acknowledged that the vehicle is not meeting anticipated performance levels. As a result, SpaceX has indicated that it plans to increase the size and thrust level of the vehicle stages to address this performance shortfall. This would result in environmental and safety issues greater than those witnessed at Boca Chica. SpaceX intends to launch a larger model at LC-39A than it is currently testing in Boca Chica” they said.
Here, they go on to talk about the size and propellant capacity of the vehicle before mentioning, “The resulting launch impacts would far exceed current impacts seen during current Boca Chica launches. Additional growth of the Starship launch vehicle may be planned if performance continues to fall below expectations. Given these changes, the EIS must perform a comparative analysis between current usage impacts and the proposed operations, with a rocket proposed to be more than double the size of any currently licensed launch vehicle and with increased frequency of launches” they said.
For reference, most of what I’ve said so far has been statements from just two of 17 total concerns. The 22 pages are filled with different problems the company thinks SpaceX and Starship could bring to the area. For one final example, they talk about the possibility of accidents. Here they are quoted saying, “SpaceX has had significant accidents and associated impacts during testing of its Starship system. In 2019, the launch of an experimental rocket at Boca Chica “almost immediately started brush fires near the launch pad,” and although emergency workers attempted to stop the fire, it spread and burned over 100 acres in the area. A similar incident occurred during a static fire test of Starship in 2022, destroying 68 acres of protected bush. In the first Starship test launch, before the rocket itself exploded, the launch caused serious damage at ground level, as the launch pad “exploded, with concrete chunks from it flying in multiple directions leaving behind a giant crater underneath,” “risk[ing] hitting the fuel storage tanks.” A federal lawsuit, on behalf of the Boca Chica community and protected wildlife areas is currently pending against SpaceX based on the environmental damage caused by that accident.
The EIS must assess the likelihood of accidents, ranging from minor to catastrophic. For example, it should clearly and accurately determine TNT (explosive) equivalence of Starship’s propellant systems, to understand the implications of an explosion at or near pad level” they said. In the coming months, we can expect the FAA to look over these concerns and determine their importance and likelihood before issuing an eventual decision.
Conclusion
Blue Origin and especially ULA are concerned about what SpaceX and Starship in particular could bring to the Cape. They have submitted comments with the hopes that the FAA will look them over and consider them when deciding what to do with Starship. We will have to wait and see how it progresses and the impact it has on the space industry.