The FAA published a notice of availability of its draft environmental assessment for issuing SpaceX a launch license for an in-flight abort test. The FAA requested comments by December 31, 2018, for a launch and abort test scheduled to take place in 2019.
An FAA license would authorize SpaceX to conduct an abort test using a Falcon 9 launch vehicle and a Dragon-2, which is SpaceX’s crew version of Dragon. The proposed abort test is part of NASA’s certification process for allowing SpaceX to carry NASA astronauts.
Because issuing a license is a major federal action under the National Environmental Policy Act, the FAA must review any environmental effects of the license it would issue. Interestingly, the FAA looks at possible environmental effects of licensing on climate. I had not known about this, and went looking for an explanation.
The Climate Law Blog provides a historical overview (with links) of how this came about. The Council on Environmental Quality issued final guidance in 2016, which:
directs federal agencies to account for the effects of a proposal on climate change, using greenhouse gas (GHG) emissions as a proxy for those effects, as well as the effects of climate change on the proposed action and its environmental impacts.
Curious as to what effects a single launch could have on climate, I went next to the draft EA. The FAA found the effects would be either minimal or negligible:
4.4.1SIGNIFICANCE THRESHOLD There are no significance thresholds for aviation or commercial space launch GHG emissions, nor has the FAA identified specific factors to consider in making a significance determination for GHG emissions. There are currently no accepted methods of determining significance applicable to aviation or commercial space launch projects given the small percentage of emissions they contribute. CEQ has noted that “it is not currently useful for the NEPA analysis to attempt to link specific climatological changes, or the environmental impacts thereof, to the particular project or emissions, as such direct linkage is difficult to isolate and to understand” (CEQ 2010). Accordingly, it is not useful to attempt to determine the significance of such impacts. There is a considerable amount of ongoing scientific research to improve understanding of global climate change and FAA guidance will evolve as the science matures or if new Federal requirements are established (FAA Order 1050.1F).
4.4.2PROPOSED ACTION A Falcon 9 launch would result in GHG emissions. Though emissions from the launch would increase the yearly levels of GHGs at KSC, the emissions would still be well below the EPA mandatory reporting threshold for stationary sources of 25,000 metric tons of CO2e, and would represent a negligible fraction of GHG emission from KSC, the United States, or the world. Based on the anticipated one-time event and the short time frame of the activities that would occur, GHG emissions would be minimal. Therefore, the Proposed Action would not result in significant impacts related to climate.
Good to know.
The CEQ quote is interesting when it says “it is not currently useful for the NEPA analysis to attempt to link specific climatological changes, or the environmental impacts thereof, to the particular project or emissions, as such direct linkage is difficult to isolate and to understand.” One might wonder why the analysis is necessary at all at this level of granularity if it is not currently useful to do.
Additionally, although the FAA mentions the EPA’s mandatory reporting threshold for stationary sources, no one should take that to mean it applies to rocket launches. First, a launch vehicle is not a stationary source. Second, any attempt on the EPA’s part to assert jurisdiction should run up against the FAA’s exclusive jurisdiction. Lastly, as the FAA noted earlier, there are no significance thresholds for green house gas emissions for aviation or commercial space launch. The FAA’s mention of the EPA standard must be taken as providing a source of comparison only, not as a standard that applies.
Comments due: December 31, 2018
Hi Laura!
You should take a look at my wife’s PhD dissertation on an Environmental Life Cycle Assessment of Commercial Space in the United States (UT Arlington 2018). Although precise information is proprietary and export controlled, she was able to put together a pretty reasonable estimate for environmental effects inc.ixding climate change.
Thanks, Scott. That sounds fascinating.