By Scheleen Walker, Director
Sierra Club Lone Star Chapter
To: Ms. Stacey M. Zee
Environmental Protection Specialist
Federal Aviation Administration
Space X EIS
c/o Cardno TEC Inc.
Dear Ms. Zee,
The Sierra Club is not at this time taking a position for or against the project, and will instead withhold final judgment pending the release of more detailed information on the proposed project and mitigation. We appreciate the willingness of representatives of Space X to engage with the Sierra Club and other stakeholders and to consider various options to minimize the project’s likely impacts, and we hope to continue this dialogue.
These comments are intended to identify some of the potential impacts that we believe must be fully explored and addressed in the final Environmental Impact Statement.
The Sierra Club is concerned about a range of environmental impacts that construction of infrastructure and launches could have on fragile, local ecosystems and sensitive species. The proposed launch site is surrounded by the 10,680 acre Boca Chica tract of the Lower Rio Grande Valley National Wildlife Refuge. The LRGVNWR was envisioned as a wildlife corridor, linking tracts of land for use by terrestrial animals, especially the ocelot and jaguarundi, which are listed as endangered under the federal Endangered Species Act. Boca Chica beach, adjacent to the launch site, is one of the few places where Kemp’s Ridley Sea Turtles, one of the world’s most critically endangered sea turtles, come ashore to nest in the spring and summer. This area also provides habitat for birds, including the piping plover and red knot, and is visited
by millions of migrating birds and bats each fall and spring. In addition, construction and operation of the proposed launch site would cause destruction of critical wetlands.
Kemp’s Ridley Sea Turtles:
While a number of sea turtle species have nested at Boca Chica beach historically and continue to nest along this part of the Gulf Coast, the endangered Kemp’s Ridley is the only one that has been documented at Boca Chica in recent years.
According to the draft EIS, "Kemp’s Ridley sea turtles nest primarily from April through July, predominantly during daylight hours. Nesting occurs in synchronized emergences which are thought to be triggered by high wind speeds and changes in barometric pressure. Over the last 5 years, there have been 38 Kemp’s Ridley nests found on Boca Chica Beach (10 in 2012, three in 2011, four in 2010, nine in 2009, and 12 in 2008).
The Sierra Club is concerned about a range of environmental impacts that construction of infrastructure and launches could have on fragile, local ecosystems and sensitive species. The proposed launch site is surrounded by the 10,680 acre Boca Chica tract of the Lower Rio Grande Valley National Wildlife Refuge. The LRGVNWR was envisioned as a wildlife corridor, linking tracts of land for use by terrestrial animals, especially the ocelot and jaguarundi, which are listed as endangered under the federal Endangered Species Act. Boca Chica beach, adjacent to the launch site, is one of the few places where Kemp’s Ridley Sea Turtles, one of the world’s most critically endangered sea turtles, come ashore to nest in the spring and summer. This area also provides habitat for birds, including the piping plover and red knot, and is visited
by millions of migrating birds and bats each fall and spring. In addition, construction and operation of the proposed launch site would cause destruction of critical wetlands.
Kemp’s Ridley Sea Turtles:
While a number of sea turtle species have nested at Boca Chica beach historically and continue to nest along this part of the Gulf Coast, the endangered Kemp’s Ridley is the only one that has been documented at Boca Chica in recent years.
According to the draft EIS, "Kemp’s Ridley sea turtles nest primarily from April through July, predominantly during daylight hours. Nesting occurs in synchronized emergences which are thought to be triggered by high wind speeds and changes in barometric pressure. Over the last 5 years, there have been 38 Kemp’s Ridley nests found on Boca Chica Beach (10 in 2012, three in 2011, four in 2010, nine in 2009, and 12 in 2008).
The launch site is approximately 500 feet from the beach. The draft EIS notes, “Noise and vibrations from rocket launches could frighten nesting turtles, causing them to abandon their nesting attempt.”
There is no information regarding the likelihood that turtles who abandon their nesting attempt would return at a later time. The final EIS should explore this impact upon sea turtles in detail. One mitigation measure described, that Space X will “avoid nighttime launches during sea turtle nesting season (March 15 – October 1),” would appear to be counterproductive, as Kemp’s Ridleys are daytime nesters. Its time frame overlaps, but does not precisely correlate, with the discussion of nesting season quoted above. It is also unclear to what extent Space X will be free to adjust launch times to accommodate nesting sea turtles or, as will be discussed later, ocelots and jaguarundi.
Currently volunteers from Sea Turtle Inc. patrol the beach in an effort to relocate eggs so as to avoid predation. On launch days these volunteers, like the rest of the public, would be kept away from the beach. Sea Turtle Inc. would be given access for an hour before the general public is allowed back in to search for nests. If undiscovered nests are on the beach during a launch the draft EIS states that the noise and vibrations that eggs currently endure during transport from the beach to Sea Turtle Inc. are greater than that of a rocket launch 500 feet from the beach.
There is no information regarding the likelihood that turtles who abandon their nesting attempt would return at a later time. The final EIS should explore this impact upon sea turtles in detail. One mitigation measure described, that Space X will “avoid nighttime launches during sea turtle nesting season (March 15 – October 1),” would appear to be counterproductive, as Kemp’s Ridleys are daytime nesters. Its time frame overlaps, but does not precisely correlate, with the discussion of nesting season quoted above. It is also unclear to what extent Space X will be free to adjust launch times to accommodate nesting sea turtles or, as will be discussed later, ocelots and jaguarundi.
Currently volunteers from Sea Turtle Inc. patrol the beach in an effort to relocate eggs so as to avoid predation. On launch days these volunteers, like the rest of the public, would be kept away from the beach. Sea Turtle Inc. would be given access for an hour before the general public is allowed back in to search for nests. If undiscovered nests are on the beach during a launch the draft EIS states that the noise and vibrations that eggs currently endure during transport from the beach to Sea Turtle Inc. are greater than that of a rocket launch 500 feet from the beach.
Elsewhere the draft EIS appears to contradict this, stating that, “The unweighted noise levels at the nearest house, which is 1.8 miles from the vertical launch area, suggest the probability of a noise induced structural vibration damage claim would be greater than 1 in 100.”The final EIS should provide more precise data regarding the likely impact of launches on undiscovered Kemp’s Ridley sea turtle nests. We also suggest that Sea Turtle Inc. be given access to the beach prior to launches, as well as after, to reduce the chances that eggs will be present during a launch.
(For the full objections by Sierra Club to SpaceX launch site proposals on Boca Chica Beach, see):
2 comments:
Now this is good information. Thanks for sharing it and thank you to the Sierra Club for making sure all points are covered and reviewed. I like the idea of SpaceX, but not at the expense of our natural wildlife and resources. If there is a happy medium, great, if not oh well.
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