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SpaceX #15 - If an LNG Unit Drops in the Middle of the Woods and Nobody Hears it...
...does it even make a sound?
CHAPTER 15: PUBLIC MEETINGS AND NEPA AND YOU
All, this dog is tired. Despite claims to the contrary, I’m not getting paid for this. Jeff Bezos isn’t mailing checks to ESG HOUND LLC (a Wyoming corporation). All I want is for the scope and impact of The SpaceX STARBASE project, as proposed by FAA, to be public knowledge prior to the public comment window closing. Let someone with authority, such as a Federal Agency or a Media Outlet tell the story. Let me write about regulatory wonkery, charts and sick Elon Musk burns in my little corner of the internet. Please.
Links to previous entries at Bottom
🚨ESG HOUND IS ON THE UP AND UP, NOW FEATURED IN TECHCRUNCH, BABY!
I will continue to write, of course, but I think I’m close to handing most of this whole thing off to reporters who know what they’re doing. As such, this will probably be the Last SpaceX post for a little bit (no guarantees). I want to make one thing clear before I take a step back:
NEPA IS A PUBLIC DISCLOSURE LAW
This is important. The National Environmental Policy Act (NEPA) of 1970 set the stage for decades of Environmental improvement in this country. Harris county, the home of Houston, has five times the oil refining capacity as it did in 1970, to go along with over double the population, all who drive cars. But smog and haze levels today are about as low as they’ve ever been since we started tracking them in the “Oil Capital of The World.” Improvement is needed still, big time, but it’s hard to argue that the 50 years since NEPA came on the scene haven’t been an objective success for environmental damage mitigation1.
NEPA and each of its successors are built on a foundation of deliberate, measured action, science based standards, and perhaps most importantly: Public Disclosure.
Forget the Rockets. SpaceX and the FAA used an “insignificant environmental impact” determination in NEPA to try to sneak the construction of a Utility Sized Power Plant, A Natural Gas Plant, an LNG unit, miles of High Pressure Gas Pipeline, and the Development of Countless new Oil and Gas Wells right under our noses.
The Pipelines aren’t even mentioned, once, in the environmental impacts document despite the obvious need for them. Neither are the implied hundreds of Gas wells that must be drilled and fracked. So I guess you could forgive the press for not focusing on these.
But what is mentioned, explicitly, in the PEA is:
A 250 Megawatt natural gas power plant, large enough to power 100,000 homes
An LNG unit (Running methane refined from natural gas through a Cryogenic liquefier is a Liquid Natural Gas/LNG process by definition)
A natural gas fractionation plant of undisclosed capacity
Let’s look at any one of these proposed facilities. Now imagine if Chevron had tried to develop just a single LNG unit on federal land and conspired with the Department of Energy to claim this was an “insignificant environmental impact.” Now imagine they tried to rush it through approval during a short public comment window, while conveniently never calling it an LNG unit, but rather a “Methane Fuel Liquefier.” Can you imagine the outrage?
So, let’s take a step back. Remember that:
NEPA IS A PUBLIC DISCLOSURE LAW
The number of mainstream news articles that discuss the existence of SpaceX’s literal, by the book LNG unit: 0
The number of mainstream news articles that discuss a natural gas separation plant that would generate thousands of barrels of Natural Gas Liquids per day (NGLs, these are essentially gasoline-like liquid hydrocarbons): 0
The number of articles referencing a utility sized natural gas power plant: 1
The single article, written by Mark Harris at TechCrunch, took weeks of me screaming about it on my Substack. I really appreciate Mark’s attention to detail here, by the way, and can’t thank him enough for not treating me like an insane person.
The other day, I saw a post from a local blog with a reasonable following
And browsing through the comments, I had an “AHA” moment:
Nobody knows about the LNG unit, like, at all. In my view, it’s the least directly dangerous or concerning of the processing units SpaceX wants to build.
“The town crank, Mr. Bill Berg, is off his meds again”
But the LNG is right there, in the document. Here:
That’s an LNG unit, by definition. You know, the thing that never causes controversy:
Again, those widely protested facilities involve a taking pipeline spec natural gas via pipeline, liquifying the nearly pure methane and then pushing that liquid into a boat for export. No Fracking, No Massive Power Plant, No Natural Gas Separation or Fractionation (all things SpaceX intends to do).
NEPA IS A PUBLIC DISCLOSURE LAW
Forget all my charts and esoteric legal asides and outrage for a second. If an action under NEPA is explicitly and legally required to disclose all related environmental impacts… AND seemingly no one in the world is aware that a massively public facing company, run by the literal Richest Man On the Planet, intends to run an LNG and oil and gas processing operation…. THEN, wouldn’t one have to conclude that NEPA itself was abused and violated?
PUBLIC MEETINGS ARE NEXT WEEK
All I’m asking is for these issues to be discussed. What better opportunity is there than a Public Comment Meeting next Monday and Wednesday in Brownsville?
I expect it’ll get a little spicy, because if I’ve done nothing else: we at ESG Hound have at the very least convinced the local rabble rousers (whom I respect immensely) that maybe they should make a stink about this topic.
Because it already stinks to high heaven from where I’m at.
PART 1 - NEPA Primer / FAA has no business permitting oil and gas facilities
PART 2 - Elon Musk’s Natural Gas Treatment Plant
PART 3 - SpaceX is building a pipeline and doesn’t feel the need to mention it
PART 4 - SpaceX dreams of drilling for a sh*tload of oil
PART 5 - A discussion on the hugeness of the project, a parade of tankers and a reality check about the Oil and Gas biz
PART 6 - The Facility would be a Major Source of Pollution under the PSD Rules in the Clean Air Act, which by statutory definition would exclude it from fast track approval under NEPA
PART 7 - The GHG and CO2 emissions are plainly nonsense
PART 8 - ESG Hound drops the gauntlet and explains why this is a massive fraud happening in plain sight.
PART 9 - The End of NEPA as we know it
PART 10 - ELON MUSK REALITY DISTORTION FIELD
PART 11 - Pipeline Plans Confirmed!
PART 12 - It turns out drilling for oil and gas has some negative environmental impacts
PART 13 - I found the Modular Gas Plant; the clue that got me there will leave you stiff with shock
PART 14 - The wildlife toll of industry, told through my personal experiences
Climate is an entirely different can of worms, so I’m not ignoring it I PROMISE