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SpaceX #20 - Musk's recent communications directly contradict what they told the FAA in September
Ok, all. Hi.
It’s been a bit since I’ve posted. I spent a whirlwind of 6 weeks feverishly posting about the numerous ways in which SpaceX’s (by way of FAA) Environmental Documents for the upcoming Starship Program in Boca Chica, Texas, are woefully inadequate.
Public comments are in, and the FAA claims they will have the Record of Decision for the assessment complete by the end of the year. This timeframe seems absurd, given the underlying law, NEPA, requires that all actions approved must incorporate response to every public comment submitted. The FAA says they received 17,000 comments. Even if 90% of them are some variation of Elon Musk superfans gushing praise for the project, that’s a lot of material to go through.
In an ordinary world, I’d look at a shortened window like this, which is nearly record speed from comment closure date to completion for the agency, to indicate that the FAA intends to issue a Record of Decision denying the issuance of a permit. However, being 2021 and given that Elon Musk has a long history of getting his way with regulators, a Finding of No Significant Impact (FONSI) and rubber stamp approval wouldn’t particularly shock me.
The environmental review was based on some reasonable assumptions along with many glaring omissions and errors (as I’ve pointed out). The assumptions themselves are the basis for the determination of Environmental impact. But here’s the thing:
The Environmental Assessment that hasn’t been approved is already inadequate due to recent events
There are two things that I want to look at here, and I hope you can see why this is troubling
Plans for the Rocket Engines themselves, which will be 30% more powerful. This nullifies all noise projections in the PEA
Elon Musk told us he doesn’t intend to stick to the launch frequency outlined in the PEA
I intended to allow the process to play out and go from there. I’ve been working on some non-SpaceX stuff, from Crypto to Bioplastics and Carbon Accounting. Lots of drafts but nothing quite ready for publication. Things have changed and we need to talk about “Move Fast, and Break Stuff.”
Background and Summary here
The Silicon Valley Creed
At this point, a think piece on “Move Fast and Break Stuff” is as played out as it gets in the blogosphere. We all know the story. Moving fast, breaking the rules via trial by error is a core value held by the Technolibertarian elite class of Silicon Valley. It’s what allowed tech pioneers over the last few decades to connect people and then rip apart the fabric of society (Facebook), to re-write the rules of legacy business to be user friendly but also more dangerous (Uber), or to make information instantly available at the cost of any privacy (Google).
Most people who talk about this phenomenon discuss it in weighing the progress with the horrific externalities. Not here. I will discuss this ethos, one held by Mr. Musk as a simple regulatory time arbitrage.
What do I mean by that? Look at Uber. Sure, the ride-sharing app took off largely due to people’s frustration with legacy taxi companies. Placing a phone call to a dispatch center staffed by the rudest people in American and wondering if and when your Taxi would ever arrive was not a fun experience. But Uber’s success wasn’t just the app experience. They bulldozed into cities with legacy laws prohibiting many of the core Uber business practices regarding taxi medallions, vehicle insurance, and livery. They knew no regulator or local government would immediately put a court order in place because no one wants to be the guy to kill a popular service. Nor does any regulatory body desire to be pointed at as the entity responsible for the demise of a rapidly growing yet unprofitable business.
Uber was exploiting regulatory time arbitrage; by the time regulators and legislators got around to finding something troubling enough about Uber to latch onto, it was too late. Uber was entrenched and more untouchable.
I’d argue that this is exactly what SpaceX is doing and has done.
Going beyond the theatrics, SpaceX has developed iterated and re-iterated rocket technology at eye-watering speed over the years, unafraid to blow stuff up and light capital on fire to do so.
But now they want to do it again, with the “largest rocket ever built” smack dab in the middle of a federally protected wildlife sanctuary. It’s been “build now, ask permission later” (a derivation of the Move Fast and Break Stuff creed) up to this point until it all had gone way too far. The FAA told them to knock it off until environmental review was complete after the disastrous SN11 mishap in March. The resulting Assessment is based on information that is already inadequate for measuring environmental impact.
The Raptor Redesign
Several sources have told me that the 1.0+ Raptor Engines, including those on the B4 booster in Boca Chica, are considered not viable, e.g. scrapped. Work on the 2.0 variation of the Raptor is in the early stages, with the first prototype hitting the test stand in October. Still, numerous production and supply chain issues mean that it’s closer to a new design than a simple re-iteration. Regardless of the work needed to get to Raptor 2.0, Musk tipped his hand in this Twitter Exchange:
Musk intends to proceed with Engines at 245 tons of thrust going forward, a 30% increase over the 187.5 tons (375 klbf) represented in the noise study in the Environmental Assessment.
Why does that matter?
Setting aside all of the nuances of sound attenuation and modeling (an extraordinarily complex field of study), a simple framework from NASA is that the sound (in dB) correlates to engine thrust on a log-log basis.
A 30% increase in thrust is a 3-4 point increase in decibel level at the reference frequency. That 3-4 point increase means the power of the sound wave itself is ~2x more powerful than the 1.x Raptor engines. The impact on the entire booster’s sound output is unclear, but it’s not likely to be less powerful.
And indeed, neighbors of SpaceX in McGregor, Texas, have noticed that the sounds coming from the test stands are, well, louder than ever, as the company tests early versions of the 2.0 engine.
MCGREGOR, Texas — In recent weeks, residents of McGregor and other nearby towns report louder engine tests from the SpaceX rocket development facility and are looking for answers.
Even people miles away from the McGregor facility report hearing the thundering sound of the engine tests in recent days.
"Rattles the door, everything rattles," said McGregor resident Anna Kaiser. "Can't even hear the TV over the rattle."
Putting it all together, SpaceX has already told us that the engines they’re going to use in Boca Chica deliver significantly more thrust than those in their own Environmental Impact documents. Any analysis from the December 2020 noise study, including those related to biological impact, is entirely worthless.
SpaceX has already exceeded specifications in a document that isn’t approved yet. That’s not to say Starship with the Heavy Booster will be twice as loud as modeled because, again, these attenuation models are complex. But no overhead was accounted for in the Environmental Assessment. It’s counting on approval and then modification after the fact that’s the problem—the Move Fast and Break Stuff ethos.
Musk’s Accelerated Launch Candance
Musk’s bizarre “We’re going bankrupt (maybe)” email this month revealed a notable excerpt:
The consequences for SpaceX if we can not get enough reliable Raptors made is that we then can’t fly Starship, which means we then can’t fly Starlink Satellite V2 (Falcon has neither the volume nor the mass to orbit needed for satellite V2). Satellite V1, by itself, is financially weak, while V2 is strong.
In addition, we are spooling up terminal production to several million units per year, which will consume massive capital, assuming that satellite V2 will be on orbit to handle the bandwidth demand. These terminals will be useless otherwise.
What it comes down to, is that we face a genuine risk of bankruptcy if we can’t achieve a Starship flight rate of at least once every two weeks next year.
Now, again, Musk appears to be pointing towards a near-term launch cadence that is wildly above the one proposed in September.
This document indicates that only three orbital launches will be attempted per year during development with a long-term run rate of five launches. SpaceX did not suggest in Filings with the FCC that Starship will be the only launch vehicle for Starlink.
The tactic seems to be filing for a lower volume of launches to get approval through the EA process and then allowing the FAA to modify the launch volume after the fact and independent of public comment and input.
The expectation for NEPA documents is to reveal the scope of a project in both the short and long term. SpaceX has a poor history of doing this, choosing instead to iterate and change course on the fly.
Perhaps an acceptable tactic for developing a photo-sharing app, but one that is fundamentally incompatible with operating a significant and potentially destructive operation on Federal Lands.
Oh, and by the way, it’s illegal. Let’s hope the regulators and agencies with the power to reign in a reckless and destructive entity don’t wait until it’s too late.