SpaceX #3: Elon Musk Wants to Build a Gas Pipeline

And he thinks you're too dumb realize this

ESG Hound

Sep 24, 2021

CLICK HERE FOR INTRO - Background

CLICK HERE FOR PART 1 - NEPA Primer / FAA has no business permitting oil and gas facilities

CLICK HERE FOR PART 2 - Elon Musk’s Natural Gas Treatment Plant

CLICK HERE FOR PART 4 - SpaceX: Drill baby, Drill

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Chapter 3: Elon Musk’s Fat Pipe

If you think I’m close to done on this, you are sadly mistaken.

Let’s Get Caught Up:

As a reminder, SpaceX is trying to get FAA to fast track changes to the 2014 authorization on their Boca Chica, TX launch facility. This process is for inconsequential/minimal/insignificant environmental changes.
This minor change request includes launching bigger rockets, a 250 Megawatt power plant and a Natural Gas Plant (roughly 50-70 MMscf/Day)
The media has bizarrely focused exclusively on the rockets. Don’t get me wrong, these rockets are clearly vexxing the local human and avian populations, but while the launches happen once a month or so, major industrial activity happens 24/7/365.
FAA’s jurisdiction is Airports and Launchpads, but because they are the funding agency, they take lead on the NEPA effort (and they’re currently messing up badly). FERC and Land Management agencies are much more capable at handling these types of operations.
The NEPA mandated EIA must include ALL activities related to the proposed action, so if SpaceX intends to power their SPACEPORT with a power plant and fill the fuel tank up with a gas plant, those related processes MUST be included in the scope. It’s literally the law.

Last time we talked about the gas plant. We’ll talk about liquified natural gas LNG (Or LCH4) production at a later date. Today I want to talk about inputs.

A natural gas fired 250 Megawatt cogeneration steam generating turbine power plant will consume about 1,250 MMBtu per hour (5000 Btu/kWh, from GE’s website for new high efficiency units), that’s about 30 Million Standard Cubic feet (MMscf) of processed natural gas (97%+ Methane) per day. Field Gas is 70-80% pure and there needs to be some leftovers for LCH4 production, say 20%, so that gets us a daily nat gas demand of 50 MMScf every day.

How does one get that much gas into a gas plant?

This is a serious question, because reading the Draft Programmatic Environmental Assessment (PEA), you’d have no idea. It’s not mentioned, as if 50 million scuffs would just appear as if by magic.

I’m kidding, of course. The gas will come in a pipeline. Because that is how gas is transported. But there’s just a wee little problem:

There is no pipeline to the facility.
The closest pipeline is 8 miles away, and as I explained last time, they have zero capacity
The SpaceX gas plant is spec’d for field gas

Ergo, Elon needs to build a pipeline. But SpaceX doesn’t want to tell you that. See?

THE CONSTRUCTION OF A LITERAL PIPELINE REQUIRED TO RUN THIS FACILITY IS APPARANTLY NOT AN ENVIRONMENTAL IMPACT, PER THIS P.E.A. THIS IS INSANITY AHHHHHHHH

If I’m with FERC, I’m Pissed. If I’m with EPA, I’m super pissed. Hell if I’m any regulatory agency in the government, I know my domain and I don’t try to shove the construction of a pipeline through expedited review without mentioning it. The NEPA framework, as a regulatorily effective and credible process, is at stake here.

This is literally happening, right now. People get mad about pipelines! It’s a thing they do! This is not a new phenomenon!

I’m not anti-pipeline. I am anti-secret-pipeline-constructed-at-the-whims-of-a-childish-billionare-who-has-a-mile-long-rap-sheet-of-blatantly-ignoring-regulations-if-they’re-even-slightly-inconvenient-for-him.

A Lay of the Land

Here’s a map from PHMSA of all regulated pipelines, overlayed with a BLM government managed land layer:

Blue Lines are natural Gas, Red is Liquids/Y-grade

That blue line on the bottom adjacent to SpaceX’s site probably has Elon’s defenders hot and bothered to scream about how wrong I am: “there is a pipe, IDIOT FUDSTER!” they’ll holler, blue in the face.

No, there’s not:

This pipeline is permanently abandoned, which does have a definition in PHMSA regulations. The agency is so passionate about it, they sent out an advisory bulletin on the matter in 2016:

The operational status of a pipeline has often been referred to offhandedly as “idled,” “inactive,” or “decommissioned.” These pipelines may still contain hazardous materials. The formal operational status of a pipeline is either “active” or “abandoned,” and not “idled,” “inactive,” or “decommissioned.” Each status invokes a certain procedure for safety and maintenance of the pipelines by the owner or operator. For example, in order to properly abandon a pipeline, all combustibles must be purged and all remaining facilities sealed. §§ 192.727 and 195.402(c)(10). Importantly, “abandoned,” as defined by the PHMSA, means permanently removed from service and subject to “an irreversible process of discontinuing the use of a pipeline.” § 192.3. “No attempts are made to maintain the serviceability” of an abandoned pipeline. Id. If a pipeline does not comply with the abandonment procedures and may be used at a later time, this is considered “active” by PHMSA. These pipelines are subject to all safety and maintenance requirements for “active” pipelines. Pipelines that contain hazardous material and were once classified as “idled” are now deemed active until the owner or operation follows all formal procedures for changing the status to “abandoned.”

This pipeline literally does not exist as a legal entity. It’s a rusting piece of metal in the ground.

For reference, FERC has some active projects including one for a 60 miles of 24 inch pipeline through Missouri. The EIA for the pipeline is massive and it literally just about the pipeline. This case has been in back and forth litigation for 5 years and just got issued this year. This is what environmental review looks like under NEPA. And while a gathering pipeline system wouldn’t be authorized by FERC: the NEPA requirements for gas pipelines, regarding environmental impact studies, should be similar in scope and breadth.

So to summarize:

SpaceX needs to construct a pipeline (likely 12+ inches) to his facility
This pipeline will go through Fish and Wildlife Service Land
Not one word of the above is mentioned in the draft PEA
This Pipeline is needed for the proposed gas plant and power plant. It is very much in scope with the project and is required to be included in the assessment by NEPA.
This fact alone should halt the Review process for the PEA

Get out the pipe, put on the new GRIMES album and let’s ride this rocket to mars, baby

(ed update 9/24/21: clarified NEPA/FERC relationship as it relates to this project)