SpaceX #7: The Proposed Project would be subject to a GHG permit under the Clean Air Act
All irony aside, another huge f*ckup from the SpaceX team
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 3 - SpaceX is building a pipeline and doesn’t feel the need to mention it
CLICK HERE FOR PART 4 - SpaceX dreams of drilling for a sh*tload of oil
CLICK HERE FOR PART 5 - A discussion on the hugeness of the project, a parade of tankers and a reality check about the Oil and Gas biz
CLICK HERE FOR 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
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Chapter 7: SpaceX has a problem calculating GHG emissions
(Required Reading: The tl:dr section from yesterday’s post)
Yesterday, I covered how the facility as represented in the NEPA document would constitute a Major Source under the PSD program from the 1977 Clean Air Act Amendments. This oversite is a major, embarrassing screw-up for both SpaceX and the FAA contractors responsible for reviewing Air Pollution impacts. But more importantly, a Major Source PSD permitting exercise cannot count as an insignificant or de minimus impact under NEPA by statute.
Today, let’s talk briefly about the CO2 emissions as represented in the Draft PEA:
Ok, let’s take a look at the “power plant” emissions. 9,858 tons of CO2 sounds like a lot, right? Well, let’s take a look at the EPA emission factor for natural gas combustion:
9858 tons CO2 would result from the combustion of 185,789 million Btu of natural gas. The power plant is 250 Megawatts, which means it consumes at least 1,300 mmBtu per hour. The power plant would take 143 hours to emit 9,858 tons of CO2. That’s about 6 days.
Whoops!
I’m going to ignore the rocket emissions, because rockets are not a stationary source under the Clean Air Act and also I think going after rocket CO2 emissions is lazy and reductive. Rockets burn fuel. Everyone knows this and I think most people, myself included, are ok with a hundred or so annual global rocket launches a year (I like rockets and space exploration!)
Anyways, the CO2 from the power plant isn’t the only Greenhous Gas at play here. Fugitive emissions of methane add up, as do any industrial refrigerants. And the gas plant (that they refuse to call a gas plant) has quite a few as well.
There is a GHG permitting rule in the Clean Air Act. It’s had some scrutiny put on it (and some associated drama), but courts have ruled (and EPA agreed) that GHG permits are still legal if the source is PSD Major for one of the Criteria Pollutants (NOx, SO2, PM, etc). We covered in part 6 that the source as represented is a PSD Major source, so the SpaceX facility is subject to the PSD GHG “Tailoring Rule.” That threshold is 100,000 or 250,000 tons per year CO2e (CO2 equivalents, some GHGs like methane count for more per pound, I’ve covered here and here)
For Clean Air Act permitting, you have to use Potential to Emit (PTE) calculations for most sources, which assumes the plant runs 24/7/365. Power plants are subject to this level for permitting for obvious reasons (no one installs a power plant to run it 6 days a year).
If you calculate the GHG emissions just from CO2 alone for combustion sources at the power plant and a gas plant a hilarious picture emerges:
The power plant alone accounts for 600,000 tons of CO2 per year. I was extremely conservative with other emissions sources, but things like fugitive leaks, N2O and refrigerants could easily add another couple hundred thousand tons per year.
Again this has nothing to do with rockets, but rather an insane oversite and/or distain for the Clean Air Act, one of the most important and impactful pieces of legislation in the past 60 years.
Oh well
Until next time, ESGH
9/29 update:
This Twitter Thread explains how patently absurd the CO2 calculations are
3 SpaceX Environmental Engineers and about a dozen FAA contractors and you are the only competent one in the bunch...imagine that. If the folks from ICF are unqualified or grossly incompetent, perhaps you ought to file a complaint with whichever organization licenses them?