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Tell us what state representative you contacted! Did you call the Corp of Engineers! (409-766-3869 Phone)
SpaceX is asking the US Army Corps of Engineers for permission to fill 0.16 acres of wetlands to build a second launchpad, replacing the current launch pad and test stand at Boca Chica Beach—Army Corps of Engineers notice.
Comments submitted by Bob Achgill to Army Corp of Engineers AGAINST permitting new SpaceX launch tower in Boca Chica, Texas
To:
Policy Analysis Branch
Regulatory Division, CESWG-RDP
U.S. Army Corps of Engineers
2000 Fort Point Road
Galveston, Texas 77550
409-766-3869 Phone
409-766-3931 Fax
[email protected]
District Engineer
Galveston District
Corps of Engineers
From: Robert (Bob) F. Achgill
My Comments against permission to rebuild Starship SpaceX vertical launch tower
Background about myself:
I am a Mechanical engineer.
I worked 7 years in a Chemical plant in Texas City.
I worked 5 years for IBM FSD on the NASA contract. My responsibilities were to bridge all the Failure Mode and Effects Analysis (FEMA-CIL) from all 18 Space Shuttle subcontractors in to one central reporting system post Challenger disaster in order to help flight managers make better decisions regarding safety of people, vehicle and mission. If put all on paper, the stack of FMEA-CILs would be 18 feet tall.
So far I have only been able to find public access to less than half an inch of data on Starship and all that half inch is for a normal launch... no failure mode effects analysis.
As a an engineer in both a commercial and government setting where public safety was at issue i feel compelled to respectfully offer these comments.
I have seen personally the 18 foot high ways that things can go wrong on a rocket. And I attest that there is absolutely no transparency with regard to issues of public safety with the SpaceX launch system. It's amazing technology but needs to be positioned 30 miles from the nearest public.
If SPACEX is requesting to build another vertical launch tower, then I have these questions:
1) They must provide a launchpad explosion scenario failure analysis report, independently verified, that ensures no harm will come to the public before proceeding.
2) Until now, SPACEX has paid Texans nothing for access to space from sovereign Texas airspace for the first three launches and numerous fire tests. SPACEX has been operating in silent partnership with Texans to have access to Texas airspace. Before proceeding with building a new vertical launch tower, SPACEX must now formalize and sign a contract with all Texans, giving all legal resident United States citizen Texans a controlling interest and profits greater than 51 percent from future revenues acquired by any payload launched to space from Texas airspace.
Why? Texans have maintained a majority contribution to the silent partnership in enabling the launches. SPACEX may have paid a small amount to develop the rocket hardware, but no launches or testing could take place without Texans granting such right to launch into Texan’s airspace. Access to space from Texas is as much a mineral “right” as oil or gas and should be remunerated back to all Texans equally. Not to the Texas government where it will be filtered, but directly to all Texans just as mineral rights are distributed.
Why all Texans equally? The reach of oil and gas deposits are limited by the nature of the ground. The reach to space from Texas is a resource held in common by all Texans. If Boca Chica turns out to not be a safe place to launch, Texans, as holding a majority interest in the partnership with SpaceX, the space developer, can find another safer place to offer in Texas to have access to space. Norway is a good example of equally distributed mineral “rights”. Each Norwegian receives an equal direct payment into a trust for oil pumped from the North Sea. No strong-arming by oil developers, no cheating by politicians, it’s all under contract… and Norwegians have always maintained the controlling interest for the last 54 years. Every Norwegian is a millionaire now thanks to the two men who advised them to set up this trust fund mechanism. If this legal “right” of Texans for space access is not given away for free as it has been by Texas politicians, then 51%+ of profits from StarLink or any other profit-making payloads will go directly to ALL Texans. If Texans maintain the controlling interest in granting access to space, Texans will do a better job at keeping Texans safe, than space developers, whose only motivation is profit.
3) If the silent partnership contract (See item 2) is not negotiated with Texans, SPACEX must pay back rent to all land and property owners and all Texans who were prevented from using the public beaches during each fire test or launch. This includes all residents in neighboring towns that received fallout or sound pressure levels greater than what is the normal community sound pressure level. Texans will not give away trillions of dollars to a space developer for nothing in return for their space rights. No further launches will be allowed in silent partnership until the contract between SpaceX and ALL Texans has been signed.
4) SPACEX must pay for independent advocates on behalf of the public, who can ask all the questions that the public is not trained to ask in verifying the safety of the public, and these advocates must make all these communications transparent to the public. I’m sorry. Until now, the government agencies have not served as independent advocates on behalf of the public. It’s time to even the conversation between SpaceX and ALL Texans. Just because SpaceX knows so much does not make it right to proceed when Texans don’t know what questions to ask regarding public safety. Amry Corps of Engineers, your calling is to defend and protect citizens of the U.S.. A launch tower 6 miles away from a city is not serving that protector role, unless you have data you can share with the public otherwise.
5) These independent advocates (see 4 above) will be fully funded from blind trusts funded by SPACEX to:
5A) Set up sound pressure level stations to record levels at various locations where the public and wildlife reside.
5B) Set up public live and recorded webcams of animal cages at varying perimeters from the launchpad so the public can witness that SPACEX is treating these animals with respect and responsibility by seeing their live reactions to the sound pressure levels.
5C) Set up a dedicated public response media “townhall” where the public can see the communications from the independent advocates and SPACEX responses in real-time and the public can participate in asking questions and giving reactions and sharing inputs such that all can see. E.g.,
6) The U.S. Army has done testing on shockwaves proceeding from launch pad rocket explosions in the 1950’s. Has the Army Corps referenced those studies? Why or why not?
6A) Given the amount of fuel on Starship and Super Heavy Booster, ChatGPT says that at 5 miles out the shock wave will be 170db. That humans will suffer hearing loss, brain damage, and other organ damage. It will be 1,000 times louder than a rock concert. The leader of SpaceX has said publicly that he feels that a launchpad failure is a possibility. He said, “I just hope it does not burn down his launch tower.” As an Army Corp of Engineers, engineer to you verify that the only result from 1000 tons of Methane and Oxygen side by side will only result in fire? In my understanding, it will be an explosion. It is up to you to tell us how big and how that shock wave and flying pieces of the launch tower will extend. The Texas City port explosion was of similar magnitude. The blast broke windows ten miles away in Galveston and sent a 5 ton anchor flying 1,000’s of feet. Will a 172db shock wave blast the good people of nearby cities into oblivion like an IED under a Humvee in Afghanistan permanently disabling or at minimum leaving the people with PTSD as our army soldiers have suffered and still suffer? Your requiring a full launchpad failure analysis before even the next launch from the existing launch tower is owed to Texans. The Army goes to fight battles elsewhere so that we can enjoy freedom from war at home. Will a launchpad explosion of Starship with Super Heavy Booster put nearby cities in a war zone?
6B) How was the “safe” 5-mile perimeter decided? This suggests that some analysis has been done to even make that decision. If the data that warranted the decision of a 5 mile safety perimeter cannot stand the test of public scrutiny, is something trying to be hidden from the public regarding their safety?
6C) Why has a launchpad explosion not been considered relative to public safety? I asked the Point of Contact with the FAA for the SpaceX project, before the first launch of Starship with Super Heavy Booster if a launchpad explosion scenario failure analysis had been performed and shared with the public. She wrote back and directed me to the public information that includes only a sound pressure level assessment survey for a normal launch. The FAA was admitting that no consideration has been given to the impact on the public in neighboring towns in the event of a launchpad explosion. Why? Did the Army Corps of Engineers participate in helping the FAA know that this is a true concern, especially launching within 6 miles of a city? Cape Canaveral is 12 miles from the nearest city and the Saturn 5 rocket was half the fuel of Starship with Super Heavy Booster. The Army Corp has access to the testing that the Army has done with launch pad explosions from their work in the 50’s. If a concern then, then why not now?
6D) As follow-up verification to the published anticipated sound pressure levels for the launch path, has SPACEX recorded actual sound pressure levels from the 3 launches to verify the predictions for a normal launch? If not, why not? If so, why has this verification report not been made public?
6E) Is the shock wave from a launchpad explosion scenario going to wash all the wastewater from retention ponds into marshlands thereby contaminating sensitive habitats? A launchpad explosion shock wave, if like Texas City port explosion, could move a 5 ton anchor 1,000’s of feet in the air, any wastewater retention ponds will likely be sprayed in sheets of driving horizontal rain across thousands wet land acres.
6F) Has any reasonable thought been given to firing a rocket with a sound pressure level as high as, no one can come within 5 miles, what is it going to do to the ears of animals adjacent to the launchpad. Will birds even be able to hear themselves sing? When I was a teenager… someone drove a dune buggy into Yellowstone National Park forest. The rangers apprehended him. The dune buggy was airlifted by helicopter so as to not further disturb the protected park further. I think the guy had to pay for the airlift along with the fine. How far we have advanced in technology since then… invention of computers, internet, cell phones, returnable rockets … but have we left something behind?
I really do hope that you will do the next public feedback session before making this decision in a location more accessible to the people whose lives are on the line. Making people carpool 6 hours to come provide 3 minutes of testimony, spending their own money for travel, as the Texas Parks and Wildlife commission did, is a bullying tactic not becoming of a government organization whose job is to serve the people at the will of the people. I know you will consider the public as you would lay down your life for them.
Thank you for all you do to ensure safe engineering designs. People are precious in the eyes of God and man has a responsibility before God to value each life… and be good stewards of the animals and nature.
By way of public transparency, I will copy this note to some local newspapers and TV stations.
Bob Achgill
LinkedIn: https://www.linkedin.com/in/SpaceX-achgill-122a609/
Policy Analysis Branch
Regulatory Division, CESWG-RDP
U.S. Army Corps of Engineers
2000 Fort Point Road
Galveston, Texas 77550
409-766-3869 Phone
409-766-3931 Fax
[email protected]
District Engineer
Galveston District
Corps of Engineers
From: Robert (Bob) F. Achgill
My Comments against permission to rebuild Starship SpaceX vertical launch tower
Background about myself:
I am a Mechanical engineer.
I worked 7 years in a Chemical plant in Texas City.
I worked 5 years for IBM FSD on the NASA contract. My responsibilities were to bridge all the Failure Mode and Effects Analysis (FEMA-CIL) from all 18 Space Shuttle subcontractors in to one central reporting system post Challenger disaster in order to help flight managers make better decisions regarding safety of people, vehicle and mission. If put all on paper, the stack of FMEA-CILs would be 18 feet tall.
So far I have only been able to find public access to less than half an inch of data on Starship and all that half inch is for a normal launch... no failure mode effects analysis.
As a an engineer in both a commercial and government setting where public safety was at issue i feel compelled to respectfully offer these comments.
I have seen personally the 18 foot high ways that things can go wrong on a rocket. And I attest that there is absolutely no transparency with regard to issues of public safety with the SpaceX launch system. It's amazing technology but needs to be positioned 30 miles from the nearest public.
If SPACEX is requesting to build another vertical launch tower, then I have these questions:
1) They must provide a launchpad explosion scenario failure analysis report, independently verified, that ensures no harm will come to the public before proceeding.
2) Until now, SPACEX has paid Texans nothing for access to space from sovereign Texas airspace for the first three launches and numerous fire tests. SPACEX has been operating in silent partnership with Texans to have access to Texas airspace. Before proceeding with building a new vertical launch tower, SPACEX must now formalize and sign a contract with all Texans, giving all legal resident United States citizen Texans a controlling interest and profits greater than 51 percent from future revenues acquired by any payload launched to space from Texas airspace.
Why? Texans have maintained a majority contribution to the silent partnership in enabling the launches. SPACEX may have paid a small amount to develop the rocket hardware, but no launches or testing could take place without Texans granting such right to launch into Texan’s airspace. Access to space from Texas is as much a mineral “right” as oil or gas and should be remunerated back to all Texans equally. Not to the Texas government where it will be filtered, but directly to all Texans just as mineral rights are distributed.
Why all Texans equally? The reach of oil and gas deposits are limited by the nature of the ground. The reach to space from Texas is a resource held in common by all Texans. If Boca Chica turns out to not be a safe place to launch, Texans, as holding a majority interest in the partnership with SpaceX, the space developer, can find another safer place to offer in Texas to have access to space. Norway is a good example of equally distributed mineral “rights”. Each Norwegian receives an equal direct payment into a trust for oil pumped from the North Sea. No strong-arming by oil developers, no cheating by politicians, it’s all under contract… and Norwegians have always maintained the controlling interest for the last 54 years. Every Norwegian is a millionaire now thanks to the two men who advised them to set up this trust fund mechanism. If this legal “right” of Texans for space access is not given away for free as it has been by Texas politicians, then 51%+ of profits from StarLink or any other profit-making payloads will go directly to ALL Texans. If Texans maintain the controlling interest in granting access to space, Texans will do a better job at keeping Texans safe, than space developers, whose only motivation is profit.
3) If the silent partnership contract (See item 2) is not negotiated with Texans, SPACEX must pay back rent to all land and property owners and all Texans who were prevented from using the public beaches during each fire test or launch. This includes all residents in neighboring towns that received fallout or sound pressure levels greater than what is the normal community sound pressure level. Texans will not give away trillions of dollars to a space developer for nothing in return for their space rights. No further launches will be allowed in silent partnership until the contract between SpaceX and ALL Texans has been signed.
4) SPACEX must pay for independent advocates on behalf of the public, who can ask all the questions that the public is not trained to ask in verifying the safety of the public, and these advocates must make all these communications transparent to the public. I’m sorry. Until now, the government agencies have not served as independent advocates on behalf of the public. It’s time to even the conversation between SpaceX and ALL Texans. Just because SpaceX knows so much does not make it right to proceed when Texans don’t know what questions to ask regarding public safety. Amry Corps of Engineers, your calling is to defend and protect citizens of the U.S.. A launch tower 6 miles away from a city is not serving that protector role, unless you have data you can share with the public otherwise.
5) These independent advocates (see 4 above) will be fully funded from blind trusts funded by SPACEX to:
5A) Set up sound pressure level stations to record levels at various locations where the public and wildlife reside.
5B) Set up public live and recorded webcams of animal cages at varying perimeters from the launchpad so the public can witness that SPACEX is treating these animals with respect and responsibility by seeing their live reactions to the sound pressure levels.
5C) Set up a dedicated public response media “townhall” where the public can see the communications from the independent advocates and SPACEX responses in real-time and the public can participate in asking questions and giving reactions and sharing inputs such that all can see. E.g.,
- “I found this heat tile on the beach.”
- “I took my daughter to the doctor because… something related to a launch.”
- “I tried to go to the beach but a SPACEX guard blocked the road.”
6) The U.S. Army has done testing on shockwaves proceeding from launch pad rocket explosions in the 1950’s. Has the Army Corps referenced those studies? Why or why not?
6A) Given the amount of fuel on Starship and Super Heavy Booster, ChatGPT says that at 5 miles out the shock wave will be 170db. That humans will suffer hearing loss, brain damage, and other organ damage. It will be 1,000 times louder than a rock concert. The leader of SpaceX has said publicly that he feels that a launchpad failure is a possibility. He said, “I just hope it does not burn down his launch tower.” As an Army Corp of Engineers, engineer to you verify that the only result from 1000 tons of Methane and Oxygen side by side will only result in fire? In my understanding, it will be an explosion. It is up to you to tell us how big and how that shock wave and flying pieces of the launch tower will extend. The Texas City port explosion was of similar magnitude. The blast broke windows ten miles away in Galveston and sent a 5 ton anchor flying 1,000’s of feet. Will a 172db shock wave blast the good people of nearby cities into oblivion like an IED under a Humvee in Afghanistan permanently disabling or at minimum leaving the people with PTSD as our army soldiers have suffered and still suffer? Your requiring a full launchpad failure analysis before even the next launch from the existing launch tower is owed to Texans. The Army goes to fight battles elsewhere so that we can enjoy freedom from war at home. Will a launchpad explosion of Starship with Super Heavy Booster put nearby cities in a war zone?
6B) How was the “safe” 5-mile perimeter decided? This suggests that some analysis has been done to even make that decision. If the data that warranted the decision of a 5 mile safety perimeter cannot stand the test of public scrutiny, is something trying to be hidden from the public regarding their safety?
6C) Why has a launchpad explosion not been considered relative to public safety? I asked the Point of Contact with the FAA for the SpaceX project, before the first launch of Starship with Super Heavy Booster if a launchpad explosion scenario failure analysis had been performed and shared with the public. She wrote back and directed me to the public information that includes only a sound pressure level assessment survey for a normal launch. The FAA was admitting that no consideration has been given to the impact on the public in neighboring towns in the event of a launchpad explosion. Why? Did the Army Corps of Engineers participate in helping the FAA know that this is a true concern, especially launching within 6 miles of a city? Cape Canaveral is 12 miles from the nearest city and the Saturn 5 rocket was half the fuel of Starship with Super Heavy Booster. The Army Corp has access to the testing that the Army has done with launch pad explosions from their work in the 50’s. If a concern then, then why not now?
6D) As follow-up verification to the published anticipated sound pressure levels for the launch path, has SPACEX recorded actual sound pressure levels from the 3 launches to verify the predictions for a normal launch? If not, why not? If so, why has this verification report not been made public?
6E) Is the shock wave from a launchpad explosion scenario going to wash all the wastewater from retention ponds into marshlands thereby contaminating sensitive habitats? A launchpad explosion shock wave, if like Texas City port explosion, could move a 5 ton anchor 1,000’s of feet in the air, any wastewater retention ponds will likely be sprayed in sheets of driving horizontal rain across thousands wet land acres.
6F) Has any reasonable thought been given to firing a rocket with a sound pressure level as high as, no one can come within 5 miles, what is it going to do to the ears of animals adjacent to the launchpad. Will birds even be able to hear themselves sing? When I was a teenager… someone drove a dune buggy into Yellowstone National Park forest. The rangers apprehended him. The dune buggy was airlifted by helicopter so as to not further disturb the protected park further. I think the guy had to pay for the airlift along with the fine. How far we have advanced in technology since then… invention of computers, internet, cell phones, returnable rockets … but have we left something behind?
I really do hope that you will do the next public feedback session before making this decision in a location more accessible to the people whose lives are on the line. Making people carpool 6 hours to come provide 3 minutes of testimony, spending their own money for travel, as the Texas Parks and Wildlife commission did, is a bullying tactic not becoming of a government organization whose job is to serve the people at the will of the people. I know you will consider the public as you would lay down your life for them.
Thank you for all you do to ensure safe engineering designs. People are precious in the eyes of God and man has a responsibility before God to value each life… and be good stewards of the animals and nature.
By way of public transparency, I will copy this note to some local newspapers and TV stations.
Bob Achgill
LinkedIn: https://www.linkedin.com/in/SpaceX-achgill-122a609/
More news on SpaceX - the big Texas giveaway and safety
KBTX interview - call for more SpaceX transparency on public safety
Here is the TV news report on KBTX regarding the Texas Parks and Wildlife land swap with SpaceX https://www.kbtx.com/2024/03/15/spacex-launches-third-test-flight-near-boca-chica-beach/