FAA, FWS & other permits/licenses for Boca Chica DISCUSSION (Thread 5)

[ZachF]

I spoke out in favor of environmental regulations previously, but it's important to differentiate enforcement from timeline. I think companies must be made to comply with permitting and regulation, but there isn't a good reason to drag out the process. I'm sure many here are skeptical that a 60 day delay is justified.

Perhaps not in this case, but sometimes there are good reasons to drag out the process.  Some environmental analyses are, necessarily, subject to the environment.  For example, you can only do certain types of analyses at certain times of year (baby birds, maximum runoff time, only during hurricane season, whatever).

I would also point out that, in this case, we have only heard one side of the story.  And we likely won't ever hear the other side.  I have been on the other side of this sort of thing (and, in fact, am in one right now), and I have heard from the people I serve that there's no reason for the process to take as long as it is taking, when in fact, there is a good reason, they just don't know what it is.  Often, when I inform them of the reason, they understand and realize why things are the way they are.  When the system is opaque, you can only make guesses about why it is the way it is, and in my experience, those guesses are essentially always wrong.

Defaulting to administrative bloat is why many young people in the west can’t afford homes.

In Canada, the permitting paperwork literally costs more than building a fricken house.

Administrative bloat is why we can’t have HVDC lines in the USA that bring renewable energy from where it’s produced to where it’s needed.

I’m tired of the default being deferring to people who have a self-interest in dragging the process out. It’s grown to a point that the west can’t have nice things anymore.

[dglow]

There’s no way to know for certain what exactly is going on. And as much I wish for a world where this wouldn’t be the case, I also know we don’t live in such a world, so…

It’s election season. Elon has firmly thrown in with one side. Are we naive to think this isn’t couldn’t be the other side throwing back?

[edzieba]

you are claiming equivalent results are different because maybe it will never rain ever.

No, and you are once more putting words in my mouth.
The process is pretty simple: you can't not be rained on, but you can not discharge water. If you want to discharge water, you (in the US) apply for a permit to do that.

This was also part of your nonsensical claim that Florida rules should apply to Texas. Different states have different sets of permits and different rules, mappings will not be obviously 1 to 1.

Yet as it turns out, if you discharge water you need a discharge permit in Florida, and if you discharge water you need a discharge permit in Texas.

This is now 2 posts in a row that you have completely misrepresented the conversation, after you made a baseless and slanderous accusation of nepotism at SpaceX.

Again with the putting words into my mouth.

I would also point out that, in this case, we have only heard one side of the story.  And we likely won't ever hear the other side.  I have been on the other side of this sort of thing (and, in fact, am in one right now), and I have heard from the people I serve that there's no reason for the process to take as long as it is taking, when in fact, there is a good reason, they just don't know what it is.  Often, when I inform them of the reason, they understand and realize why things are the way they are.  When the system is opaque, you can only make guesses about why it is the way it is, and in my experience, those guesses are essentially always wrong.

There's also the framing of the up-to-60-days response period as a '60 day delay' (or "indefinite delay" in one case), which is rather misleading.

Also, point of order: the CNBC report, whilst nonsensical and hilariously wrong (and based not not reading the whole permit application) garbage, is also irrelevant. The FAA themselves found out about the permit application and contacted SpaceX to ask what the heck was going at least a week before the CNBC article was published, but notably they found out weeks after the permit application, which is why it ended up in a sudden cancellation of the public comment period and the 'is there anything else that needs to be updated for the next license modification?' factfinding exercise. Since the FAA are the ones responsible for corralling the various agencies involved, being out of the loop here spooked them into checking if there was anything else they were not copied in on.

[novo2044]

There’s no way to know for certain what exactly is going on. And as much I wish for a world where this wouldn’t be the case, I also know we don’t live in such a world, so…

It’s election season. Elon has firmly thrown in with one side. Are we naive to think this isn’t the other side throwing back?

The FAA is a government agency tasked with protecting the public, funded by taxpayers.  The obvious solution would be for them to explain their process, what the hold-ups are, and their justification.  Like.  Why shouldn't they?  Why are we in the dark at all?  SpaceX is a private company they don't owe us anything, really.  The federal government most definitely does

[meekGee]

There’s no way to know for certain what exactly is going on. And as much I wish for a world where this wouldn’t be the case, I also know we don’t live in such a world, so…

It’s election season. Elon has firmly thrown in with one side. Are we naive to think this isn’t the other side throwing back?

As much as I hate this, I can't imagine it's retaliatory.  That would be plain dumb and a recipe for backfiring spectacularly.

I suspect the usual case of the feet-draggers do-nothingers seeding enough doubt to cause delay.

I hate so much that environmentalism has become synonymous with that.

Maybe those guys are more galvanized by anti-Muskism, but I somehow suspect they'd be at it anyway.

[chopsticks]

In Canada, the permitting paperwork literally costs more than building a fricken house.

Huh? I live in Québec where we love paperwork but this is just not true for most people. Maybe it is if you're building a tiny house or something or want to build in a sensitive area, but please don't make broad and misleading statements like this.

/off topic correction

[daveklingler]

It's too bad that SpaceX has never been through any of this process in the past, or they might have submitted their applications a great deal sooner and/or chosen tests based on what they already had permitted.  Changes to launch licenses would seem to play an important part in the development GANTT chart, so one idea would be for SpaceX to have people who know the process have an input into planning.

Of course, this would require planning.  With billions of dollars' worth of equipment, employment and business riding on Starship, one might expect the engineering management to include strict attention to little details like launch licenses and their requirements.

Or one could just stick a finger in the air and decide to make some changes, and take a chance on regulatory delay.

[dglow]

The Starship and Super Heavy vehicles for Flight 5 have been ready to launch since the first week of August.

Sure, but you're currently putting a lot of time into Mechazilla, so...

True, however, all of this work has been performed ahead of the originally anticipated license date of Mid-September. Until we cross that date range, any work being performed would've been in effort to meet that original estimated date.

If SpaceX are going to post a very, how to say, charged piece on their website, then it behooves them to be scrupulous with the details. Half-truths like the "vehicles for Flight 5 have been ready to launch" don't do them any favors, IMO.

When one begins to detect Elon's exaggerating tone, it's fair to ask how many other details have been stretched.

[Lee Jay]

There’s no way to know for certain what exactly is going on. And as much I wish for a world where this wouldn’t be the case, I also know we don’t live in such a world, so…

It’s election season. Elon has firmly thrown in with one side. Are we naive to think this isn’t the other side throwing back?

The FAA is a government agency tasked with protecting the public, funded by taxpayers.  The obvious solution would be for them to explain their process, what the hold-ups are, and their justification.  Like.  Why shouldn't they?  Why are we in the dark at all?  SpaceX is a private company they don't owe us anything, really.  The federal government most definitely does

Sometimes, you can get between a rock and a hard place.  The rock is the desire to be transparent and the hard place(s) is/are the lawyers, the company's desire for privacy, the contractual T's & C's, federal and state law, and the need to interact with other agencies, federal, state and local.

[dabomb6608]

The process is pretty simple: you can't not be rained on, but you can not discharge water. If you want to discharge water, you (in the US) apply for a permit to do that.

And indeed they did as directed with the Stormwater Permit.

Yet as it turns out, if you discharge water you need a discharge permit in Florida, and if you discharge water you need a discharge permit in Texas.

 It wasn't claimed that they wouldn't need one...Just that the processes and permits themselves aren't identical state to state.

[chopsticks]

Well SpaceX likes to "move fast and break things". Including the law apparently.

[Lee Jay]

Well SpaceX likes to "move fast and break things". Including the law apparently.

There's little evidence that they broke any laws or rules, at least rules that they knew about.

[eriblo]

It's too bad that SpaceX has never been through any of this process in the past, or they might have submitted their applications a great deal sooner and/or chosen tests based on what they already had permitted.  Changes to launch licenses would seem to play an important part in the development GANTT chart, so one idea would be for SpaceX to have people who know the process have an input into planning.

Of course, this would require planning.  With billions of dollars' worth of equipment, employment and business riding on Starship, one might expect the engineering management to include strict attention to little details like launch licenses and their requirements.

Or one could just stick a finger in the air and decide to make some changes, and take a chance on regulatory delay.

Yes, SpaceX could of course eliminate most of their regulatory delays by just stretching out their development schedules by a factor of 5 or so. 

[novo2044]

There’s no way to know for certain what exactly is going on. And as much I wish for a world where this wouldn’t be the case, I also know we don’t live in such a world, so…

It’s election season. Elon has firmly thrown in with one side. Are we naive to think this isn’t the other side throwing back?

The FAA is a government agency tasked with protecting the public, funded by taxpayers.  The obvious solution would be for them to explain their process, what the hold-ups are, and their justification.  Like.  Why shouldn't they?  Why are we in the dark at all?  SpaceX is a private company they don't owe us anything, really.  The federal government most definitely does

Sometimes, you can get between a rock and a hard place.  The rock is the desire to be transparent and the hard place(s) is/are the lawyers, the company's desire for privacy, the contractual T's & C's, federal and state law, and the need to interact with other agencies, federal, state and local.

That's all legitimate.  If those are the elements that are preventing transparency, then they should say so.  Federal agencies should be accountable to the public.  If various federal and state laws or agencies are the problem, then the public needs to know what they are so they can pressure their elected representatives to actually fix them.  The public is not well informed, and often makes bad decisions, but they have the right to know why they aren't getting what they want, and what pathways exist to fix the issues, even if they are tortuous. 

The public doesn't actually care about the snail darter, at the end of the day.

[Lee Jay]

The public doesn't actually care about the snail darter, at the end of the day.

What the public cares about is not the only consideration.  Part of the foundation of this country is preventing the "tyranny of the majority". 95% of people care about their own lives, not whatever is going on at the Texas-Mexico border.  That doesn't mean it shouldn't be done.

[dodageka]

Well SpaceX likes to "move fast and break things". Including the law apparently.

Pushing the regulatory boundary is part of innovating. I am not saying that laws should be broken, but if every startup always strictly adhered to rules & regulations and the prevailing interpretation at the time, not many would have made it

[InterestedEngineer]

Of course, this would require planning. 

That requires knowing what your requirements are.  Which leads to top-down design.  Which leads inevitably to slow expensive programs like SLS and other cost-plus government/defense boondoggles that carry a ton of bad requirements as baggage along the entire way.

Quick iteration means finding your bad requirements and discarding them.  That the license folks can't keep up is an indictment of the licensing folks, not the engineers or program managers.

[meekGee]

Well SpaceX likes to "move fast and break things". Including the law apparently.

That's just inflammatory.  What law did they break?

I see them unhappy about the length they have to wait until their application is approved.

OTOH, statements like yours, if they held any weight, would be breaking defamation laws.

[InterestedEngineer]

BTW the filtered water you had in your fancy Yeti thermos at the beach and dumped out before you left was also no longer portable in pretty much the exact same way.

Don't even get me started on the toxic disaster that dumping out your warm Coke or leftover beer is!!!

How many thousands of gallons of warm Coke are you dumping on the regular?

Per entire beach worth of partying undergrads?  And factoring in just how much more polluted beverages are?  You'll be on the losing end of that one.

There are 7M visitors a year to South Padre Island.  1M of them dumping a 16oz coke or pepsi on a beach would result in 125,000 gallons of polluted sugar water.   1000x worse than deluge water.  The phosphoric  acid content of 100kg is enough to damage a reasonable swath of ecosystem.  the 50t of sugar is really bad for the environment as well, as it really messes up the oxygen balance of ecosystems:

https://www.sciencedirect.com/science/article/abs/pii/S0959652621034223

Yet I note that sugar-phophor water sales are not regulated on South Padre island. 

Our distributed pollution is far worse than most industrial pollution these days.  Especially compared to those dumping recently-potable water.  Compare to the distributed pollution of plastic in the oceans, for example.  Try swimming in the Med sometime, it's absolutely filled with plastic bits, all dumped a little bit at a time.

[Lee Jay]

Our distributed pollution is far worse than most industrial pollution these days. 

If that is true, it's because of decades of environmental regulations on industry, as they were obviously far worse in 1924 than was the public.