No, you tell me that everything I point out that is blatantly a violation must be a Typo. You don't understand emissions calculations and confidently claim expertise in something you just pulled up on Wikipedia.
I am well aware that they don't need a giant gas plant or 250 mw power plant, but that's exactly what they applied for. Your arguments are nonsensical so I stopped replying after repeatedly and calmly explaining the rules to you
Heres a tl;dr from Reddit. I'm very tired as this is a big deal and no, I don't have a cohesive narrative throughout the series. I was trying to get as much information out there during the very short 30-day window for public comment. I believe public comment is super important for these types of projects. I have over a decade of experience in this specific field, and have worked as a regulator, for non-profits, and as an employee of big oil and gas. Please go easy on me
SpaceX and FAA snuck a bunch of oil and gas infrastructure including a gas plant, a LNG a 250 MW power plant into an "insignificant/minor change" NEPA environmental review document that was supposed to just be for bigger rockets.
It has tons of basic errors, missing data, and even though NEPA is a public disclosure law, no one is talking about the oil stuff at all Also implied, but explicitly not noted in the document are a
1. Pipeline that needs to be constructed and
2. the huge amount of newly drilled oil and gas wells in a region of Texas that currently has no production to speak of.
Oh and all of this is on a federally protected wildlife reserve. And it's super illegal and unprecedented and brings about all sorts of uncomfortable questions about regulatory capture
> I believe public comment is super important for these types of projects.
Something I've always wondered: How is it that public comments have power? What stops officials from mostly ignoring them or misconstruing them? And if the comments do have power, what stops vested interests from hijacking them?
I'm not sure about these types of projects but public commenting for the FDA proposed regulations regarding hemp was actually really helpful for the industry.
Not sure why you are getting downvoted but the GP comment had a very specific request, link to the data source. You've no doubt got those links somewhere right? Adding a post of links to all the public filings would be a real asset here.
Would it be helpful to maybe discuss which step of the discussion that people are getting tripped up on?
The core of this particular argument is the following:
> Think about it like this. We have 3 variables:
> 1. Inlet Gas Flow rate (measured by mmscf/d but easily convertible to pounds methane equiv.)
> 2. The VOC content mass % of the inlet stream
> 3. The Loss Rate through leaks in valves, fittings, etc. This is the fraction of the total inlet stream is lost to the air
> We simply multiply these three items together to get:
> 4. The VOC emission rate in tons per year (US short tons are EPA standard)
> Since we know #4 (The PEA told us), we know #2 (Pipeline Quality Gas is always <0.1% VOCs, and usually lower), and #3 is a range (with modern cryo plants at the lower end), we can simply go backwards to calculate implied flow rate
#1 is what this post is trying to calculate, to see what is or isn't reasonable.
And is basically the starting point of all calculations. Just Ctrl-F "45.8", the number that ESG_Hound uses in his excel-spreadsheet. That gets you to page 44, the number seems to check out. This post is trying to answer the question: when they wrote this PEA, what assumptions did the engineers make?
#3 is a reasonable assumption that doesn't change much.
The last variable is #2: which has two paths:
1. 99.9% pure pipeline methane -- When we plug in 99.9% pure methane into the calculations, the numbers are absurd. This is a "disproof by absurdity". So we know it can't be 99.9% methane from standard pipelines.
2. Maybe its "raw" methane from a well (varies from 3% to 10%). -- When plugging in these numbers, we calculate a 4.77% VOC rate, which suggests that all the calculations in the PEA were done __ASSUMING__ raw methane.
Now sure, our model isn't going to be the same model as whoever prepared this PEA. but we're probably going to be "within the same magnitude". Calculations, when done independently, will rhyme.
-------------
It seems like a simple argument to me. What part of the discussion are people getting tripped up on?
When using 99.9% pure methane, the amount of Mega-scf of natural gas goes completely out of whack with any reasonable excel-sheet formula. As such, 99.9% pipeline methane cannot be the source of SpaceX's methane (at least, not with the assumptions listed in the PEA).
Does anyone have a problem with any of the assumed numbers? #1, #2, #3 or #4?
-------
So the QED is: SpaceX, when they wrote this PEA, assumed they'd be using raw, untreated natural gas straight from a well. Why would they make this assumption? Is SpaceX planning to set up a pre-treatment natural gas plant inside of Starbase?
What it ignores is that to perform the maximum number of launches permitted under this new license will consume around 1% of the methane this would produce. This equipment will be be used, at most, a few hours every month, but he's producing numbers under the assumption that it would be running 24/7.
You seem confused. This topic is about the pretreatment plant, not the power-plant.
You don't build a pretreatment plant if you're only using a fraction of its capacity. You'd instead just ship in pre-treated methane by pipeline or by truck.
But that's not what SpaceX is asking for. SpaceX is asking for their own, private, pretreatment plant. For... some reason. (The underlying theory is: SpaceX seems to be trying to mine their own natural gas)
--------
EDIT: And if the power plant was expected to be operating at only a minor fraction of the year, you'd expect something in the PEA to note that fact.
And the document writes "45.8" as their yearly VOC emissions rate from that pretreatment plant, page 44.
Do you see any reason to disagree with this 45.8 number?
------
If you do have beef with other blogposts / other things (It seems like you want to talk about the power plant), you're welcome to do so. But my earlier points in this thread are rather specific to this #16 blogpost.
This is not true at all. Doubly not true when your program is subsidized by Federal dollars and takes place adjacent to protected federal lands.
The FAA is subject to NEPA review, and hence any SpaceX activity in this area must go through the same process as every other industrial activity that impacts federal interests.
Surely you know by now that Elon/SpaceX will get its fuel no matter what, even if it means trucking the fuel there, seems to me your best case scenario will increase net emissions.
Protecting the environment is not the point of this stunt, is it?
It's not true at all. Federal regulations dictate most environmental standards and in top of that TCEQ is a very competent and at times tough regulator.
EPA definitely has a dog in the fight, especially considering that a 250 megawatt power plant would be a literal "major stationary source" under the clean air act
I don't know anything about this sort of regulation, but it might be worth noting that the PEA does indicate that SpaceX will be seeking a permit from TCEQ (on page 42 of the PEA)
> SpaceX would apply for authorization under the Oil and Gas Standard Permit with the TCEQ and adhere to any permit conditions
FAA's document is subject to NEPA and table 2.1 in the PEA considers the gas plant and power plant to be in scope. FAA is the overseeing agency for this action so it doesn't matter that it's not in "FAA's domain"
FERC and DOE do these types of NEPA approvals all the time and include full EPA participation.
SpaceX and FAA didn't consult with EPA and that was likely intentional. This is essentially an unprecedented action under NEPA. Feel free to shoot emails or ask questions. Finally getting lots of attention here.
