On March 25, the U.S. Air Force published a notice that it intended to prepare an environmental assessment in anticipation of building two landing pads at Johnston Atoll. The pads would be part of the Air Force’s “Rocket Cargo Vanguard Program,” which will reportedly use Elon Musk’s SpaceX rockets to deliver tons of military gear within hours to anyplace around the world in a matter of hours.
Or, as the notice in the Federal Register put it, the proposed action “is to safely test and demonstrate the expeditious delivery of tons of materiel through space in support of ongoing research, development, test, and experiment under the [Department of the Air Force] Rocket Cargo Vanguard program…. [T]he Air Force Research Laboratory is leading a science and technology effort to determine the viability and utility of using large commercial rockets for Department of Defense global logistics, potentially expanding the portfolio of capabilities the United States Space Force presents to combatant commanders. The need for the proposed action is to advance novel space capabilities to transport materiel in hours anywhere around the globe.”
The notice stated that the draft EA would be available for public review in early April 2025. As of press time, it was not yet published.
Why was Johnston Atoll selected?
According to the Federal Register notice, the Air Force needs a landing location “that ensures public safety” and complies with federal regulations concerning launch and re-entry licensing requirements. Also, the location should not interfere with ongoing military operations; should be in a “remote, securable, U.S. Government-controlled” area that is able to support the transport of personnel and materiel; and can “support the disposition and removal of re-entry vehicles via barged transport.”
Johnston Atoll was the only site that met all operational requirements, the Air Force determined.
The Federal Register notice says expected effects “include but are not limited to” effects on fish, migratory birds, and other protected species. To address these issues, the Air Force “is committed” to working with the Fish and Wildlife Service and the National Marine Fisheries Service, among other stakeholders, “to advance cultural, ecological, and conservation protections at Johnston Atoll, the Johnston Atoll National Wildlife Refuge, and the Pacific Islands Heritage Marine National Monument.”
While the notice did not mention Elon Musk’s involvement, in official correspondence between the Fish and Wildlife Service and the Air Force, the use of Musk’s SpaceX rockets is specifically referenced. For example, an informational memorandum drafted last November by John Klavitter, monument superintendent, in anticipation of a meeting of then-FWS Director Marsha Williams and the Council on Environmental Quality, states, “SpaceX is under contract with the Air Force to develop new technology for rapid transportation of cargo … using 50-m tall Starship Rockets. Johnston Island, within the Refuge, is proposed as a test Starship Rocket landing site.” By this time, FWS had already provided comments on the first and second drafts of the EA (on September 3 and October 31, respectively).
According to the description of planned operations in the memo, there would not be continuous human presence on the island, “but personnel would be mobilized during construction, rocket landings, and demobilization” as many as ten times a year for up to four years. Rockets would be launched from Texas or Florida.
Although the island is under the administrative jurisdiction of the Air Force, FWS has been active in managing it as part of its refuge system. Actions it has undertaken include the decade-long, multi-million-dollar effort to eradicate the yellow crazy ant, which had been decimating populations of nesting seabirds. “Every effort should be made to protect this investment by preventing introductions of invasive species from project activities,” the memo says.
Reference is made to a site visit by SpaceX and Air Force personnel in February 2024. “Because the Air Force has administrative jurisdiction over the emergent lands, no permits from FWS were required for work on land” for that visit. “However, [FWS] issued a Special Use Permit (SUP) for activities in Refuge and Monument waters, because the Air Force and SpaceX accessed Johnston Atoll [National Wildlife Refuge] by boat for their site visit, conducted water depth surveys, and evaluated stability of the seawall. … A SUP would be required to cover activities in Refuge and Monument waters for work associated with landing rockets on Johnston Island.”
While FWS didn’t issue any Migratory Bird Treaty Act permits for the site visit, the memo states, such permits “will likely be required if rocket landings proceed. Some measures proposed by the Air Force in the future (e.g., clearing of birds from impact areas to facilitate construction) would require an MBTA permit and associated [National Environmental Policy Act compliance].”
No species listed as endangered or threatened “would be affected by the project as proposed, if landings go as planned,” the memo continues. “However, SpaceX has experienced rocket mishaps where debris and unintentional spills expand far beyond the launch site. If similar instances occurred at Johnston Atoll, debris could potentially expand into the water impacting threatened and endangered species, including sea turtles, monk seals, corals, sharks, and marine mammals.”
Around the same time, the Pacific Regional director for FWS, Hugh Morrison, provided extensive comments on the draft EA then being circulated.
“We believe that the draft EA should more adequately analyze impacts to protected seabirds from infrastructure construction activities and associated human presence, noise, heat, vibration, potential for mis-landings and subsequent spills, and debris and disruption to aquatic/marine habitat, including coral reefs. Alternatively, the Air Force should consider doing an Environmental Impact Statement due to the uncertainties around potential effects to the ecosystem on Johnston Atoll from this proposed project. An EIS would allow for a more complete description of the action, alternatives, and evaluation of effects from those alternatives.”
Morrison highlighted other concerns as well. The EA should incorporate adaptive management planning, “given uncertainties regarding potential impact from proposed activities and the potential for accidental scenarios.” This would outline a process for the FWS, Air Force and SpaceX “to modify operations as needed in response to real-time information on actual effects.”
Also, SpaceX and the Air Force should implement “a robust biosecurity plan and protocols … at both the port of departure and arrival at Johnston Atoll, as well as a biological monitoring crew to systematically and regularly monitor for the presence of invasive species and their impacts on the atoll ecosystem.”
Morrison also stressed the need to restore all impacted areas to pre-project conditions, with the effectiveness of restoration work monitored and documented for a minimum of ten years, “keeping in mind that restoration of the seabird community could take decades due to their low fecundity.”
Finally, he expressed concerns “that Air Force/SpaceX have not adequately addressed the potential impacts of disturbance of existing plutonium on site to humans and wildlife, nor how to monitor for plutonium during digging and soil disturbances from the rocket plume downdraft. For example, the EA states that, ‘all digging will be monitored with Geiger counters.’ However, a typical Geiger counter cannot detect plutonium because it emits alpha radiation. … We recommend thorough evaluation of potential plutonium effects prior to ground disturbance activities.”
(Johnston Island was a test site for nuclear weapons in the late 1950s and early 1960s. At least two launch failures in 1962 left the island heavily contaminated with plutonium. Cleanup consisted of scraping the surface area around the launch site, burying most of it on one end of the island, capping it, and fencing off the area.)
By December, the FWS was commenting on what was apparently the third draft of an EA for the proposed rocket-landing facility. Klavitter, the monument supervisor, submitted extensive comments.
He wanted to see the EA include language from the presidential proclamation that expanded the monument, including the requirement that the Armed Forces “shall ensure … that its vessels and aircraft act in a manner consistent, so far as is reasonable and practicable, with this proclamation. In the event of threatened or actual destruction of, loss of, or injury to a monument expansion resource or quality resulting from an incident, including but not limited to spills and groundings, caused by a component of the Department of Defense or the United States Coast Guard, the cognizant component shall promptly coordinate with the Secretary of Interior or Commerce, as appropriate, for the purpose of taking appropriate actions to respond to and mitigate any actual harm and, if possible, restore or replace the monument expansion resource or quality.”
Other points Klavitter raised:
Wastewater: The presence of 150 people during operations “will be substantial. Need to describe in detail what will be done with the waste. … Note: Release of this is not allowed in waters within 12 nm of the shoreline.”
Seabirds: “The EA should include the fact that here are 15 species of seabirds on Johnston, including the world’s largest colony of red-tailed tropicbirds, with nearly 13,000 nesting pairs counted … in 2021.”
Public access: “Please delete the following sentence: ‘Although the refuge lands and outdoor spaces have remained open for the public to enjoy, which creates a public safety risk.’ [sic] The islands are closed to the public.”
Klavitter called out a number of statements with which he disagreed, such as the claims that “site preparation and construction would have no or negligible impact on biological resources” and that “landing activities would have no to negligible impacts to vegetation, short-term and minor impacts to terrestrial wildlife, and no to minor impacts to marine wildlife.” Hundreds of eggs and chicks and possibly some number of adults will most likely be killed by construction activities, he wrote. “Potentially, 50 percent of the seabird population will be displaced by rocket landings, with some level of adult mortality.”
The language of the draft EA concerning hazardous materials was also criticized by Klavitter. The draft EA claimed, “It is unlikely that hazardous materials would be introduced to harm the human or natural environment at Johnston Atoll, and any impacts would be short-term and minor. Accordingly, the [Department of the Air Force] concludes the use of hazardous materials during the construction and vehicle re-entry phase would be less than significant.” To this, Klavitter responds: “If a rocket explodes where the plutonium is buried on Johnston, there is some likelihood that it would spread the plutonium through a significant portion of the marine environment. When USFWS staff visit the island, we do not allow them to do any digging (even by hand) because of the risk of inhaling plutonium that is spread throughout the island. During the last extensions of the island, DoD dredged through the plutonium plume in the ocean and used the material to expand the island.”
He took exception to the breezy dismissal of the island’s importance to seabirds in its claim that “Johnston Atoll does not appear to be a significant rookery location for any species.” “This statement is untrue,” he wrote. “The 640-acre refuge sustains the world’s largest colony of red-tailed tropicbirds, with nearly 13,000 nesting pairs … in 2021. This is the only terrestrial seabird habitat in over 570,000 square miles of open ocean, with 15 species of breeding seabirds relying on this refuge. Seabirds have not experienced major human activities for over 20 years. Seabirds have low productivity, so it will take many years for seabird populations to recover if they are impacted. Approximately 50 percent of the seabird population could be displaced or killed by actions. Again, it could take decades for seabird populations to recover once the project is finished.”
The two sites selected for the landing pads are the worst of the four areas considered, he wrote. The selected sites are the wharf and the aircraft parking ramp. Early on in the EA drafting process, FWS had noted that selecting these locations “would be the most harmful … because of their proximity to nesting seabirds. Additionally, the parking apron is near to endangered green turtle haul-out locations. Selecting the least harmful sites is one of the only ways the negative impacts of this project can be mitigated.”
Klavitter also commented on the negative impacts that communication towers, antennas, and the like would have on birds.
Then there is the effect of lighting associated with the operations of the facility as well as the presence of 150 people. “Many seabirds are phototactic,” he wrote, “meaning that they are attracted to, stunned, and often trapped by bright or misdirected lighting. All lighting associated with human activities and presence should be designed to reduce impacts to seabirds by using the dimmest light possible, directing light downward and away from nesting seabirds, and employing shielding to direct lighting only to where it is needed for essential night-time activities.”
Apparently the proposed actions described in the draft EA Klavitter was reviewing include the venting of liquid methane onto the island during “safing” operations. This discussion, Klavitter said, was inadequate, neither described nor addressed. “Please describe the effects of this activity in terms of the number of birds that will be killed or injured through asphyxiation,” he wrote.
“This assessment of impacts of rocket landing activities is inadequate and unrealistic,” he continued. “The noise, the blast, and the heat caused by the landings will cause many thousands of seabirds nesting and resting on Johnston Atoll irreparable harm, injury, and death, or to permanently abandon the island.”
An appendix in the draft EA “portrays the temperature profile of the rocket blast. At the source, the temperature described is 4,000 Deg-R[ankine]. The temperature 700 feet downstream of the blast is approximately 800 Deg-R. These numbers convert to approximately 3500 degrees and 340 degrees Fahrenheit. Most living organisms cannot survive these high temperatures. Any birds within 700 feet of the blast – most of the island – will likely be injured or die from the intense heat. Adult birds would suffer burns or death, and any unprotected chicks or eggs would be cooked. If adults are injured, their lack of return to the nest would also cause nests to fail, which is a take under the Migratory Bird Treaty Act.
“Contrary to the inadequate description in this EA, they will not likely be flushed, to return immediately and resume their normal activities. It is more likely that adult birds, young, and eggs will be immediately killed by the heat of the blast. Furthermore, the sonic boom created by the landing will irreparably damage the birds’ ears, potentially causing them a slow, painful death rather than an immediate one. According to Appendix D, sound levels of 115 dB will extend across the island. At this sound level, human ears would require hearing protection to experience one event without injury, but any birds surviving the blast would be subjected to up to 40 ear-damaging events during the four years of landings. It is likely that many birds that do survive a landing would abandon the island and any ongoing nests in response to the trauma of the heat and noise created by the landings.”
SpaceX responded to Klavitter’s comments.
Regarding wastewater, “Ships have blackwater and grey water storage tanks amounting to XXX gallons [sic] and will be used to haul off all wastewater. Portable toilets would only be placed over paved surfaces or within staging areas.”
“Qualified biological monitors, approved by USFWS, shall be present to monitor construction activities at all times deemed necessary by the DAF throughout the length of the project. … SpaceX has seen no changes to the number of shorebirds or migratory birds near Starbase Boca Chica TX during launch. Launch includes 33 Raptor engines firing with over 103MN thrust.” (MN stands for Million Newtons, a measure of force; 103MN is about 280 metric tons of force.) “Landing will have approximately 3-9MN with only 1-3 Raptor engines firing. This is similar to Falcon booster landings at the Cape which have also not seen a reduction in shorebird or migratory bird numbers.”
SpaceX disputed the risk that its activities might cause the release of sequestered plutonium on the island. “Appropriate measures will be taken to ensure digging can be accomplished safely when digging is necessary and launch providers will implement operational and engineering measures during reentry vehicle landing to protect critical locations.” SpaceX cites the environmental baseline study produced in 2005, after the cessation of nerve-gas disposal operations on the island, which found that only 1.1 percent of the original amount of weapons-grade plutonium is contained within the Radiological Control Area landfill; 87 percent is in the lagoon; the remainder, 11.9 percent, was shipped off-island during earlier cleanup activities or was incorporated into the island when it was expanded by dredge-and-fill operations.”
As for the methane venting, “No birds will be injured or killed during venting,” SpaceX said. “Methane is lighter than air and will rise and quickly dissipate. This is a normal operation for rockets and no bird at any SpaceX installation has ever been asphyxiated by venting procedures.”
SpaceX dismissed concerns about birds being harmed by the heat and noise when rockets re-enter. “Starship noise will last approximately 15 seconds and the birds are expected to startle. Launched rockets do flush birds and they do return immediately to their nests as seen by Wallops Island, VSFB [Vandenberg Space Force Base], Cape Canaveral, KSC [Kennedy Space Center], and Boca Chica TX. Heat numbers … are for the plume. The plume is exactly the same whether a candle or a rocket. A candle has various temperature degrees. … No one dies if they are next to a candle. It is not how a plume works. Rockets work the same way.”
SpaceX also disputed the assertion that the EA should include a discussion of the impacts of potential accidents.
In rebuttal, FWS noted that the National Environmental Policy Act does, in fact, require the analysis of “reasonably foreseeable” events that have catastrophic consequences, even if their probability of occurrence is low. “Because rockets similar to what are being proposed have failed (exploded/fires) and the fuel is highly flammable, it is within the rule of reason that an accident could occur even if the chance of occurrence is low. Therefore, impact from and contingencies of a failure should be evaluated and discussed.”
(A 2023 lawsuit against the Federal Aviation Administration filed by the Center for Biological Diversity over SpaceX activities in Boca Chica, Texas, notes that rocket launches and testing there had resulted in at least eight explosions over the previous five years. “FAA has acknowledged that many more such ‘anomalies’ are expected over the next five years,” the complaint states.)
FWS also wanted more information on the claims of SpaceX that birds near other SpaceX operations were unaffected. The agency recommended the EA provide and cite the data from other SpaceX facilities. “To our knowledge, based on discussions with other USFWS biologists involved with the other SpaceX facilities, the avian monitoring only includes presence/absence and count data … which is not adequate to monitor impacts to reproductive success and the specific concerns relevant to the seabird species at Johnston.”
As for SpaceX’s dismissal of concerns over the venting of methane, FWS wasn’t buying it. FWS’s comment: “Recommend including language to describe the potential side effects of methane venting upon rocket landing. A past SpaceX rocket launch (the March 30 2021 Starship test flight from Boca Chica) failed due to a methane leak causing an explosion, so it seems reasonable to expect that there is some explosion risk if the rocket exhaust includes methane gas. Recommend including a more thorough description of all potential impacts from these chemical compounds entering the environment and known and likely risks of these chemical compounds.”
On May 27, SpaceX experienced yet another failure as it attempted to launch a Super-Heavy rocket from Texas – or, as the company described it, “a rapid unscheduled disassembly.”
— Patricia Tummons
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