Draft Environmental Assessment for the 
Houston Spaceport, City of Houston, 
Harris County, Texas  
 
 
December 2014

 Draft Environmental Assessment for the Houston Spaceport, City of Houston, Harris
County, Texas 

AGENCY: Federal Aviation Administration (FAA), lead; National Aeronautics and Space
Administration, cooperating agency.

ABSTRACT: This Draft Environmental Assessment (EA) addresses the potential environmental
impacts of Houston Airport System?s (l-lAS?s) proposal to establish and operate a commercial
space launch site at the Ellington Airport (EFD), in Houston, Texas and offer the site to
prospective commercial space launch operators for the operation of horizontal takeoff and
horizontal landing Concept and Concept reusable launch vehicles (RLVs). To operate a
commercial space launch site, HAS must obtain a commercial space launch site operator license
from the FAA. Under the Proposed Action addressed in the Draft EA, the FAA would: (1) issue a
launch site operator license to HAS for the operation of a commercial space launch site at 
(2) issue launch licenses to, prospective commercial space launch operators that would ?allow
them to conduct launches of horizontal take?off and horizontal landing Concept and Concept
RLVs from EFD, and-(3) provide unconditional approval to the Airport Layout Plan (ALP)
modifications that reflect the designation of a spaceport boundary and construction of planned
spaceport facilities and infrastructure. Proposed launch operations would begin in 2015 and
continue through 2019 in accordance with the terms of the launch site operator license. HAS
proposes to provide RLV operators the ability to conduct up to 50 launches and landings '(or 100

operations) per year, with approximately five percent of the operations expected to occur during
night?time hours.

This Draft EA evaluates the potential direct, indirect, and cumulative environmental effects that
may result from the Proposed Action. The successful completion of the environmental review
process does not guarantee that the FAA would issue a launch site operator license to HAS or
launch licenses to RLV operators. Nor does completion of the NEPA process guarantee the FAA
would provide unconditional ALP approval. The project must also meet all FAA safety, risk, and
financial responsibility requirements per 14 Code of Federal Regulations (CFR) Part 400 and not

affect adversely the safety, utility, or efficiency of the airport per 49 United States Code (U.S.C.) 
47107(a)(16). -

PUBLIC REVIEW PROCESS: In accordance with the National Environmental Policy Act of 1969,
as amended 42 U.S.C. 4321, et seq.), Council on Environmental Quality NEPA
implementing regulations (40 CFR Parts 1500 to 1508), FAA Order 1050.1E, Environmental
Impacts: Policies and Procedures, Change 1, and FAA Order 5050. 4B, 'the FAA has initiated a
public review and comment period for this Draft EA. Interested parties are invited to submit
comments on the Draft EA, preferably in writing, on or before January 31, 2015, or 30 days from

the date of publication of the Notice of Availability in the Federal Register, whichever is later. An
electronic version of the Draft EA is available on theFAA website:

ua nepa_docs/ review
/documents_progress/.

An open house public meeting to receive comments on the Draft EA will be held on January 22,

2015, from 5:30 pm. to 8:30 pm. at Space Center Houston, Silvermoon Conference Room (lst
floor), 1601 NASA Parkway, Houston, TX.

CONTACT INFORMATION: To request?copies of or submit comments on the Draft EA, please
contact Mr. Daniel Czelusniak, Office of Commercial Space Transportation, Federal Aviation
Administration, 800 Independence Avenue, SW, Suite 325, Washington, DC 20591; email
or phone (202) 267?5924.

This environmental assessment becomes a Federal document when evaluated, signed, and
dated by the Responsible FAA Official. 

      

 



  

Issued in Washington DC on:

    

 

D/?f?ieorge 
?Associate Administrator for
Commercial'Space Transportation

TABLE OF CONTENTS

TABLE OF CONTENTS
Chapter 1 Introduction .................................................................................................................................................................. 1-1
1.1
1.1.1
1.2
1.2.1
1.2.2
1.2.3
1.3
1.4
1.4.1
1.4.2
1.5
1.5.1
1.5.2
1.6

Background ................................................................................................................................................................... 1-3
Houston Spaceport Proposal ............................................................................................................................ 1-3
FAA Roles ....................................................................................................................................................................... 1-7
FAA Licenses, Permits, and Approvals ........................................................................................................... 1-8
Airport Layout Plan................................................................................................................................................ 1-8
Letter of Agreement.............................................................................................................................................. 1-9
NEPA Process .............................................................................................................................................................. 1-10
Purpose and Need .................................................................................................................................................... 1-10
FAA’s Purpose and Need .................................................................................................................................. 1-10
Houston Airport System’s Purpose and Need.......................................................................................... 1-11
Agency and Public Involvement .......................................................................................................................... 1-12
Early Notification Letters ................................................................................................................................... 1-12
Draft EA Notification and Distribution......................................................................................................... 1-12
Other Environmental Requirements .................................................................................................................. 1-13

Chapter 2 Proposed Action and Alternatives ....................................................................................................................... 2-1
2.1
2.1.1
2.1.2
2.2
2.2.1
2.2.2

Proposed Action .......................................................................................................................................................... 2-3
Horizontal Take-off and Landing Vehicles ................................................................................................... 2-4
Construction of Spaceport Development................................................................................................... 2-12
Alternatives Considered ......................................................................................................................................... 2-16
No Action Alternative ......................................................................................................................................... 2-16
Alternatives Considered and Not Carried Forward For Further Analysis ....................................... 2-16

Chapter 3 Affected Environment ............................................................................................................................................... 3-1
3.1
3.1.1
3.2
3.3
3.4
3.4.1
3.5
3.6
3.7
3.8
3.8.1

Air Quality ...................................................................................................................................................................... 3-3
Air Quality Status ................................................................................................................................................... 3-3
Climate ............................................................................................................................................................................ 3-6
Coastal Resources ....................................................................................................................................................... 3-7
Compatible Land Use ................................................................................................................................................ 3-7
Existing Land Use ................................................................................................................................................. 3-11
Department of Transportation, Section 4(f) Properties ............................................................................. 3-11
Fish, Wildlife, and Plants ......................................................................................................................................... 3-12
Floodplains .................................................................................................................................................................. 3-23
Hazardous Materials, Pollution Prevention, and Solid Waste ................................................................. 3-23
Petroleum Fuels and Existing Fuel Farm ..................................................................................................... 3-27

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 TABLE OF CONTENTS
3.8.2
3.8.3
3.9
3.10
3.11
3.12
3.13

Other Hazardous Materials .............................................................................................................................. 3-27
Existing Contamination Concerns ................................................................................................................. 3-27
Historical, Architectural, Archaeological, and Cultural Resources ......................................................... 3-30
Light Emissions and Visual Resources .............................................................................................................. 3-32
Natural Resources and Energy Supply.............................................................................................................. 3-32
Noise .............................................................................................................................................................................. 3-32
Socioeconomics, Environmental Justice, and Children’s Health and Safety Risks........................... 3-33

3.13.1

Socioeconomics............................................................................................................................................... 3-33

3.13.2
3.13.3

Environmental Justice.................................................................................................................................... 3-35
Children’s Environmental Health and Safety Risks ............................................................................ 3-41

3.14

Water Quality .............................................................................................................................................................. 3-43

3.14.1
3.14.2
3.14.3
3.15

Surface Water ................................................................................................................................................... 3-43
Groundwater ..................................................................................................................................................... 3-43
Wastewater and Stormwater ...................................................................................................................... 3-43

Wetlands ....................................................................................................................................................................... 3-45

Chapter 4 Environmental Consequences ............................................................................................................................... 4-1
4.1
4.1.1
4.1.2
4.2
4.2.1
4.2.2
4.3
4.3.1
4.3.2
4.4
4.4.1
4.4.2
4.5
4.5.1
4.5.2
4.6
4.6.1
4.6.2
4.7
4.7.1

Air Quality ...................................................................................................................................................................... 4-4
Significance Thresholds ....................................................................................................................................... 4-4
Environmental Consequences........................................................................................................................... 4-4
Climate ............................................................................................................................................................................ 4-9
Significance Thresholds ....................................................................................................................................... 4-9
Environmental Consequences........................................................................................................................... 4-9
Coastal Resources ..................................................................................................................................................... 4-11
Significance Thresholds ..................................................................................................................................... 4-11
Environmental Consequences......................................................................................................................... 4-11
Compatible Land Use .............................................................................................................................................. 4-12
Significance Threshold ....................................................................................................................................... 4-12
Environmental Consequences......................................................................................................................... 4-13
Department of Transportation Act Section 4(f) Properties ...................................................................... 4-14
Significance Threshold ....................................................................................................................................... 4-14
Environmental Consequences......................................................................................................................... 4-14
Fish, Wildlife, and Plants ......................................................................................................................................... 4-15
Significance Threshold ....................................................................................................................................... 4-15
Environmental Consequences......................................................................................................................... 4-15
Floodplains .................................................................................................................................................................. 4-17
Significance Threshold ....................................................................................................................................... 4-17

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 TABLE OF CONTENTS
4.7.2
4.8

Environmental Consequences......................................................................................................................... 4-18
Hazardous Materials, Pollution Prevention, and Solid Waste ................................................................. 4-20

4.8.1
4.8.2
4.9

Significance Threshold ....................................................................................................................................... 4-20
Environmental Consequences......................................................................................................................... 4-21
Historic, Architectural, Archeological, and Cultural Resources ............................................................... 4-24

4.9.1
4.9.2
4.10

Significance Threshold ....................................................................................................................................... 4-24
Environmental Consequences......................................................................................................................... 4-24
Light Emissions and Visual Impacts ................................................................................................................... 4-25

4.10.1
4.10.2
4.11

Natural Resources and Energy Supply.............................................................................................................. 4-27

4.11.1
4.11.2
4.12

Significance Thresholds ................................................................................................................................ 4-33
Environmental Consequences.................................................................................................................... 4-34

Water Quality .............................................................................................................................................................. 4-35

4.15.1
4.15.2
4.16

Significance Threshold .................................................................................................................................. 4-32
Environmental Consequences.................................................................................................................... 4-32

Socioeconomic Impacts, Environmental Justice, and Children’s Health and Safety Risks ........... 4-33

4.14.1
4.14.2
4.15

Significance Threshold .................................................................................................................................. 4-28
Environmental Consequences.................................................................................................................... 4-29

Secondary (Induced) Impacts ............................................................................................................................... 4-30

4.13.1
4.13.2
4.14

Significance Threshold .................................................................................................................................. 4-27
Environmental Consequences.................................................................................................................... 4-27

Noise .............................................................................................................................................................................. 4-28

4.12.1
4.12.2
4.13

Significance Threshold .................................................................................................................................. 4-25
Environmental Consequences.................................................................................................................... 4-25

Significance Threshold .................................................................................................................................. 4-35
Environmental Consequences.................................................................................................................... 4-36

Wetlands ....................................................................................................................................................................... 4-37

4.16.1
4.16.2

Significance Threshold .................................................................................................................................. 4-37
Environmental Consequences.................................................................................................................... 4-38

Chapter 5 Cumulative Impacts ................................................................................................................................................... 5-1
5.1
5.2
5.3
5.4
5.5
5.5.1

Past Actions ................................................................................................................................................................... 5-3
Present Actions ............................................................................................................................................................ 5-4
Reasonably Foreseeable Actions........................................................................................................................... 5-4
Significance Thresholds ............................................................................................................................................ 5-5
Environmental Consequences ................................................................................................................................ 5-5
Proposed Action ..................................................................................................................................................... 5-5

Chapter 6 References ..................................................................................................................................................................... 6-1
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 TABLE OF CONTENTS
Chapter 7 List of Preparers .......................................................................................................................................................... 7-1
7.1
7.2
7.2.1
7.2.2
7.2.3
7.2.4
7.3
7.3.1

Lead Agency .................................................................................................................................................................. 7-3
Principal Preparers ...................................................................................................................................................... 7-3
HAS .............................................................................................................................................................................. 7-3
RS&H........................................................................................................................................................................... 7-3
Community Awareness Services ...................................................................................................................... 7-6
KB Environmental Sciences, Inc. ....................................................................................................................... 7-7
Cooperating Agency .................................................................................................................................................. 7-7
NASA ........................................................................................................................................................................... 7-7

Appendix A Early Notification…………………………………………………………………………......................................................A-1
Appendix A-1 Early Notification Letters………………………………………………………….................................................A-3
Appendix A-2 Agency Response Letters………………………………………………………................................................A-17
Appendix B Airspace and Airports............................................................................…………………………………………………B-1
Appendix C Final Air Quality Assessment Protocol............................................................................................................C-1
Appendix D Section 106 Coordination...................................................................................................................................D-1
Appendix E Summary of Noise Methodology......................................................................................................................E-1

LIST OF FIGURES
Figure 1-1 Location Map .............................................................................................................................................................. 1-5
Figure 2-1 Examples of Concept Vehicles ............................................................................................................................. 2-5
Figure 2-2 Proposed RLV Flight Path ...................................................................................................................................... 2-9
Figure 2-3 Proposed Development ........................................................................................................................................ 2-13
Figure 2-4 Houston Area Class B Airspace .......................................................................................................................... 2-19
Figure 2-5 HAS Airports’ Total Operations By Year ......................................................................................................... 2-20
Figure 3-1 Construction and Operation Regions of Influence ...................................................................................... 3-2
Figure 3-2 Coastal Boundary ...................................................................................................................................................... 3-8
Figure 3-3 Existing Land Use....................................................................................................................................................... 3-9
Figure 3-4 Parks Within the Construction ROI................................................................................................................... 3-13
Figure 3-5 Federally Designated Critical Habitat Areas ................................................................................................. 3-22
Figure 3-6 100-Year Floodplains ............................................................................................................................................. 3-24
Figure 3-7 USEPA Regulated Facilities .................................................................................................................................. 3-26
Figure 3-8 Potential Hazardous Material Locations at EFD .......................................................................................... 3-29
Figure 3-9 Area of Potential Effect (APE) ............................................................................................................................. 3-31
Figure 3-10 Existing DNL 65 – 75 dBA Noise Contours and EFD Tier Boundaries .............................................. 3-34
Figure 3-11 Percent Increase in Population (2010-2012) within the Construction ROI .................................... 3-35
Figure 3-12 Percent Increase in Population (2010-2012) within the Operation ROI .......................................... 3-35
Figure 3-13 Percentage of Individuals Below the Poverty Level within the
Construction ROI (2008-2012) ........................................................................................................................ 3-37

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 TABLE OF CONTENTS
Figure 3-14 Percentage of Individuals Below the Poverty Level within the
Operation ROI (2008-2012) .............................................................................................................................. 3-37
Figure 3-15 2012 Median Household Income ................................................................................................................... 3-38
Figure 3-16 Race and Ethnicity Characteristics within the Construction ROI ........................................................ 3-39
Figure 3-17 Race and Ethnicity ................................................................................................................................................ 3-40
Figure 3-18 Race and Ethnicity Characteristics within the Operation ROI ............................................................. 3-39
Figure 3-19 Percentage of Children (Under 18) within the Construction ROI ...................................................... 3-41
Figure 3-20 Schools Within the Construction ROI ........................................................................................................... 3-42
Figure 3-21 Percentage of Children (Under 18) within the Operation ROI ............................................................ 3-41
Figure 3-22 Stream Segments .................................................................................................................................................. 3-44
Figure 3-23 Wetlands .................................................................................................................................................................. 3-46
Figure 4-1 Proposed Development and 100-Year Floodplains................................................................................... 4-19
Figure 4-2 Concept X and Z Nominal Sonic Boom Contour ........................................................................................ 4-31

LIST OF TABLES
Table 2-1 Design Concept RLV Characteristics.................................................................................................................... 2-6
Table 2-2 Estimated Number of Launches Per Year ........................................................................................................ 2-12
Table 2-3 Maximum Quantities of Fuel/Oxidizer Stored On-Site for the Proposed Action ............................ 2-15
Table 3-1 Attainment Designations ......................................................................................................................................... 3-4
Table 3-2 Air Monitoring Data in the EFD Area (2011 – 2013)...................................................................................... 3-5
Table 3-3 HAS Land Use Compatibility Matrix .................................................................................................................. 3-10
Table 3-4 Public Parks within the Operation ROI ............................................................................................................. 3-14
Table 3-5 Federally Listed Threatened and Endangered Species in Brazoria,
Galveston, and Harris Counties ........................................................................................................................... 3-19
Table 3-6 Texas Parks and Wildlife Department’s Listed Species in Brazoria,
Galveston, and Harris Counties ........................................................................................................................... 3-19
Table 3-7 2013 Poverty Guidelines......................................................................................................................................... 3-36
Table 4-1 Construction Emissions Inventory Summary.................................................................................................... 4-6
Table 4-2 Operational Cap Emissions Inventory Summary ............................................................................................ 4-8
Table 4-3 Operational HAP Emissions Inventory Summary ........................................................................................... 4-8
Table 4-4 General Conformity Applicability.......................................................................................................................... 4-8
Table 4-5 Operational GHG Emissions Inventory Summary ......................................................................................... 4-11
Table 4-6 Project Specific Stormwater Runoff Increases ............................................................................................... 4-18
Table 4-7 Maximum Quantity of Fuel/Oxidizer Stored On-Site ................................................................................. 4-23

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vi

 ACRONYMS AND ABBREVIATIONS
A

C Continued

AAIA

Airport and Airway
Improvement Act

ABS

Acrylonitrile Butadiene Styrene

AC

Advisory Circular

ACHP

Advisory Council on Historic
Preservation

AHPA

Archeological and Historic
Preservation Act

AIRFA

American Indian Religious
Freedom Act

ALP

Airport Layout Plan

APCP

Ammonium Perchlorate
Composite Propellants

ASNA

Aviation Safety and Noise
Abatement Act

CERCLA

Comprehensive Environmental
Response, Compensation, and
Liability Act

CFR

Code of Federal Regulations

CMP

Coastal Management Program

CNRA

Coastal Natural Resource Areas

CO

Carbon Monoxide

CWA

Clean Water Act

CZMP

Coastal Zone Management
Program

D
dB

Decibel

dBA

A-weighted decibel

DHHS

Department of Health and
Human Services

ATC

Air Traffic Control

ATCT

Airport Traffic Control Tower

DL

Federally Delisted Species

ATO

Air Traffic Organization

DNL

Day Night Average Sound Level

AZA

Airport Zoning Action

DoD

Department of Defense

DOI

Department of the Interior

B
BMP

Best Management Practice

C
C

Federal Candidate Species for
Listing

E
E

State Listed Endangered Species

EA

Environmental Assessment

Ec

Expected Casualty

CBRA

Coastal Barrier Resources Act

EFD

Ellington Airport

CBRS

Coastal Barrier Resource
Systems

EIS

Environmental Impact
Statement

CCA

Coastal Coordination Act

EO

Executive Order

CEQ

Council on Environmental
Quality

ESA

Endangered Species Act

CAP

Criteria Air Pollutant

Houston Spaceport Environmental Assessment – Draft

vii

 ACRONYMS AND ABBREVIATIONS
F

I Continued

FAA

Federal Aviation Administration

ILD

Intraline Distance

FAA-ARP

FAA Office of Airports

INM

Integrated Nosie Model

FAR

Federal Aviation Regulations

L

FEMA

Federal Emergency
Management Agency

lbs

Pounds

FHWA

Federal Highway Administration

LE

Federally Listed Endangered
Species

FIRM

Floodplain Insurance Rate Map

LOA

Letter of Agreement

FONSI

Finding of No Significant Impact

LOX

Liquid Oxygen

FPPA

Farmland Protection Policy Act

LT

FR

Federal Register

Federally Listed Threatened
Species

FTA

Federal Transit Administration

LWCA

FWCA

Fish and Wildlife Coordination
Act

Land and Water Conservation
Fund Act

M

G
GCP

General Construction Permit

GLO

General Land Office

GO

Generation Orbit

H
H2O2

Hydrogen Peroxide

HAS

Houston Airport System

H-GAC

Houston-Galveston Area Council

HGB

Houston-Galveston-Brazoria

HOU

William P. Hobby Airport

HTPB

Hydroxyl-terminated
Polybutadiene

I

MALSR

Medium Intensity Approach
Lighting System with Runway
Alignment Indicator Lights

MBTA

Migratory Bird Treaty Act

MOA

Memorandum of Agreement

MSGP

Multi-Sector General Permit

MSL

Mean Sea Level

N
N2O

Nitrous Oxide

NAAQS

National Ambient Air Quality
Standards

NASA

National Aeronautics and Space
Administration

NEPA

National Environmental Policy
Act

IAH

George Bush Intercontinental
Airport

NHD

National Hydrography Dataset

IBD

Inhabited Building Distance

NHPA

National Historic

IFR

Instrument Flight Rules

Houston Spaceport Environmental Assessment – Draft

Preservation Act
NL

Not Federally Listed Species
viii

 ACRONYMS AND ABBREVIATIONS
N Continued

ROA

NMFS

National Marine Fisheries
Service

NO2

Nitrogen Dioxide

NOAA

National Oceanic and
Atmospheric Administration

NOI

Notice of Intent

NOTAM

Notice to Airmen

NPL

National Priorities List

NPS

National Park Service

NRCS

Natural Resource Conservation
Service

NRHP

National Register of Historic
Places

NRI

Nationwide Rivers Inventory

NWI

National Wetlands Inventory

O
O3

Ozone

OLA

Oxidizer Loading Area

OPA

Oil Pollution Act

P

Runway Operating Area

R Continued
ROD

Record of Decision

S
SAGA

Sustainable Aviation Guidance
Alliance

SDWA

Safe Drinking Water Act

SHPO

State Historic Preservation
Officer

SIC

Standard Industrial Classification

SIP

State Implementation Plan

SO2

Sulfur Dioxide

SOP

Standard Operating Procedure

SPCC

Spill Prevention Control and
Countermeasures

SWPPP

Stormwater Pollution Prevention
Plan

T
T

State Listed Threatened Species

TAF

Terminal Area Forecast

TCEQ

Texas Commission on
Environmental Quality

Pb

Lead

PCB

Polychlorinated Biphenyl

TCP

Traditional Cultural Properties

PIC

Pilot-in-Command

TFR

Temporary Flight Restriction

PM

Particulate Matter

THC

Texas Historical Commission

PTRD

Public Traffic Route Distance

THPO

Tribal Historic Preservation
Officer

TMDL

Total Maximum Daily Load

R
R

Rare Species, but no Regulatory
Listing Status

TPDES

Texas Pollutant Discharge
Elimination System

RCRA

Resource Conservation and
Recovery Act

TPWD

Texas Parks and Wildlife
Department

RLV

Reusable Launch Vehicle

Houston Spaceport Environmental Assessment – Draft

ix

 ACRONYMS AND ABBREVIATIONS
TRACON

Terminal Radar Approach
Control

TSCA

Toxic Substance Control Act

T Continued
TX

Texas

TxANG

Texas Air National Guard

TxARNG

Texas Army National Guard

U
USACE

United State Army Corps of
Engineers

U.S.C.

United States Code

USCG

United States Coast Guard

USDOT

United States Department of
Transportation

USEPA

United States Environmental
Protection Agency

USFWS

United States Fish and Wildlife
Service

V
VALE

Voluntary Airport Low Emission

VFR

Visual Flight Rules

VOC

Volatile Organic Compound

W
WSRA

Wild and Scenic Rivers Act

Z
ZHU ARTCC

Houston Air Route Traffic
Control Center

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INTRODUCTION

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1-2

 INTRODUCTION
As an introduction to this Environmental Assessment (EA) for a proposed commercial space launch site at
Ellington Airport (EFD), this chapter provides background information about commercial space
transportation, the role of the Federal Aviation Administration (FAA) in supporting commercial space
flight, and the Houston Airport System (HAS) proposal to establish a commercial space launch site at EFD.
In addition, this chapter describes the process that the FAA and HAS must follow in licensing, developing,
and operating a commercial space launch site. The chapter concludes with the statement of purpose and
need for the federal actions required as part of the National Environmental Policy Act (NEPA) process.

1.1 BACKGROUND
The space launch environment is evolving from medium- and heavy-lift orbital launches to the use of
small commercial orbital and suborbital launches. The shift to smaller launches is largely due to the
development of smaller satellites, an emerging suborbital space tourism market, and a national security
environment demanding quick launch capability. Privatization, increased efficiency, and lower cost also
contribute to the economic pressures driving a marketplace favoring the creation of commercial space
launch sites.
The changing nature of space transportation is leading to the interest in small, responsive, commercially
focused vehicles as low-cost solutions for private and government clients. An FAA launch site operator
license would enable HAS to offer EFD as a site for commercial space launch vehicle operators to conduct
horizontal take-off and horizontal landing of reusable launch vehicles (RLVs). This would help establish the
State of Texas as a national and international node for commercial space transportation.
Private companies are interested in operating at non-federal launch sites because of the potential to be
“bumped” by a higher priority federal launch at a federally controlled site. Title 10, Chapter 135 of the
United States Code (U.S.C.), states it is the policy of the United States for the President to undertake
actions appropriate to ensure, to the maximum extent practicable, that the United States has the
capabilities necessary to launch and insert United States national security payloads into space whenever
such payloads are needed (10 U.S.C. § 2273). Additionally, the 1997 Memorandum of Agreement (MOA)
among the Department of Defense, FAA, and the National Aeronautics and Space Administration (NASA)
on Federal Interaction with Launch Site Operators states that critical national security or civil sector
mission requirements may take precedence over commercial use of federal launch property and launch
services.

1.1.1

Houston Spaceport Proposal

HAS proposes to operate a commercial space launch site at EFD, also referred to as the Houston
Spaceport, and offer the site to commercial space launch operators for the operation of horizontal takeoff and horizontal landing RLVs. To operate a commercial space launch site, HAS must obtain a launch site
operator license from the FAA. HAS is in the process of developing an application for a launch site
operator license for the operation of a commercial space launch site at EFD. The process includes an
update to the Airport Layout Plan (ALP).
Under the Proposed Action addressed in this EA, the FAA would: (1) issue a launch site operator license to
HAS for the operation of a commercial space launch site at EFD, (2) issue launch licenses to prospective
operators that would allow them to conduct launches of horizontal take-off and horizontal landing RLVs
Houston Spaceport Environmental Assessment – Draft

1-3

 INTRODUCTION
from EFD, and (3) provide unconditional approval to the ALP modifications that reflect the designation of
a spaceport boundary (i.e., Airport property boundary) and existing and planned spaceport facilities and
infrastructure. As explained in Section 1.2, the Proposed Action is subject to environmental review under
the National Environmental Policy Act (NEPA) of 1969 as amended (42 United States Code [U.S.C.] §4321,
et seq.).
EFD is one of three airports HAS operates and is located in Harris County, in the southeastern portion of
the City of Houston. EFD is approximately 20 miles southeast of the center of downtown Houston, 10
miles north of Galveston Bay, and 30 miles north of the Gulf of Mexico (see Figure 1-1). Major roadways
around EFD include Interstate 45, the Sam Houston Tollway, and State Highway 3 (Old Galveston Road).
Union Pacific Railroad tracks parallel Highway 3 along the southwest boundary of EFD. The proposed
Houston Spaceport is approximately 8 miles southeast of William P. Hobby Airport (HOU).
1.1.1.1 Existing Facilities
EFD has approximately 2,600 acres of land. There are currently three active runways, eight active taxiways,
and one active taxilane. Runway 17R-35L is 9,001 feet (ft) long by 150 ft wide. Runway 17L-35R, the
shortest runway, is 4,609 ft long by 75 ft wide. Runway 4-22, the crosswind runway, is 8,001 ft long by 150
ft wide. The crosswind runway is not certified under Federal Aviation Regulations (FAR) Part 139 for
commercial use.
EFD is classified by the FAA as a commercial primary small-hub airport and is currently certified for 14 CFR
Part 139 operations. Under Part 139, the FAA issues airport operating certificates to airports that:

»
»
»

serve scheduled and unscheduled air carrier aircraft with more than 30 seats;
serve scheduled air carrier operations in aircraft with more than 9 seats but less than 31 seats; and
the FAA Administrator requires a certificate of operations (FAA, 2013a).

There are also a series of service roads around the airfield currently used for airport maintenance and
service operations. The primary uses of these roads include accessing navigational aid equipment,
performing ground maintenance operations, performing perimeter fence inspections, and maintaining
airfield security. The roads are approximately 10-12 ft wide and made of asphalt. There are also service
roads along the east and west edges of the general aviation parking apron.
Current tenants at EFD include three military units, NASA, and a Fixed Base Operator. The three military
tenants are the Texas Air National Guard (TxANG), the Texas Army National Guard (TxARNG), and the U.S.
Coast Guard (USCG). These three tenants and NASA own land within EFD. They are not bound by any
lease agreement and the City of Houston maintains a Joint Use Agreement with these tenants. There are
also several unused buildings on EFD property, which could be repurposed for new tenants.
EFD currently supports a mix of aircraft operations. A yearly average total of 146,472 operations occurred
at EFD between 2009 and 2013 (FAA, 2013b). Of the 146,472 operations, an average of 89,442 operations
(61%) were performed by general aviation aircraft, and an average of 47,801 operations (33%) were
conducted by the military (FAA, 2013b). Air taxis and air carriers conducted an average of 1,753 (1%) and
7,475 (5%) of the total operations, respectively (FAA, 2013b).

Houston Spaceport Environmental Assessment – Draft

1-4

 INTRODUCTION

 

 

 

 

 

 

 

   

 

 

 

 

 

 

 

 

 

 

 

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Houston Spaceport Environmental Assessment Draft 1-5

INTRODUCTION
There is a large amount of undeveloped land around the EFD airfield. The developable portion of the
north airside area, approximately 50 acres, is primarily vacant. The western area of EFD has approximately
80 acres available for airside development and approximately 100 acres for non-airside development.1
Development options include light industrial, corporate hangars, and most non-residential land uses.
There are approximately 440 acres of EFD property in the southeast available for either airside or nonairside development.
1.1.1.2 Potential for Spaceport Development
A Spaceport Feasibility Study was completed in February 2012 for HAS (RS&H, 2012). The purpose of the
study was to evaluate the potential for EFD to support spaceport operations in the Houston area. The
decision to evaluate EFD was based on a number of factors, including:

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existing runway lengths;
proximity to Johnson Space Center and other NASA training facilities;
proximity to the Gulf of Mexico; and
compatibility with existing aircraft operations.

The feasibility study identified the goals and objectives of a proposed spaceport. EFD was evaluated for
compatibility with federal regulations in achieving those goals. The feasibility study included an
infrastructure inventory and preliminary analysis based on various factors, including a preliminary
environmental overview. The feasibility study concluded that EFD could support spaceport operations.
The proposed Houston Spaceport would commence operations in early 2015, and operations would
continue through 2019, in accordance with the terms of the launch site operator license. HAS proposes to
provide RLV operators the ability to conduct up to 50 launches and landings (or 100 operations) per year,
which is substantially less than the 144,702 annual aircraft operations EFD currently experiences
(FAA, 2013b). However, based on the current design and development of RLVs, approximately 35 launches
and landings are anticipated in 2019. For a conservative analysis, this EA assesses up to 50 launches and
landings in 2019, with approximately five percent of the operations expected to occur during night-time
hours.
Two types of horizontal RLVs are being considered to operate at the Houston Spaceport: the Concept X
RLV and the Concept Z RLV. The Concept X RLV would take off under conventional jet engine power and
make either a powered or unpowered (glide) landing. The Concept Z RLV is a two-part vehicle, including a
carrier vehicle and an attached RLV that would separate at an altitude approximately 40,000 ft above
mean sea level (MSL). The Concept Z RLV would land gliding. Unlike vertical launch vehicles, the operation
of these RLVs would be similar to the operation of commercial jet aircraft. These vehicles would use
common fuels and oxidizers for propulsion such as conventional Jet-A fuel, liquid oxygen (LOX), and

1

Airside development – Areas of land on airport property with the potential for future development and provides direct access to

the airfield system (i.e., aprons, taxiways, runways).
Non-airside development – Areas of land on airport property with the potential for future development that do not provide access
to the airfield system.

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1-6

 INTRODUCTION
refined kerosene. The designation of vehicle safety areas and established operating procedures would
help to ensure the safety of the uninvolved areas surrounding EFD.2

1.2 FAA ROLES
Upon approval of the Proposed Action, the FAA would be responsible for issuing licenses to operate a
commercial space launch site at EFD and for the issuing of licenses for the operation of commercial space
launch vehicles. Since HAS plans to develop facilities to accommodate RLVs at the Houston Spaceport, the
FAA would also be responsible for approving changes to the EFD ALP showing these proposed facilities.
The FAA’s issuance these licenses and its approval of changes to an ALP are considered major federal
actions under NEPA. Therefore, the FAA is responsible for analyzing the potential environmental impacts
associated with each aspect of the Proposed Action. As these are connected actions, the potential
environmental impacts of both the licensing and the ALP approval are analyzed in this EA. The FAA is the
lead Federal agency and is preparing this EA in accordance with NEPA, Council on Environmental Quality
(CEQ) Regulations for Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations
[CFR] Parts 1500-1508), FAA Order 1050.1E, Change 1, Environmental Impacts: Policies and Procedures,
and FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions for Airport
Actions.
The FAA licenses and regulates U.S. commercial space launch and reentry activity, as well as the operation
of non-federal launch and reentry sites, as authorized by Executive Order (EO) 12465, Commercial
Expendable Launch Vehicle Activities, and the Commercial Space Launch Act of 2011 (51 U.S.C. Subtitle V,
ch. 509, §§ 50901-50923). The FAA’s mission is to ensure public health and safety and the safety of
property while protecting the national security and foreign policy interests of the U.S. during commercial
launch and reentry operations. In addition, the FAA is directed to encourage, facilitate, and promote
commercial space launches and reentries.
The FAA has the responsibility, under the Commercial Space Launch Act, to do the following:

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Promote economic growth and entrepreneurial activity through use of the space environment for
peaceful purposes.

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Encourage the U.S. private sector to provide launch vehicles, reentry vehicles, and associated
services by:
o simplifying and expediting the issuance and transfer of commercial licenses, and
o facilitating and encouraging the use of government-developed space technology.

2

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Ensure that the Secretary of Transportation provides oversight and coordinates the conduct of
commercial launch and reentry operations, issue and transfer commercial licenses authorizing
those operations, and protect the public health and safety, safety of property, and national
security and foreign policy interests of the U.S.

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Facilitate the strengthening and expansion of the U.S. space transportation infrastructure,
including the enhancement of U.S. launch sites and launch-site support facilities, and

These would be operator dependent and would be included in the RLV operator license.

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 INTRODUCTION
development of reentry sites, with federal, state, and private sector involvement, to support the
full range of U.S. space-related activities.

1.2.1

FAA Licenses, Permits, and Approvals

A license to operate a launch site authorizes a licensee to offer its launch site to a launch operator for
each launch point, launch vehicle type, and weight class identified in the license application and upon
which the licensing determination is based. Issuance of a license to operate a launch site does not relieve
a licensee of its obligation to comply with any other laws or regulations, nor does it confer any
proprietary, property, or exclusive rights in the use of airspace or outer space (14 CFR §420.41). A launch
site operator license remains in effect for five years from the date of issuance unless surrendered,
suspended, or revoked before the expiration of the term and is renewable upon application by the
licensee (14 CFR §420.43).
The FAA issues separate licenses for operation of launch vehicles. Therefore, prospective vehicle operators
(e.g., Rocket Crafters) would need to obtain individual launch licenses from the FAA before launching from
EFD.
The FAA issues launch licenses for the operation of RLVs (14 CFR Part 431). A launch license for a RLV is
valid for a two-year renewable term and authorizes a licensee to launch and reenter, or otherwise land,
any of a designated family of RLVs within authorized parameters, including launch sites and trajectories,
transporting specified classes of payloads to any reentry site or other location designated in the license. A
licensee can renew its license by submitting an application to the FAA at least 90 days before the license
expires. An RLV mission-specific license authorizes a licensee to launch and reenter, or otherwise land, one
model or type of RLV from a launch site approved for the mission to a reentry site or other location
approved for the mission. A RLV mission-specific license expires upon completion of all activities
authorized by the license or the expiration date stated in the reentry license, whichever occurs first.
The following describes the launch licenses that could be obtained by operators:

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RLV Mission Operator License – “[A]uthorizes a licensee to launch and reenter, or otherwise land,
any of a designated family of RLVs within authorized parameters” (14 CFR § 431.3(b)).

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RLV Mission-Specific License – “[A]uthorizes a licensee to launch and reenter, or otherwise land,
one model or type of RLV from a launch site approved for the mission to a reentry site or other
location approved for the mission” (14 CFR §431.3(a)).

1.2.2

Airport Layout Plan

The Airport and Airway Improvement Act of 1982 directs the Secretary of Transportation to maintain a
plan (i.e., an ALP) for developing public use airports (49 U.S.C. Chapter 471). An ALP is an FAA-approved
plan that depicts both existing facilities and planned development for an airport and is required by statute
to be up-to-date [49 U.S.C. § 47107(a)(16)]. The ALP must depict the following:

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boundaries and proposed additions to all areas owned or controlled by the sponsor for airport
purposes;

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location and nature of existing and proposed airport facilities and structures; and

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 INTRODUCTION

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location on the airport of existing and proposed non-aviation areas and improvements.

Therefore, the improvements, as part of the Houston Spaceport, are required to be shown on the EFD ALP
(FAA, 2013c). Under the Proposed Action, the EFD ALP modifications reflect the following actions (see
Chapter 2 for further details):

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designation of the spaceport boundary;
construction of a hangar/processing facility;
construction of a connector taxiway;
designation of an oxidizer loading area:
construction of an oxidizer storage tank pad;
construction of a RP-1 truck parking area;
construction of a vehicle parking area;
construction of an access road;
construction of FAA-approved fencing; and
construction of a storm water treatment pond.

In approving changes to an ALP, the FAA Office of Airports reviews proposed development to:

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assess operational factors affecting the safe and efficient control of air traffic;

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review and approve construction plans and specification; and

establish conformance with FAA airport design criteria, federal regulations, and federal grant
agreements (CFR Parts 77, 139, 150, 152, 157, and 169);
review and approve an amended Airport Certification Manual (Part 139).

As part of the ALP review process, the Office of Airports initiates coordination of airspace studies with the
FAA Air Traffic Organization (ATO); circulates the ALP to other FAA offices and divisions for review and
comment; and coordinates with the airport sponsor to resolve outstanding issues. Following the
resolution of any outstanding issues, the Office of Airports may conditionally approve the ALP pending
completion of NEPA review. The FAA Southwest Region/Texas Airport District Office has approval
authority for the updates to the EFD ALP.
A federal action for this EA is to provide unconditional approval to the ALP modifications that reflect the
designation of a spaceport boundary and existing and planned spaceport facilities and infrastructure, as
listed above and further described in Chapter 2 of this EA.

1.2.3

Letter of Agreement

As part of the launch site operator license application process, HAS will have to negotiate and enter into a
Letter of Agreement (LOA) with all relevant Air Traffic Control facilities to accommodate the flight
parameters of the RLVs. Coordination with the FAA Office of Air Traffic would result in the identification of
a flight corridor such that a Temporary Flight Restriction (TFR) would be put into place in the RLV
operating area when flights occur. The RLV operating area would be defined in cooperation with the FAA

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 INTRODUCTION
Office of Commercial Space Transportation, the FAA ATO, affected military air traffic control agencies, and
airspace users such as airlines, private pilots, and off-shore helicopter transportation routes (i.e., the
transportation of oil rig personnel).

1.3 NEPA PROCESS
The purpose of a NEPA analysis is to ensure full disclosure and consideration of environmental
information in federal agency decision-making. NEPA also serves as a way to inform the public of
potential impacts of, and alternatives to, a proposed federal action before decisions are made and actions
are taken. As noted above, FAA licensing and ALP approval are federal actions requiring NEPA review and
approval. In the NEPA process, the FAA must analyze the potential environmental impacts associated with
the issuance of licenses (including the LOA, construction of spaceport development, and RLV operations)
and ALP approval. The FAA is the lead federal agency for this NEPA process.
The FAA invited NASA to participate in this NEPA process as a Cooperating Agency.3 NASA agreed to
participate as a Cooperating Agency and provided technical review and input for this EA.
This EA is being conducted in accordance with the following regulations and orders:

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Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of
NEPA (40 CFR Parts 1500-1508),

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FAA Order 1050.1E, Change 1, Environmental Impacts: Policies and Procedures, and
FAA Order 5050.4B, NEPA Implementing Instructions for Airport Actions.

This EA evaluates the potential direct, indirect, and cumulative environmental effects that may result from
the Proposed Action described in Chapter 2. The successful completion of the environmental review
process does not guarantee that the FAA would issue a launch site operator license to HAS or launch
licenses to RLV operators. The project must also meet all FAA safety, risk, and financial responsibility
requirements per 14 CFR Part 400 and not affect adversely the safety, utility, or efficiency of the airport
per 49 USC § 47107(a)(16).

1.4 PURPOSE AND NEED
The purpose and need provides the foundation for identifying reasonable alternatives to a Proposed
Action. According to FAA Order 1050.1E, Change 1, Paragraph 405(c), the purpose and need identifies the
problem facing the proponent (i.e., the “need” for the action), the proposed solution to the problem (i.e.,
the “purpose” of the action), and the proposed timeframe for implementing the action.

1.4.1

FAA’s Purpose and Need

The need for the FAA action of issuing a launch site operator license and launch licenses results from the
statutory direction from Congress under the Commercial Space Launch Act to protect the public health
and safety, safety of property, and national security and foreign policy interests of the U.S. and to

A Cooperating Agency is an agency that has jurisdiction by law or special expertise regarding any environmental impact resulting
from a proposed action or reasonable alternative.
3

Houston Spaceport Environmental Assessment – Draft

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 INTRODUCTION
encourage, facilitate, and promote commercial space launch and reentry activities by the private sector in
order to strengthen and expand U.S. space transportation infrastructure.
The purpose of the FAA action in connection with HAS’s proposal is to fulfill the FAA’s responsibilities
under the Commercial Space Launch Act, 51 U.S.C. Subtitle V, Ch. 509 §§ 50901-50923, for oversight of
commercial space launch activities, including issuing launch site operator licenses for the operation of
commercial space launch sites, and launch licenses to operate reusable orbital and suborbital launch
vehicles. The Proposed Action would be consistent with the objectives of the Commercial Space Launch
Act.
Additionally, the purpose and need of the FAA action, in connection with HAS’s request, is to ensure the
proposed alterations at EFD do not adversely affect the safety, utility, or efficiency of EFD. Pursuant to 49
U.S.C. § 47107(a)(16), the FAA Administrator (under authority delegated from the Secretary of
Transportation) must approve any revision or modification to an ALP before the revision or modification
takes effect. The Administrator’s approval reflects a determination that the proposed alterations to the
airport, reflected in the ALP revision or modification, do not adversely affect the safety, utility, or efficiency
of the airport.

1.4.2

Houston Airport System’s Purpose and Need

HAS’s need for the proposed commercial space launch site is to further the City’s goals to grow economic
activity within the City and support economic activity in the region. HAS’s mission statement is to connect
people, businesses, cultures, and economies of the world to Houston. The City of Houston Economic
Development Division promotes diversifying the local economy and enhancing the region as a business
and employment center. The City’s strategy is to provide development areas that attract and
accommodate the needs of new businesses. To be successful as a commercial space launch site, the area
should have characteristics that would accommodate horizontal take-off and horizontal landing RLVs at a
HAS airport. These characteristics include:

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location within the Houston Airspace System;
location in an area with a comparatively low population density;
a runway with minimum length of 8,000 ft;4
a minimum of 45,000 square ft of hangar space;5 and
extensive airspace separation distances from other aircraft operating in the Houston area
airspace.

The purpose of HAS’s proposal to establish a commercial space launch site at EFD is to help the City
achieve its economic goals. Establishing a launch site at EFD would enable a HAS airport to serve as an
alternative to a federal launch facility or other commercial launch sites for the operation of horizontallylaunched and horizontally-landed Concept X and Z launch vehicles. HAS proposes that launch operations
would begin in 2015 and continue through 2019.

4
5

Length was determined as a result of recent communications with RLV operators.
Area was determined as a result of recent communications with RLV operators.

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 INTRODUCTION

1.5 AGENCY AND PUBLIC INVOLVEMENT
Agency consultation and coordination was conducted to obtain meaningful input regarding the Proposed
Action and potential for environmental impacts. Additionally, this Draft EA is being published for agency
and public review and comment.

1.5.1

Early Notification Letters

An early notification letter was distributed to various federal, state, and local agencies on October 11,
2013 announcing HAS’s Proposed Action to obtain a launch site operator license. The early notification
letter was initiated to:

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provide information about the Proposed Action;
obtain feedback from the federal, state, and local agencies;
inform those agencies who may be interested and potentially affected; and
provide the opportunity for early comments.

See Appendix A-1 for the early notification letter and list of agencies contacted. Over 100 various federal,
state, and local agencies, federally recognized Native American Tribes, and EFD tenants have been
contacted regarding the preparation of this EA. During the early agency consultation process, the
following agencies and tenants provided comments:

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NASA
USCG
National Park Service (NPS)
United States Fish and Wildlife Service (USFWS)
Federal Emergency Management Agency (FEMA)
Texas Historical Commission (THC)
TxANG
Texas Commission on Environmental Quality (TCEQ)
Texas Parks and Wildlife
Harris County Public Health and Environmental Services
Flying Tigers (EFD tenant)

See Appendix A-2 for response letters received from agencies.

1.5.2

Draft EA Notification and Distribution

In accordance with NEPA, CEQ Regulations, FAA Order 1050.1E, Change 1, and FAA Order 5050.4B, the
FAA has initiated a public review and comment period for this Draft EA. Interested parties are invited to
submit comments on the Draft EA, preferably in writing, on or before January 31, 2015, or 30 days from
the date of publication of the Notice of Availability in the Federal Register (FR), whichever is later. An
electronic version of the Draft EA is available on the FAA website.6
6

http://www.faa.gov/about/office_org/headquarters_offices/ast/environmental/nepa_docs/review/documents_progress/

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1-12

 INTRODUCTION

The FAA will hold a public meeting to solicit comments from the public concerning the scope and content
of the Draft EA. Comments or questions on the Draft EA can be addressed to Mr. Daniel Czelusniak, Office
of Commercial Space Transportation, Federal Aviation Administration, 800 Independence Avenue, SW,
Suite 325, Washington, DC 20591 or submitted by email to houstonspaceportEA@houstontx.gov. The FAA
invites interested agencies, organizations, Native American tribes, and members of the public to submit
comments on all aspects of this Draft EA. The FAA will consider all comments on this Draft EA in preparing
a Final EA. To facilitate FAA consideration and response to comments, it is critical that comments be as
specific as possible and clearly state concerns or recommendations related to the issues addressed in this
Draft EA.

1.6 OTHER ENVIRONMENTAL REQUIREMENTS
In addition to NEPA, this EA addresses the following relevant special purpose laws, including:

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Endangered Species Act of 1973 (threatened or endangered species and critical habitat)
EO 11988 (floodplains)
EO 11990 (wetlands)
Title 36 CFR Part 800 (historic properties)
U.S. Department of Transportation (USDOT) Act Section 4(f) (recreation areas and historic sites)

Other laws, regulations, permits, and licenses may be applicable to the proposed construction, operation,
and maintenance of facilities and infrastructure of a commercial space launch site at EFD. Additional
environmental requirements may include the following:

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City of Houston Building Permit;
TCEQ General Construction Permit (GCP) TXR150000;
Texas Pollutant Discharge Elimination System (TPDES) Permit; and
National Pollutant Discharge Elimination System (NPDES) Permit.

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 PROPOSED ACTION AND ALTERNATIVES

CHAPTER 2

PROPOSED ACTION AND ALTERNATIVES

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 PROPOSED ACTION AND ALTERNATIVES

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2-2

 PROPOSED ACTION AND ALTERNATIVES
This chapter describes the Proposed Action’s development and operational characteristics and the
consideration and evaluation of reasonable alternatives to the Proposed Action.

2.1 PROPOSED ACTION
HAS proposes to operate a commercial launch site at EFD in Harris County, Texas and offer the site to
commercial space launch operators for the operation of horizontal take-off and horizontal landing RLVs.
To be successful as a commercial space launch site, the area must meet the technical and operational
requirements to accommodate horizontal take-off and horizontal landing RLVs. These requirements
include: location within the HAS; location in an area of comparatively low population density in order to
comply with 14 CFR Part 420; a runway with minimum length of 8,000 ft; a minimum of 45,000 square ft of
hangar space; and extensive airspace separation distances from other aircraft operating in the Houston
area airspace. HAS proposes to provide RLV operators the ability to begin launch operations in 2015 and
continue through 2019.
To operate a commercial space launch site, HAS must obtain a launch site operator license from the FAA.
Under the Proposed Action addressed in this EA, the FAA would: (1) issue a launch site operator license to
HAS for the operation of a commercial space launch site at EFD, (2) issue launch licenses to prospective
operators that would allow them to conduct launches of horizontal take-off and horizontal landing RLVs
from EFD, and (3) provide unconditional approval to the ALP modifications that reflect the designation of
a spaceport boundary and existing and planned spaceport facilities and infrastructure. Under the modified
ALP, the spaceport boundary would be coterminous with the airport property boundary.
As noted in Section 1.2.3, as part of the launch site operator license application process, HAS will have to
negotiate and enter into an LOA with all relevant Air Traffic Control facilities to accommodate the flight
parameters of the RLVs. In order to accommodate the potential operations, airspace around Houston was
examined by representatives from Houston Air Route Traffic Control Center (ZHU ARTCC), I90 Terminal
Radar Approach Control (I90 TRACON), FAA ATO Central Service Center, HAS, and the FAA early in the
spaceport licensing process. The Proposed Action includes a draft route and procedures to allow for RLVs
to safely operate in and out of the Houston Spaceport without adversely affecting urban areas, existing
airspace conditions, or the neighboring public-use airports. This information is described within a draft
LOA, as required by 14 CFR Part 420.31(b). A final LOA would be negotiated by an actual operator during
the application process for a launch license, using the precise flight parameters of the subject vehicle.
These procedures would be fully developed prior to RLV operations occurring in and out of EFD. The draft
LOA calls for Air Traffic Control to issue a Notice to Airmen (NOTAM) defining the affected airspace and to
issue a TFR for the affected area. A NOTAM provides notice of unanticipated or temporary changes to
components of, or hazards in, the National Airspace System (FAA Order JO 7930.2M, Air Traffic
Organization Policy).
Coordination with the FAA Office of Air Traffic would result in the identification of a flight corridor such
that a TFR would be put into place in the RLV operating area when flights occur. The extent of the TFR will
be determined in cooperation with the vehicle operator when the final LOA is negotiated. The RLV
operating area would be defined in cooperation with the FAA Office of Commercial Space Transportation,

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 PROPOSED ACTION AND ALTERNATIVES
the FAA ATO, affected military air traffic control agencies, and airspace users such as airlines, private
pilots, and off-shore helicopter transportation routes (i.e., the transportation of oil rig personnel).
The FAA would not alter the dimensions (shape and altitude) of the airspace. However, temporary closures
of existing airspace may be necessary to ensure public safety during the proposed operations. Advance
notice via NOTAMs would assist general aviation pilots in scheduling around any temporary disruption of
flight activity at EFD. Launches would be infrequent (less than 1 percent of the total operations occurring
at EFD), of short duration, and scheduled well in advance to minimize interruption of airport operations.
For the above reasons, environmental impacts from the temporary closure of airspace and the issuance of
NOTAMs and TFRs under the Proposed Action are not anticipated and thus are not addressed further in
the EA (see Appendix B, Airspace and Airports, for further information). Moreover, in accordance with FAA
Order 1050.1E, Chapter 3 (Advisory and Emergency Actions and Categorical Exclusions), the issuance of
NOTAMs is categorically excluded from NEPA review absent extraordinary circumstances.
The following sections describe the operational characteristics of the concept RLVs proposed to operate
at EFD and physical development proposed at EFD to accommodate those operations.

2.1.1

Horizontal Take-off and Landing Vehicles

Design parameters have been established for concept RLVs considered in this EA. Figure 2-1 shows
examples of RLVs and Table 2-1 summarizes the parameters of the Concept X and Z RLVs. This
information is based on publicly available information from various RLV operators. The purpose of
establishing these characteristics, or parameters, is to conservatively assess the potential impacts of RLV
operations at EFD. This information does not necessarily reflect the exact RLV that would operate at the
Houston Spaceport. Instead, it defines the scope (or bounds) of the analysis, such that if a prospective
operator’s RLV parameters fall within the parameters in this EA, the environmental consequences of
launching would fall within this EA’s scope. Based on the Houston Spaceport Economics and Business Study
(XArc, 2013), the HAS anticipates the proposed RLVs to operate from the Houston Spaceport include the
parameters described within Table 2-1. However, if the operator’s RLV parameters fall outside the
parameters in this EA, the FAA would re-evaluate the potential impacts and potentially prepare additional
NEPA analysis (FAA Order 1050.1E, Paragraph 411).
Propellant types and quantities are RLV dependent. Fuels that could be used include rocket propellant-1
(RP-1), Jet-A fuel, hydroxyl-terminated polybutadiene (HTPB), acrylonitrile butadiene styrene (ABS), nylon,
and ammonium perchlorate composite propellants (APCP). Oxidizers include LOX, nitrous oxide (N2O),
and hydrogen peroxide (N2O2).

Houston Spaceport Environmental Assessment – Draft

2-4

 PROPOSED ACTION AND ALTERNATIVES
FIGURE 2-1
EXAMPLES OF CONCEPT VEHICLES

Houston Spaceport Environmental Assessment – Draft

2-5

 PROPOSED ACTION AND ALTERNATIVES
TABLE 2-1
DESIGN CONCEPT RLV CHARACTERISTICS

Characteristics
Typical Maximum Takeoff Thrust

Design Concept X RLV
30,000 lbs

Wingspan

30 ft

Typical Maximum Takeoff Weight

45,000 lbs
Jet-A / ABS / N2O
Jet-A / RP-1 / LOX

Common Propellants Combinations

Design Concept Z RLV
27,600 lbs
Carrier Vehicle – 140 ft
Space Vehicle – 60 ft
120,000 lbs
Jet-A / APCP
Jet-A / HTPB / N2O
Jet-A / Nylon / N2O
Jet-A / RP-1 / LOX

Source: RS&H, 2014

2.1.1.1 Concept X RLV
The Concept X RLV is a dual-propulsion RLV, similar to a current airplane. The RLV takes off from a runway
using jet power and flies to a specified location and altitude (approximately 40,000 ft to 55,000 ft MSL)
before igniting its rocket engine(s) to complete its flight profile. Upon completion of its mission, the
Concept X RLV returns for a horizontal landing by either restarting its jet engines or by gliding. The
Concept X RLV is anticipated to be capable of providing suborbital flights for passengers and/or scientific
payloads. Concept X RLVs can also serve as a reusable first stage for small satellite delivery to low earth
orbit.
2.1.1.2 Concept Z RLV
The Concept Z launch vehicle is a two-part space vehicle consisting of a reusable carrier aircraft and a
reusable or an expendable space vehicle. The carrier aircraft is powered by jet engines and designed
and/or modified to carry the space vehicle to a safe location and high altitude (approximately 40,000 ft
MSL), where the two components detach and the rocket engine of the space vehicle is ignited. The carrier
aircraft flies back to the Spaceport and lands under jet engine power. The space vehicle, which can be
either suborbital or orbital, completes its mission and either returns for a horizontal landing by gliding or
is expended.
2.1.1.3 Pre-Flight Activities
This section describes general pre-flight activities associated with either the Concept X or Concept Z
flights. A ground crew would perform and supervise all pre-flight, flight, and landing operations and
would be trained with the operating protocols for the specific RLV.
Preplanning - RLV operators would be required to notify HAS before a planned launch at EFD and the
HAS would coordinate all operations with the control tower chief. Designated HAS personnel would notify
the launch operator of other activities at EFD, resolve potential conflicts for use, and notify other
appropriate airspace scheduling agencies. Flights would be rehearsed with all flight and ground support
crews before each flight, and rehearsals would be repeated with various failure scenarios and irregular
performance to ensure crew readiness.

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Propellant Loading - Aircraft on the ground at EFD would experience minimal interruptions during RLV
propellant loading operations, as described below for each concept RLV.

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Concept X RLV: The Concept X RLV would roll out of its hangar and receive Jet-A fuel to top off
the fuel tanks. At this point, there would be no oxidizer on board. Therefore, other aircraft
operating on the ground at EFD would be required to maintain only a 50-foot distance from the
RLV, similar to conventional aircraft operating practices.
When fueling is complete, the vehicle would taxi or be tugged to the RP-1 fueling area (which
could be as close as 25 feet away), and RP-1 fuel would be loaded. At this point, other aircraft
would still be required to maintain a 50-foot distance from the RLV.
The RLV would taxi north from Runway 4-22 to Taxiway G, and then to Taxiway B in order to
access the oxidizer loading area (OLA). Refer to Section 2.1.2.1 for the location of the OLA. The
Concept X RLV would meet the LOX tanker truck and any required portable filtering and pumping
equipment at this location. This would require all other aircraft to maintain a safe distance from
the RLV. While the LOX tanker truck is in transit to and from the RLV, it would be required to
maintain a 100-foot distance from all aircraft. The LOX truck and portable equipment would
return to storage. Runway 4-22 would remain open and operational during this time. In the event
of inclement weather, the RLV would be de-fueled and removed from the runway, and the launch
would be cancelled.

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Concept Z RLV: The Concept Z RLV would follow similar operational procedures as Concept X,
except this vehicle would roll out of its hangar with the HTPB solid fuel installed. The vehicle
would receive Jet-A fuel in the ramp area to top off the fuel tanks. Also, instead of LOX being
added, this vehicle could require the loading of N2O at the OLA.

Passenger Loading - After the oxidizer and safety checks are complete, passengers are loaded on to the
RLV. Procedures for passenger loading include:

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arrival/departure of any necessary vehicle ingress/egress aids (stairs, ladders);
docking/undocking of ingress/egress aids to vehicle;
arrival/departure of the passenger-carrying vehicle;
loading of passengers;
securing of passenger cabin;
final vehicle pre-flight checks; and
presentation of passenger safety and emergency procedures.

RLV Runway Operating Area - The RLV Runway Operating Area (ROA)7 would meet all FAA safety, risk, and
financial responsibility requirements per 14 CFR Part 400 and not adversely affect the safety, utility, or

7

Term referring to the runway identified as the recommended runway for RLV operations.

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 PROPOSED ACTION AND ALTERNATIVES
efficiency of EFD per 49 USC § 47107(a)(16). The bounds of the RLV ROA are generally contained within
the EFD property line, with the exception of areas just beyond the south end of the runway. The RLV ROA
is only active immediately prior to an RLV takeoff and until such time as the vehicle departs the runway.
Procedures to occur in the RLV ROA include:

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final RLV pre-flight checklist;
air traffic control communications; and
RLV takeoff.

2.1.1.4 RLV Flight Profile
Once the RLV is loaded with oxidizer and passengers (if applicable) at the OLA and the equipment and
personnel have safely left the area, the RLV would taxi or be towed to the north end of Runway 17R-35L
for immediate departure. Runway 17R-35L would be reserved for RLV departure in the same manner as
other aircraft departing or arriving at EFD. Both the Concept X and Z RLVs would fly from EFD to existing
Special Use Airspace8 over the Gulf of Mexico. The proposed RLV would depart EFD to the south and
complete all launch operations in the Offshore Warning Areas (W-147D and W-147C) located in the Gulf
of Mexico (see Figure 2-2).9
In general, the flight begins in the Class D airspace of EFD.10 Upon exiting EFD Class D airspace, the RLV
would fly through two layers of Class B Airspace.11 The RLV would continue south for approximately 18
miles. The RLV would then bank approximately 16 degrees to the southeast and would continue through
Alert Area A-381 Airspace Gulf within Class A airspace. The flight profile of the Concept X and Z RLVs are
described in further detail in the following paragraphs. Appendix B provides more information regarding
the airspace and airports.

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Concept X RLV Flight Profile - The Concept X RLV would take-off to the south under turbojet
power. The vehicle would fly to a designated launch area over the Gulf of Mexico, approximately
20 miles away from land. Rocket ignition would occur at approximately 60 miles offshore at
approximately 40,000 ft MSL with a vertical orientation. The rocket engines would shut off at
150,000 ft MSL at a maximum speed of Mach 3.5. The RLV would reach an apogee above 62
miles.

Special use airspace consists of airspace of defined dimensions identified by an area on the surface of the Earth wherein activities
must be confined because of their nature, or wherein limitations are imposed upon aircraft operations that are not a part of those
8

activities, or both.
9

A warning area is airspace of defined dimensions, (extending from 3 nautical miles outward from the coast of the United States),

designated to contain activity that may be hazardous to nonparticipating aircraft.
10 Class D airspace starts at ground level and extends out for approximately four nautical miles from the center of EFD up to an
elevation of 2,000 feet above ground level.
The Class B airspace is associated with HOU, located approximately 15 and 20 nautical miles from the center of HOU and at an
elevation of 2,000 feet MSL to 10,000 feet MSL and 4,000 feet MSL to 10,000 feet MSL, respectively.
11

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 PROPOSED ACTION AND ALTERNATIVES
FIGURE 2-2
PROPOSED RLV FLIGHT PATH

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The reentry and decent phase would be powered (turbofan) or unpowered (gliding) with the pilot
in command of the vehicle requesting authorization from EFD’s airport traffic control tower
(ATCT) for a horizontal landing. A sonic boom generated by the Concept X RLV would occur
during ascent and descent (or reentry). The sonic boom generated during the RLV’s supersonic
portion of the ascent would not impact the Earth’s surface due to the steep ascending flight path
angle. The sonic boom generated during the supersonic portion of the RLV’s reentry would occur
at around 80,000 ft over the Gulf of Mexico, approximately 30 miles from the Texas shoreline (see
Section 4.12 for further details). Total flight time is estimated to be less than one hour.12

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Concept Z RLV Flight Profile - The Concept Z carrier vehicle and attached space vehicle would
take-off to the south and fly to a designated launch site over the Gulf of Mexico, approximately
20 miles away from land. The carrier vehicle and attached space vehicle would ascend to an
altitude of approximately 40,000 ft MSL. At this stage, the carrier vehicle would release the
attached space vehicle. Once released, the space vehicle would free fall for a few seconds prior to
ignition of its rocket engine, approximately 60 miles offshore.
Following ignition of the rocket engine, the space vehicle would climb at supersonic speed (in
excess of 768 miles per hour) until propellants are consumed at or around 150,000 ft MSL. The
rocket engine would shut off and the space vehicle would coast to an apogee of at least 360,000
ft MSL. Like the Concept X RLV, a sonic boom would be generated during ascent and reentry. The
ascent boom would not impact the Earth’s surface, and the reentry boom would occur at around
80.000 ft over the Gulf of Mexico, approximately 30 miles from the Texas shoreline. The RLV
would descend from the point of reentry and glide, with no propellant combustion, to a
horizontal landing at EFD.
The carrier vehicle, remaining in flight after the release of the RLV at approximately 50,000 ft MSL,
would follow the RLV back to EFD. The carrier vehicle would then make a powered landing at EFD.
The total flight time is estimated to be less than one hour.13

Following a successful suborbital flight, the RLV would return to EFD’s Class D airspace under jet power or
as a glider and be handed off to the EFD ATCT like any other aircraft. An RLV returning as a glider would
utilize the HI-TACAN Runway 35L arrival.14 Once the RLV lands, the use of Runway 17R-35L would be
temporarily suspended until the RLV is removed from the runway. Non-aircraft operations such as towing
equipment, and other required support equipment, would be permitted on all other taxiways and aprons
not occupied by the RLV. Once the RLV is removed from the runway, EFD would resume normal
operations.
The time between the RLV’s initial contact with the Ellington ATCT on its return and the termination of the
RLV’s flight on its designated ramp area would depend on how quickly spaceport or RLV operator

12

The flight time is ultimately operator dependent.

13

The flight time is ultimately operator dependent.
A Categorical Exclusion was completed for this approach path and, therefore, was not included in the analysis for this EA.

14

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 PROPOSED ACTION AND ALTERNATIVES
personnel would be able to reach the RLV with the required towing equipment. The time the RLV lands
and is towed back to its designated ramp area is estimated to be approximately ten minutes, but is
ultimately RLV operator dependent. As this time would be minimal, impacts to normal operations at EFD
would be insignificant.
Contingency Landing Locations - Since the concept RLVs would return to EFD either under jet power or
gliding, potential contingency sites are considered in the event that the RLV is unable to return to EFD.
According to the 2012 Feasibility Study, there are two general aviation airports between a possible
ignition point in the Gulf of Mexico and EFD. These airports are Scholes International Airport in Galveston,
TX and Brazoria County Airport in Angleton/Lake Jackson, TX. The feasibility of using these airports is
dependent on runway length and the requirements of the RLV operator. Should additional runway lengths
be needed at either of these two airports by the RLV operator, a runway extension would be considered
as part of the NEPA action for the vehicle licensing proposal, separate from this launch site operator
license.
Potential Launch Failures - For each mission, HAS would establish areas to ensure public safety according
to regulations in 14 CFR Part 431. FAA regulations as defined in 14 CFR Parts 417, 420, and 431 all require
safety to the general public as their primary consideration in granting a license. In addition, as part of the
licensing process and as part of maintaining safety of air traffic, the FAA would require HAS to establish
agreements with ZHU ARTCC, I90 TRACON, and the 147th Reconnaissance Wing to coordinate the use of
the required airspace.
In terms of potential effects for a nominal trajectory, the flight path does not include flights over highly
populated areas. In the unlikely event of a launch failure, the debris impacts would be expected to be
contained within a FAA approved hazard area. Nominal spaceport operations would not be expected to
significantly impact operations at nearby airports because the flight path would be carefully coordinated
to avoid the airspace of publicly owned airports in the area. Impacts to nearby airports expected as a
result of spaceport operations would be those related to an RLV emergency landing. If an emergency
landing were required, Air Traffic Control (ATC) would assist the RLV pilot to safely land the vehicle.
Normal operations would only be interrupted if the RLV pilot-in-command (PIC) declared an emergency
and required assistance. If the PIC chose to land the RLV at a location other than EFD as a result of a
distress situation, the RLV would be maneuvered to land at an airport of the PIC’s choice and in
coordination with Houston ATC. Upon landing, the RLV would likely be disabled and remain on the
runway until assistance could be rendered. After landing, all other aircraft would be required to maintain a
safe distance from the RLV because the vehicle might not have expended all its fuel.
Spaceport operations at EFD would only impact aircraft operations at nearby airports in the unlikely event
of an emergency landing. As noted earlier, only licensed RLVs would be permitted to operate from the
Houston Spaceport, reducing the likelihood that an emergency landing would be required.

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2.1.1.5 Post-Flight Activities
For nominal launches, all of the oxidizer would be consumed during the RLV powered flight. For aborted
flights, the oxidizer would be released and evaporate before landing, while the fuel would remain onboard
and would be returned to the ground by the RLV. For a nominal launch, no hazardous post-flight ground
operations would be required to return the RLV to safe conditions. In the event the oxidizer is not
completely consumed or released, the RLV would be moved to an area with an established safety clear
zone (i.e., OLA), and the remaining oxidizer and fuel would be removed in accordance with safety
procedures developed for the Houston Spaceport. After safety checks of the RLV are completed, postflight activities would also include:

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transporting the RLV from the runway to the hangar/processing facility (either by ground service
equipment or under power);

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passenger and pilot deplaning; and
post-flight checkouts and inspections.

2.1.1.6 Proposed Launch Operations
HAS proposes to provide RLV operators the ability conduct up to 50 launches per year at the Houston
Spaceport (see Table 2-2) during the study years for this EA. Based on the Houston Spaceport Economics
and Business Study (XArc, 2013), launches are anticipated to reach 35 launches per year during the
timeframe of the license (2015-2019). However, for a conservative analysis, this EA assesses up to 50
launches in each year of the license. Approximately five percent of these launches could occur during
nighttime hours.
TABLE 2-2
ESTIMATED NUMBER OF LAUNCHES PER YEAR

RLV Vehicle
Concept X
Concept Z
Total

2015
25
25
50

2016
25
25
50

2017
25
25
50

2018
25
25
50

2019
25
25
50

Note: For analysis purposes only. The number of launches per year is operator dependent and would be
further assessed within a launch site operator license application. If the application included launches
outside the scope of this EA, a supplemental EA would be prepared.
Source: RS&H, 2014.

2.1.1.7 Personnel
Depending on the vehicle operator and types of operations, an operator may employ 10 to 40 people.
This could include mechanics and ground crew, air crew staff, trainers, office staff, and flight controllers.
The estimated number of employees is subject to change based on the number and type of operations.

2.1.2

Construction of Spaceport Development

Figure 2-3 shows the proposed facilities associated with the Proposed Action. Design and construction of
the proposed hangar/processing facility would be to store, maintain, and operate multiple types of
concept RLVs.

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FIGURE 2-3
PROPOSED DEVELOPMENT

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This facility would be comparable to existing EFD hangars and office facilities, and would be constructed
in 2015 (upon FAA approval of a Houston Spaceport launch site operator license application, including a
decision on the Final EA and an FAA approved ALP, as described previously in Section 1.2).
The proposed Houston Spaceport development projects pursuant to this license are reflected on an
updated ALP subject to FAA Airports Division approval. Should EFD need additional spaceport facilities
beyond the Proposed Action described in the following subsections, further environmental reviews would
be completed accordingly.
2.1.2.1 Landside Development
As shown in Figure 2-3, relatively minor physical development would be required to support spaceport
activity. This section describes the proposed landside development associated with the Proposed Action.
Hangar/Processing Facility and Apron - The Proposed Action includes the construction of an initial
hangar/processing facility and apron area. According to the updated ALP, the dimensions of the
hangar/processing facility are 200 ft x 230 ft. The hangar/processing facility would be constructed
adjacent to a new 220 ft x 500 ft concrete apron area. The proposed location of the initial
hangar/processing facility is southeast of Runway 4-22 within the HAS hay program area.15
Other landside development associated with the Proposed Action at EFD includes the following:

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construction of a 200 ft x 70 ft vehicle parking area (approximately 30-35 parking spots);
construction of 1,270 ft of access road;
construction of 1,065 ft of FAA-approved fencing; and
construction of a storm water treatment pond (e.g., FAA compliant pond(s) to collect rainfall
runoff from new impervious surfaces associated with the Proposed Action).

Propellant Storage - Fuels needed to support the types of RLVs that would operate at EFD could include
RP-1, Jet-A fuel, HTPB, ABS, nylon and APCP. Oxidizers include LOX, N2O, and H2O2. Table 2-3 shows the
maximum quantities of fuel and oxidizer that could be stored on-site at one time for RLV operations
under the Proposed Action.
Propellants, except Jet-A fuel, HTPB, APCP, and nylon/ABS, would be stored offsite and delivered to EFD
by tanker truck. Due to the inert nature of solid fuel, it is reasonable to assume that as many as ten hybrid
rocket motor casings containing solid fuel (ABS or HTPB) could be stored in the same processing hangar
as the RLV. Jet-A fuel would be stored in existing infrastructure and supplied according to existing
Standard Operating Procedures (SOPs) at EFD.
Other oxidizers not currently used at EFD would be brought in by tanker trucks, park at the oxidizer
storage area for safety, and would be transferred to the RLV during loading/unloading for flights at the

Since 2006, HAS has managed an area within the southeast portion of EFD property for farming activities (e.g., tilling, seeding,
cutting, baling, etc.) in order to produce Coastal Hay and Tifton 85 Bermuda grass.
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 PROPOSED ACTION AND ALTERNATIVES
OLA. These oxidizers are similar in composition and management requirements to the Jet-A fuel currently
used at EFD.
TABLE 2-3
MAXIMUM QUANTITIES OF FUEL/OXIDIZER STORED
ON-SITE FOR THE PROPOSED ACTION

LOX

Maximum Quantity
(1,000s of lbs)
171

N2O
RP-1
Jet-A/a/
HTPB (solid, inert)
Nylon/ ABS (solid, inert)
APCP

121
68
952
150
150
60

Oxidizers/Propellants

/a/ This is EFD’s current storage capacity. This is not the quantity of
Jet-A fuel that would be used for RLV operations.
Source: RS&H, 2014

The proposed location of the oxidizer storage area is south of Runway 4-22 for the temporary storage of
trucks transporting oxidizer. This places the oxidizer outside of all aviation operating areas. Four 75 ft x 75
ft concrete pads are proposed in order for the safe temporary storage of the oxidizer.
Oxidizer Loading Area - The proposed OLA would consist of a 150 ft x 150 ft concrete pad to be located
along Taxiway B in between Runway 17R-35L and Runway 17L-35R. This area is the currently designated
“Hot Pad” used by the TxANG at EFD for sensitive tasks (e.g., ordinance loading/unloading).
Oxidizer loading operations are more hazardous than the aviation fuel loading operations for the
following reasons:

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The RLV already contains aviation fuel, therefore adding an oxidizer is considered a hazard.
A common oxidizer, LOX, is cryogenic and requires unique handling and equipment.
N2O is stored at high pressure at room temperature and requires special loading equipment.

2.1.2.2 Airside Development
Airside development includes those aspects of development associated with the runway and taxiway
system. As described in Section 1.1.1.1, EFD has an 8,000 ft and 9,000 ft runway. Runway 17R-35L can
accommodate the departure and return of the Rocket Crafters’ Sidereus and Generation Orbit RLV
concept vehicles. As shown in Figure 2-3, the Proposed Action would include:

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construction of 1,000 linear ft of taxiway from the apron area to the airfield system;
pavement repair to Taxiway D southeast of Runway 4-22; and
construction of 220 ft of roadway to access the oxidizer storage area.

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A new 1,000-ft taxiway would accommodate the movement of the RLV from the apron to the airfield and
subsequently to the oxidizer loading area. Based on the current performance characteristics of Virgin
Galactic’s Spaceship Two/White Knight Two, the airport’s current runway lengths would not accommodate
this Concept Z vehicle. HAS would need to add approximately 2,000 ft of runway length at EFD to
accommodate the operation of this RLV. However, additional runway length at the airport is not being
proposed at this time, and thus is not part of the Proposed Action in this EA. The operation of Spaceship
Two/WhiteKnight Two at the Houston Spaceport is for conservative environmental analysis purposes only.

2.2 ALTERNATIVES CONSIDERED
NEPA, the CEQ Regulations, and FAA Orders 1050.1E and 5050.4B require an analysis of alternatives that
could satisfy the purpose and need for proposed activities. This serves as a basis for comparison of
alternatives and may prompt selection of an alternative that has fewer environmental effects. The
following alternatives were considered.

2.2.1

No Action Alternative

NEPA requires agencies to consider a “no action” alternative in their NEPA analyses and to compare the
effects of not taking action with the effects of the action alternative(s). Thus, the No Action Alternative
serves as a baseline to compare the impacts of the Proposed Action. Under the No Action Alternative, the
FAA would not issue a launch site operator license to HAS, and thus no launch licenses to individual
launch vehicle operators to operate at EFD. Also, there would be no need to update the EFD ALP, and thus
there would be no FAA approval of a revised ALP. Existing operations would continue at EFD.
The No Action Alternative would not satisfy the purpose and need for the Proposed Action because it
would not allow for operation of a commercial space launch site and would not satisfy the HAS’s need to
diversify the local economy and enhance the region as a business and employment center.

2.2.2

Alternatives Considered and Not Carried Forward For Further Analysis

This section describes other alternatives considered and eliminated from further environmental analysis.
FAA Order 1050.1E, Change 1, paragraph 506.e states that alternatives “…must be reasonable, feasible,
and achieve the project’s purpose.” Potential alternatives that would not meet these criteria are eliminated
from further consideration.
To satisfy the need of HAS’s proposal (see Section 1.4), a commercial space launch site must meet the
following criteria (“Screening Criteria”) to accommodate horizontal take-off and horizontal landing of
RLVs in the Houston area:

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a location within the Houston airport system;

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a runway with minimum length of 8,000 ft;

a location in an area of comparatively low population density in order to comply with 14 CFR Part
420;
a minimum of 45,000 square ft of hangar space; and
extensive airspace separation distances from other aircraft operating in the Houston area
airspace.

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Based upon the Screening Criteria, alternative sites were examined by HAS. This section describes
alternative sites considered by HAS, which for the reasons provided in the following subsections, were
found to be infeasible. These alternative sites were not carried forward for further analysis in the EA.
2.2.2.1 Alternative 1: Other Airports
Alternative 1 would entail the development and subsequent operation of the same infrastructure
associated with the Proposed Action (e.g., hangar, apron, unloading area, access roads, and storm water
treatment) located at a different airport or facility.
As described in Section 1.4 of this EA, the purpose of HAS’s proposal to establish a commercial space
launch site is to help the City achieve its economic goals. Establishing a launch site would enable a HAS
airport to serve as an alternative to a federal launch facility or another commercial launch site for the
operation of horizontally-launched and horizontally-landed Concept X and Z RLVs. As the commercial
launch site operator, HAS must meet FAA regulations, specifically, License to Operate a Launch Site –
Control Access, requiring a licensee to control public access (14 CFR § 420.53).
HAS manages and operates two other airports: George Bush Intercontinental Airport (IAH) and William P.
Hobby Airport (HOU). While there are about 28 public use airports in the Houston Metropolitan Area, HAS
does not have the authority to manage or conduct operations at these other airports, nor would HAS
acquire another regional airport solely for the purpose of providing a commercial space launch site, as
this would not be economically feasible. The range of potentially reasonable alternative airports is
therefore limited to those currently under HAS management.
IAH - IAH is located approximately 23 miles north of
downtown Houston, near the Sam Houston Tollway.
In 2012, IAH ranked 5th among U.S. airports in terms
of aircraft activity. IAH encompasses more than
11,000 acres of property with five passenger terminals
accommodating 20 passenger airlines, and 20 million
passengers in 2012.
The IAH airfield accommodated over 517,000 annual
aircraft operations in 2012; nearly 1,400 on an annual
average day. The airfield at IAH (see photo left)
includes five runways as described below:

Source: Google, 2013.

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Houston Spaceport Environmental Assessment – Draft

15L-33R – 12,000 ft by 150 ft,
9-27 – 10,000 ft by 150 ft,
8R-26L – 9,400 ft by 150 ft,
15R-33L – 10,000 ft by 150 ft, and
8L-26R – 9,000 ft by 150 ft.

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 PROPOSED ACTION AND ALTERNATIVES
HOU - HOU, the second busiest commercial airport in the Houston area, is located in the City of Houston,
about seven miles south of downtown, in Harris County. Major roadways close to HOU include Interstate
45 to the west, Interstate 610 to the north, and
Beltway 8 to the south. HOU is by far the smallest of
the HAS airports with an area of approximately 1,500
acres. Currently, HOU has one terminal with 25 gates
which accommodated approximately five million
passengers in 2012.
HOU accommodated nearly 200,000 aircraft
operations in 2012. HOU has four runways: two air
carrier runways (12L-30R and 12R-30L), and two
runways (4-22 and 17-35) used primarily by general
aviation aircraft (see photo right). The dimensions of
these runways are as follows:

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4-22 – 7,602 ft by 150 ft,
12R-30L – 7,602 ft by 150 ft,
12L-30R – 5,148 ft by 100 ft, and
17-35 – 6,000 ft by 150 ft.

Source: Google, 2013.

Evaluation of Other Airports - The following paragraphs describe the ability and/or inability of IAH and
HOU to satisfy the need of HAS’s proposal based on the Screening Criteria.

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A location within the Houston airport system: Both airports are owned and operated by HAS,
thereby meeting the criteria of being located within the Houston airport system.

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A location in an area of comparatively low population density in order to comply with 14 CFR Part
420: Figure 2-4 shows that, compared to EFD, RLVs operating out of either IAH or HOU would
need to travel farther and transit over more populated areas to reach the Gulf of Mexico and the
Warning Areas. Flight paths from either airport do not meet the criteria of being located in an
area of comparatively low population density.

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A runway with a minimum length of 8,000 ft: The four runways at IAH are over 8,000 ft long.
Therefore, they have sufficient length to meet this criteria. None of the runways at HOU are 8,000
ft or longer. Therefore, HOU would not meet the minimum runway length criteria.

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A minimum of 45,000 square ft of hangar space: Both airports would be able to accommodate the
development associated with the Proposed Action in some manner (e.g., reuse of an old hangar,
removal of existing airport development). IAH and HOU would meet the minimum developable
space criteria.

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FIGURE 2-4
HOUSTON AREA CLASS B AIRSPACE

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Extensive airspace separation distances from other aircraft operating in the Houston area airspace:
Figure 2-4 shows the FAA’s Terminal Area Chart for Houston, which is centered on the Class B
Airspace surrounding IAH and HOU. Class B Airspace is controlled airspace surrounding the
nation’s busiest airports and is designed to contain all of the published instrument approaches
once an aircraft enters the airspace. An FAA ATC clearance is required to operate in Class B
Airspace. IAH and HOU are the focal points of most published instrument approaches in the
Houston airspace and, consequently, operating a commercial launch facility at either IAH or HOU
significantly would disrupt airport operations and regional air traffic more than at EFD.
An RLV flight requires extensive separation distances from other aircraft, effecting Houston
airspace. The operation of an RLV at IAH or HOU would include a detailed flight procedure that
would shift a significant number of IAH and HOU aircraft operations within the airspace and
substantially increase ATC coordination managed by I90 TRACON and ZHU ARTCC. Prior to a
scheduled RLV operation, airspace coordination among the I90 TRACON, ZHU ARTCC, and ATCT
would begin to clear the airspace from IAH or HOU to a Warning Area over the Gulf of Mexico.
This would require the re-routing a significant number of aircraft operations arriving and
departing IAH or HOU to allow for a cleared flight path for the operation of the RLV. The rerouting of aircraft could significantly disrupt and/or congest the Houston area airspace, reducing
the potential safety of aircraft passengers and crew. In addition, RLV flights from IAH would also
entail longer transit times to the Gulf of Mexico and the Warning Area in which they would
operate, much of it over urbanized areas. Therefore, a RLV flight departing from IAH or HOU
would be significantly more difficult to coordinate and implement for arriving and departing air
carrier operations when compared to the Proposed Action at EFD.
Additionally, as shown in Figure 2-5, IAH had approximately 517,000 operations in 2012, of which
approximately 288,000 were air carrier operations. The 2013 FAA Terminal Area Forecast (TAF)
shows HOU having approximately 198,000 total operations and approximately 109,500 air carrier
operations in 2013. These two air carrier airports alone account for approximately 714,000 total
annual operations within the Houston area airspace. By comparison, in 2013, EFD had
approximately 144,702 total operations and 1,852 air carrier operations.
FIGURE 2-5
HAS AIRPORTS’ TOTAL OPERATIONS BY YEAR

700,000

IAH

600,000
500,000
400,000
300,000
200,000

HOU
EFD

100,000
0
2000

2005

2010

2015

2020

2025

Source: FAA TAF, 2013

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While IAH and HOU meet some of the criteria to satisfy the need of HAS’s proposal, neither airport is
located in an area of comparatively low population density nor provide extensive airspace separation
distances from other aircraft operating in the Houston area airspace. For these reasons, neither IAH nor
HOU would be a reasonable alternative to the Proposed Action. Therefore, Alternative 1 is not carried
forward for further environmental analysis.
2.2.2.2 Alternative 2: Other On-Airport Alternatives at EFD
Early planning coordination among FAA, HAS, HAS contractors, and EFD tenants (e.g., TxANG, NASA, etc.)
addressed the potential for locating the spaceport landside improvements (hangar/processing facility,
propellant storage, and OLA) at other on-Airport locations at EFD. The current west side of the airport is
fully developed. Based on the current airfield configuration and the associated safety areas (runway safety
areas, taxiway safety areas, runway protection zones, building restriction lines, etc.), the northern,
southern, and eastern portions of the on-Airport property would not accommodate the proposed
hangar/processing facility and apron. Therefore, the southeast location for the hangar/processing facility
and apron as set forth in the Proposed Action (Figure 2-3) is the only feasible location. Other on-Airport
locations for the landside improvements were precluded from further analysis.

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CHAPTER 3

AFFECTED ENVIRONMENT

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This chapter describes the physical, natural, and human environment within the project regions of
influence (ROIs) (see Figure 3-1).16 This information establishes a baseline for use in determining potential
impacts of the Proposed Action and the No Action Alternative, as described in Chapter 2.
As described in Section 1.1.1, EFD is located in Harris County, in the southeastern portion of the City of
Houston. EFD is approximately 20 miles southeast of the center of downtown Houston, 10 miles north of
Galveston Bay, and 30 miles north of the Gulf of Mexico. Major roadways around EFD include Interstate
45, the Sam Houston Tollway, State Highway 3 (Old Galveston Road), and a freight rail line. EFD is
approximately eight miles southeast of HOU and encompasses approximately 2,600 acres of land. At the
time of this analysis, there are three active runways, eight active taxiways, and one active taxilane. Runway
17R-35L is 9,001 feet long by 150 feet wide. Runway 17L-35R is 4,609 feet long by 75 feet wide. Runway
4-22 is 8,001 feet long by 150 feet wide. Refer to Section 1.1.1 for more details regarding EFD
characteristics.
This EA examines two ROIs encompassing the areas potentially subject to impacts caused by construction
and operation of the Proposed Action. The ROIs encompass areas adequate to address potential impacts
as required by FAA Order 1050.1E, Change 1, Environmental Impacts: Policies and Procedures, and FAA
Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions.
The construction ROI represents: (1) the area where ground disturbance could potentially occur during
construction of the Proposed Action and (2) the environment immediately surrounding EFD. The
construction ROI is defined by the U.S. Census block groups directly adjacent to EFD’s property and
encompasses approximately 19 square miles. The U.S. Census block groups were used to define the
construction ROI for purposes of this EA in order to more accurately describe the population and
economic characteristics of the area surrounding EFD which could experience construction-related effects
of the Proposed Action. For environmental considerations dealing with impacts from operation of the
Proposed Action, an operation ROI was established. The operation ROI is based on the operational area of
the Proposed Action, including EFD, the area below the RLVs flight path to the Gulf of Mexico, and the
nominal sonic boom contour that could result from RLV reentry. The operation ROI encompasses
approximately 7,000 square miles and includes portions of Harris, Brazoria, and Galveston counties, with a
majority of this ROI over the Gulf of Mexico. Figure 3-1 shows the construction and operation ROIs.
FAA Order 1050.1E, Change 1 requires an evaluation of impacts for specific environmental categories. This
chapter describes in detail the existing conditions for the following categories:

»
»
»

16

Air Quality (Section 3.1)
Climate (Section 3.2)
Coastal Resources (Section 3.3)

The physical environment refers to the geographic overview, climate, water resources, floodplains, soils, and air quality. The natural

environment refers to biotic communities, threatened and endangered species, and wetlands. The human environment refers to land
use and local governments, Section 4(f) properties, historical and archaeological resources, airport noise, demographics, social
groups, and socioeconomics.

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 ENVIRONMENTAL CONSEQUENCES
FIGURE 3-1
CONSTRUCTION AND OPERATION REGIONS OF INFLUENCE

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»
»
»
»
»
»
»
»
»
»

Compatible Land Use (Section 3.4)

»
»

Water Quality (Section 3.14)

USDOT Act, Section 4(f) Properties (Section 3.5)
Fish, Wildlife, and Plants (Section 3.6)
Floodplains (Section 3.7)
Hazardous Materials, Pollution Prevention, and Solid Waste (Section 3.8)
Historical, Architectural, Archaeological, and Cultural Resources (Section 3.9)
Light Emissions and Visual Resources (Section 3.10)
Natural Resources and Energy Supply (Section 3.11)
Noise (Section 3.12)
Socioeconomics, Environmental Justice, and Children’s Environmental Health and Safety Risks
(Section 3.13)
Wetlands (Section 3.15)

This EA does not analyze potential impacts to the following environmental categories:

»

Farmlands - There are no prime or unique farmlands, or farmlands of statewide or local
importance, as defined by the Farmland Protection Policy Act (FPPA), within the construction ROI.
Although some soil types within the construction ROI are generally considered prime farmland
(e.g., Bernard clay loam, Bernard-Edna complex, Lake Charles clay), the entire construction ROI is
recognized by the U.S. Census Bureau as an urbanized area. Under Section 523(10)(B) of the
FPPA, land identified as urbanized areas on Census Bureau maps are not subject to the provisions
of the FPPA (USDA, 2012). Additionally, EFD was established in 1917 by the U.S. Military and
converted to urban land use prior to the establishment of the FPPA. Section 658.2(c)(1) of the
FPPA, enacted on August 4, 1984, states the act does not apply if the acquisition of land or
easements for the project occurred prior to that date.

»

Wild and Scenic Rivers - There are no wild and scenic rivers as designated by the Wild and Scenic
Rivers Act located within the ROIs. The closest Wild and Scenic River segment to EFD is the Saline
Bayou Wild and Scenic River, approximately 250 miles northeast of EFD.

Chapter 4 discusses secondary (induced) impacts, also listed in FAA Order 1050.1E, Change 1, as an
impact category.

3.1 AIR QUALITY
This section summarizes details on the current (2013) and historical attainment status with respect to the
National Ambient Air Quality Standards (NAAQS), as well as recently recorded air monitoring data for the
area surrounding the proposed Houston Spaceport at EFD. This section also discusses greenhouse gases.

3.1.1

Air Quality Status

The U.S. Environmental Protection Agency (USEPA) sets NAAQS in order to protect the public health and
environmental welfare. The USEPA has identified the following six criteria air pollutants for which NAAQS

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are applicable: carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO2), ozone (O3), particulate matter
(PM10 and PM2.5), and sulfur dioxide (SO2). EPA calls these pollutants "criteria" air pollutants because it
regulates them by developing human health-based and/or environmentally-based criteria (science-based
guidelines) for setting permissible levels (USEPA, 2012).
Geographic areas found to be in violation of one or more NAAQS are classified as nonattainment areas.
Nonattainment designations are generally based on the degree of nonattainment (e.g., serious, severe,
moderate, marginal) which dictates the deadline (i.e., the attainment year) by which the area must be
brought back into attainment of a NAAQS. States with nonattainment areas must develop a State
Implementation Plan (SIP) demonstrating how the area will be brought back into attainment of the
NAAQS within designated timeframes. Areas where concentrations of the criteria pollutants are below (i.e.,
within) the NAAQS are classified as attainment areas. Lastly, areas with prior nonattainment status that
have since transitioned to attainment are known as maintenance areas.
The 2013 attainment/nonattainment designations for the area surrounding EFD (i.e., Harris County) are
listed on Table 3-1. The area is in marginal nonattainment of the EPA’s 2008 NAAQS for O3. The area is
also still considered to be in severe nonattainment for the 1997 O 3 NAAQS. EPA proposed to revoke the
1997 NAAQS in June 2013 (78 FR 34178) but until this action is published as a final rule in the FR, both the
severe and marginal designations apply in Harris County.
TABLE 3-1
ATTAINMENT DESIGNATIONS

Pollutant

Designation

Carbon monoxide (CO)
Lead (Pb)
Nitrogen dioxide (NO2)

Attainment
Attainment
Attainment

Ozone (O3), 1-Houra
Ozone (O3), 8-Hour (1997)b
Ozone (O3), 8-Hour (2008)
Particulate Matter (coarse or PM10)
Particulate Matter (fine or PM2.5)
Sulfur dioxide (SO2)

Severe-17
Severe-15
Marginal
Attainment
Attainment
Attainment

a

Standard revoked.

b

Standard anticipated to be revoked.

Source: US Environmental Protection Agency Green Book Nonattainment Areas
(http://www.epa.gov/airquality/greenbk/), 2013.

As required by the USEPA, the TCEQ (with local assistance from the City of Houston Health Department
and other entities) has established and maintains a permanent network of air quality monitoring stations
throughout the state. These monitors record concentrations of pollutants in the ambient (i.e., outdoor) air
to gauge compliance with the NAAQS. Table 3-2 summarizes air quality monitoring data collected at the
Houston Deer Park #2 monitoring station, the closest station to the construction ROI (approximately three
miles northeast of the construction ROI) for the period of 2011 to 2013. For ease of reference, the
applicable NAAQS for each monitored pollutant is included in the table. As shown in Table 3-2, violations
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of the 8-hour O3 NAAQS were registered at the Houston Deer Park #2 monitoring station during this
timeframe.
TABLE 3-2
AIR MONITORING DATA IN THE EFD AREA (2011 – 2013)

Site Name
and
Address
(Direction
from EFD)

Pollutant

8-hour2

NAAQS

Year
2011

2012

2013

Average

Exceeds
NAAQS

1

9 ppm

1.0

.09

1.3

NA

No

1-hour

2

35 ppm

1.5

1.2

1.8

NA

No

1-hour

3

100 ppb

40.3

36.8

37.6

38.2

No

4

Annual

53 ppb

15.7

16.6

15.9

NA

No

O3

8-hour5

0.075 ppm

0.083

0.085

0.069

0.079

Yes

Pb

Rolling 3month6

0.15 µg/m3

0.02

<0.01

<0.01

NA

No

Annual7

12 µg/m3

8.5

10.1

9.0

9.2

No

21.3

22.1

28.0

23.8

No

41

47

49

46

No

CO
Houston
Deer Park
#2
4514 1/2
Durant St.
(3.5 miles
NE)

Averaging
Period

NO2

PM2.5
PM10
SO2

3

24-hour

8

35 µg/m

3
3

24-hour

150 µg/m

1-hour9

75 ppb

26.6

22.7

9.3

18.2

No

0.5 ppm

0.017

0.015

0.007

NA

No

3-hour

2

Notes: NA = not applicable, ppb = parts per billion ppm = parts per million, µg/m 3 = micrograms per cubic meter.
1

Three-year average only reported if applicable to NAAQS evaluation.

2 Not

to be exceeded more than once per year.

3 98th

Percentile of 1-hour daily maximum concentrations, averaged over 3 years.

4 Annual

mean.

5 Annual

fourth-highest daily maximum 8-hr concentration, averaged over 3 years.

6 Not

to be exceeded.

7 Annual
8 Not

mean, averaged over 3 years.

to be exceeded more than once per year on average over 3 years.

9 99th

percentile of 1-hour daily maximum concentrations, averaged over 3 years.

Source: USEPA AIRData – Monitor Data Queries 2014; and USEPA Air Quality System – Detailed AQS Data, 2013.

Per the General Conformity Rule codified at 40 CFR Part 51, federally obligated actions occurring in
nonattainment or maintenance areas are required to demonstrate conformity with any existing SIP
designed to remedy violations of the NAAQS or prevent future violations. The primary way to accomplish
this is to compare annual emissions associated with a federal action against de minimis thresholds for
pollutants of concern as specified in the General Conformity Rule. This process is called a General
Conformity Applicability Test. If a project-related construction- or operational-related emissions exceed de
minimis thresholds during any year, a formal General Conformity Determination must be prepared. If not,
the project is said to conform to any applicable SIP.

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As previously stated, the Houston area is considered nonattainment for both the currently enforceable
1997 and 2008 8-hour NAAQS. The area is also technically designated nonattainment of the now historical
1-hour O3 standard. After revoking the 1-hour O3 standard, the USEPA ruled that most areas, including
Harris County, were no longer subject to the 1-hour standard as of 2005. Nonetheless, the antibacksliding provisions of the CAA may subject the area to certain federal requirements for nonattainment
and maintenance areas.17
The 2009 Houston-Galveston-Brazoria (HGB) Eight-Hour Ozone Nonattainment Area Reasonable Further
Progress State Implementation Plan Revision (Rule Log 2006-030-SIP-NR), adopted by the TCEQ on
May 23, 2007 and approved by the USEPA in April of 2009 (74 FR 18298) is the O3 SIP for the Houston
area. Since then, TCEQ has prepared and adopted the HGB Reasonable Further Progress State
Implementation Plan for the 1997 Eight-Hour Ozone Standard (Rule Log 2009-018-SIP-NR) and the HGB
Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (Rule Log No. 2009-017SIP-NR). The USEPA has recently proposed to approve these SIP revisions (78 FR 55029, 78 FR 55037) and
once approved they will become the applicable SIPs for the Proposed Action at EFD.
Therefore, the most stringent of the O3 de minimis thresholds applicable to the Houston area (i.e., the
severe nonattainment area designation under the 1997 8-hour standard) correspond to 25 tons per year
of nitrogen oxides (NOx) or volatile organic compounds (VOC), both of which are considered precursors to
ground level O3 formation. Accordingly, a General Conformity Applicability Test outlined at 40 CFR
§93.153(b) has been prepared, the results of which are discussed in Section 4.1.2.2, whereby operational
and construction CAP emissions associated with the Proposed Action occurring below the local
atmospheric mixing height (i.e., below 3,038 feet for the Houston Area) are compared to these
thresholds.18

3.2 CLIMATE
Research has shown there is a direct correlation between fuel combustion and greenhouse gas (GHG)
emissions. In terms of U.S. contributions, the U.S. Government Accountability Office reports that "domestic
aviation contributes about three percent of total CO2 emissions, according to EPA data," compared with
other industrial sources, including the remainder of the transportation sector (20%) and power generation
(41%) (GAO, 2009). The International Civil Aviation Organization (ICAO) estimates that GHG emissions from
aircraft account for roughly three percent of all anthropogenic GHG emissions globally (Melrose, 2010).
Climate change due to GHG emissions is a global phenomenon, so the affected environment is the global
climate (USEPA, 2009).
The scientific community is continuing efforts to better understand the impact of aviation emissions on
the global atmosphere. The FAA is leading and participating in a number of initiatives intended to clarify

17

Codified under 40 CFR 51.905, the anti-backsliding provisions of the CAA prevent the rescission of measures or requirements

applicable to areas in which a NAAQS is revoked or relaxed by the EPA, such that select requirements continue to apply to an area
after revocation or relaxation of the NAAQS in question (i.e., the 1-hour O3 NAAQS), if the requirements were applied in the area
based on the area's prior designation.
The local mixing height is defined as the vertical extent in the troposphere above which emitted pollutants do not mix downwa rd
to ground level.
18

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 ENVIRONMENTAL CONSEQUENCES
the role that commercial aviation plays in GHG emissions and climate. The FAA, with support from the U.S.
Global Change Research Program and its participating federal agencies (e.g., National Aeronautics and
Space Administration, National Oceanic and Atmospheric Administration, U.S. EPA, and U.S. Department
of Energy), has developed the Aviation Climate Change Research Initiative in an effort to advance
scientific understanding of regional and global climate impacts of aircraft emissions. FAA also funds the
Partnership for Air Transportation Noise & Emissions Reduction Center of Excellence research initiative to
quantify the effects of aircraft exhaust and contrails on global and U.S. climate and atmospheric
composition. Similar research topics are being examined at the international level by the ICAO (Maurice &
Lee, 2007).

3.3 COASTAL RESOURCES
The State of Texas has a Coastal Management Program (CMP), which ensures the long-term
environmental and economic health of the Texas coast through management of the state’s coastal natural
resource areas. The Texas CMP was finalized in 1997 and accepted into the Coastal Zone Management
Program (CZMP) by the National Oceanic and Atmospheric Administration (NOAA), following the passing
of the Coastal Coordination Act (CCA) in 1991. The CCA set the boundaries of the Texas coastal zone to
include all or part of 18 coastal counties and more than eight million acres of land and water. EFD is in
Harris County, which partially lies within the Texas Coastal Zone Boundary (CZB). Due to the County’s
location within the coastal zone, the impact of the State’s CMP is important to the future of Harris County
and surrounding counties. Figure 3-2 depicts EFD’s location within the coastal zone boundary.
The Texas CMP is managed by the Texas Land Commissioner within the Texas General Land Office (GLO).
In accordance with the Texas Administrative Code, §501.1, the purpose of the CMP is to “make more
effective and efficient use of public funds and to more effectively and efficiently manage coastal natural
resource areas and the activities that may affect them.”
There is a Texas Coastal Preserve within the operation ROI, approximately six miles east of EFD. There are
no Coastal Barrier Resource Systems (CBRSs) within the construction or operation ROIs. There is an
otherwise protected area, Unit TX-05P, in the operation ROI. This resource is approximately 28 miles away
from the construction ROI (USFWS, 2013).

3.4 COMPATIBLE LAND USE
Land use and zoning is the right and responsibility of local or state governments, not federal agencies.
The City of Houston has not enacted conventional zoning. Rather, the City of Houston implements airport
compatible land use regulations in the Code of Ordinances, Chapter 9, Article VI (Ordinance No. 20081052) (City of Houston, 2008a). This article establishes airport land use areas that extend one and one-half
miles from either side of a runway center line and five miles from each runway end.
Article VI also establishes three land use tiers, shown in Figure 3-3. These tiers have certain restrictions
created to protect each HAS airport from the encroachment of sensitive land uses. Article VI’s definition of
sensitive land uses includes childcare facilities, nursing homes, assisted living centers, boarding houses,
schools, hospitals, or medical facilities (City of Houston, 2008b). Article VI also institutes rules for issuing
land use permits allowing compatible developments within each tier.

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 ENVIRONMENTAL CONSEQUENCES
FIGURE 3-2
COASTAL BOUNDARY

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FIGURE 3-3
EXISTING LAND USE

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The Tier 1 and 2 boundaries follow the average day-night sound level (DNL) 65 A-weighted decibel (dBA)
and DNL 60 dBA noise contours, respectively. Tier 3 is an overlay of the Texas Local Government Code
Section 241, Airport Zoning Act (AZA). AZA establishes a “controlled compatible land use area” around
EFD. The HAS land use compatibility matrix outlines the compatibility of various land uses within each tier
(see Table 3-3).
TABLE 3-3
HAS LAND USE COMPATIBILITY MATRIX

Land Uses
Residential Dwellings (Single Family or Multi-family)
A. Enlargement of existing single family structures
B. Renovation of existing single family structures
C. Replacement of existing single family structures after casualty/b/
D. Enlargement, renovation, or replacement of existing multi-family
structures
E. New Multi-family development
F. New mobile home parks or subdivisions

Tier 1/a/

Tier 2

/

/









/

/



x
x

/
x




/



/



/
/




/

G. New single family construction, including demolition, in existing
/
developed residential areas
H. New construction in undeveloped or non-residential areas
x
Sensitive and Public Assembly Use (e.g., hospitals, nursing homes, K-12 schools)
A. Enlargement or renovation of existing structures
/
B. New Construction
/
Lodging
A. Enlargement or renovation of existing structures
/
B. New Construction
Commercial and Employment Uses (e.g., retain, restaurants, offices)
A. Enlargement or renovation of existing structures
B. New Construction
Notes:

Tier 3

/

/













/a/ Must meet certain notification requirements
/b/ “Casualty” means destruction by accidental or natural causes.
 Compatible
/ Conditionally Compatible - Compatible only with sound insulation measures. Subject to conditions including sound
insulation and execution of avigation easement. For enlargement, conditions will apply if the enlargement of the structure
is more than 51% of the appraised value of the livable area.
x Not Compatible

Source: HAS, 2011

The operation ROI covers portions of Harris, Brazoria, and Galveston counties. These counties are part of
the Houston-Galveston Area Council (H-GAC). Nearly all types of H-GAC designated land uses occur
within the operation ROI. A general field survey of the project ROIs was conducted in August 2013. The
land uses observed during the field survey support the H-GAC land use classifications and the applicability
of these land use classifications for this EA.

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3.4.1

Existing Land Use

The northern portion of the operation ROI consists mostly of residential land uses. There are commercial,
industrial, parks/open spaces, and vacant developable (including farming) land uses scattered throughout
this area. The northeastern portion of the operation ROI has a greater presence of industrial, parks/open
spaces, and vacant developable (including farming) land uses.
The majority of the central portion of the operation ROI consists of vacant developable (including
farming) land uses. The residential land uses in this area are primarily along Highway 6. Similarly, the
commercial and industrial land uses occur mostly along Highway 6 and Highway 35. Amoco Chemical
Company is located in this portion of the ROI, along Farm to Market (FM) Road 2004. The central portion
of the operation ROI also has a number of land uses classified as undevelopable.
The southern portion of the operation ROI is primarily vacant developable (including farming) and
parks/open spaces land uses. There are also large tracts of industrial and undevelopable land uses.
Residential areas are mostly toward the southwest and along the Gulf of Mexico, although there are
residential land uses scattered throughout the area. Similarly, there are commercial land uses in the
southwestern area and along the Gulf of Mexico.
The areas within the construction ROI contain government/medical/educational, commercial, industrial,
and vacant developable (includes farming) land uses. There are residential land uses approximately onehalf mile east and west of EFD. There is a large area of vacant developable (including farming) land south
and northeast of EFD. This area corresponds closely with the present and future DNL 65 dBA contours of
EFB and the Tier 1 Boundary. New residential development, within the Clear Lake community, is currently
taking place southeast of EFD. There are also new industrial parks being developed. The Southeast Water
Purification Plant is expanding, located north of EFD.
Wildlife is managed at EFD to reduce the risk of wildlife hazards to aircraft operations. However, there are
several existing wildlife hazards near EFD. The industrial and commercial area directly north of EFD has
multiple open water ponds and water retention facilities. Standing Stone Solstice Circle, a public park, is
located south of EFD and has a small pond. There are also wetlands directly east of EFD. These open water
ponds, water retention facilities, and wetlands could attract wildlife and create potential wildlife hazards.
Landfills may also create wildlife hazards. Three closed landfills are located near EFD. These are to the
north and northwest, with the closest closed landfill approximately one-half mile north of EFD. The closest
active landfill to EFD is an H-GAC designated Type IV landfill labeled #1708, approximately two miles
northwest of EFD. This type of landfill allows for the disposal of brush, construction and demolition waste
and/or rubbish free of putrescible, and household wastes. The landfill is covered weekly (H-GAC, 2013).

3.5 DEPARTMENT OF TRANSPORTATION, SECTION 4(F) PROPERTIES
Section 4(f) properties are publicly owned lands including public parks, recreation areas, wildlife and
waterfowl refuges, or publicly or privately owned historic sites of National, State, and/or local importance.
The term historic sites includes prehistoric and historic districts, sites, buildings, structures, or objects
listed in, or eligible for listing in, the NRHP. Section 4(f) properties are protected under Section 4(f) of the

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USDOT Act, codified and renumbered as 49 U.S.C. §303(c). In accordance with § 4(f), the FAA will not
approve any program or project that requires the use of any Section 4(f) property determined by the
officials having jurisdiction thereof, unless no feasible and prudent alternative exists to the use of such
land and such program, and the project includes all possible planning to minimize harm resulting from
the use.
Figure 3-4 shows publicly owned parks within the construction ROI. The closest parks to EFD are the
Standing Stone Solstice Circle, Pasadena Municipal Golf Course, and Holly Bay Court Park. There are no
wildlife refuges, waterfowl refuges, or historic sites within the construction ROI.
According to H-GAC, there are 146 public parks within the operation ROI (see Table 3-4).19 The Brazoria
National Wildlife Refuge is also within the operation ROI (Houston Wildlife Refuges, 2014). There are no
waterfowl refuges within the operation ROI. Additionally, there are four NRHP-listed resources within the
operation ROI (see Section 3.9).

3.6 FISH, WILDLIFE, AND PLANTS
Relevant federal laws, regulations, and EO20 that protect biotic communities include the following:

»
»
»

Airport and Airways Development Act, Section 47106(c)(B);

»
»
»
»

Fish and Wildlife Conservation Act of 1980 (16 U.S.C. § 661, et. seq.);

Endangered Species Act (ESA) (16 U.S.C. §1531-1544);
Related Essential Fish Habitat Requirements of the Magnuson-Stevens Act, as amended by
Sustainable Fisheries Act [16 U.S.C. § 1855 (b)(2)];
EO 13112, Invasive Species (64 FR 6183);
Migratory Bird Treaty Act (MBTA) (16 U.S.C. § 703-712); and
Presidential Memorandum on Environmentally and Economically Beneficial Landscape Practices
on Federally Landscaped Grounds (60 FR 40837).

The following regulations implement the federal acts that protect biotic communities:21

19

»

50 CFR Part 402 provides instructions on federal agency consultation with the USFWS. This also
provides instructions on preparing biological assessments to determine project-related effects on
federally-listed endangered and threatened species. 50 CFR 600.920 requires federal agencies
approving or funding federal actions which may affect essential fish habitat to consult with the
National Marine Fisheries Service (NMFS).

»

50 CFR Parts 10 and 10.13 discusses the taking and protection of the listed migratory birds.

Country clubs and homeowner association parks are not included in this list as they are not public facilities (membership is

required).
Due to the number of federal laws and EOs applicable to the Proposed Action, this section presents only the legal citations or
references for those requirements in lieu of summarizing their requirements. See FAA Order 1050.1E, Appendix A for more
20

information.
Note there are no regulations implementing the FWCA. Section 662 of the Act requires federal agencies to coordinate with USFWS
when an action would affect a waterway.
21

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3-12

 ENVIRONMENTAL CONSEQUENCES
FIGURE 3-4
PARKS WITHIN THE CONSTRUCTION ROI

Houston Spaceport Environmental Assessment – Draft

3-13

 ENVIRONMENTAL CONSEQUENCES
TABLE 3-4
PUBLIC PARKS WITHIN THE OPERATION ROI

Park
ID
446
447
448
449
454

Name
Galveston Island State Park
Lafittes Harbor Acres
Trimble & Lindsey Acres
Galveston Country Club
Audobon Society Bird Preserve

Park Type
Regional Park
Community Park
Neighborhood Park
Golf Course
Nature Conservancy/ Reserves/Wetlands

460
461
462
465
466
467
472
473
474
481
487
490

San Bernard
Mahan Park
Carbide Park
Jack Brooks Park
Westlawn
Unknown
Runge Park
Santa Fe Trails
Castle Estates
Bob Briscoe Park
Hillcrest Golf Club
Pearson Park

Nature Conservancy/ Reserves/Wetlands
Urban Park
Urban Park
Regional Park
Mini Park
Mini Park
Sports Fields
Mini Park
Mini Park
Recreational Sports Facility
Golf Course
Recreational Sports Facility

496
502

Morgan Park
City Of Alvin Ball Park

Recreational Sports Facility
Sports Fields

504
508

Unknown
Prairie Dog Park

Recreational Sports Facility
Mini Park

509
511
512
513
515
516

Alvin Park
Unknown
Alvin Park
Unknown
Alvin Park
Newman Park

Mini Park
Neighborhood Park
Mini Park
Mini Park
Mini Park
Mini Park

517
520
521
532
534
535

Chaparral Recreation Association
Bay Colony Pointe
Bay Colony Recreation Center
Big League Dreams
River Oaks At Friendswood
Sequoia Gold Magnolia Creek

Golf Course
Mini Park
Recreational Sports Facility
Sports Fields
Golf Course
Golf Course

536
539
540
542

Magnolia Creek Recreation Center
Westover Park
Westover Park
Unknown

Recreational Sports Facility
Mini Park
Mini Park
Golf Course

543
545

Brittany Lakes
Brittany Lakes

Mini Park
Mini Park

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 ENVIRONMENTAL CONSEQUENCES
TABLE 3-4 CONTINUED
PARKS WITHIN THE OPERATION ROI

Park
ID
546
547
550
551
552

Name
Westover Park
Unknown
Rustic Oaks
Unknown
Unknown

Park Type
Recreational Sports Facility
Community Park
Mini Park
Mini Park
Recreational Sports Facility

553
554
557
559
560
561

Rustic Oaks
Rustic Oaks
Unknown
Claremont Park
The Landing
Villages Of Oak Creek Colony

Mini Park
Mini Park
Sports Fields
Mini Park
Recreational Sports Facility
Community Park

565
567
568
572
573
575

Claremont Park
Unknown
Braskora Gardens
Greenridge
Magnolia Estates
Park On Clear Creek

Mini Park
Urban Park
Neighborhood Park
Mini Park
Neighborhood Park
Urban Park

577
582

Creekside Estates
Boraska Gardens

Neighborhood Park
Urban Park

584
587

Challenger 7 Memorial Park
Unknown

Regional Park
Recreational Sports Facility

588
589
591
592
594
596
597
599
603
606
607
608

Unknown
Butler Oaks
City Park
Walter Hall Park
Forest Bend Park
Stevenson Park
Unknown
Unknown
The Park On Egret Bay
Bayou Brae Civic Club
Heritage Park
Renwick Park

Recreational Sports Facility
Mini Park
Community Park
Urban Park
Community Park
Recreational Sports Facility
Neighborhood Park
Nature Conservancy/ Reserves/Wetlands
Mini Park
Recreational Sports Facility
Recreational Sports Facility
Sports Fields

610
612
613
615

Unknown
Unknown
Unknown
Pearson Park

Regional Park
Neighborhood Park
School Park
Mini Park

617
618

Nassau Bay Peninsula Wildlife Park
Unknown

Urban Park
Mini Park

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 ENVIRONMENTAL CONSEQUENCES
TABLE 3-4 CONTINUED
PARKS WITHIN THE OPERATION ROI

Park
ID
624
625
627
631
633

Name
1776 Park
City Of Webster
Independence Park
Egret Bay Villas
Green Acres

Park Type
Neighborhood Park
Community Park
Athletic Facility
Mini Park
Mini Park

634
639
640
641
647
650

Aaron Pasternak Memorial Park
Randolph Park
Howard L Ward Park
Woodcreek
Portofino Village
Timber Creek

Mini Park
Urban Park
Neighborhood Park
Mini Park
Mini Park
Golf Course

651
652
653
654
655
657

Hyde Park
Clear Lake Park
Clear Lake Park
Unknown
Golfcrest Country Club
Sterling Knoll Park

Mini Park
Recreational Sports Facility
Neighborhood Park
Urban Park
Golf Course
Mini Park

658
659

Zychlinski Park
Clear Lake Golf Club

Mini Park
Golf Course

662
671

Williams Park
Unknown

Recreational Sports Facility
Sports Fields

673
677
678
679
684
688
689
690
691
697
698
699

Armand Bayou Park
Sagemeadow Park
Rodriguez (Sylvan) Park
Rodriguez (Sylvan) Park
Unknown
Rodriguez (Sylvan) Park
Unknown
Kirkwood South Park
Twin Creek Woods
Sagemont Park
Oasis Garden At Bay Area Park
Jones Park

Regional Park
Mini Park
Mini Park
Mini Park
School Park
Regional Park
Mini Park
Recreational Sports Facility
Mini Park
Community Park
Recreational Sports Facility
Recreational Sports Facility

701
705
706
710

Roy D. Kipper Mease Park
Blackhawk Park
Beverly Hills Park
Pasadena Ellington Golf Club

Regional Park
Urban Park
Recreational Sports Facility
Golf Course

715
726

Gulf Palms Park
Unknown

Community Park
Recreational Sports Facility

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3-16

 ENVIRONMENTAL CONSEQUENCES
TABLE 3-4 CONTINUED
PARKS WITHIN THE OPERATION ROI

Park
ID
726
731
734
740
744

Name
Unknown
Wilson Memorial Park
Fairmont Estates
Fairmont Park
Parkgate North

Park Type
Recreational Sports Facility
Community Park
Neighborhood Park
Recreational Sports Facility
Mini Park
Parks/Flood Control/Retention
Regional Park
Mini Park

1695
1703
1704
1705

Southbelt Hike And Bike Trail
El Franco Lee Park
Clear Creek Crossing
Bay Colony Parkside Community
Park
Bay Colony Parkside Community
Park
Leisure Lakes Community Park
Centennial Park
Friendswood Sports Park
Polly Ranch

1757
1776
2067
2177
2178
2184

Holly Bay Court Park
Burke/Crenshaw Park
Unknown
Dixie Farm Road Park
Oxnard Park
Heritage Park Hike And Bike Trail

Urban Park
Urban Park
Neighborhood Park
Urban Park
Community Park
Parks/Flood Control/Retention

2221
3232
3234
3553
3554
3555

Kingspoint Dog Park
Westover Park
Unknown
Unknown
Unknown
Unknown

Community Park
Neighborhood Park
Regional Park
Nature Conservancy/ Reserves/Wetlands
Nature Conservancy/ Reserves/Wetlands
Nature Conservancy/ Reserves/Wetlands

3626
3629
3630
3634

Unknown
Unknown
Alvin Branch Library
Unknown

Library
Library
Library
Library

1452
1478
1692
1693
1694

Mini Park
Neighborhood Park
Mini Park
Urban Park
Sports Fields
Community Park

Source: HGAC Parks Score Viewer, http://arcgis02.h-gac.com/park_score/index.html, accessed May 2014.

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 ENVIRONMENTAL CONSEQUENCES
EFD is located in the Upper Coastal Prairie Grasslands of the Gulf Prairies and Marshes of Texas’s
biogeographic area. Most of the Coastal Prairie has been converted to row crops or tame pasture.
Overgrazing and fire suppression have also led to the increase of native and introduced woody species.
These include the Chinese tallow tree (Sapium sabiferum), Huisache (Acacia farnesiana), Macartney rose
(Rosa bracteata), and Honey mesquite (Prosopis glandulosa).
Table 3-5 shows the federally listed threatened and endangered species for the counties intersecting the
operation ROI (Brazoria, Galveston, and Harris). Table 3-6 shows the state status for the species found in
the counties intersecting the operation ROI. As noted in the U.S. Fish and Wildlife Service (USFWS) letter in
response to an early coordination letter (see Appendix A), freshwater mussels are candidates for listing
under the ESA and may occur in various regions throughout Texas. Texas Parks and Wildlife lists the Texas
fawnsfoot (Truncilla macrodon) as occurring in Brazoria County. A small area of designated critical habitat
for the piping plover (Charadrius melodus) exists in the operation ROI at the southwestern end of
Galveston Island. This area is located over 30 miles from EFD.
The majority of the area within the construction ROI is either previously disturbed or paved. In 2001, the
giant sharpstem umbrella-sedge (Cyperus cephalanthus) was observed two miles northeast of EFD. In
1984, the Texas windmill-grass (Chloris texensis) was observed two miles southwest of EFD. Both plant
species are listed as species of concern in Texas (HAS, 2013b).
In many areas of the EFD property, native plants have been replaced with cultivated turf and ornamental
shrubs. Most unpaved areas are cleared and maintained regularly. As described in the June 2013 Ellington
Airport Self-Service Fueling Facility EA, no threatened or endangered species, species or habitat of
concern, or critical habitat are currently known to exist within the EFD property (HAS, 2013b). According to
the HAS 2004 Comprehensive Master Plan for EFD, suitable habitat for the federal and state endangered
Texas prairie dawn (Hymenoxys texana) is common in undeveloped portions of EFD environs, particularly
to the east of EFD (HAS, 2004a). HAS currently mows and maintains this area for hay production. The state
endangered Houston Toad (Bufo houstonensis) was observed at EFD until 1973. According to the USFWS,
it is likely the Houston toad is no longer in Harris County (USFWS, 2011).
The MBTA and EO 13186, Responsibilities of Federal Agencies to Protect Migratory Birds, provide protection
to all migratory birds (including their eggs, active nests, and bird parts) within the United States. Texas is
part of the Central Flyway as defined by the USFWS. Species included on MBTA may utilize the Central
Flyway. Bald eagles are also known to occur in Harris and Brazoria counties. According to Texas Parks and
Wildlife, the bald eagle’s nesting range includes Harris and Brazoria counties (TPW, 2013). There are
colonial waterbird rookeries present in the operation ROI. The closest rookery to the construction ROI is
approximately 24.5 miles south in West Bay. Figure 3-5 shows the colonial waterbird rookeries and
designated critical habitat for the piping plover within the operation ROI. Fourteen bird strikes were
reported at EFD in 2012 (FAA, 2013d).

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 ENVIRONMENTAL CONSEQUENCES
TABLE 3-5
FEDERALLY LISTED THREATENED AND ENDANGERED SPECIES
IN BRAZORIA, GALVESTON, AND HARRIS COUNTIES

Common Name
Birds
Attwater's Greater PrairieChicken
Brown Pelican
Eskimo curlew
Piping Plover
Whooping Crane
Mammals
West Indian Manatee
Reptiles
Green Sea Turtle
Hawksbill Sea Turtle
Kemp's Ridley Sea Turtle
Leatherback Sea Turtle
Loggerhead Sea Turtle
Plants
Texas Prairie Dawn

Scientific Name

Federal
Status/a/

County(ies) Where
Listed

Tympanuchus cupido
attwateri
Pelecanus occidentalis
Numenius borealis
Charadrius melodus
Grus americana

E

Galveston

DM
E
E,T
E, EXPN

Brazoria, Galveston
Galveston
Brazoria, Galveston
Harris, Galveston

Trichechus manatus

E

Brazoria, Galveston

Chelonia mydas
Eretmochelys imbricata
Lepidochelys kempii
Dermochelys coriacea
Caretta caretta

E,T
E
E
E
T

Brazoria, Galveston
Brazoria, Galveston
Brazoria, Galveston
Brazoria, Galveston
Brazoria, Galveston

Hymenoxys texana

E

Harris

/a/Status:

E – Endangered, T -Threatened; DM - Recovered, Delisted and Being Monitored; EXPN – Experimental Essential
Population
Source: U.S. Fish and Wildlife Service, County by County Species List, http://www.fws.gov/southwest/es/ES_Lists_Main.cfm,
accessed May 2014.

TABLE 3-6
TEXAS PARKS AND WILDLIFE DEPARTMENT’S LISTED SPECIES
IN BRAZORIA, GALVESTON, AND HARRIS COUNTIES

Common Name

Scientific Name

State
Status/a/

County(ies)

T
R
E

Harris, Brazoria, Galveston
Harris, Brazoria, Galveston
Galveston

Bald Eagle
Black Rail
Brown Pelican
Eskimo Curlew
Henslow's Sparrow
Mountain Plover

Falco peregrinus anatum
Falco peregrinus tundrius
Tympanuchus cupido
attwateri
Haliaeetus leucocephalus
Laterallus jamaicensis
Pelecanus occidentalis
Numenius borealis
Ammodramus henslowii
Charadrius montanus

T
R
R
E
R
R

Harris, Brazoria, Galveston
Harris, Brazoria, Galveston
Harris, Brazoria, Galveston
Brazoria, Galveston
Harris, Brazoria, Galveston
Harris, Galveston

Peregrine Falcon
Piping Plover

Falco peregrinus
Charadrius melodus

T
T

Harris, Brazoria, Galveston
Brazoria, Galveston

Birds
American Peregrine Falcon
Arctic Peregrine Falcon
Attwater's Greater Prairie-Chicken

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 ENVIRONMENTAL CONSEQUENCES
TABLE 3-6 CONTINUED
TEXAS PARKS AND WILDLIFE DEPARTMENT’S LISTED SPECIES
IN BRAZORIA, GALVESTON, AND HARRIS COUNTIES

Common Name
Birds Continued
Red-cockaded Woodpecker
Reddish Egret
Snowy Plover
Sooty Tern
Southeastern Snowy Plover
Sprague's Pipit
Western Snowy Plover
White-faced Ibis
White-tailed Hawk
Whooping Crane
Wood Stork
Mammals
Jaguarundi
Louisiana Black Bear
Plains Spotted Skunk
Ocelot
Rafinesque's Big-eared Bat
Red wolf
Southeastern Myotis Bat
West Indian Manatee
Fishes
American Eel
Creek Chubsucker
Sharpnose Shiner
Smalltooth Sawfish
Mollusks
Little Spectaclecase
Louisiana Pigtoe
False Spike Mussel
Sandbank Pocketbook
Smooth Pimpleback
Texas Fawnsfoot
Texas Pigtoe
Wabash Pigtoe
Amphibians
Houston Toad

Scientific Name

State
Status/a/

County(ies)

Picoides borealis
Egretta rufescens
Charadrius alexandrinus
Sterna fuscata
Charadrius alexandrinus
tenuirostris
Anthus spragueii
Charadrius alexandrinus
nivosus
Plegadis chihi
Buteo albicaudatus
Grus americana
Mycteria americana

E
T
R
T
R

Harris
Galveston
Harris, Brazoria, Galveston
Brazoria
Harris, Brazoria, Galveston

R
R

Harris, Galveston
Brazoria,

T
T
E
T

Harris, Galveston
Harris, Galveston
Harris, Galveston
Harris, Galveston

Herpailurus yaguarondi
Ursus americanus luteolus
Spilogale putorius interrupta
Leopardus pardalis
Corynorhinus rafinesquii
Canis rufus
Myotis austroriparius
Trichechus manatus

E
T
R
E
T
E
R
E

Brazoria
Harris, Galveston
Harris, Galveston
Brazoria
Harris
Harris, Brazoria, Galveston
Harris
Brazoria, Galveston

Anguilla rostrata
Erimyzon oblongus
Notropis oxyrhynchus
Pristis pectinata

R
T
R
E

Galveston
Harris
Brazoria
Harris, Galveston

Villosa lienosa
Pleurobema riddellii
Quadrula mitchelli
Lampsilis satura
Quadrula houstonensis
Truncilla macrodon
Fusconaia askewi
Fusconaia flava

R
T
T
T
T
T
T

Harris
Harris
Brazoria
Harris
Brazoria
Brazoria
Harris
Harris

Anaxyrus houstonensis

E

Harris

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 ENVIRONMENTAL CONSEQUENCES
TABLE 3-6 CONTINUED
TEXAS PARKS AND WILDLIFE DEPARTMENT’S LISTED SPECIES
IN BRAZORIA, GALVESTON, AND HARRIS COUNTIES

Common Name
Reptiles
Alligator Snapping Turtle
Atlantic Hawksbill Sea Turtle
Green Sea Turtle
Gulf Saltmarsh Snake
Kemp's Ridley Sea Turtle
Leatherback Sea Turtle
Loggerhead Sea Turtle
Texas Diamondback Terrapin
Texas Horned Lizard
Smooth Green Snake
Timber/Canebrake Rattlesnake
Plants
Coastal Gay-feather
Correll's False Dragon-head
Florida Ladies-tresses
Giant Sharpstem Umbrellasedge
Grand Prairie Evening Primrose
Houston Daisy
Neglected Coneflower
Panicled Indigobush
Texas Ladies'-tresses
Plants Continued
Texas Meadow-rue
Texas Prairie Dawn
Texas Windmill-grass
Threeflower Broomweed
/a/

Scientific Name

State
Status/a/

County(ies)

Macrochelys temminckii
Eretmochelys imbricata
Chelonia mydas
Nerodia clarkii
Lepidochelys kempii
Dermochelys coriacea
Caretta caretta
Malaclemys terrapin littoralis
Phrynosoma cornutum
Liochlorophis vernalis
Crotalus horridus

T
E
T
R
E
E
T
R
T
T
T

Harris, Brazoria, Galveston
Brazoria, Galveston
Harris, Brazoria, Galveston
Harris, Brazoria, Galveston
Harris, Brazoria, Galveston
Harris, Brazoria, Galveston
Harris, Brazoria, Galveston
Brazoria, Galveston
Brazoria, Galveston
Harris
Harris, Brazoria, Galveston

Liatris bracteata
Physostegia correllii
Spiranthes brevilabris var.
floridana
Cyperus cephalanthus

R
R
R

Harris, Brazoria, Galveston
Galveston
Harris

R

Harris, Brazoria,

Oenothera pilosella ssp
sessilis
Rayjacksonia aurea
Echinacea paradoxa var.
neglecta
Amorpha paniculata
Spiranthes brevilabris var.
brevilabris

R

Galveston

R
R

Harris, Galveston
Harris

R
R

Harris
Harris, Galveston

Thalictrum texanum
Hymenoxys texana
Chloris texensis
Thurovia triflora

R
E
R
R

Harris, Brazoria,
Harris
Harris, Brazoria, Galveston
Harris, Brazoria, Galveston

Status: LE, LT - Federally Listed Endangered/Threatened; C - Federal Candidate for Listing; DL - Federally Delisted; NL -

Not Federally Listed; E, T - State Listed Endangered/Threatened; R - Rare, but no regulatory listing status.
Source: Texas Parks and Wildlife Department, Wildlife Division, Diversity and Habitat Assessment Programs. County Lists of
Texas’ Special Species. Harris, Brazoria and Galveston Counties, Sept. 2013

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 ENVIRONMENTAL CONSEQUENCES
FIGURE 3-5
FEDERALLY DESIGNATED CRITICAL HABITAT AREAS

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 ENVIRONMENTAL CONSEQUENCES

3.7 FLOODPLAINS
Floodplains are flood prone areas adjacent to rivers, creeks, ditches, lakes, or other surface water features.
Floodplains can also be isolated areas adjacent to water sources that experience temporary ponding.
Large storm events, downstream constrictions, or obstructions typically cause flooding in these areas.
FEMA, often assisted by the U.S. Army Corps of Engineers (USACE), determines the boundaries of
floodplains based on hydraulic modeling. FIRMs show the results of this modeling. Areas within the 100year floodplain (Zone A) have a one percent chance of becoming flooded each year.
In addition to the risk and safety concerns for property and human life, development in a floodplain can
impact on the amount of flood storage the floodplain can provide. As a result, federal, state, and local
agencies regulate construction within the 100-year floodplain. EO 11988 – Floodplain Management
regulates federally-approved or funded projects that encroach on floodplains. USDOT Order 5650.2,
Floodplain Management and Protection, requires FAA, as a USDOT agency, to meet the EO’s requirements.
FEMA’s Floodplain Management Guidelines provides information on how to meet those requirements.
According to FEMA mapping, the construction ROI includes areas delineated as 100-year floodplains.
These floodplains are associated with existing storm water detention ponds, which are incorporated into
drainage infrastructure and Horsepen Bayou and flows southeast to Clear Lake (USGS, 2013a). FEMA FIRM
data was used to create an inventory of existing 100-year floodplains on EFD property. Figure 3-6
presents the location and extent of the delineated 100-year floodplains within the construction ROI.

3.8 HAZARDOUS MATERIALS, POLLUTION PREVENTION, AND SOLID WASTE
An airport’s airside and landside operations use, transport, or generate various kinds of hazardous
materials. For example, ground vehicles regularly transport hazardous materials such as jet fuels to EFD.
Aircraft fueling trucks and hydrant systems also transport hazardous materials to EFD. In addition, airport
construction and maintenance activities often use chemicals classified as hazardous materials. Various
federal, state, and local laws regulate the use, storage, transportation, or disposal of hazardous materials.
These laws may extend to past, present, and future landowners of properties containing these materials.
Additionally, disrupting sites containing hazardous materials may create pathways allowing contaminants
to effect human health and the environment.
Applicable federal requirements22 used to assess hazardous waste effects include:

22

»

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
(42 U.S.C. § 9601);

»
»
»

the Oil Pollution Prevention Act of 1990 (33 U.S.C. § 2701);
Toxic Substances Control Act (TSCA) (15 U.S.C. § 2601-2692);
Resource Conservation and Recovery Act (RCRA) (42 U.S.C. § 6901 et. seq.);

Note that due to the number of federal laws and EOs applicable to the Proposed Action, this Section presents only the legal

citations or references for those requirements in lieu of summarizing their requirements. Please see FAA’s Desk Reference, Chapter
10, Section 2, for more information on these requirements.

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 ENVIRONMENTAL CONSEQUENCES
FIGURE 3-6
100-YEAR FLOODPLAINS

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 ENVIRONMENTAL CONSEQUENCES

»
»
»

Clean Water Act (CWA) (33 U.S.C. § 1251 et. seq.);
EO 12088, Federal Compliance with Pollution Control Standards (43 FR 47707);
EO 12856, Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements
(58 FR 41981); and

»

EO 12580, Superfund Implementation (52 FR 2923).

Generally, the terms "hazardous wastes," "hazardous substances," and "hazardous materials" are
associated with industrial wastes, petroleum products, dangerous goods or other contaminants. In a
regulatory context, these terms have very precise and technical meanings:

»

Hazardous Wastes: Subpart C of the RCRA defines this term. Hazardous wastes (sometimes called
characteristic wastes) are solid wastes that are ignitable, corrosive, reactive, or toxic. Examples
include waste oil, mercury, lead or battery acid. In addition, Subpart D of RCRA contains a list of
specific types of solid wastes that the EPA has deemed hazardous (sometimes called listed
wastes). Examples include degreasing solvents, petroleum refining waste, or pharmaceutical
waste.

»

Hazardous Substances: Section 101(14) of the CERCLA defines this term broadly. It includes
hazardous wastes, hazardous air pollutants, or hazardous substances designated as such under
the CWA and TSCA and elements, compounds, mixtures, or solutions, or substances listed in 40
CFR Part 302 that pose substantial harm to human health or environmental resources. Pursuant to
CERCLA, hazardous substances do not include any petroleum or natural gas substances and
materials. Examples include ammonia, bromine, chlorine, or sodium cyanide.

»

Hazardous Materials: According to 49 CFR Part 172, hazardous materials are any substances
commercially transported that pose unreasonable risk to public health, safety, and property.
These substances include hazardous wastes and hazardous substances as well as petroleum and
natural gas substances and materials. As a result, hazardous materials represent hazardous wastes
and substances. Examples include household batteries, gasoline, or fertilizers.

There are no sites within the Construction ROI that are included on the EPA National Priorities List (NPL).
An abandoned landfill, known as the Harris (Farley Street) Site, was listed on the EPA NPL from 1982-1988.
It was removed from the NPL after a contaminated soil removal effort, and is part of the operating
solid-waste landfill (USEPA, 2013b).There are a number of USEPA regulated CERCLA, TSCA, and RCRA sites
within the Construction ROI. Figure 3-7 shows the location of each of these sites.
Specific to the EFD property, the USEPA currently lists “Ellington Field” (Handler ID: TXD981057946) and
Ellington Field 147 Fighter Wing (Handler ID: TX1572824067) as hazardous waste sites under RCRA. USEPA
also lists Continental Express (Handler ID: TXD988071817) and United Postal Service at Ellington (Handler
ID: TXD988089207) as hazardous waste sites on EFD property. These sites are located in the western
portion of EFD.23 The “U.S. Air Force Texas ANG JRB 147th Fighter Wing” (Registry ID: 110025317351) is
also listed as a toxic release site on EFD property.

23

Note that Continental Express and United Postal Service are no longer tenants at EFD.

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FIGURE 3-7
USEPA REGULATED FACILITIES

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The closest TSCA site to EFD is Avanti International (Registry ID: 110035825033), less than 0.5-mile
southwest of EFD. The closest Superfund site under CERCLA is Harris Landfill (Registry ID: 110009346243)
(USEPA, 2013a).
Hazardous materials are used and managed at EFD. HAS has policies and procedures in place for
managing and disposing of hazardous and solid wastes in accordance with applicable regulations. These
policies and procedures cover the handling of hazardous materials, solid waste, chemicals, and other
substances, including jet fuel.
Stormwater at EFD is managed under the provisions of EFD’s Storm Water Pollution Prevention Plan
(SWPPP), in accordance with its TPDES Stormwater Multi-Sector General Permit (Permit Number
TXR05T730).

3.8.1

Petroleum Fuels and Existing Fuel Farm

By volume, petroleum fuels such as Jet-A fuel, diesel, and gasoline for ground support vehicles are the
primary hazardous materials stored at EFD. The storage of petroleum is regulated under 40 CFR 112 and
managed under provisions of EFD’s Spill Prevention Control and Countermeasures (SPCC) Plan.
EFD currently has an aboveground storage tank fuel farm located at the southern side of the property.
Fuel is regularly transported to the individual tenants by truck. There are no underground pipelines or
hydrants. Southwest Services supplies fuel for all non-military tenants at EFD from storage tanks holding
140,000 gallons of Jet A and 18,000 gallons of 100LL fuel. Southwest Services operates seven fuel tanker
trucks, including four 5,000-gallon trucks used to transport Jet A, two 750-gallon 100LL trucks, and one
1,200-gallon de-fueler. According to the July 2013 EA for a self-service fueling facility at EFD, the average
monthly fuel flowage from Southwest Services is approximately 300,000 gallons (HAS, 2013b).
In addition, the TxANG maintains one 10,000-gallon floating roof tank and two 30,000-gallon horizontal
tanks which store JP-8. The TxANG has between seven and eight fuel trucks that transport fuel to
helicopters and other aircraft. Typical annual fuel consumption varies between 2-5 million gallons. HAS
maintains eleven smaller aboveground fuel tanks that are primarily used to supply backup generators. The
total combined capacity of these tanks is approximately 11,750 gallons (HAS, 2004b).

3.8.2

Other Hazardous Materials

In addition to petroleum based fuels, lesser quantities of various hazardous materials are used on an ongoing basis for airport operations. These may include: solvents, lubricants, cleaners, paints, compressed
gases, peroxides, caustics, pesticides, herbicides, alcohols, foams, and batteries. These materials may be
used for a wide range of operational purposes including maintenance of aircraft, ground vehicles and
facilities, heating and cooling, painting and paint stripping, cleaning, landscaping, and pest control. These
materials are used in relatively small amounts and are managed under existing SOPs at EFD.

3.8.3

Existing Contamination Concerns

Due to its history as a former U.S. Air Force base, past industrial activities at EFD involved the use of
hazardous materials that could have resulted in contamination. Figure 3-8 shows the sites of potential

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hazardous materials contamination at EFD. Potential hazardous materials issues may include soil and/or
groundwater contamination from leaking fuel tanks or spills from fueling operations. Other potential
contaminants include:

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polychlorinated biphenyls (PCBs) related to electrical generators and transformers;
asbestos in existing buildings;
paint and cleaning solvents; and
lead contamination on the site of a former military firing range (HAS, 2013b).

According to the July 2013 EA, several underground petroleum storage tanks were operated at EFD. In the
1990’s, the City of Houston began efforts to remove underground storage tanks. The July 2013 EA
identified six areas with leaking underground storage tanks. The EA noted these sites have been
completely remediated and TCEQ has closed the cases regarding those sites (HAS, 2013b).
Areas where tenants such as the TxANG and the USCG own and operate their own fuel storage tanks,
waste oil storage, and backup generators show evidence of fuel spill contamination. These areas represent
potential sources of soil and/or groundwater contamination. According to the USEPA NEPAssist, the
TxANG is a toxic release site under TSCA (USEPA, 2013a).
Several sites at EFD housed electrical generators which often contain PCB’s. The City of Houston
successfully undertook a program to remove PCB’s by replacing a majority of the electrical equipment.
However, the presence of PCB’s indicates a potential source of soil and/or groundwater contamination.
Given the age of some buildings at EFD, asbestos also poses certain concerns. The 2004 Phase I screening
analysis observed there may be the presence of asbestos in the older buildings at EFD. There is also a
heavy metal contamination site (i.e., lead contaminants) at the “military firing range” located on the U.S.
Military portion at the southern end of EFD. There are also several sites at EFD where hazardous wastes
are stored.
At the time of transfer from the U.S. Government to the City of Houston in 1984, an environmental impact
statement (EIS) was conducted and an environmental cleanup was completed. In the 2004 Airport Master
Plan Update, a Phase I analysis was conducted and concluded there may be potential hazardous materials
located predominately along the western periphery of the apron area. The July 2013 EA for a self-service
fueling facility at EFD included an analysis of potential hazardous materials sites, which is incorporated
into this analysis.

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FIGURE 3-8
POTENTIAL HAZARDOUS MATERIAL LOCATIONS AT EFD

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3.9 HISTORICAL, ARCHITECTURAL, ARCHAEOLOGICAL, AND CULTURAL
RESOURCES
The National Historic Preservation Act (NHPA) of 1966, as amended, established the Advisory Council on
Historic Preservation (ACHP). The ACHP oversees federal agency compliance with the NHPA. The NHPA
also establishes the NRHP, which the National Park Service (NPS) oversees. Other applicable statues
include:

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The Archeological and Historic Preservation Act of 1974 (AHPA) (16 U.S.C. § 470 et. seq.);
The American Indian Religious Freedom Act of 1978 (AIRFA) (42 U.S.C. § 1996);
EO 13007, Indian Sacred Sites (61 FR 26771); and
EO 13175, Consultation and Coordination with Indian Tribal Governments (36 FR 8921).

For purposes of this EA, historic, archaeological, and cultural resources are districts, sites, buildings,
structures, objects, landscapes, and Native American Traditional Cultural Properties recorded by the Texas
Historical Commission (THC) as Historical Markers, or on or eligible for listing on the NRHP. NRHP
properties are nationally important due to their significant and respective roles in American history,
prehistory, architecture, archaeology, engineering and culture. Historical markers recognize the history
and architecture of houses, buildings, religious congregations, military sites, and events or individuals that
THC has determined to have made lasting contributions to the State (THC, 2013).
In accordance with 36 CFR §800.4(a)(1), the FAA has established an Area of Potential Effect (APE) for the
proposed undertaking (i.e., Proposed Action) (see Appendix D). The FAA determined an APE in
consideration of both potential direct and indirect effects to archaeological and architectural resources as
a result of implementing the undertaking.
The APE is defined as the area encompassed by the existing Day-Night Average Sound Level (or DNL) 65
A-weighted decibel (or dBA) aviation noise contour (see Figure 3-9) and potential ground disturbing
activities. The APE encompasses all potential direct and indirect effects on archaeological and architectural
resources. Although this APE does not account for the additional noise that would be generated from up
to 50 annual RLV launches, based on the existing number of annual flights at EFD (approximately 144,702)
and the fact that the RLVs would use jet engines during takeoff and landing (the Concept Z vehicle would
conduct an unpowered, glide landing), it is unlikely the existing DNL 65 dBA aviation noise contour would
change notably (see Section 4.12 for further details).
The RLVs would generate sonic booms over the Gulf of Mexico during RLV ascent and reentry. During
ascent, the sonic boom would be propagated upwards and would not impact the Earth’s surface and
therefore, would not be heard. A second sonic boom would be generated during RLV reentry, at
approximately 80,000 feet over the Gulf of Mexico. This sonic boom would impact the water surface of
the Gulf of Mexico and would not be heard on land. Therefore, sonic booms were not considered when
defining the APE because they would have no potential for effect on historic properties.

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FIGURE 3-9
AREA OF POTENTIAL EFFECT (APE)

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For archaeological resources, potential effects would be limited to the area within the APE where ground
disturbance would occur from construction of the hangar, hangar access road and parking area, apron,
fencing around the apron, taxiway, and propellant truck parking area. The oxidizer loading area is
currently a paved area. For architectural resources, potential effects would extend to the boundary of the
APE. On June 6, 2014, the Texas State Historic Preservation Officer concurred with the FAA’s materials
provided, including the establishment of the APE (see Appendix D).
As shown in Figure 3-9, there are no NRHP-listed resources within the APE. Based on the THC Atlas,
NRHP, and coordination with the THC, the FAA has determined that there are also no properties eligible
for the NRHP within the APE. The closest THC historic landmark is the Webster Presbyterian Church,
approximately four miles southeast of EFD.

3.10 LIGHT EMISSIONS AND VISUAL RESOURCES
Many airside and landside structures on EFD property are illuminated during nighttime hours for security
and safety reasons. EFD also operates lighting infrastructure required for navigational and safety purposes
during night hours and times of inclement weather. The approach and lighting system at EFD is composed
of a variety of systems approved for the safe movement of aircraft including:

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airport beacon (green/white)
medium intensity approach lighting system with runway alignment indicator lights (MALSR);
centerline lights; and
lighted touchdown point.

Vegetation and development (e.g., trees, shrubs, roadways, and commercial and industrial buildings)
provide buffers between nearby residential areas and current EFD light emissions. The surrounding area is
also at a similar elevation as EFD. There is no dramatic height difference in landforms between EFD and
the residential neighborhoods to the north and east. Surrounding residential areas do not have a direct
view of EFD.

3.11 NATURAL RESOURCES AND ENERGY SUPPLY
It is FAA policy, consistent with CEQ NEPA implementing regulations, to encourage the development of
facilities that exemplify the highest standards of design, including the principles of sustainability. These
high standards should apply to the conservation of energy and other resources.
EFD does not currently have a sustainability program or green initiatives in place; however, other HAS
airports have pursued sustainability initiatives. HAS’s vehicle fleet includes hybrid vehicles purchased with
the aid of federal grants from the FAA's Voluntary Airport Low Emission (VALE) program.

3.12 NOISE
The U.S. Congress has determined that aviation noise effects fall under FAA’s purview. The following
statutes are related to the consideration of noise impacts:

»

Airport and Airway Improvement Act of 1982 (AAIA) (49 U.S.C. § 4701 et. seq.);

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Airport Noise and Capacity Act (ANCA) (49 U.S.C. § 2101 et. seq.);
Aviation Safety and Noise Abatement Act of 1979 (ASNA) (49 U.S.C. § 47501-47507);
The Control and Abatement of Aircraft Noise and Sonic Boom Act of 1968 (49 U.S.C. § 47101); and
The Noise Control Act of 1972 (49 U.S.C. § 44715).

Humans are most sensitive to frequencies near the normal range of speech communications. The “Aweighting” scale reflects this sensitivity by emphasizing mid-range frequencies and de-emphasizing high
and low frequencies. A better predictor of human reaction to environmental noise than the un-weighted
decibel is dBA, and is therefore the basis for the metrics most frequently used in noise compatibility
planning (Chantlett, 1973).
In addition to the frequencies of noise sources, research shows that the loudness of individual events, the
number of events during a given period, and the time of day in which noise events occur influences the
sensitivity to noise. The DNL accounts for these factors by accumulating the sound energy generated by
all noise events during the course of a given period (typically an annual average day) with a 10 dBA
penalty to sound levels occurring between 10:00 p.m. and 6:59 a.m. This 10 dBA penalty means that one
nighttime sound event is equivalent to 10 daytime events of the same level.
DNL has been widely accepted as the best available method to describe aircraft noise exposure. The
USEPA identifies the DNL as the principal metric for airport noise analysis. The FAA requires DNL as the
noise descriptor for use in aircraft noise exposure analysis and noise compatibility planning. DNL levels
are commonly shown as lines of equal noise exposure, similar to terrain contour maps.
In December 2009 and February 2010, the City of Houston established land use regulations around IAH,
HOU, and EFD. These regulations created land use tier boundaries with certain restrictions to protect
these airports from encroachment of sensitive developments. Additionally, it instituted rules for providing
land use permits that would allow compatible developments within the boundaries. Section 3.4 provides
further details on these tiers. Figure 3-10 shows EFD’s existing DNL 65 – 75 dBA noise contours.

3.13 SOCIOECONOMICS, ENVIRONMENTAL JUSTICE, AND CHILDREN’S HEALTH
AND SAFETY RISKS
This section describes the existing demographics within the operation ROI as they related to
socioeconomics, environmental justice, and children’s environmental health and safety risks.

3.13.1 Socioeconomics
Among other requirements, Section 101(a) of NEPA notes the policy of the federal government is to
create and maintain conditions that fulfill the social needs of present and future American generations.
Demographic data for the construction ROI and the operation ROI is included as the basis for evaluating
potential future growth in the region and potential economic impacts. Figures 3-11 and 3-12 depict the
population growth from 2010 to 2012 in the construction and operation ROIs, respectively.

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FIGURE 3-10
EXISTING DNL 65 – 75 DBA NOISE CONTOURS AND EFD TIER BOUNDARIES

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FIGURE 3-11
PERCENT INCREASE IN POPULATION (2010-2012) WITHIN THE CONSTRUCTION ROI

Harris County

Harris County and the City of
Houston have a growth rate 2
times that of the construction

City of Houston

ROI.
Constructin ROI
0%

1%

2%

3%

4%

Source: American Fact Finder, 2014; U.S. Census Bureau, State and County Quick Facts, 2012

FIGURE 3-12
PERCENT INCREASE IN POPULATION (2010-2012) WITHIN THE OPERATION ROI

United States

Texas and the counties
intersecting the operation ROI
have a growth rate almost 2
times that of the U.S. as a

Texas
Harris County

whole.

Brazoria County
Galveston County
0%

1%

2%

3%

4%

Source: U.S. Census Bureau, State and County Quick Facts, 2012

Surface Transportation - Roadways within the construction ROI include Galveston Road/Highway 3,
Sam Houston Tollway, and Space Center Boulevard. Based on the 2013-2016 Transportation Improvement
Program, none of these roadways are planned for improvements (H-GAC, 2012). Galveston Road/
Highway 3 is the main road serving EFD. Galveston Road has a northwest-southeast orientation with four
lanes. It borders the southeast portion of EFD property. Galveston Road provides access to Sam Houston
Tollway and Interstate 45. Sam Houston Tollway is north-northwest of EFD. There is not direct access to
EFD from Sam Houston Tollway. Space Center Boulevard borders the eastern portion of EFD property.
Space Center Boulevard has a north-south orientation with four lanes. This roadway connects the Clear
Lake area neighborhood southeast of EFD with Genoa Red Bluff Road, just north of EFD.

3.13.2 Environmental Justice
EO 12898 requires federal agencies to analyze project effects relative to low-income and minority
populations. Environmental justice analysis considers the potential of a proposed action and alternatives
to cause disproportionate and adverse effects on low-income or minority populations. The analysis of
environmental justice impacts and associated mitigation ensures that no low-income or minority

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population bears a disproportionate burden of effects resulting from the implementation of a preferred
alternative.
To help describe environmental justice, this EA relies on the instructions in FAA Order 1050.1E,
Appendix A, Section 16, which is consistent with the USDOT Order 5610.2 on Environmental Justice.
Poverty is measured two ways within the U.S. – poverty thresholds and poverty guidelines. Poverty
thresholds are the original version of the federal poverty measure and are updated each year by the U.S.
Census Bureau. The thresholds are used mainly for statistical purposes – for instance, preparing estimates
of the number of Americans in poverty each year.
Poverty guidelines are issued each year in the FR by the Department of Health and Human Services
(DHHS). These guidelines are a simplification of the poverty thresholds for administrative purposes
including determining financial eligibility for certain federal programs. Table 3-7 lists the 2013 poverty
guidelines for the 48 contiguous states and District of Columbia.
TABLE 3-7
2013 POVERTY GUIDELINES

Persons in family/household/a/
1

Poverty Guideline
$11,490

2

$15,510

3
4

$19,530
$23,550

5

$27,570

6

$31,590

/a/

For the 48 contiguous states and the District of Columbia

Source: DHHS. www.aspe.hhs.gov, accessed September 2013.

Figure 3-13 compares the poverty level of the construction ROI to the City of Houston and Harris County.
Poverty level data is not available at the U.S. Census block group level, therefore Figure 3-13 uses data at
the U.S. Census Tract level. Based on the average household size and median household income for each
block group within the construction ROI, the majority of the population is above the poverty threshold.
The lowest median household income within the construction ROI is $37,114, with an average household
size of 2.92.

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FIGURE 3-13
PERCENTAGE OF INDIVIDUALS BELOW THE POVERTY LEVEL WITHIN THE CONSTRUCTION ROI (2008-2012)

Harris County

The percentage of individuals
in the construction ROI below
the poverty level is less
compared to the City of
Houston and Harris County.

City of Houston

Construction ROI
0%

5%

10%

15%

20%

25%

Source: U.S. Census Bureau, State and County Quick Facts, 2012; American Community Survey, 2010

Figure 3-14 illustrates the 2012 median household income within the construction and operation ROIs,
which is dominated by middle and upper income ranges. The Construction ROI consists mainly of median
household incomes of $53,001 or more. The southwestern portion of the Construction ROI does have
areas with median household incomes of $24,001 to $53,000. The majority of the operation ROI has a
median household income above $39,001. Small pockets with median household incomes of $24,000$39,000 exist in the southern and northern portion of the Operation ROI.
Figure 3-15 compares the poverty level of the United States with Texas and the counties intersecting the
operation ROI.

FIGURE 3-14
PERCENTAGE OF INDIVIDUALS BELOW THE POVERTY LEVEL WITHIN THE OPERATION ROI (2008-2012)

United States
The percentage of individuals
in the operation ROI below
the poverty level is not
significantly different from
the U.S. and Texas.

Texas
Harris County

Brazoria County
Galveston County
0%

5%

10%

15%

20%

Source: U.S. Census Bureau, State and County Quick Facts, 2012

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FIGURE 3-15
2012 MEDIAN HOUSEHOLD INCOME

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Figure 3-16 demonstrates the race and ethnicity characteristics of the construction ROI in comparison to
the City of Houston and Harris County. Figure 3-17 compares the race and ethnicity characteristics of the
U.S. compared to Texas and the counties within the operation ROI. Figure 3-18 illustrates the race
characteristics within the construction and operation ROIs.
FIGURE 3-16
RACE AND ETHNICITY CHARACTERISTICS WITHIN THE CONSTRUCTION ROI

80%
The construction ROI has a lower
percentage of Hispanics and Latinos
compared to the City of Houston and
Harris County.

The construction ROI is

60%

predominantly white.

40%

20%

0%
White alone

Black or African
American, alone

Other

Two or More
Races

Construction ROI

City of Houston

Hispanic or Latino

Harris County

Source: ESRI, 2014

FIGURE 3-17
RACE AND ETHNICITY CHARACTERISTICS WITHIN THE OPERATION ROI

90%
80%

The counties intersecting the
operation ROI are predominantly

70%

The counties also have a
higher percentage of
Hispanics and Latinos
compared to the U.S.

white.

60%
50%
40%
30%
20%
10%
0%
White alone
United States

Black or African
American, alone
Texas

Other

Harris County

Two or More
Races
Brazoria County

Hispanic or Latino
Galveston County

Source: United States Census Bureau, State and County QuickFacts, 2010

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FIGURE 3-18
RACE AND ETHNICITY

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3.13.3 Children’s Environmental Health and Safety Risks
EO 13045 requires federal agencies to make child protection a high priority because children may be
more susceptible to environmental effects than adults.
For the purpose of this analysis, children are considered to be less than 18 years of age. Figure 3-19
compares the percentage of children in the construction ROI to the percentage of children in the City of
Houston and Harris County. Figure 3-20 compares the percentage of children in Harris, Brazoria, and
Galveston Counties compared to the rest of the Nation and the State of Texas. Figure 3-21 identifies the
locations of schools within the construction ROI. The closest school to EFD is North Pointe Elementary
School at 3200 Almond Creek Drive, approximately one mile east of EFD.
FIGURE 3-19
PERCENTAGE OF CHILDREN (UNDER 18) WITHIN THE CONSTRUCTION ROI

Harris County
The percentage of children in
the construction ROI is similar
to the City of Houston and
Harris County.

City of Houston

Construction ROI
0%

5%

10%

15%

20%

25%

30%

Source: U.S. Census Bureau, State and County Quick Facts, 2010

FIGURE 3-20
PERCENTAGE OF CHILDREN (UNDER 18) WITHIN THE OPERATION ROI

United States
Texas

The percentage of children in
the three counties intersecting the
operation ROI is similar to the
U.S. and Texas.

Harris County
Brazoria County
Galveston County
0%

5%

10%

15%

20%

25%

30%

Source: U.S. Census Bureau, State and County Quick Facts, 2010

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FIGURE 3-21
SCHOOLS WITHIN THE CONSTRUCTION ROI

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3.14 WATER QUALITY
Several laws and EOs address and regulate federal airport activities and their effects on water quality. The
following list are the laws most applicable to airport projects:

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Federal Water Pollution Control Act, as amended by the CWA (33 U.S.C. § 1251 et. seq.);
CWA, as amended by the Oil Pollution Act of 1990 (OPA) (42 U.S.C. § 1252 et. seq.);
Safe Drinking Water Act, as amended (SDWA) (42 U.S.C. § 300(f)); and
FWCA (16 U.S.C. § 661 et. seq.).

In addition to the above federal regulations, the TCEQ at has issued water standards to protect the state’s
waters through Title 30, Chapter 307 of the TAC. The standards are written by the TCEQ under the
authority of the CWA and Texas Water Code (TWC).

3.14.1 Surface Water
The topography of the construction ROI and the operation ROI is generally flat with elevations as high as
40 feet MSL to as low as seal level. The construction ROI is part of the Armand Bayou watershed. The
natural drainage of EFD flows west and south to Horsepen Bayou. According to the USEPA, Horespen
Bayou is currently listed as an impaired waterbody due to bacteria (USEPA, 2010). Horespen Bayou is a
tributary of Armand Bayou. Armand Bayou flows into Clear Lake, an estuary connected to the west side of
Galveston Bay. EFD is approximately nine miles west of Galveston Bay. See Figure 3-22 for river segments
within the construction ROI.

3.14.2 Groundwater
Much of the local area’s groundwater comes from the Chicot and Evangeline aquifers. Both aquifers are
part of a vast coastal aquifer system that extends throughout the margin of the coastal plain of Texas and
Louisiana. Freshwater is available in the upper 1,000 to 2,000 feet of the aquifer system. Saltwater exists in
deeper portions of the aquifer system at depths greater than 2,000 feet. Recharge to the Evangeline
aquifer is provided by precipitation and surface runoff north of the Houston area (USGS, 2013b).

3.14.3 Wastewater and Stormwater
EFD has four drainage basins covering approximately 1,721 acres. The existing storm sewer systems
consists of an enclosed conduit system on and the landside and airside ranging from 12-inch to multibarrel box culverts on the landside, and 10-inch perforated metal pipe (PMP) to 54-inch PMP on the
airside. The system covers EFD, including the airfield and former military facilities. The system has a
capacity to include additional development since much of the previous impervious surfaces associated
with military facilities have been turned into green space (HAS, 2004a). EFD’s primary Standard Industrial
Classification (SIC) code is 4581 (Airports, Flying fields, and Airport Terminal Services, including aircraft
maintenance and fueling) and is subject to Sector S: Air Transportation Facilities under the Multi-Sector
General Permit (MSGP). EFD operates under the TPDES stormwater MSGP (TXR050000) for the discharge
of stormwater associated with industrial activity within Texas (TCEQ, 2006a). The permit expires on August
14, 2016, unless amended. Among the conditions and requirements, HAS must implement a SWPPP.
Stormwater at EFD is managed under the provisions of EFD’s SWPPP, in accordance with its TPDES
Stormwater Multi-Sector General Permit (Permit Number TXR05T730).

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FIGURE 3-22
STREAM SEGMENTS

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3.15 WETLANDS
The CWA defines wetlands as “…those areas that are inundated or saturated by surface or groundwater at
a frequency and duration sufficient to support, and under normal circumstances do support, a prevalence
of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps,
marshes, bogs, and similar areas” (Environmental Laboratory, 1987).
Federal regulations addressing wetlands are:

»

33 CFR Part 323, Permits for Discharges of Dredged or Fill Material into Waters of the United States,
which implements the portion of the CWA addressing the dredging or filling of waters of the U.S.,
including jurisdictional wetlands.

»

USDOT Order 5660.1A, Preservation of the Nation’s Wetlands, sets forth USDOT policy on
jurisdictional and non-jurisdictional wetlands.

A wetland may be “jurisdictional” under federal regulations in some instances due to the wetland’s
connection to navigable waters.24 The USACE regulates dredge and fill activities in jurisdictional wetlands
under Section 404 of the CWA. In other cases, a wetland may be “non-jurisdictional” because it has no
such connection. Federal and state agencies (e.g., USFWS, EPA) oversee actions in both wetland
categories. The designation of a wetland does not rely on its jurisdiction or non-jurisdictional status.
Instead, the technical definition of a wetland depends on whether the area’s soils, vegetation, and
hydrology meet certain criteria. Such “delineations” are determined according to the USACE’s Wetlands
Delineation Manual (USACE, 1987).
Wetlands are productive parts of the landscape. They are important to watershed and biotic health.
Wetlands absorb floodwaters, supply base flow, protect shorelines, trap sediments, recharge groundwater,
and provide habitat for fish and wildlife.
According to the National Wetlands Inventory mapping system, there are wetlands within the
construction ROI (see Figure 3-23). There are a few isolated wetlands located on EFD property, primarily in
the southern and western portions. The wetlands found on EFD property are freshwater emergent
wetlands and freshwater forested shrub wetlands.
Freshwater emergent wetlands are marshes and wet meadows that usually exist in shallow topographic
depressions. As a result, they are usually subject to extended periods of flooding. Freshwater forested
shrub wetlands occur in deep swamps and include a variety of shrubs, ferns, and other herbs that are
present in more swamp-like forest areas.

24

Navigable waters are those waters affected by the ebb and flow of tides, and are, or have been, used for interstate commerce.

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FIGURE 3-23
WETLANDS

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CHAPTER 4

ENVIRONMENTAL CONSEQUENCES

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This chapter presents an analysis of the potential impacts upon various components of the environment
that could result from implementation of the Proposed Action or No Action Alternative. The analysis in
this chapter is in accordance with FAA Orders 1050.1E and 5050.4B. To evaluate potential impacts, the
analyses presented in this chapter overlay the components of the Proposed Action described in
Chapter 2 onto baseline conditions within the ROIs for each environmental impact category presented in
Chapter 3.25 In addition, this chapter evaluates the potential environmental impacts of the forecast of RLVs
operating within the operation ROI. The significance thresholds identified in this chapter are those
presented in Appendix A of FAA Order 1050.1E. This chapter discusses the potential construction26 and
operation impacts on following impact categories:

»
»
»
»
»
»
»
»
»
»
»
»
»
»

Air Quality (Section 4.1)
Climate (Section 4.2)
Coastal Resources (Section 4.3)
Compatible Land Use (Section 4.4)
USDOT Act, Section 4(f) Properties (Section 4.5)
Fish, Wildlife, and Plants (Section 4.6)
Floodplains (Section 4.7)
Hazardous Materials, Pollution Prevention, and Solid Waste (Section 4.8)
Historic, Architectural, Archeological, and Cultural Resources (Section 4.9)
Light Emissions and Visual Impacts (Section 4.10)
Natural Resources and Energy Supply (Section 4.11)
Noise (Section 4.12)
Secondary (Induced) Impacts (Section 4.13)
Socioeconomic Impacts, Environmental Justice, and Children’s Environmental Health and Safety
Risks (Section 4.14)

»
»

Water Quality (Section 4.15)
Wetlands (Section 4.16)

In accordance with CEQ regulations, this EA integrates the requirements of NEPA and other planning and
environmental review procedures required by applicable law or agency practice. This integration allows
the appropriate review procedures to run concurrently rather than consecutively (40 CFR §1500.2(c)). This
chapter includes the environmental analyses associated with the following federal statues, EOs, and
regulations:

»
»

Federal Coastal Zone Management Act of 1972 (Coastal Resources, Section 4.3);
Title 49 U.S.C. 303 and 23 U.S.C. 138 (USDOT Section 4(f), Section 4.5);

25

As described in Chapter 3, farmlands and wild and scenic rivers are not within the construction and/or operation
ROI. Therefore, they are not analyzed further in Chapter 4.
26
Rather than as a separate impact category, construction impacts are considered within each impact category (e.g.,
air quality) that could be affected by construction activities. See FAA Order 1050.1E, Appendix A Section 5.

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»
»
»
»

Endangered Species Act of 1973 (Fish, Wildlife, and Plants, Section 4.6);
EO 11988 (Floodplains, Section 4.7);
Section 106 of the NHPA (Historic Resources, Section 4.9); and
EO 11990 (Wetlands, Section 4.16).

As stated in Chapter 1 of this EA, spaceport operations would begin in 2015 and continue operating
through 2019. Therefore, this EA uses the study years 2015 and 2019 to compare the potential
environmental impacts of the Proposed Action and No Action Alternative. Based on the HAS Houston
Spaceport Economics and Business Study, 35 RLV launches are proposed in 2019. However, for a
conservative analysis, this EA assesses up to 50 launches in 2019. For the purposes of this EA, the Concept
X and Concept Z RLV descriptions presented in Chapter 2 are used for assessing potential impacts of RLV
operations at EFD.
As described in Section 2.1, the FAA would not alter the dimensions (shape and altitude) of the airspace.
Temporary closures of existing airspace may be necessary to ensure public safety during the proposed
operations. Advance notice via NOTAMs would assist general aviation pilots in scheduling around any
temporary disruption of flight activity at EFD. Launches would be infrequent (less than 1 percent of the
total operations occurring at EFD), of short duration, and scheduled well in advance to minimize
interruption of airport operations. For these reasons, environmental impacts from the temporary closure
of airspace and the issuance of NOTAMs and TFRs under the Proposed Action are not anticipated (see
Appendix B, Airspace and Airports, for further information). Moreover, in accordance with FAA Order
1050.1E, Chapter 3 (Advisory and Emergency Actions and Categorical Exclusions), the issuance of NOTAMs
is categorically excluded from NEPA review absent extraordinary circumstances.

4.1 AIR QUALITY
This section describes the potential effects of the No Action Alternative and Proposed Action on air
quality.

4.1.1

Significance Thresholds

Potentially significant air quality impacts associated with an FAA project or action would be demonstrated
if a project or action would lead to pollutant concentrations that would violate one or more of the NAAQS
for any of the time periods analyzed.

4.1.2

Environmental Consequences

CAP, hazardous air pollutant (HAP), and GHG emissions associated with the Proposed Action are disclosed
pursuant to the NEPA and according to FAA Order 5050.4B 706 f(3). The Proposed Action’s compliance
with the General Conformity Regulations of the CAA (40 CFR Part 93) is also assessed.
The approach for the Houston Spaceport air quality assessment is consistent with FAA Order 1050.1E,
Appendix A, Section 2.1. Further, the air quality assessment methodology is formulated in accordance with
the following regulations and guidance and is detailed in the following sections:

»

FAA Air Quality Procedures for Civilian Airports and Air Force Bases (FAA, 2004);

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 ENVIRONMENTAL CONSEQUENCES

»

FAA Guidance for Quantifying Speciated Organic Gas Emissions from Airport Sources
(FAA, 2009b);

»
»

FAA Order 1050.1E, Change 1, Guidance Memo #3 (FAA, 2012); and
FAA Final Programmatic EIS for Horizontal Launch and Reentry of Reentry Vehicles (FAA, 2005).

As described in Section 3.1, the area is designated nonattainment for the now historical 1-hour O3
standard, and is also considered nonattainment for both the currently enforceable 1997 and 2008 8-hour
NAAQS. Based on these designations, the most stringent of the O3 de minimis thresholds applicable to
the Houston area (i.e., a severe nonattainment area) correspond to 25 tons per year of nitrogen oxides
(NOx) or VOC, both of which are considered precursors to ground level O 3 formation. Accordingly,
operational and construction CAP emissions associated with the Proposed Action occurring below the
local atmospheric mixing height (i.e., below 3,038 feet for the Houston Area) are compared to these
thresholds. The local mixing height is defined as the vertical extent in the troposphere above which
emitted pollutants do not mix downward to ground level.
Operational emissions inventories for years 2015 and 2019 were developed for the Proposed Action,
which consists of FAA approval for airport development and issuance of licenses and permits needed to
operate horizontally-launched and horizontally-landing commercial spacecraft at the proposed Houston
Spaceport. Emissions sources included in the evaluation comprise Concept X and Concept Z RLVs, their
support equipment (i.e., fuel trucks and tractors), and routine jet engine testing taking place at ground
level to ensure safe operation.
Additionally, calendar year 2015 construction emissions were estimated using EPA’s MOVES2014 model,
the TCEQ’s Texas NonRoad Model (TexN Version 1.6) and other appropriate guidelines . The emission
estimates combine information on construction schedule, equipment type, fuel type, equipment hours of
operation, and horsepower and construction footprint along with equipment emissions data specific to
the construction ROI. For more detailed information on the air quality analysis, see Appendix C for the
final air quality assessment protocol.
4.1.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual RLV operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (e.g., mowing, hay production) would also continue at EFD. There would
be no impacts to air quality beyond those already occurring.
4.1.2.2 Proposed Action
Equipment and vehicle operations, demolition activities, paving activities and other construction practices
for the landside and airside development features of the Proposed Action (see Section 2.1.2) may result in
emissions. Table 4-1 summarizes the estimated construction emissions from various sources.

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TABLE 4-1
CONSTRUCTION EMISSIONS INVENTORY SUMMARY

Source
Nonroad Construction Equipment
Onroad Construction Vehicles
Employee Vehicles
Asphalt Paving
Fugitive Dust
Total

CO
28.5
0.2
2.6
--31.3

2015 Emissions (tons)
NOx SOx PM10 PM2.5
2.5 <0.1
0.2
0.2
0.4 <0.1 <0.1
<0.1
0.3 <0.1 <0.1
<0.1
------7.6
0.8
3.2 <0.1
7.8
1.0

VOC
1.1
0.1
0.1
0.4
-1.7

Note: Values reflect rounding. Emissions are expected to occur in 2015 only.
Source: KB Environmental Sciences, Inc.

The TCEQ has promulgated the following regulations into the TAC on the control of fugitive dust
emissions occurring from materials handling, construction and demolition, and road travel:

»

30 TAC §111.143(1): application of water or suitable chemicals or some other covering on
materials stockpiles and other surfaces which can create airborne dusts;

»

30 TAC §111.143(3)(a) and (b): application of water or suitable chemicals, or complete covering of
materials contained in open-bodied trucks, trailers, or railroad cars transporting such materials
which can create airborne particulate matter in areas where the general public has access;

»

30 TAC §111.145(1): use of water or of suitable oil or chemicals for control of dust in the
demolition of structures, in construction operations, in work performed on a road, street, alley, or
parking area, or in the clearing of land;

»

30 TAC §111.145(3): application of asphalt, other paving materials, water, suitable oil, or chemicals
on construction and/or demolition site access roads; and

»

30 TAC §111.147(2): removal from public thoroughfares, as necessary, of soil or other materials,
except for sand applied for the specific purpose of snow or ice control.

The following additional emissions reduction measures and best management practices (BMPs) during
construction would help reduce adverse air quality effects:

»
»
»
»

reduce equipment idling times;

»
»
»

limit construction activities during high wind events to prevent dust;

»

reduce vehicle speeds on unpaved roads.

use cleaner burning or low emissions fuels in equipment;
encourage employee carpooling;
limit construction activities when atmospheric conditions are conducive to O 3 formation (i.e.,
“high ozone days”);
utilize warm-mix asphalt during paving operations;
install tire washes and truck washes to deter tracking dirt and mud to areas outside the airport as
vehicles enter and leave the disturbed, project-related work sites; and

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Under the Proposed Action, each concept RLV conducts a powered take-off with the capability to propel
the RLV into suborbit. The Concept X RLV is estimated to conduct 50 takeoffs and 50 landings per year.
Under current designs, the Concept X RLV could combust jet-A during takeoff, combust RP-1 fuel and
LOX oxidizer during rocket engine launch procedures (ignited once the RLV reaches approximately 40,000
ft MSL over the Gulf of Mexico), and could rely on jet engine power to assist during landing; if it does not
return gliding.
The Concept Z RLV consists of the carrier vehicle (e.g., White Knight Two) as well as its launch vehicle (e.g.,
SpaceShip Two). The Concept Z RLV is similarly estimated to conduct 50 takeoffs and 50 landings per year.
Under current designs, the Concept Z RLV could combust Jet-A fuel during takeoff, combust HTPB and
N2O oxidizer during rocket engine launch of the RLV over the Gulf of Mexico (e.g., Spaceship Two). The
carrier vehicle could combust Jet-A upon landing and the launch vehicle would glide back to EFD or be
expended (e.g., Generation Orbit).
Operation of RLV jet propulsion engines would cause CAP and HAP emissions within the lower
troposphere (i.e., up to 3,038 ft), free troposphere (3,038 ft to 32,000 ft), and stratosphere (i.e., 32,000 ft to
163,500 ft). CAP and HAP emissions from support equipment operation and ground-level engine testing
would also occur. However, the CAP and HAP emissions occurring above the local atmospheric mixing
height (3,038 ft) would not reach ground level, and accordingly these emissions are not addressed in this
EA. Table 4-2 summarizes the CAP emissions resulting from commercial spaceport operations in 2015
(and 2019 as activity levels are identical between years). For disclosure purposes, HAP emissions are
presented on Table 4-3.
Of note, engine testing at EFD currently occurs adjacent to the NASA Sonny Carter Training Facility where
divers refill NITROX SCUBA tanks for use. Engine testing emissions are minimal and testing is not
anticipated to occur frequently enough to have a significant deleterious effect on local air quality. These
minor levels of contaminants could be present in the makeup air that is taken into the SCUBA tanks and
compressed during refilling.27 Accordingly, further HAS and/or RLV operator coordination may need to
occur with the Sonny Carter Training Facility to ensure that engine testing activities associated with the
Proposed Action are conducted such that potential contaminants in refilling NITROX SCUBA tanks are
minimized.

27

Letter from NASA Johnson Space Center to Dave Alberts, Reynolds, Smith and Hills, re: Scoping Comments on Proposed

Spaceport Environmental Assessment. November 18, 2013.

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TABLE 4-2
OPERATIONAL CAP EMISSIONS INVENTORY SUMMARY

Source
Concept X RLVs
Concept Z RLVs

CO
0.4
0.3

Support Equipment
Engine Testing
Total

<0.1
53.9
54.6

2015/2019 Emissions (tons)
NOx SOx PM10 PM2.5 VOC
0.1
<0.1 <0.1 <0.1
<0.1
0.1
<0.1 <0.1 <0.1
0.1
<0.1
0.2
0.4

<0.1
<0.1
0.1

<0.1
<0.1
<0.1

<0.1
<0.1
<0.1

<0.1
<0.1
0.1

Note: Values reflect rounding. Emissions inventory depicts impacts in the lower
troposphere only.
Source: KB Environmental Sciences, Inc.

TABLE 4-3
OPERATIONAL HAP EMISSIONS INVENTORY SUMMARY

2015/2019 HAP Emissions (pounds)
HAP
1,3-butadiene
2-methylnaphthalene
Acetaldehyde
Acetone
Acrolein
Benzaldehyde
Benzene
Ethylbenzene
Formaldehyde
Isopropylbenzene (cumene)
M & P-xylene
Methyl alcohol
Naphthalene
N-heptane
O-xylene
Phenol (carbolic acid)
Propionaldehyde
Styrene
Toluene

RLV Jet Engines
4.0
<0.1
8.0
<0.1
4.0
<0.1
4.0
<0.1
24.0
<0.1
<0.1
4.0
2.0
<0.1
<0.1
2.0
2.0
<0.1
2.0

Support Equipment
--<0.1
--<0.1
--<0.1
-------<0.1
---

Engine
Testing
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
2.0
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1

Total
4.0
<0.1
8.0
<0.1
4.0
<0.1
4.0
<0.1
26.0
<0.1
<0.1
4.0
2.0
<0.1
<0.1
2.0
2.0
<0.1
2.0

Note: -- signifies that the HAP are not calculated because no emission rates are provided in existing FAA guidance. Values reflect
rounding. Emissions inventory depicts impacts in the lower troposphere only.
Source: KB Environmental Sciences, Inc.

General Conformity Applicability - Table 4-4 lists the 2015 and 2019 emissions of NOx and VOC expected
to occur as a result of the construction and operation of the Proposed Action, and compares the total
annual emissions for each year against the applicable de minimis thresholds for NOx and VOC. As shown,
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 ENVIRONMENTAL CONSEQUENCES
the year of maximum project-related emissions occurs in 2015 because of the overlap of the project’s
construction and commencement of operations in that year. Emissions in 2015 resulting from the
Proposed Action are less than the applicable de minimis thresholds and are less than 10 percent of the
regions emissions, indicating that the Proposed Action will not require a General Conformity
Determination, nor will it cause or contribute to new or existing violations of NAAQS.
TABLE 4-4
GENERAL CONFORMITY APPLICABILITY

Construction
Operation
Total
De minimis
Exceeds de minimis?

Operation
Total
De minimis
Exceeds de minimis?

2015 Emissions (tons)
NOx
VOC
3.2
1.7
0.4
0.1
3.6
1.8
25
25
No
No
2019 Emissions (tons)
NOx
VOC
0.4
0.1
0.4
0.1
25
25
No
No

Values Reflect Rounding.
Source: KB Environmental Sciences, Inc.

Mitigation and Best Management Practices - Emissions associated with the construction and operation of
the Proposed Action are within EPA’s de minimis thresholds and are not expected to significantly affect
the air quality of the area. Accordingly no air quality mitigation measures are proposed. As previously
described in Section 4.1.2.2, although no mitigation measures are required, best management practices
can nonetheless be applied during the project construction phase that would ensure adherence to local
dust control regulations and generally provide a good faith effort to minimize emissions wherever
possible.

4.2 CLIMATE
This section describes the potential effects of the No Action Alternative and Proposed Action on the
Earth’s climate.

4.2.1

Significance Thresholds

While there is no significance threshold for aviation-related GHG emissions, the projected increase in GHG
emissions from the proposed action is discussed in the context of national and global GHG emissions
from all sources (FAA, 2012).

4.2.2

Environmental Consequences

Although there are no federal standards for aviation-related GHG emissions, it is well established that
GHG emissions can affect climate. The CEQ has indicated that climate should be considered in NEPA

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 ENVIRONMENTAL CONSEQUENCES
analyses (FAA, 2012). As noted by CEQ, "it is not currently useful for the NEPA analysis to attempt to link
specific climatological changes, or the environmental impacts thereof, to the particular project or
emissions; as such direct linkage is difficult to isolate and to understand" (CEQ, 2010). Aviation has been
calculated to contribute approximately three percent of global CO2 emissions; this contribution may grow
to five percent by 2050. Climate modeling methodologies do exist to scientifically predict global average
impact, and have been used in NEPA documentation, but for the Proposed Action’s small increment of
emissions any impact would be much less than the level of uncertainty inherent in the methodology.
4.2.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual RLV operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (e.g., mowing, hay production) would also continue at EFD. There would
be no impacts to climate.
4.2.2.2 Proposed Action
Operation of RLV jet and rocket propulsion systems would cause emissions of GHG within the lower
troposphere (i.e., up to 3,038 ft), free troposphere (3,038 ft to 32,000 ft), and stratosphere (i.e., 32,000 ft to
163,500 ft). Additionally, GHG emissions from propellant and oxidizer combustion during take-off, rocket
ignition, and landing28 occur up to the stratospheric level. Ozone depleting substance emissions to the
stratosphere from Concept X and Z RLVs are not of concern because neither of the concept RLVs
proposed emit hydrogen chloride or chlorine ions that would lead to significant impacts related to ozone
depletion. Additionally, emissions to the mesosphere would be negligible to non-existent. Powered
engine operations would not occur in the ionosphere, so assessment of electron-depleting substances in
the F-layer of the ionosphere are not addressed. Table 4-5 summarizes GHG emissions by atmospheric
layer that would occur due to operation of the Proposed Action in 2015 and 2019.
Moreover, the Proposed Action would only increase GHG emissions by 2,546 MT CO2 e over the No Action
Alternative. This increase would comprise less than 0.000039 percent of all U.S.-based GHG emissions.

28

The Concept X RLV could land using jet power or glide. The Concept Z carrier vehicle would land under jet power
while the launch vehicle would land gliding or be expended.

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TABLE 4-5
OPERATIONAL GHG EMISSIONS INVENTORY SUMMARY

Atmospheric Layer
Lower Troposphere

Source
Concept X RLVs
Concept Z RLVs
Support Equipment
Engine Testing

Subtotal – Lower Troposphere

CO2
50.4
38.5
5.6
51.2

2015/2019 Emissions (metric tons)
CH4
N2O
CO2e
H2O
<1.0
<1.0
50.7
-<1.0
<1.0
38.8
-<1.0
<1.0
5.6
-<1.0
<1.0
51.2
--

145.7

<1.0

<1.0

146.3

--

1,072.9
938.4

---

---

1,072.9
938.4

40.1
--

2,011.3

--

--

2,011.3

40.1

304.7
84.4

---

---

304.7
84.4

121.9
35.2

Subtotal – Stratosphere

389.1

--

--

389.1

157.0

Grand Total

2,546.0

<1.0

<1.0

2,546.7

197.1

Free Troposphere

Concept X RLVs
Concept Z RLVs

Subtotal – Free Troposphere
Stratosphere

Concept X RLVs
Concept Z RLVs

Note: -- signifies that the GHG is not emitted from the subject emissions source, except in the instance of water vapor for some
sources. Some sources do actually emit water vapor, but it is not quantified in the lower troposphere for this assessment. Values
reflect rounding.
Source: KB Environmental Sciences, Inc.

4.3 COASTAL RESOURCES
This section describes the potential effects of the No Action Alternative and Proposed Action on coastal
resources. This section does not discuss the requirements of the Coastal Barrier Resources Act (CBRA)
because the ROIs for the Proposed Action do not include land within the CBRA system (see Section 3.3).
Therefore, the project would not affect any barrier islands in the Gulf of Mexico.

4.3.1

Significance Thresholds

FAA Order 1050.1E does not provide a significance threshold; however, it does provide a number of
factors to consider when determining the severity and context of a project’s unavoidable coastal zone
effects. Those factors include:

»

the project proponent’s determination that a proposed action is consistent with the applicable
CZMP;

»

the responsible state agency’s finding regarding a project proponent’s consistency determination;
and

»

a project to change a project so it is consistent with the CZMP.

4.3.2

Environmental Consequences

This EA uses the requirements of the regulations protecting coastal zone resources described in
Section 3.3 and FAA Order 1050.1E, Appendix A, Section 3 in order to assess environmental consequences.

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4.3.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. There would
be no impacts on coastal resources.
4.3.2.2 Proposed Action
Implementation of the Proposed Action would result in development entirely on EFD property (see
Section 2.1.2). The development would include seven acres of new impervious surface at EFD located
approximately 30 miles inland, which is not within the limits required for a Section 10 permit.29 The
additional impervious surface would not impact coastal resources, including floodplains or wetlands (see
Sections 4.7 and 4.16); consequently, a Section 404 permit would not be required.
Jet fueling operations would occur at the proposed apron, approximately 1,500 feet from nearest isolated
wetland, and in designated areas of EFD (see Section 4.16). Rocket fueling operations would occur at the
OLA (see Figure 2-3). If a fuel spill occurs, the launch operator would be responsible for necessary cleanup
and remediation under the SPCC. As no impacts to coastal zone resources would occur, the proposed
activity complies with Texas’ approved CMP and would be conducted in a manner consistent with such
program.
An early notification letter regarding this EA and Proposed Action was sent to agencies, including the
Texas GLO, to solicit preliminary comments (see Appendix A). Also, e-mail correspondence with the Texas
GLO determined a copy of the Draft EA would need to be submitted to the Texas GLO for review. Once
the Texas GLO determines the document is administratively complete, a notice will be posted in the Texas
Register for 30 days. The Texas GLO will issue a decision as to whether it concurs with the FAA’s
consistency determination following the 30-day notification period.

4.4 COMPATIBLE LAND USE
This section describes the potential effects of the No Action Alternative and Proposed Action on land use.

4.4.1

Significance Threshold

A significant land use impact would occur if analysis shows that the Proposed Action would cause a
significant noise impact. A significant noise impact would occur if the proposed action would cause a
noise sensitive area to experience an increase in noise of DNL 1.5 dB or more at or above the DNL 65 dB
noise exposure when compared to the No Action Alternative for the same timeframe (see Section4.12). A
significant land use impact may also occur if the proposed action would result in other significant impacts
with land use ramifications, such as community disruption.

29

Section 10 of the Rivers and Harbors Act (33 U.S.C. 401 et seq.) permit is required whenever construction is going to
take place from mean high tide seaward to the limits of state jurisdictional waters (10.36 miles).

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4.4.2

Environmental Consequences

This EA examines and discloses how the Proposed Action would affect land use activities. According to
FAA Order 5050.4B, paragraph 1203a(1), an airport sponsor should show a proposed action is reasonably
consistent with existing plans of public agencies responsible for the development in the area. FAA Grant
Assurance 21, Compatible Land Use, also “relates to the obligations of the airport sponsor to take
appropriate actions to zone and control existing and planned land uses to make them compatible with
aircraft operations at the airport” (FAA, 2009a).
4.4.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. There would
be no impacts related to compatible land use.
4.4.2.2 Proposed Action
Development associated with obtaining a launch site operator license would occur entirely on EFD
property (see Chapter 2) and would be compatible with the existing EFD environment. The communities
surrounding EFD would not be disrupted, nor would any residences and/or businesses be relocated. The
Proposed Action would not significantly alter the aviation noise at EFD or aviation noise contours (see
Section 4.12). Therefore, the Proposed Action would not alter the established land use tiers around EFD
(see Section 3.4).
Although the undeveloped portions of EFD are primarily cleared and maintained, areas surrounding EFD
could be potential wildlife attractants (see Section 3.4). Although these potential wildlife hazards are
located near EFD, the development associated with the Proposed Action would not increase the existing
wildlife hazard. Stormwater retention ponds associated with the proposed development would meet the
requirements of FAA Advisory Circular (AC) 150/5200-33B and would not create additional wildlife
hazards.
Airport operations would increase due to implementation of the Proposed Action; however, as previously
described, the total launches of Concept X and Z RLVs would be approximately 50 per year. The Concept
X and Z RLVs use jet engines for takeoff and landing. The vehicles are anticipated to generate noise levels
comparable to the existing aviation activities at EFD. As described in Section 4.12, the Proposed Action
would not significantly alter the size or shape of the aviation noise contours, demonstrating the increase
in flights would not cause a significant noise-related impact.
Rocket engine noise associated with the two RLVs would begin when the vehicles are at a considerable
altitude (approximately 40,000 feet) and over the Gulf of Mexico (approximately 60 miles offshore). Rocket
engine noise and sonic booms are not anticipated onshore and are not anticipated to be perceived
onshore (see Section 4.12).

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Overall, implementation of the Proposed Action would be compatible with land use in the construction
and operation ROIs.

4.5 DEPARTMENT OF TRANSPORTATION ACT SECTION 4(F) PROPERTIES
This section describes the potential effects of the No Action Alternative and Proposed Action on Section
4(f) properties.

4.5.1

Significance Threshold

A significant impact to a Section 4(f) property would occur if a project resulted in a non-minimal physical
or constructive use of a Section 4(f) property and if mitigation does not eliminate or reduce the effects of
the use below the threshold of significance.

4.5.2

Environmental Consequences

The analysis contained in this EA follows the requirements of the regulations protecting Section 4(f)
properties.
Multiple Federal, State, and local agencies, and federally recognized Native American Tribes have been
contacted regarding the preparation of this EA. See Appendix A-1 for the early notification letter and list
of agencies contacted. See Appendix A-2 for response letters received from agencies. With the release of
this Draft EA, agencies with jurisdiction of Section 4(f) properties are provided another opportunity to
comment.
The construction and operation ROIs were reviewed for any publicly-owned parks, recreational areas,
wildlife or waterfowl refuges, or publicly or privately owned historic sites. For Section 4(f) purposes, a
proposed action would ”use” a property in one of two ways:

»

Physical use: The action physically occupies and directly uses the Section 4(f) resource. An action’s
occupancy or direct control (via purchase) causes a change in the use of the Section 4(f) resource.

»

Constructive use: The action indirectly uses a Section 4(f) resource by substantially impairing the
resource’s intended use, feature, or attributes.

An analysis of whether any components of the Proposed Action would have a physical or constructive use
of the Section 4(f) property was conducted and described in the following sections.
4.5.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation demands. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. There would be no impacts on Section 4(f) properties.
4.5.2.2 Proposed Action
As previously described, the development of the Proposed Action would occur entirely on EFD property.
Additionally, operation of the Concept X and Z RLVs would not require the temporary use of any Section

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4(f) properties (e.g., park closures). Therefore, the Proposed Action would not require the physical use
(direct impact) of Section 4(f) properties.
Operation of the Concept X and Z RLVs would increase flight activity at EFD by 0.09 percent. The noise
associated with this additional activity would not be significant (see Section 4.12). Noise during vehicle
takeoff and landing would be similar to jet engines currently operating at EFD. A sonic boom impacting
the Earth’s surface would occur during reentry, but would not occur over land (see Section 4.12). The sonic
boom would occur entirely off-shore, and Section 4(f) properties would not be subject to the sonic boom.
Additionally, the Proposed Action would not significantly affect air quality (see Section 4.1) or have other
effects that would substantially impair Section 4(f) resources (e.g., water quality, floodplains).
Therefore, the Proposed Action is not anticipated to result in constructive use (indirect impact) of a
Section 4(f) property in the operation ROI.

4.6 FISH, WILDLIFE, AND PLANTS
This section describes the potential effects of the No Action Alternative and Proposed Action on fish,
wildlife, and plants.

4.6.1

Significance Threshold

A significant impact would occur if the USFWS (or National Marine Fisheries Service) determined the
project would be likely to jeopardize the continued existence of a federally listed species or would result
in the destruction or adverse modification of designated critical habitat. For non-listed species, the FAA
considers population dynamics and sustainability (e.g., reproductive success rates, natural mortality rates,
non-natural mortality, and minimum population levels required for population maintenance) when
considering the potential for significant impacts.

4.6.2

Environmental Consequences

The following considerations were made in determining the potential impact of the Proposed Action on
biological resources and populations of threatened and endangered species:

»

proximity of unique or high-value habitats including wetlands, wild and scenic rivers, and
ecologically critical or important areas;

»

potential for the action to adversely affect an endangered or threatened species, or its habitat, in
particular federally designated critical habitat; and

»

regulatory requirements and applicable federal, state and local laws governing the conservation
and protection of threatened and endangered species.

4.6.2.1

No Action Alternative

Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation demands. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. There would be no impacts on fish, wildlife, and plants.

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4.6.2.2 Proposed Action
The USFWS Ecological Services Field Office in Houston, Texas was consulted to solicit comments
regarding potential environmental, social, and economic issues related to the Proposed Action (see
Appendix A). USFWS provided guidance regarding candidate species, potential threats to migratory birds,
colonial waterbird rookeries, bald eagles, and aquatic resources. USFWS identified the following potential
areas of concern for this assessment: sedimentation of streams and wetlands due to construction
activities, threats to migratory birds from overhead utility lines and communications towers, and possible
disturbance to colonial waterbird rookeries or protected bird species, including bald eagles.
The Texas Parks and Wildlife Department (TPWD) stated in their letter dated December 3, 2013 (see
Appendix A-2), “[b]ecause construction activities associated with this project would be located within
previously-disturbed portions of the existing airport, adverse impacts to fish and wildlife resources from
the footprint of the proposed project are expected to be minimal.” TPWD also stated it has “minimal
concerns regarding noise impacts upon terrestrial species.”
Construction activities required for the Proposed Action would occur on previously disturbed and
currently maintained areas within the existing airport boundary, and would not disturb any unique or high
value habitats. The area where spaceport facilities would be located has been regularly disturbed with
farming activities (e.g., tilling, seeding, cutting, baling, etc.) for hay production. These areas have very little
biological diversity and are of little value to wildlife (NASA, 2006). There would be no construction within
or near any fish-bearing streams. Thus, there would be no impacts to fish.
There are no natural aquatic habitats at EFD (NASA, 2006). The closest wetland is located approximately
1,500 feet away from the area where development of the Proposed Action would occur. Construction
activities would take place in accordance with applicable erosion control regulations, NPDES permits, and
stormwater control BMPs. Erosion controls, as well as the distance to nearby water bodies, would prevent
sedimentation of streams. For those reasons, no significant impacts to wetlands, streams, or other aquatic
habitats are anticipated.
Fueling of the RLVs would occur in designated areas on the airfield, and would not be located near
streams, wetlands, or ecologically sensitive areas. These activities would occur on impervious surfaces and
in accordance with applicable rules and regulations (see Section 4.8).
During construction activities, direct mortality to individual animals could occur as a result of excavation
and grading. On-site fill material is proposed to be used for the project components of the Proposed
Action. Sensitive flora or fauna do not occur in areas that would provide fill. Federally or state protected
fish, wildlife, or plants do not occur within the construction area; thus construction activities would have
no effect on these protected species.
Regarding migratory birds, colonial waterbird rookeries do not occur within the construction ROI. It is
highly unlikely that bald eagles or bald eagle nesting sites would be near EFD when construction would
begin. The area where construction activities would occur is a flat meadow without trees or other features
suitable for bald eagle nesting sites. In the event a bald eagle was sighted near planned construction

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activities, consultation with USFWS would occur prior to construction to avoid potential impacts to this
species.
Migratory birds would not be significantly impacted by operation of the Concept X or Z RLVs. In 2012, 14
bird strikes were reported at EFD in the course of more than 114,000 aircraft operations at the EFD. Due to
the limited number of RLV launches (up to 50 per year, or 0.09 percent of EFD’s total operations), the
likelihood of bird strikes related to the Proposed Action would not significantly increase in comparison to
the operations under the No Action Alternative at EFD. Impacts on migratory birds from operation of the
RLVs would be similar to existing airport operations.
Since the Concept X and Z RLVs would take off and land under jet engine power (or make a gliding
landing), operation of these vehicles would be similar to the current military and civilian aircraft that
routinely operate in the construction and operation ROIs. Operation of RLVs is not anticipated to
significantly affect air quality, noise, and/or water quality (see Sections 4.1, 4.12, and 4.15, respectively).
The sonic boom produced as a result of the RLV operation would occur over the Gulf of Mexico 30 miles
off-shore (see Section 4.12). Because sonic booms would be infrequent and small in magnitude, no
significant impacts on marine species are anticipated.
Wildlife species in the construction ROI have adapted to a developed, urban setting and are therefore less
likely to be affected by any short‐term noise associated with the proposed construction and operational
activities. Due to their habituation to relatively high ambient noise levels and the limited area of habitat
that would be impacted by proposed construction activities, there would be no significant impacts to
wildlife from proposed construction and operational activities under the Proposed Action.
In summary, in compliance with Section 7 of the ESA, the FAA has determined the Proposed Action would
have “no effect” on federally listed species. Similarly, the Proposed Action would not result in significant
impacts on state-listed and non-listed species.

4.7 FLOODPLAINS
This section describes the potential effects of the No Action Alternative and Proposed Action on
floodplains.

4.7.1

Significance Threshold

FAA Order 1050.1E, Change 1, states, “…floodplain impacts would be significant pursuant to NEPA if they
cause notable adverse impacts on natural and beneficial floodplain values. Mitigation measures for base
floodplain encroachments may include committing to special flood-related design criteria, elevating
facilities above base flood level, locating nonconforming structures and facilities out of the floodplain, or
minimizing fill placed in floodplains.”
FAA Order 1050.1E, Change 1 also describes the analysis shall indicate if there is a significant
encroachment. An action would cause a significant encroachment with one or more of the following
impacts:

»

high probability of loss of human life;

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»

have substantial, encroachment-associated costs or damage, including interruption of aircraft
service or loss of a vital transportation facility; or

»

have adverse impacts on natural and beneficial floodplain values.

4.7.2

Environmental Consequences

The methodology for determining and comparing unavoidable floodplain impacts involves quantifying
the area of floodplain encroachment that each component of the Proposed Action would cause and the
corresponding runoff resulting from the introduction of additional impervious surfaces.
In order to calculate the increases in stormwater runoff, an annual rainfall of 49.77 inches was used in
calculations (NWS, 2013). The additional annual runoff was calculated using a coefficient of 0.95 for
Portland cement (TxDOT, 2011). The results of these calculations were compared to the capacities of EFD’s
affected drainage basins.
4.7.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. There would
be no impacts on floodplains.
4.7.2.2 Proposed Action
As shown in Figure 4-1, implementation of the Proposed Action would not encroach on designated
floodplains. While the Proposed Action would involve construction of impervious surfaces and contribute
to an annual increase in runoff, the additional runoff would have no material effect on floodplain
elevations. Table 4-6 provides a summary of these project-related runoff increases. The Proposed Action is
in EFD’s designated drainage basin areas C and D. These drainage basins have a total of 1,348 acres (HAS,
2009). The Proposed Action would add approximately seven acres of impervious surface to these drainage
basins.
Although the Proposed Action involves the introduction of additional impervious surfaces, the
corresponding increase in associated annual runoff is not considered significant due to the small amount
of additional impervious surface, and the presence of adequate flood controls and drainage infrastructure.
The Proposed Action would not involve development or construction activities within a floodplain, and
the introduction of additional impervious surfaces would not have a significant adverse effect on the
natural or beneficial values of nearby floodplains. Additionally, as there would be no floodplain
encroachment, the project would be compliant with EO 11988, Floodplain Management. Therefore, the
Proposed Action would not result in a significant adverse effect to floodplains.

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FIGURE 4-1
PROPOSED DEVELOPMENT AND 100-YEAR FLOODPLAINS

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TABLE 4-6
PROJECT SPECIFIC STORMWATER RUNOFF INCREASES

Project Component

Access Roadway and
Parking
Truck Parking
Taxiway
Apron
Hangar
Oxidizer Storage Access
Road
Oxidizer Storage Tank Pad
Net Total:

Net Component
Impervious Increase
(square feet)

Floodplain
Encroachment
(square feet)

Additional
Annual
Runoff/a/b/
(acre-feetc)

45,904

0

4.15

15,084
81,537
106,369
47,572

0
0
0
0

1.36
7.37
6.62
4.30

2,877

0

0.26

4,680
304,023 (7 acres)

0
0

0.42
27.5

/a/

Annual rainfall of 49.77 inches was used in calculations (National Weather Service, 2013).

/b/

Runoff coefficient of .95 was used for cement (TxDOT, 2011).
An acre-foot is the volume of water that will cover an area of one acre to a depth of one foot.

/c/

Sources: RS&H, 2013; NOAA, 2013

4.8 HAZARDOUS MATERIALS, POLLUTION PREVENTION, AND SOLID WASTE
This section describes the potential effects of the No Action Alternative and Proposed Action related to
hazardous materials, pollution prevention, and solid waste.

4.8.1

Significance Threshold

FAA Order 1050.1E, Change 1, Appendix A.10, states that additional analysis of the potential for significant
impacts, beyond the information that is disclosed in this EA (Section 3.8), generally “is needed only if
problems are anticipated with respect to meeting the applicable local, State, Tribal, or Federal laws and
regulations on hazardous or solid waste management.” Moreover, actions that involve a property on or
eligible for the NPL are significant. If no such issues are anticipated, there would typically be no significant
impacts in this category. More specifically, the following factors may indicate a significance impact with
regard to hazardous materials and hazardous wastes.

»

If a proposed action or reasonable alternative involves a property on or eligible for the NPL, 30 the
FAA recommends that any NEPA document disclose presence of contamination within the within
boundaries of the entire NPL site to help the decision maker determine if there are areas within
the site that are not contaminated. The National Priorities List (NPL) is the list of areas throughout
the United States and its territories that have had releases or threatened releases of hazardous
substances, pollutants, or contaminants. The NPL’s primary purpose is to guide the EPA in
determining those sites warranting further investigation.

30

The National Priorities List (NPL) is the list of areas throughout the United States and its territories that have had
releases or threatened releases of hazardous substances, pollutants, or contaminants. The NPL’s primary purpose is to
guide the EPA in determining those sites warranting further investigation.

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»

If an airport would have difficulty meeting applicable, state, or federal laws and regulations
addressing hazardous wastes or hazardous materials, then the FAA recommends that any NEPA
document disclose that difficulty to help the decision maker determine if extraordinary measures
are necessary to mitigate project-related disturbances of contaminates that would endanger the
health and/or safety of citizens (e.g., connecting the project area to a new water supply or moving
local residents to avoid contamination).

»

If there is an unresolved issue regarding hazardous materials, FAA recommends that any NEPA
document discuss how a proposed action or reasonable alternative would affect a site known or
suspected to be contaminated to inform the decision maker that the effects of the contamination
are not fully understood, but corrective actions may be needed.

4.8.2

Environmental Consequences

This EA uses the 2013 EFD Self-Service Fueling Facility EA and the EPA NEPAssist online tool to determine
potential hazardous materials in the construction and operation ROIs. In order to determine potential
impacts to those areas, this EA analyzes the potential increase in hazardous materials and waste at EFD
under the Proposed Action. This EA also analyzes how those materials and wastes would be handled and
stored at EFD. This methodology is consistent with the requirements of FAA Order 1050.1E,
Appendix A.10.
4.8.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. EFD
averages the distribution of approximately 3,600,000 gallons (24,480,000 lbs) of Jet-A fuel annually, with
140,000 gallons (952,000 lbs) of existing storage capacity (HAS, 2013b). There would be no impacts
related to hazardous materials, pollution prevention, and solid waste.
4.8.2.2 Proposed Action
Construction of the Proposed Action would result in a temporary increase of on-site hazardous material
storage. This would predominantly occur in the form of diesel fuel, which is necessary for the operation of
construction equipment. Construction wastes would be managed in accordance with existing regulations
and EFD’s SOPs for solid and hazardous waste management. Implementation of the Proposed Action
would also result in a temporary increase in the quantity of solid waste generated at EFD. The County has
the ability to accommodate solid waste generated as a result of constructing the Proposed Action (TCEQ,
2013).
Although contaminated sites exist at EFD (see Section 3.8), there are no known contamination sites in the
vicinity of planned construction under the Proposed Action. Implementation of the Proposed Action
would not affect the status or remediation of known hazardous sites. Therefore, the Proposed Action
would not directly or indirectly impact RCRA, TSCA, or CERLA sites described in Section 3.8. Significant

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impacts related to hazardous waste or hazardous materials are not anticipated due to construction
activities under the Proposed Action.
Implementation of the Proposed Action would result in a net increase in the use and storage of hazardous
materials at EFD. The types of hazardous materials used and stored would be similar to those currently
handled at EFD and significant quantities of additional hazardous materials would not be permanently
stored onsite. Under the Proposed Action, hazardous materials would be appropriately managed in
compliance with applicable regulations, in accordance with existing BMPs outlined in EFD’s SPCC Plan
(HAS, 2009). These BMPs are enforced through inspection, tests, and records conducted and filed by EFD
personnel.
To prevent the release of hazardous materials to the environment, EFD would implement measures to
ensure hazardous materials are handled, stored, and used in compliance with federal, state and local
regulations. Such measures would include, but not would not be limited to:

»

implementing SPCC measures while loading and unloading fuel, such as preventing movement of
transport vehicles during product handling operations and inspecting vehicle outlets for leakage
before filling and truck departure;

»

storing bulk hazardous materials in approved containers that meet National Fire Protection
Association industrial fire protection codes and required containment systems; and

»

storing hazardous materials in protected and controlled areas designed to comply with sitespecific SPCC plans.

The Proposed Action would also result in a net increase in the amount of hazardous waste and solid waste
generated. Due to the limited number of RLV launches (50 per year) under the Proposed Action, the
increase in hazardous waste generation would be minimal in relation to the generation under the No
Action Alternative.
The Proposed Action would comply with all existing and future hazardous waste generator requirements
as well as manage hazardous and solid wastes in accordance with federal, state and local regulations. As
with existing activities, the Proposed Action would operate under a NPDES permit, which would ensure
that appropriate pollution control measures are in place. The generation of hazardous and solid wastes
associated with flights under the Proposed Action would not pose a substantial hazard to the public or
the environment. The hazardous materials associated with each RLV are further described in the following
paragraphs.
Concept X and Z RLV Operation - The Concept X and Z RLVs require Jet-A fuel for takeoff and landing,
with a rocket engine stage using either solid or liquid propellants. Significant impacts related to hazardous
materials or wastes are not anticipated as a result of operating Concept X and/or Z RLVs.
Due to the limited number of launches per year (50) compared to airport traffic under the No Action
Alternative, the similarity of propellant types to fuels currently used at EFD, and the limited quantities of

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propellants and other hazardous materials on board each RLV, the risk of impacts related to a flight
anomaly would be similar to the activities under the No Action Alternative.
Propellant Types and Quantities - Fuels and oxidizers comprise the most significant increase in hazardous
materials, by weight. Small quantities of other hazardous materials needed for vehicle maintenance and
operations (i.e., paints, solvents, oils and greases, etc.) would be relatively insignificant when compared to
the amounts required for flights. Fuels needed to support concept RLV flights include RP-1, Jet-A fuel,
HTPB, and ABS. Oxidizers include LOX, N2O, and H2O2. Table 4-7 shows the maximum quantities of fuels
and oxidizers that could be stored onsite at one time for the Proposed Action.
A maximum of 239,000 lbs of Jet-A fuel would be needed to support all flights under the Proposed Action
for one year. This quantity represents less than a one percent increase compared to EFD’s use of Jet-A
under the No Action Alternative. EFD distributes on average approximately 3,600,000 gallons (24,480,000
lbs) annually, with 140,000 gallons (952,000 lbs) of existing storage capacity (HAS, 2013b). Jet-A fuel
would be supplied according to existing SOPs at EFD. No new fuel farms and/or permanent onsite storage
tanks would be required to support the Proposed Action.
TABLE 4-7
MAXIMUM QUANTITY OF FUEL/OXIDIZER STORED ON-SITE

LOX
N2O
RP-1
Jet-A*
HTPB (solid, inert)

Maximum Quantity
(1,000s of lbs)
171
121
68
952
150

Nylon/ ABS (solid, inert)
APCP

150
60

Oxidizers/Propellants

*This is representative of EFD’s existing storage capacity.
Source: RS&H, 2014

Other liquid fuels and oxidizers not currently used at EFD would be brought in on tanker trucks and would
be temporarily stored onsite until such time they are needed for loading/unloading the concept RLVs
prior to flights. Oxidizer, such as LOX, would be supplied by conventional industrial gas suppliers and
would be delivered to the site by tanker truck at the time of each flight. Offsite storage would be
maintained by industrial gas suppliers and is outside the scope of this EA. These liquid propellants are
similar in composition and management requirements to the Jet-A fuel currently used at EFD. Propellants
would be temporarily stored and used in compliance with 14 CFR §420.65-70 for solid and liquid
propellants.
As many as ten Hybrid Rocket Motor casings containing solid fuels (ABS and HTPB), weighing up to 3,000
lbs each, could be stored in the proposed hangar. Due to the inert nature of HTPB and ABS solid fuels,
these materials would not pose any risk of a hazardous release.

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Loading/Unloading Operations - Fuel and oxidizer loading/unloading operations would take place in
designated areas located on impervious surfaces, with spill prevention and emergency response
procedures in place. Fueling operations would take place under the provisions of the EFD SPCC Plan. The
risk of hazardous material releases due to leaking storage tanks, tanker trucks, delivery lines, or other
infrastructure would be limited by proper handling practices, in compliance with 14 CFR §420.65 and
14 CFR §420.67 for solid and liquid fuels, respectively.
In conclusion, there would be no significant impacts related to hazardous materials or wastes related to
operation of the Concept X or Z RLVs.

4.9 HISTORIC, ARCHITECTURAL, ARCHEOLOGICAL, AND CULTURAL RESOURCES
This section describes the potential effects of the No Action Alternative and Proposed Action on historic,
architectural, archaeological, and cultural resources.

4.9.1

Significance Threshold

FAA Order 1050.1E, Change 1, Appendix A.11, Section 11.3, states an adverse effect does not
automatically trigger a significant impact (36 CFR 800.8(a)) and preparation of an EIS. Instead, FAA, after
consulting with the SHPO and other interested parties, determines the level of effect and if that effect
warrants preparation of an EIS.

4.9.2

Environmental Consequences

The NRHP and THC Atlas were utilized to determine historic resources in the ROIs (see Section 3.9). The
proximity of these resources to ground disturbing activities were analyzed to determine potential direct
impacts.
Potential indirect impacts to historic resources within the operation ROI were also assessed by
determining any potential indirect impacts from air quality, noise, and water quality that could potentially:

»

alter the visual, audible, or atmospheric characters of the property, if the setting contributes to
the property’s qualification for the NRHP; or

»

cause neglect of the property resulting in the property’s deterioration or destruction.

4.9.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation demands. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. There would be no impacts on historic, architectural, archeological, and cultural resources
beyond those already occurring.
4.9.2.2 Proposed Action
As described in Section 3.9, there are no historic properties within the APE. Therefore, neither construction
activities nor operations under the Proposed Action would affect historic properties. In accordance with
Section 106 of the NHPA, the FAA coordinated with the Texas State Historic Preservation Officer (SHPO).

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The SHPO concurs with the FAA’s determination of “No Historic Properties Affected” by the Proposed
Action. See Appendix D for the correspondence letters.

4.10 LIGHT EMISSIONS AND VISUAL IMPACTS
This section describes the potential effects of the No Action Alternative and Proposed Action related to
light emissions and visual impacts.

4.10.1 Significance Threshold
There are no special purpose laws identifying significance thresholds for light emissions or visual effects.
Evaluation of potential light emission effects is in terms of potential for human annoyance. FAA Order
1050.1E, Change 1, requires the FAA consider the extent to which any lighting associated with a proposed
action would create an annoyance among residents near a proposed action or interfere with normal
activities.
Potential aesthetic effects of an action are generally assessed to the extent that the development
contrasts with a No Action Alternative environmental setting and whether a jurisdictional agency
considers this contrast objectionable. For this EA, visual effects resulting from constructing and operating
the Proposed Action include physical changes to the visually aesthetic qualities of the construction ROI,
including landforms, vegetation, and water surfaces. Effects may also include those resulting from actions
which may have both beneficial and detrimental effects.
This EA gives special consideration to light emissions and visual effects to historic properties, national or
state parks, recreation areas or other visually sensitive areas near the construction ROI.

4.10.2 Environmental Consequences
Airport facilities are illuminated by various types of lighting that can impact light-sensitive land uses in the
vicinity an airport.
The potential for adverse light emissions and visual effects of the No Action Alternative and Proposed
Action were qualitatively evaluated to determine the extent of light emissions. Airport-related light
emissions are considered to have a notable impact only if light is directed towards a residential area.
Impacts from lighting associated with the No Action Alternative and Proposed Action were determined by
evaluating the individual lighting systems to be developed at EFD and assessing distance, light angle, and
intensity as they relate to the surrounding light-sensitive land uses.
This effort provided a way to identify potential new sources of lighting, glare, and visual effects on lightsensitive land uses that could result in annoyance to local residents.
4.10.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve its forecast aviation demands.
Maintenance activities (i.e., mowing, hay production) would also continue at EFD. Implementation of the

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No Action Alternative would not involve construction of structures or construction activities that would
result in temporary or permanent increases in adverse light emission or visual effects in the construction
or operation ROIs. There would be no impacts related to light emissions and visual resources.
4.10.2.2 Proposed Action
As described in Chapter 2, and shown in Figure 2-3, implementation of the Proposed Action would involve
the construction of an access roadway, parking, a hangar, associated taxiway and apron areas, an oxidizer
loading and storage area, a RP-1 truck parking area, and up to 50 annual combined Concept X and
Concept Z launches at EFD. The Proposed Action would have more light emissions and differ visually
compared to the No Action Alternative.
Light Emissions - The development of the following project components would require lighting for safety
and security reasons and would represent new sources of light emissions:

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hangar/processing facility;
taxiway from the apron area to the airfield system;
vehicle parking area; and
access road.

Lighting for the hangar would illuminate the interior and exterior of the hangar. The new parking area
would be lighted with directional and focused lighting for the safe movement of vehicles and pedestrians.
The access road would include lighted signage and roadway post lights, resulting in light emissions.
Directional and focused lighting would not be angled toward surrounding neighborhoods. Additionally,
construction activities would not likely occur during nighttime hours and nighttime glare from
construction activities is not anticipated.
The operation of the Concept X and Concept Z RLVs would occur primarily during the daytime hours. As
previously described, approximately five percent of the launches under the Proposed Action could occur
during nighttime hours. However, this would not require the use of additional on-Airport lighting. Airport
lighting during nighttime launches would remain the same as other aircraft operations that take place
during nighttime hours. Additionally, the RLVs are anticipated to have similar lighting as aircraft currently
operating at EFD during the nighttime hours. Therefore, light emissions of the RLVs would not
significantly impact light sensitive areas.
Visual Effects - The Proposed Action would involve the construction of additional infrastructure required
for the storage, maintenance, and operation of the Concept X and Concept Z RLVs. The proposed
infrastructure required for operations would be similar to the existing infrastructure and buildings at EFD.
In addition, nearby land uses are separated from EFD by a vegetative buffer. Construction of these
structures would not, therefore, represent a visual impact compared to the No Action Alternative.

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4.11 NATURAL RESOURCES AND ENERGY SUPPLY
This section describes the potential effects of the No Action Alternative and Proposed Action on natural
resources and energy supply. Sustainable design features that could be included in the Proposed Action
are also described.

4.11.1 Significance Threshold
A project requiring natural resource or energy supplies that would exceed supplies would likely cause a
significant impact on natural resources or energy supplies.

4.11.2 Environmental Consequences
FAA Order 1050.1E, Appendix A, Section 13.2a notes that FAA NEPA documents must examine natural
resource and energy usages only when an action, “…involves a need for unusual materials or those in
short supply.” Although Section 13.2a notes these instances are rare, examples of this would be:

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an airport terminal that would use large volumes of water to serve passenger needs; or
constructing a runway that would require large volumes of concrete that would strain local or
regional concrete supplies.

Review of aerial photographs, USGS Topographic 7.5 Minute Series Quadrangles for the construction ROI,
and land use maps were used to determine if any natural sources of mineral or energy resources would be
impacted by the Proposed Action. With regard to fuel supply, examination of changes in the volumes of
jet fuel or aviation fuel for projects involving changes in airside operations is required. This examination
provides the information needed to disclose how those changes would alter existing jet fuel demands and
supplies.
To evaluate the No Action Alternative and Proposed Action, common industry information related to
sustainable design and sustainable practices was reviewed to describe measures to reduce the potential
landside development demands on natural resource and energy supplies. These useful references,
recognized by the FAA, are:

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the Airports Cooperative Research Program Synthesis 10, Airport Sustainability Practices; and
the Sustainable Aviation Guidance Alliance (SAGA) Database.

4.11.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. There would
be no impacts on natural resources and energy supply.

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4.11.2.2 Proposed Action
The Proposed Action would not place excessive demands on local supplies of fuel, energy, or natural
resources. Potential effects to natural resources, fuel use, and sustainable design are further described in
the following paragraphs.
Natural resources - Construction of the Proposed Action would result in temporary increases in energy
demand. Airside and landside improvements associated with the Proposed Action would include the use
of aggregate, sub-base materials, and oils associated with the construction of asphalt pavements. In
addition, trucks and construction equipment would consume fuels as needed for construction purposes.
None of these materials are rare or in short supply. Large volumes of materials would not be required in
order to build the hangar, apron, taxiway and other development under the Proposed Action.
Fuel Use - Fuel use to support the Proposed Action would not represent a significant increase relative to
the No Action Alternative. The total quantity of Jet-A fuel needed to support all missions under the
Proposed Action would be 239,000 lbs or less over the 5-year license period, or approximately 47,800 lbs
per year. Current use of Jet-A at Ellington is approximately 3,600,000 gallons (24,480,000 lbs) per year
(HAS, 2013b). Therefore, the Proposed Action would represent far less than a one percent increase in total
fuel consumption at EFD, and would not have a significant impact on local fuel supplies. Propellants
needed to support the Proposed Action are not in short supply, and demand for these materials could be
met without difficulty.
Sustainable Design - Due to current energy efficient building code provisions, it is likely the associated
hangar would be designed to operate more energy efficiently than similar existing facilities at EFD.
Sustainable design elements could be considered during the design phase of the project, as well as
opportunities to reduce waste, recycle, and reuse materials during the construction phase. Sustainable
design elements suggested in the Airport Cooperative Research Program Synthesis 10, Airport
Sustainability Practices, and the SAGA Database could be used by the selected contractor for the design,
construction, and operation of the development under the Proposed Action.
The Proposed Action would not require the use of unusual materials or materials in short supply and
would not measurably increase demand on local supplies of energy or natural resources. For these
resources, implementation of the Proposed Action would not cause significant impacts with respect to
natural resources or energy supplies.

4.12 NOISE
This section describes the potential effects of the No Action Alternative and Proposed Action related to
noise.

4.12.1 Significance Threshold
A significant noise impact would occur if analysis shows that a proposed action would cause noise
sensitive areas to experience an increase in noise of DNL 1.5 dB or more at or above DNL 65 dB noise
exposure when compared to a no action alternative for the same timeframe. For example, an increase
from 63.5 dB to 65 dB over a noise sensitive area is considered to be a significant impact.

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4.12.2 Environmental Consequences
The primary mechanism of aircraft noise emissions results from air pressure fluctuations induced from the
operation of aircraft during the various phases of flight. While pressure fluctuations can originate from
subsonic aerodynamic forces or mechanical systems, the majority of noise related to RLV operations is a
result of engine noise and sonic boom generation.
To quantify the potential jet engine noise related to RLV operations at EFD, the analysis utilizes the FAA’s
Area Equivalent Method Version 7.0c. The AEM uses a mathematical procedure to estimate a change in
the area of the DNL 65 noise contour that would occur if the number and/or type of aircraft operations
were to change. If the AEM calculations indicate that a proposed action would result in less than a 17
percent (approximately a DNL 1 dB) increase in the DNL 65 dB contour area, it may be concluded that
there would be no significant impact over noise sensitive areas and that no further noise analysis is
required (FAA, 2006).
To quantify the potential impact of sonic boom generation related to RLV operations, the analysis utilizes
PCBoom4, a single-event prediction model produced by Wyle Laboratories. PCBoom4 is utilized by the Air
Force Center for Engineering and Environment and is widely accepted to determine the specific pattern
and amplitude of a sonic boom footprint (Wyle Laboratories, 2002).
Appendix E provides additional technical information regarding the FAA approved noise analysis
methodology.
4.12.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation demands. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. There would be no impacts related to noise.
4.12.2.2 Proposed Action
Temporary noise impacts as a result of construction vehicles and machinery would be limited to the
immediate vicinity of EFD. Earthwork and site preparation would result in temporary noise generation
while these activities are taking place. Noise levels would vary dependent on the nature of construction
activities and the type and model of equipment used. Given the distance to the nearest residential areas
(one-half mile east and west) and the presence of vegetated buffers surrounding EFD, temporary
construction noise impacts would not be significant. Additionally, construction is not likely to occur at
night when surrounding areas may be more sensitive to noise.
The RLVs proposed for operation at EFD have the potential to create noise from engine operation similar
to aircraft currently operating at EFD. The AEM analysis results indicate that the increase in the DNL 65 dB
contour area is less than 0.01 percent between the No Action Alternative and Proposed Action. This is
because the Proposed Action includes a maximum of 50 launches per year, whereas EFD experiences over
100,000 operations per year. This area is far less than the 17 percent increase in the DNL 65 dB contour

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area by DNL 1 dB necessary to constitute a significant impact. The Proposed Action would not cause noise
sensitive areas to experience an increase in noise of DNL 1.5 dB or more at or above DNL 65 dB.
Therefore, the noise generated by concept RLV operation would not cause a significant impact.
The RLVs proposed for operation at EFD also have the potential to create a sonic boom. A sonic boom,
which is similar to the sound of thunder, is the sound associated with the shock waves created by an
object moving through the air faster than the speed of sound. For the Proposed Action, a sonic boom
could be generated during two portions of the RLV’s flight: at the rocket ignition during ascent to and
gliding from the RLV’s apogee (approximately 330,000 ft MSL).
The sonic boom created during the RLV’s supersonic portion of the ascent 60 miles away from the
shoreline over the Gulf of Mexico would not reach land due to the steep ascending flight path angle. The
sonic boom would propagate along an upward angle that is unlikely to reach the ground and therefore
would not cause a significant impact. A sonic boom analysis was completed for the supersonic portion of
the RLV’s reentry which would occur over the Gulf of Mexico, approximately 30 miles from the Texas
shoreline. Figure 4-2 shows the extent of the nominal sonic boom contour, which is the area where a sonic
boom may be heard.
The sonic boom created during the descent of the RLV is estimated to cover approximately 7,000 square
miles. However, the sonic boom is predicted to be at levels significantly less than 1.0 psf, or approximately
63 dBA (ANSI, 2005) and is entirely over the Gulf of Mexico. The peak overpressure level generated from
an RLV (0.9 psf) would be similar to a thunder clap, but would occur in a concentrated area of
approximately one-half square mile. For the majority of the area, the sonic boom levels would be closer to
0.1 psf.
The sonic boom may be heard by personnel on oil rigs located in the area. Given the industrial
characteristics of offshore oil rigs, the sonic boom is not likely to affect offshore oil rig personnel or dayto-day activities.
In conclusion, the Proposed Action would not result in a significant noise impact.

4.13 SECONDARY (INDUCED) IMPACTS
This section describes the potential secondary (induced) impacts of the No Action Alternative and
Proposed Action.
Airport development projects may cause some level of secondary effects. Those effects may be beneficial
or adverse. Examples of beneficial effects include:

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buying construction and operating supplies from local vendors;
providing local artists on-airport areas to display their works; or
offering permanent and part-time jobs to local citizens.

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FIGURE 4-2
CONCEPT X AND Z NOMINAL SONIC BOOM CONTOUR

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Examples of adverse effects include:

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placing excessive demands on local emergency, school, or police services due to sudden influxes
of transient workers; or

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causing changes in population patterns that reduce local tax bases.

4.13.1 Significance Threshold
FAA Order 1050.1E does not provide a significance threshold for secondary (induced) impacts. Instead, the
Order states that induced impacts will normally not be significant except where there are also significant
impacts in other categories, especially noise, land use or direct social impacts.

4.13.2 Environmental Consequences
Secondary impacts were determined through the evaluation of the areas affected by the No Action
Alternative and Proposed Action. Directly affected land, buildings, and transportation facilities were
identified using information from City and County records, aerials, and field observations. This data was
used to determine if any residential or business displacements would be necessary.
Economic impacts that measure the effects of airport development on the local economy can be
characterized as direct, indirect, or induced impacts. Direct impacts are those realized on-site at the
airport that directly relate to construction and operations. Indirect impacts are those created by the
multiplier or “ripple” effect of spending and result from successive rounds of spending by employees at
both direct and indirect facilities. Induced impacts are the secondary changes in the economy that result
from airport development.
4.13.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. As a baseline
for assessing the secondary (induced) impacts of the Proposed Action, conditions under the No Action
Alternative would be similar to existing conditions.
4.13.2.2 Proposed Action
Short-term construction-related employment of local contractors would occur as a result of the Proposed
Action and is considered a positive impact. Based on the 2008-2012 American Community Survey 5-year
estimate, less than ten percent of the Harris County population work in the construction industry (U.S.
Census Bureau, 2012). With respect to changes in traffic volumes in the EFD vicinity, the increase in
construction-related traffic would be considered minor. Additional construction truck traffic could occur
along Space Center Boulevard. However, this would be temporary and is not expected to be visually
intrusive to local residences due to intervening buffers shielding or reducing the view of construction
related activities. This minor increase in construction related traffic would not result in a significant impact.

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Development associated with the launch site operator license would occur entirely on EFD property (see
Chapter 2). The development would be compatible with the existing Airport environment. The
communities surrounding EFD would not be disrupted, nor would any residences and/or businesses be
relocated (see Section 4.4). There is the potential for development, both on-and off-Airport property, to
be attracted to the area. This is likely dependent on the outcome of HAS acquiring a launch site operator
license and other commercial spaceports throughout the United States. Off-Airport development could
include commercial and government/medical/educational land uses attracted to the Houston Spaceport.
However, this possibility exceeds the timeframe of this EA and is not further analyzed in this EA.
The operation of Concept X and Z RLVs are anticipated to generate noise levels comparable to the
existing aviation activities at EFD, as jet engines are used during take-off and landing (see Section 4.12 for
further noise analysis). Rocket engine noise associated with the two concept RLVs would begin when the
vehicles are at a considerable altitude and over the Gulf of Mexico and the resulting sonic boom would
not be heard on land.
Flights associated with the Proposed Action would not cause significant air quality, noise, land use
compatibility, or socioeconomic impacts to the construction or operation ROIs. The Proposed Action
would not increase other activities that could potentially add to direct or indirect impacts in these areas
(e.g., increased vehicular emissions causing a significant air quality impact). Therefore, a significant
secondary (induced) impact would not occur.

4.14 SOCIOECONOMIC IMPACTS, ENVIRONMENTAL JUSTICE, AND CHILDREN’S
HEALTH AND SAFETY RISKS
This section describes the potential effects of the No Action Alternative and Proposed Action related to
socioeconomics, environmental justice, and children’s health and safety risks.

4.14.1 Significance Thresholds
The following sections describe the significance thresholds used to determine potential socioeconomic,
environmental justice, and children’s health and safety risk impacts.
4.14.1.1 Socioeconomics
Factors to be considered in determining whether an action would result in significant socioeconomic
impacts include the following:

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Would the action result in extensive relocation, but replacement housing would be unavailable?

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Would the action result in disruption of local traffic patterns substantially reducing the Level of
Service of those roads serving EFD and surrounding area? or

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Would the action result in a substantial loss in the tax base of the community?

Would the action result in extensive relocation of community businesses causing severe economic
hardship for the affected communities?

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4.14.1.2 Environmental Justice
FAA Order 1050.1E defines a significant impact as one that may occur when an action would cause
disproportionately high and adverse human health or environmental effects on low-income or minority
populations. Additionally, USDOT Order 5610.2(a) defines disproportionately high and adverse effects on
minority and low-income populations as an adverse effect that:

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is “predominately borne by a minority population and/or low-income population, or
will be suffered by the minority population and/or low-income population and is appreciable
more severe or greater in magnitude than the adverse effect that will be suffered by the nonminority population and/or non-low-income population.”

4.14.1.3 Children’s Health and Safety Risks
An action resulting in disproportionate health and safety risks to children indicates a significant impact.

4.14.2 Environmental Consequences
Demographic data was used to evaluate potential future growth within the construction and operation
ROIs and to consider potential impacts of the No Action Alternative and Proposed Action. This evaluation
also considers the levels and duration of project construction traffic and the probability of any
construction traffic using specific roadways and intersections near EFD.
4.14.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. There would
be no impacts related to socioeconomics, environmental justice, and children’s environmental health and
safety risks.
4.14.2.2 Proposed Action
Socioeconomics - The Proposed Action would not result in any physical changes to the surface roadway
system providing access to EFD. The Proposed Action would not require acquisition of land as the
proposed development would be within existing Airport boundaries.
Construction vehicles would need to travel on local roads and access the EFD; however, impacts to traffic
and intersections due to construction vehicles would not permanently degrade the level of service, as it
would be temporary and short-term.
As discussed in Section 3.13, the 2010 Census data shows the population within the construction and
operation ROIs is growing. The number of employees associated with the construction and operation of
the Proposed Action would be minimal compared to the populations of the construction and operation
ROIs. The potential temporary (construction increases) and long-term (operational increases) in
population as a result of the Proposed Action would not place strains on local services (e.g., police force,
firefighting services, etc.). Although the Proposed Action is not anticipated to have a significant direct

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impact on population or development, there is the potential that both on- and off-Airport development
could be attracted to EFD. Any such development would be dependent on the outcome of HAS acquiring
a launch site operator license and other commercial spaceports throughout the United States. Off-airport
development could include commercial and government/medical/educational land uses attracted to the
Houston Spaceport. The nature, timing, and extent of such development cannot be foreseen at this time
and is not included in this analysis.
In conclusion, implementation of the Proposed Action would not have adverse socioeconomic impacts
within the construction or operation ROIs.
Environmental Justice - As discussed in Section 3.13, the construction and operation ROIs are dominated
by middle and upper income ranges and does not have a high minority population percentage. The areas
with lower incomes to the south and southwest have median household incomes of $24,000 to $53,000,
and are considered to be above poverty levels, according to the U.S. Census.
Implementation of the Proposed Action would result in development associated with obtaining a launch
site operator license. This development would occur entirely on EFD property and would not disrupt
communities within the ROIs. Take-off and landing noise associated with the operation of Concept X and
Z RLVs is anticipated to be similar to the jet operations that occur today. Sonic booms occurring as a
result of rocket ignition over the Gulf of Mexico would not be perceived on land (see Section 4.12).
In conclusion, the Proposed Action is not anticipated to cause significant impacts to minority or lowincome populations.
Children’s Environmental Health and Safety Risks - As discussed previously, the development required
would occur entirely on EFD property and would not result in the acquisition or disruption of communities
within the ROIs. Schools exist within the construction ROI (see Figure 3-12) as do recreational areas for
children.
The Concept X and Z RLVs would depart and return similar to other aircraft currently operating at EFD and
would not significantly impact schools or recreational areas within the operation ROI. The sonic booms
produced as a result of RLV operations would occur entirely over the Gulf of Mexico and would not
audible at schools or other areas utilized by children.
In conclusion, implementation of the Proposed Action is not anticipated to cause significant impacts to
children’s health and safety.

4.15 WATER QUALITY
This section describes the potential effects of the No Action Alternative and Proposed Action on water
quality.

4.15.1 Significance Threshold
A significant water quality effect may occur if the EA and early consultation:

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show there is a potential to exceed water quality standards;
identify water quality effects that cannot be avoided or satisfactorily mitigated; or
indicate difficulties in obtaining required permits.

4.15.2 Environmental Consequences
Water quality regulations and consultation with agencies responsible for issuing water-related permits
normally identify issues associated with project-related water quality. In accordance with the instructions
in FAA Order 1050.1E, Appendix A, Section 17, the analysis includes consultation with the following
agencies:

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USEPA (Region 6) to determine if the project would affect a sole source aquifer; and
USFWS for information on the water quality needed to sustain wildlife, fish, and shellfish in the
project study area.

An early coordination letter was sent to the USEPA and USFWS. The USFWS provided information
relevant to this EA in their letter dated October 11, 2013 (see Appendix A-2). This information was
used in the analysis of potential environmental impacts.
The potential impacts to water quality were assessed based on the location, preliminary design plans, and
intended function of the Proposed Action. The proposed disturbed areas and new impervious areas for
the Proposed Action were analyzed to evaluate the short-term construction and long-term operational
impacts to surface waters. Possible impacts to groundwater recharge/discharge areas were investigated.
Increases to potable water consumption and domestic wastewater treatment were also considered in
regard to potential direct impacts or changes in operational activities.
4.15.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. There would
be no impacts on water quality.
4.15.2.2 Proposed Action
Implementation of the Proposed Action would result in temporary effects to water quality. Contaminants
could be discharged into groundwater resources during construction activities. However, implementation
of water-related BMPs through construction permit conditions would prevent a significant impact to
groundwater resources.
Construction activities related to the project components would cause temporary increases in suspended
solids dependent on weather conditions at EFD. Construction activities would be subject to requirements
of the TCEQ GCP TXR150000 (TCEQ, 2006a). Development of a SWPPP is required under the GCP, which
EFD already has in place. Since the Proposed Action would disturb more than five acres, a Notice of Intent

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(NOI) would be submitted to TCEQ to seek coverage under the GCP. HAS would meet additional
requirements of the GCP for construction of the Proposed Action (TCEQ, 2006b). Construction activities
would also be carried out in accordance with the BMPs of the Airport’s SWPPP, such as preforming
inspections during the construction phase to ensure drainage, wastewater, and water supply connections
are correct.
Implementation of the Proposed Action would increase the amount of impervious surface on EFD’s
property by approximately seven acres (see Section 4.7). Preparation activities such as fueling, propellant
loading, and vehicle preparation associated with the Concept X and Z RLVs could result in inadvertent
spills or releases of fuels, propellants, or materials that could impact surface and groundwater. EFD
currently has policies and procedures for handling, disposing, and cleaning up hazardous materials,
chemicals, substances, and wastes which are described in their Airport Certification Manual (ACM) as part
of their 14 CFR Part 139 certification. EFD also has a SWPPP to further eliminate and reduce stormwater
discharges. These policies and procedures would be updated for spaceport activities.
Jet fueling operations would occur on the proposed apron. Prior to initiating operations, the launch
operator would have a SPCC plan in place. If a spill of jet fuel occurs, the launch operator would be
responsible for any necessary cleanup and remediation actions, as are current operators at EFD.
A separate individual TPDES permit would be obtained for discharges of any process wastewater from
material storage or handling areas, including contaminated stormwater. Additionally, the Proposed Action
would comply with the requirements of the CWA and TWC.
In addition, the relatively low number of employees associated with the small development for spaceport
operations would not result in a significant water use. Therefore, the Proposed Action’s potential impact
on potable water supplies or local wastewater treatment facilities would not be significant.
In conclusion, the Proposed Action would not result in significant impacts to water quality compared to
the No Action Alternative.

4.16 WETLANDS
This section describes the potential effects of the No-Action Alternative and Proposed Action on wetlands.

4.16.1 Significance Threshold
A significant impact would occur if a project were to:

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adversely affect a wetland’s ability to protect the quality or quantity of municipal water supplies,
including sole source, potable water aquifers;

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substantially alter the wetland hydrology needed to sustain the functions and values of the
affected wetland or any wetland to which the affected wetland is connected;

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substantially reduce the affected wetland’s ability to retain floodwaters or storm associated runoff,
thereby threatening public health, safety or welfare (this includes cultural, recreational, and
scientific resources important to the public, or property);

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adversely affect the maintenance of natural systems that support wildlife and fish habitat or
economically-important timber, food, or fiber resources in the affected or surrounding wetlands;

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promote development of secondary activities or services that would affect the resources or
functions mentioned in the above items; or

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be inconsistent with applicable State wetland strategies.

4.16.2 Environmental Consequences
This EA uses the applicable laws and regulations and FAA Order 1050.1E, Appendix A. Section 18 to
determine potential wetland impacts. The analysis included a review of data from the NWI to determine to
location of potential wetland areas. The EA analyzes where development activities would take place in
relation to identified wetlands to determine potential impacts.
4.16.2.1 No Action Alternative
Under the No Action Alternative, the FAA would not issue HAS a launch site operator license, and thus no
launch licenses to individual launch vehicle operators to operate at EFD. Spaceport-related construction or
operations would not occur. EFD would continue to operate and serve forecast aviation activity. Airport
development would be subject to review and approval under NEPA and is not assumed under this
alternative. Maintenance activities (i.e., mowing, hay production) would also continue at EFD. There would
not be impacts to wetlands.
4.16.2.2 Proposed Action
The Proposed Action would require seven acres of new impervious surface at EFD, none of which would
be constructed within a wetland. Jet fueling operations would occur approximately 1,500 feet way from
nearest isolated wetland. In addition, HTPB solid fuel, N2O, LOX, and kerosene (RP-1) would be loaded in
designated areas of EFD, approximately 2,000 feet away from the nearest isolated wetland. If a fuel spill
occurs, the launch operator would be responsible for any necessary cleanup and remediation under a
SPCC plan. Therefore, there would be no significant wetland impacts associated with the Proposed Action.

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 CUMULATIVE IMPACTS

CHAPTER 5

CUMULATIVE IMPACTS

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Cumulative impacts are defined by CEQ in 40 CFR §1508.7 as, “the impact on the environment which
results from the incremental impact of the action when added to other past, present, and reasonably
foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such
other actions.”
The CEQ regulations further require that NEPA environmental analyses address connected, cumulative,
and similar actions in the same document (40 CFR 1508.25). Additionally, CEQ further explained in
Considering Cumulative Effects under NEPA that, “each resource, ecosystem and human community must
be analyzed in terms of its ability to accommodate additional effects, based on its own time and space
parameters.” Therefore, a cumulative effects analysis normally would encompass geographic boundaries
beyond the immediate area of the Proposed Action, and a time frame, including past actions and
foreseeable future actions, in order to capture these additional potential effects.
For this EA, spatial and temporal boundaries were delineated to determine the areas and projects within
those areas the cumulative analysis would address. The spatial boundary for this cumulative analysis is the
construction ROI. Projects described in the following sections include those which had or have the
potential to affect the environmental impact categories analyzed in this EA. For this EA, past actions
include those which have occurred within the last three years, and reasonably foreseeable actions include
those planned to occur within the next five years. Since some future projects are in various stages of
conceptual development and are speculative at this time, it is not possible to fully quantify the effects
associated with them. Projects in early planning phases do not provide enough data to ensure reasonable
analyses and are subject to change.
The past, present and reasonably foreseeable actions described in the following sections were researched
using Federal, State and local agency websites (e.g., TxDOT). In addition, agency information provided
during the early consultation process was also incorporated (see Section 1.5). HAS and Airport staff also
provided information related to cumulative projects in the vicinity of the Airport.

5.1 PAST ACTIONS
The USCG moved its Houston-Galveston headquarters to EFD. This included the construction of a new
117,000 square foot building. This building has room to house 300 employees, the Sector’s command
center, investigative services, electronic support, public affairs, and the regional civil rights office (HAS,
2013a).
Actions recently completed within the construction ROI include (City of Houston, 2014a):

»

roadway improvement to Clear Lake City Boulevard from Old Galveston Road to Space Center
Boulevard;

»
»
»

improvements to the water purification plant on Genoa Red Bluff Road;
improvements to the Ellington Park wastewater collection system; and
numerous sidewalk improvements.

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5.2 PRESENT ACTIONS
The Ellington Airport Self-Service Fuel Facility EA proposed to construct a self-service fueling facility at the
end of Taxiway J on the southwestern area of the airfield. The self-service facility would include a concrete
pad 43 feet long by 10 feet wide and an above-ground storage tank for Avgas and a pump and payment
kiosk, which would all be covered by a canopy.
Present actions occurring within the construction ROI include (TxDOT, 2014):

»
»

Houston Optimization of Airspace and Procedures in the Metroplex (Houston OAPM)

»

construction of a new road from Preston Road to Genoa Red Bluff Road.

installation and upgrades of drainage structures from Horsepen Bayou to Galveston County line;
and

5.3 REASONABLY FORESEEABLE ACTIONS
The following on- and off-Airport actions are based on information available in the City’s Capital
Improvement Plan (CIP). The CIP is for planning and budgeting purposes. These actions may or may not
occur dependent on factors not foreseen at this time.
The following on-Airport actions have been planned to a level of reasonably foreseeable certainty (City of
Houston, 2014b):

»
»
»
»

construction of a single story passenger terminal with international screening options;

»
»
»
»
»
»
»

ramp pavement reconstruction adjacent to Southwest Airport Services Fixed Based Operator;

extension of Challenger Boulevard to Brantley and reworking the roadway lighting;
rehabilitation of airfield pavement on Runway 17L/35R;
construction of the Ellington Field Bypass (Space Center Boulevard) from Highway 3 to the
existing Space Center Boulevard;
construction of a new tower;
extension of Taxiway G;
construction of a new taxilane and cargo ramp;
addition of asphalt shoulders to Runway 17R/35L and Runway 4/22;
rehabilitation of and upgrade to portions of asphalt service road; and
rejuvenate and reseal asphalt on the T-Hangar ramp and added to Taxiway D shoulders at EFD.

The Lone Star Flight Museum is also planned to be relocated to EFD from its current location in Galveston
(HAS, 2014). The City’s CIP also includes the extension of Runway 17R-35L to the north by 200 to 1,000
feet. Although this extension is described as support for spaceport operations, it is not necessary for the
RLV operations analyzed in this EA and is not reasonably foreseeable. Should future RLV operators chose
to operate at the Houston Spaceport and a runway extension is determined to be necessary, the runway
extension would be analyzed under a separate NEPA document. Therefore, this project is not included as
part of the Proposed Action analyzed in this EA.

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 CUMULATIVE IMPACTS
Off-Airport, TxDOT plans to construct a four lane thoroughfare on Preston Road from Genoa Red Bluff
Road (TxDOT, 2013). JA Billipp Company, a commercial and industrial real estate development and
investment company plans to develop 36.8 acres of land directly adjacent to EFD for aircraft and
aerospace related facilities (Webber Properties LP and JA Billipp Company, 2014).

5.4 SIGNIFICANCE THRESHOLDS
The analysis of potential cumulative impacts uses the thresholds of significance in FAA Order 1050.1E,
Change 1, Appendix A that FAA has developed for each individual impact category.

5.5 ENVIRONMENTAL CONSEQUENCES
CEQ regulations implementing NEPA require the analysis and disclosure of the Proposed Action’s
potential cumulative effects (40 CFR 1508.25(a)(2) and (3)). CEQ and NEPA do so to inform the public if the
Proposed Action, when considered with other projects occurring within the project study areas during
specific time frames (i.e., “past, present, and reasonably foreseeable actions”), would cause a significant
environmental effect.
This EA uses information presented in Sections 5.1, 5.2, and 5.3 to determine potential cumulative
impacts. Cumulative impacts are only considered for those resources the Proposed Action would affect
(e.g., air quality, noise, water quality). The Proposed Action would not result in cumulative impacts to
resources that the Proposed Action would not affect (e.g., floodplains, wetlands). Each past, present, and
reasonably foreseeable future action was cumulatively analyzed for its potential to impact the same
environmental resources impacted by the Proposed Action.

5.5.1

Proposed Action

Implementation of the Proposed Action would result in less than significant adverse environmental
impacts related to minor temporary construction efforts, minor increases in noise generation, minor
increases in air emissions, and minor stormwater runoff increases. The potential cumulative impacts to
those resources are described in the following paragraphs.
Air Quality - The past, present, and reasonably foreseeable future actions could result in increases to
emissions.
Implementation of the Houston OAPM would result in slightly more fuel burned. However, this cumulative
project is presumed to conform with the SIP. Accordingly, implementation would not cause or contribute
to a new violation of the NAAQS (FAA, 2013e). Therefore, implementation of the Houston OAPM would
not have a significant impact on air quality.
Overall, the roadway improvements could potentially lessen vehicle emissions by improving the level of
service of the roadways. The construction of these cumulative projects would not occur at the same time.
Therefore, the cumulative projects, in addition to the Proposed Action, are not anticipated to significantly
affect air quality.

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 CUMULATIVE IMPACTS
Noise - The past, present, and reasonably foreseeable future actions could result in increased noise to the
surrounding area during construction activities. The increase in noise would be temporary, lasting only as
long as construction. In addition, these cumulative projects would not all occur at the same time.
Implementation of the Houston OAPM would not result in a DNL increase of 1.5 dB or more in noise
sensitive area exposed to aircraft noise at or above DNL 65 dB (FAA, 2013e). The extension of Runway
17L-35R to the north could shift EFD’s aviation noise contours. The potential change in the noise contours
is not known as the length of the runway extension has not been determined, along with other necessary
planning. Therefore, the Proposed Action, in combination with the cumulative projects, is not anticipated
to significantly increase noise in the surrounding areas.
Water Quality - The past, present, and reasonably foreseeable future actions could result in temporary
effects to water quality during construction. Contaminants could be discharged into groundwater
resources during construction activities. The on-Airport actions would increase the overall impervious
surface of EFD; however the existing drainage and any drainage improvements associated with the actions
would mitigate for the increase in impervious surfaces. The off-Airport drainage improvements could
potentially improve the water quality in the area by ensuring stormwater is diverted to the proper
stormwater management and treatment facilities. The roadway improvements could potentially increase
the area’s impervious surface and stormwater runoff. However, potential impacts would be minimized
through the development of stormwater ponds. Cumulatively, the Proposed Action and these cumulative
projects would not significantly impact water quality.
In conclusion, when the Proposed Action is cumulatively examined with past, present, and reasonably
foreseeable projects at and in the vicinity of EFD, significant adverse cumulative effects are not
anticipated. Therefore, the Proposed Action would not result in a significant cumulative impact.

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 REFERENCES



REFERENCES

 

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The following references were used in the development of this EA.
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40 CFR 1500.2(c), Protection of the Environment, Council on Environmental Quality Policy.
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52 FR 2923 (1987), EO 12580, Superfund Implementation.
58 FR 41981 (1993), EO 12856, Federal Compliance with Right-to-Know Laws and Pollution Prevention
Requirements.
60 FR 40837 (1994), Presidential Memorandum on Environmentally and Economically Beneficial
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61 FR 26771 (1996), EO 13007, Indian Sacred Sites.
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33 U.S.C. § 1251 et. seq. (1972), Clean Water Act.
33 U.S.C. § 2701 (1990), the Oil Pollution Prevention Act of 1990.
42 U.S.C. § 300(f) (1974), Safe Drinking Water Act, as amended.
42 U.S.C. § 1996 (1978), The American Indian Religious Freedom Act of 1978.
42 U.S.C. § 1252 et. seq. (1990), Oil Pollution Act of 1990.
42 U.S.C. § 6901 et. seq. (1976), Resource Conservation and Recovery Act.
42 U.S.C. § 9601(1980) Comprehensive Environmental Response, Compensation, and Liability Act.

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49 U.S.C. § 2101 et. seq. (1990), Airport Noise and Capacity Act.
49 U.S.C. § 4701 et. seq. (1982), The Airport and Airway Improvement Act of 1982.
49 U.S.C. § 44715 (1972), The Noise Control Act of 1972.
49 U.S.C. § 47101 (1968), The Control and Abatement of Aircraft Noise and Sonic Boom Act of 1968.
49 U.S.C. § 47107(a)(16), Grant Assurance No. 29
49 U.S.C. § 47501-47507 (1979), Aviation Safety and Noise Abatement Act of 1979.
51 U.S.C. § 50901-50923 (1984), Commercial Space Launch Act.
The American National Standard Institute (ANSI) (2005), Quantities and Procedures for Description and
Measurement of Environmental Sound – Part 4: Noise Assessment and Prediction of Long-term
Community Response,” ANSI S12.9-2005/Part 4
CEQ (2010), Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse
Gas Emissions,
http://ceq.hss.doe.gov/nepa/regs/Consideration_of_Effects_of_GHG_Draft_NEPA_Guidance_FINAL_021
82010.pdf.
Chantlett, E. T. (1973), Environmental Protection, McGraw-Hill Book Co. New York.
City of Houston (2008a), Code of Ordinances, Chapter 9, Article VI, Airport Land Use Regulations,
http://library.municode.com/index.aspx?clientId=10123, accessed November 2013.
City of Houston (2008b), Code of Ordinances, Chapter 9, Article VI, Airport Land Use Regulations,
Division 4, Ellington Airport (EFD) Compatible Land Use Regulations,
http://library.municode.com/index.aspx?clientId=10123, accessed November 2013.
City of Houston (2014a), My City Map Viewer, Pubic Works, http://mycity.houstontx.gov/public/?sid=1,
accessed January 2014.
City of Houston (2014b), Aviation Facilities 2014-2018 Capital Improvement Plan,
http://www.houstontx.gov/cip/14cipadopt/has.pdf, accessed January 2014.
Environmental Laboratory (1987), Corps of Engineers Delineation Manual, Technical Report 87-1.
Executive Order 12465, Commercial Expendable Launch Vehicle Activities
FAA (1984), FAR Part 150, Appendix A.

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FAA (2004), Air Quality Procedures for Civilian Airports and Air Force Bases (with Addendum).
September, 2004.
FAA (2005), Final Programmatic Environmental Impact Statement for Horizontal Launch and Reentry of
Reentry Vehicles. December, 2005.
FAA (2006), Order 1050.1E, Environmental Impacts: Policies and Procedures, Change 1, March 2006.
FAA (2009a), Airport Compliance Manual, Order 5190,6B, Chapter 20, pg. 20-2,
http://www.faa.gov/airports/resources/publications/orders/compliance_5190_6/, accessed January
2014.
FAA (2009b), Guidance for Quantifying Speciated Organic Gas Emissions from Airport Sources version 1.
September, 2009.
FAA (2011), Advisory Circular 150/5370-10C, Standards for Specifying Construction at Airports, Item P156 Temporary Air and Water Pollution, Soil Erosion and Siltation Control.
FAA (2012), Order 1050.1E, Change 1, Guidance Memo #3, Considering Greenhouse Gases and Climate
Under the National Environmental Policy Act (NEPA): Interim Guidance, January 12, 2012.
FAA (2013a), Part 139 Airport Certification,
http://www.faa.gov/airports/airport_safety/part139_cert/?p1=faq.
FAA (2013b), Terminal Area Forecast, http://aspm.faa.gov/main/taf.asp
FAA (2013c), Office of Airports, Standard Procedure for FAA Review and Approval of Airport Layout
Plans.
FAA (2013d), Wildlife Strike Database, http://wildlife.faa.gov/database.aspx, accessed November 2013.
FAA (2013e), Final Environmental Assessment for Houston Optimization of Airspace and Procedures in
the Metroplex, January 2013.
HAS (2004a), Master Plan: Ellington Field.
GAO (2009), Report to Congressional Committees, http://www.gao.gov/new.items/d09554.pdf
HAS (2004b), Technical Report Master Plan.
HAS (2009), SPCC Plan CB701210.005.001.0121.
HAS (2013a), Coast Guard HQ Nearing Completion at EFD,
http://www.fly2houston.com/0/3921490/0/83280D83283/, accessed September 2014.

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HAS (2013b), Environmental Assessment: Ellington Airport Self-Service Fueling Facility.
HAS (2014), Lone Star Flight Museum Coming to Ellington Airport,
http://www.fly2houston.com/0/3921780/0/0/, accessed September 2014.
H-GAC (2012), 2013-2016 Transportation Improvement Program, http://www.hgac.com/taq/tip/docs/H-GAC_2013-2016%20TIP-As_Adopted-04-27-2012.pdf, accessed October 2013.
H-GAC (2013), Landfills, Transfer Stations, and Citizens’ Collection Stations, http://www.hgac.com/community/waste/facilities/transfer.aspx, accessed October 2013.
Houston Wildlife Refuges (2014), Houston Area National Wildlife Refuges,
http://www.houstonrefuges.org/refuges.html, accessed October 2014.
Journal of the Acoustical Society of America (1978), No. 64, pg. 377-405.
Maurice, Lourdes Q. & Lee, David S. (2007), Final Report of the Interactional Civil Aviation Organization
Committee on Aviation and Environmental Protection Workshop, Chapter 5: Aviation Impacts on
Climate, http://www.icao.int/icaonetlcnfrstlCAEP/CAEP SG_20082/docs/Caep8_SG2_ WPI0.pdf.
Melrose, Alan (2010), European ATM and Climate Adaptation: A Scoping Study, ICAO Environmental
Report.
NASA (2006), Environmental Resources of Ellington Field.
National Weather Service (2013), Weather Forecast Office Houston/Galveston, TX, Houston Extremes,
Normals, and Annual Summaries, http://www.srh.noaa.gov/hgx/?n=climate_iah_normals_summary,
accessed September 2013.
NPS (2013), Find a Park, www.nps.gov, accessed September 2013.
NRCS (2013), Web Soil Survey, http://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx,
accessed November 2013.
RS&H (2012), Ellington Airport Spaceport Feasibility Study.
TCEQ (2006a), Texas Pollutant Discharge Elimination System Storm Water Multi-Sector General Permit
TXR050000, http://www.tceq.texas.gov/assets/public/permitting/stormwater/txr050000.pdf, accessed
November 2013.
TCEQ (2006b), TPDES General Permit TXR150000, pg. 17-18,
http://www.tceq.texas.gov/assets/public/permitting/stormwater/TXR150000_CGP.pdf, accessed
January 2014.

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 REFERENCES
TCEQ (2013), Municipal Solid Waste in Texas: A Year in Review, FY 2012 Data Summary and Analysis,
pg. 30-31, http://www.tceq.texas.gov/assets/public/comm_exec/pubs/as/187_13.pdf, accessed January
2014.
TAC (1995a), Title 31 Natural Resources and Conservation, Part 16, §501.12,
http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_plo
c=&pg=1&p_tac=&ti=31&pt=16&ch=501&rl=12, accessed September 2013.
TAC (1995b), Title 31 Natural Resources and Conservation, Part 16, §506.20,
http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_plo
c=&pg=1&p_tac=&ti=31&pt=16&ch=506&rl=20, accessed September 2013.
TAC (1995c), Title 31 Natural Resources and Conservation, Part 16, §506.12,
http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_plo
c=&pg=1&p_tac=&ti=31&pt=16&ch=506&rl=12, accessed September 2013
THC (2013), State Historical Markers, http://www.thc.state.tx.us/preserve/projects-and-programs/statehistorical-markers, accessed October 2013.
TPW (2013), Bald Eagle, http://www.tpwd.state.tx.us/huntwild/wild/species/baldeagle/, accessed
November 2013.
TxDOT (2011), Hydraulic Design Manual, http://onlinemanuals.txdot.gov/txdotmanuals/hyd/hyd.pdf,
accessed October 2013.
TxDOT (2013), Planned Projects FY 2013, http://ftp.dot.state.tx.us/pub/txdotinfo/rider14l/fy2013_planned_projects.pdf, accessed January 2014.
TxDOT (2014), Current TxDOT Projects: Harris County, http://apps.dot.state.tx.us/appscq/project_tracker/projects.htm?view=cnty&dist=Houston&cnty=Harris, accessed January 2014.
USACE (1987), Wetlands Research Program Technical Report Y-87-1, Corps Of Engineers Wetlands
Delineation Manual.
U.S. Census Bureau (2012), American Fact Finder, Harris County Economic Characteristics,
http://factfinder2.census.gov/bkmk/table/1.0/en/ACS/12_5YR/DP03/0500000US48201%7C0400000US4
8, accessed January 2014.
USEPA (2009), Technical Support Document for Endangerment and Cause or Contribute Findings for
Greenhouse Gases under Section 202(a) of the Clean Air Act 2-3,
http://epa.gov/climatechange/endangerment.html.
USEPA (2010), 2010 Waterbody Report for Horsepen Bayou Tidal (unclassified water body),
http://oaspub.epa.gov/tmdl/attains_waterbody.control?p_list_id=TX1113B_01&p_cycle=2010&p_report_type, accessed October 2013.

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USDA (2012), Part 523 Farmland Protection Policy Act Manual, Section523.10(B),
http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1049284.pdf, accessed September 2013.

USEPA (2012), What are the Six Common air Pollutants, http://www.epa.gov/air/urbanair/, accessed
October 2014.
USEPA (2013a), NEPAssist, http://nepassisttool.epa.gov/nepassist/entry.aspx, accessed September
2013.
USEPA (2013b), Superfund Sites, http://www.epa.gov/superfund/sites/npl/nar779.htm, accessed
September 2013.
USFWS (2011), Houston Toad (Bufo houstenensis) 5-Year Review: Summary and Evaluation,
http://www.fws.gov/southwest/es/documents/r2es/houstontoad_5-yr_review_nov2011.pdf, accessed
May 2014.
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XArc (2013), Houston Spaceport Economics and Business Study, November 2013.

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 LIST OF PREPARERS

CHAPTER 7

LIST OF PREPARERS

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7.1 LEAD AGENCY
The FAA is the lead agency for the preparation of this EA. Responsibility for review and approval of this EA
rests with the FAA. Listed below are the identities of the principal FAA individuals in accordance with CEQ
Regulations Section 1502.7, FAA Order 1050.1E, Policies and Procedures, and FAA Order 5050.4B, National
Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions. The following FAA staff were
involved in the preparation of this EA:
Daniel Czelusniak
Position:
Environmental Protection Specialist
Stacey M. Zee
Position:
Environmental Protection Specialist
Ken Gidlow
Position:

Aerospace Engineer

7.2 PRINCIPAL PREPARERS
Responsibility for preparation of this EA rests with HAS. Listed below are the employees of HAS and
consulting firms responsible for preparation of this EA. Consultants to HAS include firms with experience
in spaceport and environmental planning. It is recognized that no one individual can be an expert in all of
the environmental analysis presented in this EA. Consequently, an interdisciplinary team, consisting of
technicians and experts in various topics was required to prepare and complete this EA.

7.2.1

HAS

Arturo Machuca
Position:
Business Development Manager
Carlos Ortiz
Position:

7.2.2

Assistant Director of Aviation

RS&H

David Alberts
Position:
Senior Environmental Planner, Southeast Region Environmental Service Group
Leader
Education:
Bachelor of Arts in Geography, University of South Florida, 1997
Experience:
Mr. Alberts has 17 years of NEPA related experience. He has managed and prepared
federal EISs, EAs, and documented categorical exclusions, as well as state environmental
documents for a variety of major air carrier and general aviation airports throughout the
United States.

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 LIST OF PREPARERS
Ken Ibold, AICP, CNU-A
Position:
Senior Aviation Planner
Education:
Bachelor of Science, University of Wisconsin-Madison, 1983
Experience:
Mr. Ibold is an aviation planner responsible for the execution of aviation planning efforts,
including safety management systems, FAA-licenses commercial spaceports, airport
master plans, feasibility studies, CIP development, and airport layout plans.
Jeff Mishler, P.E.
Position:
Planning Service Group Leader, Vice President
Education:
Bachelor of Science in Civil Engineering, Michigan State University, 1983
Experience:
Mr. Mishler has 25 years of experience in managing airport master planning, airport
engineering, aviation system planning, site selection, and noise/environmental planning
studies. His technical expertise includes aviation demand forecasting, airfield
demand/capacity, aircraft delay, land use, air cargo, project cost/benefit, terminal, and
financial feasibility analyses.
Brian Gulliver, PE, LEED® AP
Position:
Mechanical Design Engineer
Education:
Masters of Science in Mechanical Engineering, University of Central Florida,
2003; Bachelor of Science in Mechanical Engineering, University of Central
Florida, 2002
Experience:
Mr. Gulliver has nearly ten years of experience in the planning, design, and analysis of
launch complexes and spaceport. He has completed a large number of facilities studies,
cost estimates, and assessments for government and private customers, including NASA,
Space Florida, Lockheed Martin, ATK, Andrews Space, Jacksonville Aviation Authority,
Orbital Sciences, and Kistler. Mr. Gulliver has extensive background knowledge of both
existing and new launch complexes and launch vehicles.
Natalie Deschapelles
Position:
Environmental Planner
Education:
Masters of Science in Urban and Regional Planning, Florida State University,
Experience:

2012; Bachelor of Science in Environmental Studies and Political Science, 2010
Ms. Deschapelles has experience conducting NEPA research, analysis, and documentation
for commercial and general aviation airports nationwide. She also has experience with the
use of Geographic Information Systems (GIS).

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Ben Chandler
Position:
Senior Geologist
Education:
Bachelor of Science in Geological Sciences, Southern Illinois University, 1987
Experience:
Mr. Chandler has over 22 years of experience as a geologist conducting a variety of
environmental investigations across the United States. He has successfully managed
projects relative to environmental compliance, environmental management systems (ISO
14001/QS 9000), spill prevention control and countermeasure plans, soil and
groundwater contamination investigations (petroleum, chlorinated solvent, and heavy
metal impacts), toxic materials management, and sustainable design initiatives.
Jon Erion
Position:
Education:
Experience:

Senior Aviation Planner
Bachelor of Science, Urban Planning, University of Cincinnati, 2000
Mr. Erion is a senior airport planner with more than 14 years aviation experience at
small, medium, and large hub, general aviation, and military airports. Project experience
includes: airport master planning; on-call service planning; runway safety area
practicability analysis; non-aviation land use and industrial park planning,
airspace/obstruction analysis, runway length analysis, aircraft/airline gate utilization
studies, and forecasting.

Nick Kozlik, LEED Green Associate
Position:
Environmental Planner
Education:
Bachelor of Science in Environmental Studies, Florida State University, 2009;
Certificate in Urban and Regional Planning, Florida State University, 2009
Experience:
Mr. Kozlik has experience conducting NEPA research and preparing NEPA and California
Environmental Quality Act (CEQA) documents. He has experience preparing documents
and graphics through the use of GIS for both Categorical Exclusions and Environmental
Assessments. Mr. Kozlik has more than two years of experience in developing documents
for airports throughout the United States.
Matt K. Thomason
Position:
Education:
Experience:

Aviation Planner
Masters of Science in Airport Planning and Management, Cranfield University,
United Kingdom, 2012; Bachelor of Civil Engineering, Auburn University, 2009
Mr. Thomason has experience assisting senior aviation planners with a wide variety of
aviation and spaceport planning tasks involving research, data compilation, analytical
analysis, and the preparation of reports and studies.

Houston Spaceport Environmental Assessment – Draft

7-5

 LIST OF PREPARERS
Nathan Stinnette
Position:
Sustainability Specialist
Education:
Master of Science in Strategic Leadership Towards Sustainability, Blekinge
Technical Institute, 2010; Bachelor of Science in Geographic Science, James
Madison University, 2007
Experience:
Mr. Stinnette has more than six years of professional experience in natural resource
management and GIS mapping and analysis. He has more than two year of experience in
sustainability consulting, and more than one year of experience in environmental
compliance.
William “Bill” Willkie
Position:
Senior Environmental Planner, Western Region Environmental Service Group
Leader
Education:
Master of City Planning in Environmental, Georgia Institute of Technology, 1981
Bachelor of Fine Art in Architecture, University of New Mexico, 1973
Experience:
Mr. Willkie has over 30 years of aviation environmental planning experience. His
professional experience includes management and/or technical leadership of NEPA
studies for airport development and airspace actions, as well as noise compatibility
studies under Federal Aviation Regulations Part 150 (FAR Part 150) for commercial
airports across the nation.
Richard Rogers
Position:
Aerospace Engineer
Education:
Bachelor of Science in Aerospace Engineering, University of Central Florida, 2009
Experience:
Mr. Rogers has experience performing engineering design, analysis, and research for both
commercial and government clients in the aerospace and defense industry.

7.2.3

Community Awareness Services

Jerri Anderson
Position:
Public Involvement Director
Education:
Associate of Arts in Business, Lansing College, 1979
Experience:
Ms. Anderson has over 25 years of public involvement, management, and NEPA-related
experience. She has managed public involvement programs for a variety of
transportation-related EISs and EAs, including airport expansions, airspace optimization
studies, roadways, rail transit, and seaport expansions.

Houston Spaceport Environmental Assessment – Draft

7-6

 LIST OF PREPARERS

7.2.4

KB Environmental Sciences, Inc.

Michael Kenney
Position:
Air Quality Scientist
Education:
Bachelor of Science in Environmental Science, University of Maine, 1976; Master of
Science in Environmental Engineering Sciences, University of Florida, 1979
Experience:
Mr. Kenney has over 30 years of experience preparing air quality assessments for the
transportation sector, with a particular focus on aviation. His expertise includes emissions
inventories, atmospheric dispersion modeling, emission reduction measures, and agency
and public coordination.
Paul Sanford
Position:
Education:
Experience:

Air Quality Scientist and Environmental Specialist
Bachelor of Science in Environmental Science and Policy, University of South Florida, 2010
Mr. Sanford has six years of experience preparing air quality and environmental
contamination impact assessments for the transportation sector, including aviation, with
expertise in ensuring compliance with both federal environmental regulations such as the
NEPA, CAA, and RCRA, as well as state and local requirements.

7.3 COOPERATING AGENCY
7.3.1

NASA

Tina Norwood
Position:
NASA NEPA Manager
David Hickens
Position:
Johnson Space Center’s NEPA Manager

Houston Spaceport Environmental Assessment – Draft

7-7

 LIST OF PREPARERS

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Houston Spaceport Environmental Assessment – Draft

7-8

 EARLY NOTIFICATION LETTER

APPENDIX A

EARLY NOTIFICATION LETTER

Houston Spaceport Environmental Assessment – Draft

A-1

 EARLY NOTIFICATION LETTER

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Houston Spaceport Environmental Assessment – Draft

A-2

 EARLY NOTIFICATION LETTER

APPENDIX A-1

EARLY NOTIFICATION LETTER

Houston Spaceport Environmental Assessment – Draft

A-3

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Houston Spaceport Environmental Assessment – Draft

A-4

 EARLY NOTIFICATION LETTER

 

 

3341



LCM-E. Deere-nod Park Bro-d South
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'Ia'c?rioe 91:1. Eb EEG

fax 9'11- Eb EOE

1Elr'11f13

CONTACT NAME
AGENCY
ADDRESS

CITY, 

FIE: Earlyr Coordination for an EnvironmentafAssessment for a Proposed Houston
Spaceport at Ellington Airport, Harris County, Houston, Texas

Dear Mr. or Ms.

The purpose ofthis letter is to seelr input concerning potential environmental impacts that may be
associated with the construction of initial spaceport facilities and operation of horizontally launched
reusable launch yehicles fPL'y'sj at Ellington Airport [see Attachment 

The City of Houston, Houston Airport System (HAS) is seeldng a launch site operator's license to
allow for the horizontal departure and landing of winged PL'y's at Ellington Airport. The Federal
Ayiation Administration, Office of Commercial Space Transportation will rayiew the
license application based on scyeral factors, including the completion of an Enyironmental
Assessment (EA). HAS selected PSSH to conduct the technical and analytical studies required for
a launch site operator's license application, including the EA

The Proposed Action includes acquisition of a launch site operator's license, the construction of
initial spaceport facilities, apron area, yehicle access, stormwater treatment, and other initial
infrastructure (is, an oxidizer loading area] necessary to accommodate either a Concept or 
yehicle and support equipment. The initial infrastructure would be sized to house either PW and
would be comparable in size, constructionI and operation to existing on-Airport corporate hangars
and office facilities. Should Ellington Airport need additional spaceport facilities beyond the
Proposed Action, enyironmental approyals will be completed accordingly

Attachment 2 shows examples and descriptions of the concept yehicles. The winged PL'y's
would operate similarlyto today's aircraft and use common fuelsfor propulsion, such as Jet A. The
roclrets used by the PL'y's use refined kerosene similar to Jet A or solid hybrid fuels
chemically similar to rubber or paraffin. and oxidizers such as liquid oxygen, nitrous oxide or
hydrogen peroxide. No hypergols or other hazardous materials are used in these yehicles. At this
time. it is anticipated that the PL'y's would follow a southerly flight path toward the Gulf of lylexico to
conduct its operation to suborbital altitudes [see Attachment 

Proposed are approximately up to Ell] total commercial operations per year; significantly lower
than the current number of aircraft operations at Ellington Airport (FAA Terminal Area Forecast -
Elli? approximately total operations]. The dayelopment ofyehicle operatingrsafety areas
and established operating procedures associated with the launch site operator's license application
[1:1 CFP will help to ensure the safety of the PLHe'and the uninyolyed public

 

 

Houston Spaceport Environmental Assessment Draft

A-5

 

EARLY NOTIFICATION LETTER

 

 

1 
Page air".-

In preparing the EA. PSSH will meet the reguirements of the Council on Environmental Quality
regulations implementing the National Environmental Policy Act FAA  IZIIrder
lE, Environmental impacts Policies and Procedures, Change 1, and FAA EDEDAB,
NEPA implementing instructions for Airport Actions. The EA will evaluate the potential direct,
indirect, and cumulative environmental effects associated with the Proposed Action and analyze
reasonable alternativesto the Proposed Action; including a No?Action Altemative

On behalf of HAS, PSSH is sending this early notification letterto'

l. Advise you of the preparation of the 

2. Seek any relevant information you may have regarding the environment human,
natural, or phvsicalji within the vicinity of Ellington Airport; and

3. Solicit earlv environmental comments and concerns regarding potential environmental,
social, and economic issuesfor consideration during preparation of the EA.

We would appreciate any information andi?or comments vou would like to contribute Your inputwill
be useful to HAS, and the for making the most irfonned 
EA process. You mav send [via post or emaill information andi?or comments pv November ?11.
ENG to:

Pevnolds, Smith and Hills, lnc.

Attn. David Alherts

Deenrvood Park Boulevard South
Jacksonville, FL 32255?059?
DavidAlhertst?lrsandh com

Thank you for vour interest in this project and we look fonwiard to working with you as we prepare
this EA. If vou have any questions, or would like additional information regarding the Proposed
Action, please do not hesitate to contact me.

~Sincerelv,

l' ?ing? I
David E. Alperts
Southeast Region Environmental Service Group Leader

Attachments: Attachment 1 Location lvlap
Attachment 2 Example of Concept and ?v?e hi cles
Attachment 3 Sample Flight Path

Ce: Arturo lvlachuca, Houston Airport Svstem
Carlos lIZIIrtiz, Houston Airport System
Dan Czelusniak, FAAIAST
File

 

 

Houston Spaceport Environmental Assessment Draft A-6

 

EARLY NOTIFICATION LETTER

 

1E f11f13
Page 3 of?

Attachment 1
Location Map

 

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Houston Spaceport Environmental Assessment Draft A-7

EARLY NOTIFICATION LETTER

 

 

1E fl1f13

Page 4 ef?

AttachmentE
lConcept and Vehicle Examples

 

Concept 2 Vehicle Examples

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Reusable Launch

Vehicle
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Concept Vehicle Examplaa

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2 - Launch eel-i:an carried we. larger mrcralt to deognaled launch area
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Houston Spaceport Environmental Assessment Draft

EARLY NOTIFICATION LETTER

 

 

1Elf?l1f13
Page 5 af?

Attachment?
Sample Flight Path





 
   



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Houston Spaceport Environmental Assessment Draft

A-9

EARLY NOTIFICATION LETTER

Houston Spaceport Environmental Assessment
Early Coordination Mailing List
Federal
Mr. Daniel Czelusniak
Federal Aviation Administration
800 Independence Avenue, SW, Suite 325
Washington, DC 20591

Dr. Ellen Ochoa
NASA
2101 NASA Parkway
Houston, TX 77058

Ms. Stacey Zee
Federal Aviation Administration
801 Independence Avenue, SW, Suite 325
Washington, DC 20592

Ms. Tina Norwood
National Aeronautics and Space
Administration
300 E Street SW, Suite 5B11
Washington, DC 20546

Mr. Cameron Bryan
Federal Aviation Administration
2602 Meacham Boulevard, Room 610
Fort Worth, TX 73138
Ms. Teresa Bruner
Federal Aviation Administration
2601 Meacham Boulevard
Fort Worth, TX 76137
Mr. Dean McMath
Federal Aviation Administration
2601 Meacham Boulevard, Room 697
Fort Worth, TX 73137
Mr. Tony Robinson
Federal Emergency Management Agency
FRC 800 North Loop 288
Denton, TX 76209
Mr. Robert Tally
Federal Highway Administration
300 E. 8th Street, Room 826
Austin, TX 78701

Houston Spaceport Environmental Assessment – Draft

Dr. Roger Zimmerman
National Oceanic and Atmospheric
Administration
4700 Avenue U
Galveston, TX 77551
Mr. Salvador Salinas
Natural Resources Conservation Services
101 South Main Street
Temple, TX 76501
Col. Richard P. Pannell
U.S. Army Corps of Engineers
P.O. Box 1229
Galveston, TX 77553
Mr. Dan Deerinwater
U.S. Bureau of Indian Affairs
P.O. Box 368
Anadarko, OK 73005
Ms. Jennifer Montoya
U.S. Bureau of Land Management
1800 Marquess Street
Las Cruces, NM 88005

A-10

 EARLY NOTIFICATION LETTER

Mr. Mark Trevino
U.S. Bureau of Reclamation
5316 Highway 290 West, Suite 110
Austin, TX 78735

Mr. Edith Erfling
U.S. Fish and Wildlife Service
17629 El Camino Real, #211
Houston, TX 77058

Capt. Brian Penoyer
U.S. Coast Guard
9640 Clinton Drive
Houston, TX 77029

Mr. Denise Baker
U.S. Fish and Wildlife Service
P.O. Box 1306
Albuquerque, NM 87103

CDR Scott E. Langum
U.S. Coast Guard Air Station Houston
1178 Ellington Field, Sneider
Houston, TX 77034

Ms. Liz Agpaoa
U.S. Forest Service
1720 Peachtree Road NW
Atlanta, GA 30309

Ms. Barbara R. Britton
U.S. Department of Housing and Urban
Development
801 Cherry Street, Room 2862
Fort Worth, TX 76102

Ms. Marjorie McColl Petty
U.S. Health and Human Services
1301 Young Street, Suite 1124
Dallas, TX 75202
Mr. John Wessels
U.S. National Park Service
12795 Alameda Parkway
Denver, CO 80225

Mr. Stephen Spencer
U.S. Department of Interior
1001 Indian School Road, NW, Suite 348
Albuquerque, NM 87104
Mr. Mark Briggs
U.S. Department of Labor
17625 El Camino Real, Suite 400
Houston, TX 77058
Ms. Rhonda Smith
U.S. Environmental Protection Agency
1445 Ross Avenue
Dallas, TX 75202
Mr. Ron Curry
U.S. Environmental Protection Agency
1445 Ross Avenue, Suite 1200
Dallas, TX 75202

Houston Spaceport Environmental Assessment – Draft

The Hon. Randy Weber
U.S. House of Representatives
174 Calder Road
League City, TX 77573
The Hon. Pete Olson
U.S. House of Representatives
6302 W. Broadway Street, Suite 220
Pearland, TX 77581
The Hon. Gene Green
U.S. House of Representatives
11811 I-10 East, Suite 430
Houston, TX 77029

A-11

 EARLY NOTIFICATION LETTER

The Hon. Steve Stockman
U.S. House of Representatives
8060 Spencer Highway, San Jacinto
College, Building 1, Room 108
Pasadena, TX 77505

Ms. Kellye Rila
Texas Commission on Environmental
Quality
P.O. Box 13087, MC 160
Austin, TX 78711

The Hon. John Cornyn
U.S. Senate
5300 Memorial Drive, Suite 980
Houston, TX 77007

Ms. Jennifer Bailey
Texas Department of Agriculture
5425 Polk Street, Suite G-20
Houston, TX 77023

The Hon. Ted Cruz
U.S. Senate
1919 Smith Street, Suite 800
Houston, TX 77002

Dr. Brian Smith
Texas Department of State Health Services
5425 Polk, Suite J, MC 1906
Houston, TX 77023

State

Mr. David Fulton
Texas Department of Transportation
125 E. 11th St.
Austin, TX 78701

Mr. Milton Rister
Railroad Commission of Texas
P.O. Box 12967
Austin, TX 78711
Col. Terence Winkler
Texas Air National Guard
14657 Sneider
Houston, TX 77034
Ms. Ashley K. Wadick
Texas Commission on Environmental
Quality
5425 Polk Street, Suite H
Houston, TX 77023
Mr. David Brymer
Texas Commission on Environmental
Quality
P.O. Box 13087, MC 206
Austin, TX 78711

Houston Spaceport Environmental Assessment – Draft

Mr. Michael W. Alford
Texas Department of Transportation
P.O. Box 1386
Houston, TX 77251
Mr. Michael L. Williams
Texas Education Agency
1701 N. Congress Avenue
Austin, TX 78701
Ms. Helen Young
Texas General Land Office
P.O. Box 12873
Austin, TX 78711
Mr. Jeffrey Davis
Texas General Land Office
P.O. Box 1675
Galveston, TX 77553

A-12

 EARLY NOTIFICATION LETTER

Ms. Tara Ellis Mealy
Texas General Land Office
P.O. Box 1675
Galveston, TX 77553

The Hon. Wayne Smith
Texas House of Representatives
909 Decker Drive, Suite 104
Baytown, TX 77520

Mr. Mark Wolfe
Texas Historical Commission
P.O. Box 12276
Austin, TX 78711
Mr. Carter Smith
Texas Parks and Wildlife Department
4200 Smith School Road
Austin, TX 78744

The Hon. John E. Davis
Texas House of Representatives
1350 NASA Parkway, #212
Houston, TX 77058

Ms. Rebecca Hensley
Texas Parks and Wildlife Department
1502 FM 517 East
Dickinson, TX 77539
The Hon. Rick Perry
State of Texas
P.O. Box 12428
Austin, TX 78711
The Hon. Craig Eiland
Texas House of Representatives
9702 E.F. Lowery Expressway
Texas City, TX 77591
The Hon. Greg Bonnen
Texas House of Representatives
174 Calder Road, Suite 116
League City, TX 77573
The Hon. Dennis Bonnen
Texas House of Representatives
122 E. Myrtle
Angleton, TX 77515
The Hon. Ed Thompson
Texas House of Representatives
P.O. Box 2910
Austin, TX 78768

Houston Spaceport Environmental Assessment – Draft

The Hon. Alma A. Allen
Texas House of Representatives
10101 Fondren Road, Suite 500
Houston, TX 77096
The Hon. Carol Alvarado
Texas House of Representatives
2900 Woodridge Drive, Suite 305
Houston, TX 77087
The Hon. Garnet F. Coleman
Texas House of Representatives
5445 Almeda, Suite 501
Houston, TX 77004
The Hon. Sylvia R. Garcia
Texas State Senate
5425 Polk Street, Suite 125
Houston, TX 77023
The Hon. Larry Taylor
Texas State Senate
174 Calder Road, Suite 151
League City, TX 77573
Mr. Denise S. Francis
Governor's Office of Budget and Planning
P.O. Box 12428
Austin, TX 78711

A-13

 EARLY NOTIFICATION LETTER

Mr. Ray Newby
Texas General Land Office
1700 N. Congress
Austin, TX 78701

The Hon. Stephen D. Holmes
Galveston County
9850-A Emmett F. Lowry Expressway, Suite
A100
Texas City, TX 77591

Regional
Mr. Jack Steele
Houston-Galveston Area Council
P.O. Box 22777
Houston, TX 77227

Counties
The Hon. Donald "Dude" Payne
Brazoria County
P.O. Box 998
Clute, TX 77531
The Hon. Matt Sebesta
Brazoria County
21017 CR 171
Angleton, TX 77515
The Hon. Stacy L. Adams
Brazoria County
P.O. Box 548
Alvin, TX 77512
The Hon. Ryan Dennard
Galveston County
722 Moody, 1st Floor
Galveston, TX 77550
The Hon. Kevin O'Brien
Galveston County
111730 Highway 6
Sante Fe, TX 77510

Houston Spaceport Environmental Assessment – Draft

The Hon. Ken Clark
Galveston County
174 Calder Road
League City, TX 77573
The Hon. El Franco Lee
Harris County
1001 Preston Avenue, Suite 950
Houston, TX 77002
The Hon. Jack Morman
Harris County
16603 Buccaneer
Houston, TX 77062
Mr. Mike Talbott
Harris County Flood Control District
9900 Northwest Freeway
Houston, TX 77092
Dr. Umair A. Shah
Harris County Public Health and
Environmental Services
2223 West Loop South
Houston, TX 77027
Mr. John R. Blount
Harris County Public Infrastructure
Development
1001 Preston, 7th Floor
Houston, TX 77002
The Hon. Joe King
Brazoria County
111 E. Locust Street, Suite 102
Angleton, TX 77515

A-14

 EARLY NOTIFICATION LETTER

The Hon. Ed Emmett
Harris County
1001 Preston, Suite 911
Houston, TX 77002

The Hon. Steve Spicer
City of Jamaica Beach
5264 Jamaica Beach
Jamaica Beach, TX 77554

The Hon. Mark Henry
Galveston County
722 Moody, Suite 200
Galveston, TX 77550

The Hon. Bobby Hocking
City of La Marque
1111 Bayou Road
La Marque, TX 77568

Cities

The Hon. Tim Paulissen
City of League City
300 W. Walker
League City, TX 77573

The Hon. Gary Appelt
City of Alvin
216 West Sealy
Alvin, TX 77511
The Hon. Julie Masters
City of Dickinson
4403 Highway 3
Dickinson, TX 77539
The Hon. Kevin M. Holland
City of Friendswood
910 South Friendswood Drive
Friendswood, TX 77546
The Hon. Lewis Rosen
City of Galveston
P.O. Box 779
Galveston, TX 77553
The Hon. Tom Wilson
City of Hillcrest Village
P.O. Box 1172
Alvin, TX 77512
The Hon. Anthony Matranga
City of Hitchcock
7423 Highway 6
Hitchcock, TX 77563

Houston Spaceport Environmental Assessment – Draft

The Hon. Bill Strickland
City of Liverpool
P.O. Box 68
Liverpool, TX 77577
The Hon. Mark Denman
City of Nassau Bay
P.O. Box 58448
Nassau Bay, TX 77258
The Hon. Johnny Isbell
City of Pasadena
1211 Southmore
Pasadena, TX 77502
The Hon. Tom Reid
City of Pearland
3519 Liberty Drive
Pearland, TX 77581
The Hon. Ralph Stenzel
City of Santa Fe
P.O. Box 950
Santa Fe, TX 77510

A-15

 EARLY NOTIFICATION LETTER

The Hon. Matthew T. Doyle
City of Texas City
P.O. Box 2608
Texas City, TX 77592
The Hon. Floyd H. Myers
City of Webster
101 Pennsylvania
Webster, TX 77598

EFD Tenants
Mr. Robert Amey
Aerosim Flight Academy
12711 Blume Avenue, Ellington Field
Houston, TX 77034
Ms. Helene McCorvey
Flying Tigers
12711 Blume Avenue
Houston, TX 77034
Mr. William E. King
Southwest Airport Services
Ellington Field Building 500, 11811 N.
Brantly Road
Houston, TX 77034
Mr. Randall L. Reed
Starbase Jet Charter
11210 Blume Avenue
Houston, TX 77034
Ms. Laura Hays
TrustComm
11140 Aerospace Avenue
Houston, TX 7703

Houston Spaceport Environmental Assessment – Draft

A-16

 AGENCY RESPONSE LETTERS

APPENDIX A-2

AGENCY RESPONSE LETTERS

Houston Spaceport Environmental Assessment – Draft

A-17

 AGENCY RESPONSE LETTERS

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Houston Spaceport Environmental Assessment – Draft

A-18

 AGENCY RESPONSE LETTERS

Response Letters Received
Texas Parks and Wildlife.............................................................................................................................................................A-21
NASA..................................................................................................................................................................................................A-23
FEMA..................................................................................................................................................................................................A-24
Texas Commission on Environmental Quality...................................................................................................................A-27
USFWS (two letters received)...................................................................................................................................................A-29
Flying Tigers....................................................................................................................................................................................A-51
National Park Service...................................................................................................................................................................A-52
USCG..................................................................................................................................................................................................A-53
Harris County Public Health and Environmental Services.............................................................................................A-54
Texas Historical Commission....................................................................................................................................................A-55
NASA..................................................................................................................................................................................................A-57
Texas General Land Office.........................................................................................................................................................A-59

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A-19

 AGENCY RESPONSE LETTERS

This Page Intentionally Left Blank

Houston Spaceport Environmental Assessment – Draft

A-20

 AGENCY RESPONSE LETTERS

Texas Parks and Wildlife

Houston Spaceport Environmental Assessment – Draft

A-21

 AGENCY RESPONSE LETTERS

Texas Parks and Wildlife Continued

Houston Spaceport Environmental Assessment – Draft

A-22

 AGENCY RESPONSE LETTERS

NASA

 

Alherts. David

From: Norwood, Tina <tinanonvood-lr?lnasagovb-

Sent: Wednesday. October 23, 2013 1:04 PM

To: Aiberts. David; DanielCzelusniakt?ifaagov; Stacey 
Cc: Hickens, David WEBSTER. CHARLES 
Subject: Proposed Houston Spaceport

Dear Mr. Alberts;

Thank you for your letter dated 10m advising me of the spaceport the Citv of Houston is proposing at Ellington Airport. I
appreciate that vat; also sent a letter to the Director of the Johnson Space Center in Houston. I spoke to Dan this
morning as lvvasa little surprised that your letters did not invite us to be aCooperating Agency. It seems that inav not
have been aware that NASA is a major tenant at the airport. With NASA's Astronaut Corps based at JSC. NASA maintains
several hangers and T-33s the airport to support their training- It's from this field that we fly our ISS crew over to Baikanur
Cosmodrome? on a (5-3 that also serves as one of several aircraft 15C uses for atmospheric research. Additionally, Ellington
Field is where homes the Super Guppy to support large cargo transportation needs of mission.

Please accept this email as mv request to FAA and RSELH for NASA to serve as a Cooperating Agency on vow NEPA document
If Dan has a MOA he needs to document this, it can be addressed to me. I've sincerelv appreciated that FAA has involved
NASA in the other proposed spaceports. My role is focused on HQ's been informed of spaceports being planned across the
countrv that mav involve or impact NASA. and specificallv be informed of the resulting NEPA actions for each. For this specific
Spaceport, JSC should serve as vour primarv NASA point of contact, with Dave Hickens, JSC's NEPA Manager serving as our
NEPA representative. He is supported tn, Charlie Webster [both copied) who will be able to provide vou top,? of the
Environmental Resource Document for Ellington Field. JSC maintains this as a NEPA resource baselining resource
conditions.

I appreciate NASA being able to participate in and contribute to the NEPA documentation for this proposed spaceport.

Sincerelv,

Tina Norwoud

NASA NEPA Manager
i202] 358-331

 

 

 

 

Houston Spaceport Environmental Assessment Draft A-23

AGENCY RESPONSE LETTERS

FEMA

 

U. S. Department of Homeland Security
FEMA Region 

Hill] North Loop 28%

Benton, TX TQM-3 698



 FEMA

if?

?3

FEDERAL EMERGENCY MANAGEMENT AGENCY
REGION VI
MITIGATION DIVISION

PUBLIC NOTICE REVIEWIENVIRONMENTAL
CONSULTATION

 

We have no comments to o?'er. We offer the following comments:

WE WOULD REQUEST THAT THE COUNTY LODDPLAIN ADMINISTRATOR BE
CONTACTED FOR THE REVIEW AND POSSIBLE PERMIT REQUIREMENTS FOR
THIS PROJECT.

If Droieet i_s Federally fungcd, we would request nroieet to be compliant with E0 ?983
and 11990.

Joshua Stockey

Permits Manager

Public Infrastructure Department
Harris County

10555 Northwest Freeway, Suite 120
Houston, TX WUQZ


7?1 3-956-3015

 

REVIEWER: DATE: October 29, 2013
Natural Hazards Program Specialist

If additional jurisdictions are Emit-owed in the project or if you have any 
me at 940a398~5 S41.   
 
 
?m I
I mam 
  

.Ik- .

 

 

 

 

Houston Spaceport Environmental Assessment Draft A-24

AGENCY RESPONSE LETTERS

FEMA Continued

Houston Spaceport Environmental Assessment – Draft

A-25

 AGENCY RESPONSE LETTERS

FEMA Continued

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Texas Commission on Environmental Quality

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Flying Tigers

 

Deschapelles, Natalie

From: Alberta, David

Sent: November 2013 12:52 PM

To: Deediapelleer Natalie

Subject: FW: Proposed Houston Spaceport at Ellington Field

Pleaee add thieto the ENS correepondence appendix.

David E. Alberta

Soianeaet Region Environmental Service Group Leader
10248 Deen-vood Park South

Jaelteorwille. FL 32258- 

Phone: 904-256-2489 Fax: 800-464-4358

Dasid?ltuen Eiraandhcorn

 

met our at
Connect writ: on Facetioolt Twitter Linltedln

RM

mm WW MILO

vi
Plums; um: thin l_l1l1  l1_ Iinnlu.? r-mml

From: Helene Mchwev [Weed]
Sent: Tueadav, November I25, 2013 12:25 PM

To: Alberta: David

Subject: Propoaed Houaton Spaceport at Ellington Field

Commenter'Queetiona:
Will there he a TFR for each launch?
What are the impacts to flight school ope?
taxi?
tie downs?

eecurittr?

Helene L. McCorvejr, Owner
Flying Tigere

 

 

 

 

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National Park Service

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U.S. Coast Guard

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Harris County Public Health and Environmental Services

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Texas Historical Commission

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Texas Historical Commission Continued

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A-56

 NASA

AGENCY RESPONSE LETTERS

 

Reply to Alto ni'

 

National Aeronautics and
Space Administration

Lyndon B. Johnson Space Center
2101 NASA Pantway
Houston. Texas WGEB-GBEIE

November 13, 2013
.lA-l 3-007

Mr, David E. Alberta

Soulheast Region Enviromnental
Service Group I .eader

Reynolds, South and Hills, Inc.

?1743 Deerwood Park Boulevard South

Jacksonville, FL 32255-059?

Dear Mr. Alberts:

Thank you for your letter to the Johnson Space Center (JSC) requesting input on the
possible environmental impacts of a proposed Spaceport to launch and retrieve reusable
launch vehicles at Ellington Field We understand that Reynolds, Smith and Hills1
lnc. has been selected by the City of Houston, Houston Airport System (HAS) to write an
Environmental Assessment (BA) for the project. HAS is seeking a launch site operator?s
license from the Federal Aviation Administration (FAA) to allow for horizontal dopamine
and landing.

NASA operations at lit-1) are integral to several agencyr missions. NASA maintains several
hangers and Monty T413 jet training aircraft at EFD to support astronaut training. The
International Space Station crew flies to Haiku-nor Cosmodrome from EFD, and other
NASA aircraft ?y l'rom EFD to perform atmospheric and weather research and to transport
cargo items between NASA Centers. For this reason, NASA Headquarters, Environmental
Management Division (EMT) .TSC that they contacted the FAA to request
?cooperating agency11 status For development of the FAA EA. NASA EMD requested that
representatives I?rom Center Operations? Envirornnental Ollice serve as NASA
points of contact for the EA.

Enviromnental Of?ce has provided you with electronic copies of the environmental
resource documents For lilil) and the Sonny Carter Training Facility which
describe the environmental conditions at those locations. Comments were also obtained
From EFT) and SCTF personnel. NASA EFD reported that the project, as described, should
not present signi?cant environmental impacts to NASA EFD aircraft operations and
activities. reported that the only potential impacts could come From possible jet
engine testing and operations for extended periods. as the SCTF is located adiacent to the
southern boundary of EFD. Such operations could impact the ottalitjrr of the makeup air
where dive-rs in the Neutral Buoyancy Laboratory re?ll NITRDX SCUBA tanks For

 

 

 

 

 

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NASA Continued

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Texas General Land Office

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Texas General Land Office Continued

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 AIRSPACE AND AIRPORTS

APPENDIX B

AIRSPACE AND AIRPORTS

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B-1

 AIRSPACE AND AIRPORTS

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 AIRSPACE AND AIRPORTS

B.1 Existing Airspace
Within the United States, airspace is classified as either controlled or uncontrolled. Special-use airspace
and other airspace areas are additional classifications that can include both controlled and uncontrolled
segments.
Controlled airspace is airspace of defined dimensions in which air traffic control service is provided to
aircraft operating under both instrument flight rules (IFR) or visual flight rules (VFR). Controlled airspace is
a generic term covering Class A, B, C, D, and E airspace. Class G airspace is airspace not designated Class
A, B, C, D, or E airspace and is not under the jurisdiction of ATC facilities. Table B-1 describes the airspace
classifications. The following paragraphs describe other airspace designations not defined in Table B-1:

»

Special Use Airspace and Special Assigned Airspace – This airspace is used to confine certain flight
activities and to place limitations on aircraft operations that are not part of these activities. This
airspace may be designated as prohibited, restricted, warning areas, alert areas, military operating
areas, controlled firing areas, and national security areas.

»

Military training routes- these routes are established below 10,000 feet (ft) above mean sea level
(MSL) for both IFR and VFR operations and for VFR operations at speeds in excess of 250 knots.

»

En route airways and jet routes – Commercial and private aircraft use these established IFR flight
paths.

Ellington Airport (EFD) is a controlled airfield within Class D airspace, which is in effect 24 hours a day. The
Class D airspace is defined as the airspace extending upward from the surface to and including 2,000 ft
MSL within a 4.4-mile radius of EFD and within 1.3 miles each side of the Ellington instrument landing
system (ILS) localizer north31 course extending from the 4.4-mile radius to 4.6 miles north of EFD32 and
within 1.3 miles each side of the Ellington ILS localizer south 33 course extending from the 4.4-mile radius
to 4.7 miles south of the airport, excluding that airspace within the Houston, Texas, Class B airspace area..
Airspace outside of the Class D service area includes the controlled airspace associated with HOU and IAH.
Figure B-1 shows the airspace near EFD. There are four airports (excluding EFD), thirteen heliports, and
one ultralight flight park within the operation ROI.

B.2

Airports and Airspace Impacts

The following sections describe the potential impacts to airspace, airports, and airport users resulting from
the implementation of the No Action Alternative or Proposed Action. Analysis of the Proposed Action’s
impacts on airspace is not required under NEPA; pursuant to FAA Order 1050.1E, airspace is not an
environmental resource category. Nevertheless, this section is included as an attachment to this EA in
order to disclose the potential effect of operating reusable launch vehicles (RLVs) to and from EFD.
Chapter 4 of this EA describes the Proposed Action’s potential environmental impacts of RLVs operating
within the operation ROI (i.e., to/from the Houston Spaceport).
Ellington ILS north localizer is located at latitude 29°37'20"N. and longitude 95°09'52"W.
The Airport is located at latitude 29°36'27"N. and longitude 95°09'32"W.
33 Ellington ILS south localizer is located at latitude 29°35'22"N. longitude 95°09'50"W.
31
32

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B-3

 AIRSPACE AND AIRPORTS

B.2.1

No Action Alternative

Under the No Action Alternative, the Federal Aviation Administration (FAA) would not issue the Houston
Airport System (HAS) a launch site operator license at EFD. Construction of associated RLV infrastructure
(e.g., hangar, taxiway, access road, etc.) would not be developed. In addition, implementation of the No
Action Alternative would not result in RLV flights to or from EFD. EFD would continue to operator and
serve forecasted aviation demands. Therefore, the No Action Alternative would not change the
dimensions or use of the existing airspace.
TABLE B-1
AIRSPACE CLASSIFICATIONS

Classification
Class A

Uncontrolled/
Controlled
Controlled

Description
Within the contiguous United States and including 12 nautical
miles from the coastline over the oceans, Class A airspace
extends from 18,000 ft above MSL up to and including 60,000 ft.
Aircraft must be equipped with a two-way radio capable of
maintaining communications with air traffic control. All aircraft
must receive appropriate air traffic control clearance and operate

Class B

Class C

Controlled

Controlled

under IFR unless otherwise authorized
Ranges from the surface to 10,000 ft above MSL surrounding the
nation’s busiest airports. The dimensions are individually tailored
to the specific airport, and typically consist of a surface area and
two or more layers.
Ranges from the surface to 4,000 ft above the airport elevation
and surrounding those airports that have an operational control
tower, that are serviced by a radar approach control, and that
have a certain number of IFR operations or passenger
enplanements. Usually consists of an inner surface area with a 5nautical-mile radius, and an outer circle with a 10-nautical mile
radius that extends from 1,200 ft to 4,000 ft above the airport

Class D

Controlled

Class E

Controlled

Class G

Uncontrolled

elevation.
Ranges from the surface to 2,500 ft above the airport elevation
and surrounding those airports that have an operational control
tower.
Generally, defined as any controlled airspace that is not Class A,
B, C, or D and includes airspace above Flight Level 600.
Air traffic control does not have responsibility or authority over
aircraft in Class G airspace; however, most of the regulations
affecting pilots and aircraft still apply.

Source: 14 CFR Part 91

FIGURE B-1
AIRSPACE AROUND EFD

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 AIRSPACE AND AIRPORTS

an MNF 

I

Legend

Airport

Class Airspace
Urbanized Area

is a two dimensional representation.
There is also an altitude component

the airspace The exhibit is not to scale

is used for

NED Houston Spaceport EnvironmentalAssessment

Drawn b31?
by
Checked by

12/04/13
4/14 .
Airspace
4
Ellington Airport, Houston, Texas

 

A

 

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B-5

AIRSPACE AND AIRPORTS

B.2.2

Proposed Action

The Proposed Action defines a potential route the Concept X or Concept Z RLV would follow. Airspace
would be cleared for departure using similar procedures that other IFR flights departing from EFD would
normally use. The RLV would return to EFD using a similar flight path. Airspace would be cleared for arrival
using similar procedures that other IFR flights arriving to EFD would normally use.
Airspace - The departure flight path of the RLVs would begin heading south within the Class D airspace of
EFD, which starts at ground level and extends out for approximately four nautical miles from the center of
EFD up to an elevation of 2,000 ft above ground level. Upon exiting EFD Class D airspace, the RLV would
pass through two layers of Class B airspace. This airspace is associated with William P. Hobby Airport
(HOU), located approximately 15 and 20 nautical miles from the center of HOU and at an elevation of
2,000 ft MSL to 10,000 ft MSL and 4,000 ft MSL to 10,000 ft MSL, respectively.
The RLVs would continue south for approximately 18 miles until it reached an elevation of approximately
12,000 ft. The RLV would then bank eastward approximately 16 degrees to the southeast and would
continue into W-147C and/or W-147-D, as authorized by ATC. At approximately 40,000 ft, the RLV would
ignite its rockets and continue to climb through Luttrell ATCAA and up to an apogee elevation of
approximately 350,000 ft. The arrival path of the RLV would follow the same flight path shown in
Figure B-2.
Extensive coordination between HAS and representatives of the Houston Air Route Traffic Control Center,
FAA Central Service Center, FAA Air Traffic Control System Command Center, FAA Airports District Office,
Houston Terminal Radar Approach Control, 147th Reconnaissance Wing, and the National Aeronautics and
Space Administration are ongoing to establish routes and procedures that would allow for RLVs to safely
operate in and out of the Houston Spaceport at EFD without adversely affecting urban areas, existing
airspace conditions, or the neighboring public-use airports. These procedures will be refined prior to RLV
operations occurring at EFD.
Airport and Airport Users - EFD plays vital roles in the aviation system as military and NASA support and
general aviation relief. Impacts to these operations under the Proposed Action would be minimal because
the number of annual operations at EFD would be up to 50 flights per year (50 launches and 50 landings)
from 2015 to 2019. Assuming spaceport operations began in 2015, the EFD 2004 Comprehensive Master
Plan Update forecast indicates total operations at EFD, exclusive of RLV operations, would be 167,100 by
2016, similar to that proposed in 2019.
Thus, the maximum number of 50 flights under the Proposed Action would have a minimal impact to total
operations at the Airport. However, HAS would closely coordinate scheduled RLV launches with Airport
tenants and users to ensure operational efficiency.

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 AIRSPACE AND AIRPORTS
FIGURE B-2
PROPOSED RLV FLIGHT PATH

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 AIRSPACE AND AIRPORTS
Pre-Launch Impacts – Aircraft on the ground at EFD would experience minimal interruptions during RLV
pre-take-off, take-off, and landing operations, as described below for each vehicle type:

»

Concept X: The Concept X RLV would roll out of its hangar and receive Jet-A fuel to top off the
fuel tanks. At this point, there would be no oxidizer on board, so other aircraft operating on the
ground at EFD would be required to maintain only a 50-foot distance from the RLV, similar to
conventional aircraft operating practices.
When fueling is complete, the vehicle would taxi to the RP-1 fueling area (which could be as close
as 25 feet away), and RP-1 fuel would be loaded. At this point, other aircraft would still be
required to maintain a 50-foot distance from the RLV. The RLV would taxi north from Runway 422 to Taxiway G and then to Taxiway B to access the Oxidizer Loading Area (OLA). The Concept X
RLV would meet the LOX tanker truck and any required portable fueling and pumping equipment
at this location. This would require all other aircraft to maintain a safe distance from the RLV. The
LOX truck and portable equipment would return to storage. Passengers would be loaded onto the
vehicle and the vehicle would depart to the south on Runway 17R-35L. Runway 4-22 would
remain open and operational during this time. In the event of inclement weather, the RLV would
be de-fueled and removed from the runway, and the launch would be cancelled. Once the RLV is
cleared for takeoff from the OLA, it would taxi onto Runway 17R for immediate departure. At this
time, the runway is in-use and no other departure or arrival traffic would be allowed to operate at
EFD.
While the LOX tanker truck is in transit to and from the RLV, it would be required to maintain a
100-foot distance from all aircraft.

»

Concept Z: The Concept Z vehicle would follow similar operational procedures as the Concept X,
except this vehicle would roll out of its hangar with the HTPB solid fuel installed. The vehicle
would receive Jet-A fuel in the ramp area to top off the fuel tanks. Also, instead of LOX being
added, this vehicle would require N2O.

Launch Impacts - Once the Ellington ATCT clears the RLV for takeoff, the vehicle would depart EFD’s Class
D airspace in the same manner as any other aircraft departing EFD on an IFR flight plan.
RLV Recovery Impacts - The RLV would return to EFD’s Class D airspace under jet power or as a glider to
be handed off to the Ellington ATCT like any other aircraft. An RLV returning as a glider would utilize the
HI-TACAN Runway 35L arrival.34 Once the RLV lands, the use of Runway 17R/35L would be temporarily
suspended until the RLV is removed from the runway. Non-aircraft operations such as towing equipment
and other required support equipment would be permitted on all other taxiways and aprons not occupied
by the RLV. Once the RLV is removed from the runway, EFD would resume normal operations.

34

A Categorical Exclusion was completed for this approach path and, therefore, was not included in the analysis for this EA.

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 AIRSPACE AND AIRPORTS
The time between the RLV’s initial contact with the Ellington ATCT on its return, and the termination of the
RLV’s flight on its designated ramp area, would depend on how quickly spaceport personnel would be
able to reach the RLV with the required towing equipment. As this time would be minimal, impacts to
normal operations at EFD would be insignificant.
Nearby Airports - Nominal spaceport operations would not be expected to significantly impact operations
at nearby airports because the flight route would be carefully coordinated to avoid the airspace of
publicly owned airports in the area. The only impacts to nearby airports expected as a result of spaceport
operations would be those related to an RLV emergency landing. If an emergency landing were required,
ATC would assist the RLV pilot to safely land the RLV.
Figure B-3 shows three nearby airports that could accommodate a potential emergency landing. These
airports would not be required to alter normal operations during an RLV launch. Normal operations would
only be interrupted if the RLV pilot in command declared and emergency and required assistance.
If the pilot in command chose to land the RLV at a location other than EFD as a result of a distress
situation, the RLV would be maneuvered to land at an airport of the pilot’s choice and in coordination
with Houston ATC. Upon landing, the RLV would likely be disabled and remain on the active runway until
assistance could be rendered. After landing, all other aircraft would be required to maintain a safe
distance from the RLV because the vehicle might not have expended all of its fuel.
Spaceport operations at EFD would only impact aircraft operations at nearby airports in the unlikely event
of an emergency landing. Only licensed RLVs would be permitted to operate from the Houston Spaceport,
reducing the likelihood that an emergency landing would be required.

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B-9

 AIRSPACE AND AIRPORTS
FIGURE B-3
POTENTIAL EMERGENCY LANDING AIRPORTS

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B-10

 FINAL AIR QUALITY ASSESSMENT PROTOCOL

APPENDIX C

FINAL AIR QUALITY ASSESSMENT PROTOCOL

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C-1

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C-2

 Final Air Quality Assessment Protocol

for the

Houston Spaceport
Environmental Assessment

Prepared by:
KB Environmental Sciences, Inc.
and
Reynolds, Smith & Hills

Prepared for:
Houston Airport System
and the
Federal Aviation Administration

September 18, 2014

 Houston Spaceport Environmental Assessment
Final Air Quality Assessment
Protocol

Contents
1.

2.

3.
4.

5.

6.

Introduction .............................................................................................................................. 1
1.1.
Purpose of the Protocol ................................................................................................. 2
1.2.
Project Description ........................................................................................................ 2
Regulatory Background ......................................................................................................... 3
2.1.
Regulatory Agencies ...................................................................................................... 3
2.2.
Regulatory Standards and Criteria for Air Quality ...................................................... 4
2.3.
Attainment/Nonattainment Designations ................................................................... 5
2.4.
State Implementation Plans.......................................................................................... 6
Existing Conditions ................................................................................................................. 6
3.1.
Air Quality Monitoring Data ......................................................................................... 7
Operational Emissions Inventory Approach and Methodology ............................... 7
4.1.
Overall Approach ........................................................................................................... 9
4.2.
Emissions Inventory Methodology............................................................................... 9
4.2.1.
Criteria Pollutants........................................................................................................ 12
4.2.1.1. Inventory Scope ........................................................................................................... 12
4.2.1.2. Models and Methods ................................................................................................... 14
4.2.1.3. Presentation of Results................................................................................................ 17
4.2.2. Hazardous Air Pollutants ............................................................................................ 17
4.2.2.1. Inventory Scope ........................................................................................................... 18
4.2.2.2. Models and Methods ................................................................................................... 18
4.2.2.3. Presentation of Results................................................................................................ 18
4.2.3.
Greenhouse Gases....................................................................................................... 20
4.2.3.1. Inventory Scope .......................................................................................................... 20
4.2.3.2. Models and Methods ................................................................................................... 21
4.2.3.3. Presentation of Results................................................................................................22
Construction Emissions Inventory Approach and Methodology ...........................22
5.1.1.
Inventory Scope ...........................................................................................................22
5.1.2.
Models and Methods ................................................................................................... 25
5.1.3.
Presentation of Results................................................................................................ 27
Clean Air Act Conformity ................................................................................................... 28
6.1.
General Conformity .................................................................................................... 28
6.2.
Transportation Conformity ........................................................................................ 30

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Protocol

List of Tables
Table 1 – Agencies Involved in Air Quality Management in the Houston Area ............................... 5
Table 2 – National Ambient Air Quality Standards ........................................................................... 6
Table 3 – Attainment Status for the Houston Area............................................................................ 7
Table 4 – Ambient Air Monitoring Data (2010 – 2012) .................................................................... 9
Table 5 – Reusable Launch Vehicle (RLV) Operational Inputs and Assumptions ........................ 12
Table 6 – EDMS Surrogate Emissions Information for Carrier Vehicles ....................................... 18
Table 7 – RLV Fuel Truck Assignments ............................................................................................ 19
Table 8 – CAP Emissions Inventory Summary ............................................................................... 20
Table 9 – HAP Emissions Inventory Summary................................................................................22
Table 10 – GHG Emissions Inventory Summary .............................................................................26
Table 11 – Construction Emissions Inventory Summary.................................................................32
Table 12 – Required Comparisons to the Federally-approved SIP .................................................34

List of Figures
Figure 1 – Spaceport EA Study Area ................................................................................................. 13
Figure 2 – Proposed Federal Action Construction Elements ..........................................................24

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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

1. Introduction
Serving as the Project Sponsor, the Houston Airport System (HAS) is proposing a range
of improvements (i.e., the “Proposed Action”) at Ellington Airport (EFD) located in
Houston, Texas. The Proposed Action consists of FAA approval for airport development
and issuance of licenses and permits needed to operate horizontally-launched and
horizontally-landing commercial spacecraft at the proposed Houston Spaceport at EFD.
The HAS is preparing an Environmental Assessment (EA) for this action in accordance
with the National Environmental Policy Act (NEPA). The EA will evaluate a range of
potential environmental impacts, including impacts related to ambient air quality and
climate change, attributable to the construction and operation of the Houston Spaceport.
The air quality assessment will be conducted following Federal Aviation Administration
(FAA) guidelines including Order 1050.1E Change 1, Environmental Impacts: Policies
and Procedures (Appendix A, Section 2, Air Quality); Order 5050.4B, National
Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions; and
the Air Quality Procedures for Civilian Airports and Air Force Bases. The majority of the
technical analysis will be accomplished using the FAA Final Programmatic
Environmental Impact Statement (F-PEIS) for Horizontal Launch and Reentry of
Reentry Vehicles, the latest version of the FAA Emissions and Dispersion Modeling
System (EDMS Version 5.1.4.1), and other U.S. Environmental Protection Agency (EPA)
approved methods and models.
The focus of the air quality assessment will be on the EPA criteria air pollutants, which
are carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), coarse
particulate matter less than or equal to 10 microns (PM10), fine particulate matter less
than or equal to 2.5 microns (PM2.5), and lead (Pb). Ozone-forming (O3) emissions will
also be addressed through the analysis of the precursors of volatile organic compounds
(VOCs) and nitrogen oxides (NOx). Hazardous (or “toxic”) air pollutants (HAPs) will
similarly be evaluated. The assessment will take the form of an emissions inventory –
both with and without the Proposed Action. Greenhouse gases (GHG) emissions
attributable to the Proposed Action will also be addressed.
Dispersion modeling of criteria air pollutants and National Ambient Air Quality
Standards (NAAQS) will not be conducted. At the time when this project was initiated,
the Air Quality Procedures for Civilian Airports and Air Force Bases states that
atmospheric dispersion modeling is not considered for actions at airports with fewer than
2.6 million annual passengers and/or 180,000 General Aviation (GA)/Air Taxi
Operations. Per the FAA Terminal Area Forecast (TAF), EFD is forecast to have 0.001534
million annual passengers in both 2015 and 2020. Similarly, the level of GA/Air Taxi
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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

Operations during these years is forecast to be 96,635. Both of these values are beneath
the atmospheric dispersion modeling threshold provided in FAA guidance. Therefore
dispersion modeling is not considered.
The results of the criteria air pollutants emissions inventory will be compared to
appropriate federal Clean Air Act (CAA) General Conformity Rule applicability
thresholds. The overall goal is to help ensure that the Proposed Action would be
constructed and operated in compliance with NEPA, the State Implementation Plan (SIP)
and other applicable federal, state and local air quality regulations.

1.1.

Purpose of the Protocol

This document, referred to as the Air Quality Assessment Protocol, outlines and describes
the overall technical approach and methodology for conducting the air quality analysis
for the Houston Spaceport EA. The primary objective for producing this protocol is to
advise air quality regulatory agencies of the analysis and methodology and receive their
concurrence. This will help ensure that work is completed in an acceptable manner and
the Proposed Action will comply with applicable federal, state, and local air quality
regulations.
The information provided in this document should be treated as a synopsis of the
technical approach of the air quality assessment in which results of the analysis will be
described in the Draft EA, Final EA, and any accompanying Air Quality Technical
Appendices.

1.2.

Project Description

The scope of the Proposed Action includes the following landside and airside development
features, all of which will be addressed in the air quality assessment of the Proposed
Action and are discussed in greater detail within Protocol Sections 4 and 5:
 

Hangar/Processing Facility and Apron Construction: The Proposed Action
includes the landside development of an initial hangar/processing facility and
apron area. The dimensions of the hangar/processing facility are 200’ x 230’.
Adjacent to the hangar/processing facility would be a 220’ x 500’ apron area. The
location of the initial hangar/processing facility is southeast of Runway 4-22.

 

Propellant and Oxidizer Storage and Fueling: Oxidizers and propellants needed to
support horizontally-operating commercial spacecraft would be stored adjacent to
the existing fuel storage facility and/or stored offsite and delivered via tanker
truck. No new fuel farms or onsite storage tanks would be required to support the
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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

Proposed Action, although the Proposed Action does include installation of a fuel
truck parking area in the southwest corner of the airport and a temporary oxidizer
storage area south of Runway 4-22. Four 75’ x 75’ concrete pads are proposed in
order for the safe temporary storage of the oxidizer. As many as ten Hybrid Rocket
Motor casings containing solid propellants, weighing up to 3,000 lbs. each, could
be stored in the hangar/processing facility described above.
 

Oxidizer Loading Area Construction: The Oxidizer Loading Area (OLA) is a 150’ x
150’ concrete pad to be located along Taxiway B in between Runway 17R-35L and
Runway 17L-35R.

 

Airside Modifications and Connected Actions: Other activities necessary to
support the Proposed Action include: (1) the construction of a 1,000’ taxiway from
the proposed apron area to the existing airfield system; (2) pavement repair to
Taxiway D; (3) construction of a 220’ access roadway to the Oxidizer Storage Tank
Pad; construction of a 200’ x 70’ vehicle parking area; (4) construction of a 1,270’
access road and (5) installation of fencing and stormwater treatment areas.

2. Regulatory Background
2.1.

Regulatory Agencies

On the national level, the EPA establishes clean air goals and sets unified air quality
standards under the federal CAA. Throughout Texas and within the Houston area, the
achievement of these goals and enforcement of these standards is delegated primarily to
the Texas Council on Environmental Quality (TCEQ) and the Houston-Galveston Area
Council (H-GAC).
The HAS is responsible for the overall management of air quality at the three airports
under its jurisdiction, comprising EFD, George Bush Intercontinental Airport (IAH), and
William P. Hobby International Airport (HOU). However, as the lead Federal Agency for
the Houston Spaceport EA, the FAA is primarily responsible for assessing the air quality
impacts for the Proposed Action in accordance with NEPA and the General Conformity
Rule of the CAA. As the region’s Metropolitan Planning Organization (MPO), the H-GAC
takes the lead role in the region’s highway planning, transit planning, and demonstration
of Transportation Conformity with respect to the CAA. The Federal Highway
Administration (FHWA) and Texas Department of Transportation (TxDOT) may support
the H-GAC in the assessment of air quality impacts associated with surface transportation
facilities throughout Houston, including the Transportation Conformity Rule of the CAA.

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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

Table 1 provides a summary listing of these federal, state and local agencies’ roles and
responsibilities as they potentially apply to the Houston Spaceport EA air quality
assessment.
Table 1 – Agencies Involved in Air Quality Management in the Houston Area
Agency

Roles and Responsibilities

U.S. Environmental
Protection Agency
(EPA)

Federal agency – Sets national clean air policies under the federal
CAA; promulgates the NAAQS; reviews and approves SIPs. Also
regulates aircraft emissions. Texas is part of EPA’s Region 6,
headquartered in Dallas, Texas.

Federal Aviation
Administration
(FAA)

Federal agency – Responsible for reviewing and approving the
Houston Spaceport EA under NEPA and ensuring compliance with the
General Conformity Rule of the CAA. The FAA Southwest Regional
Offices are located in Fort Worth, Texas.

Federal Highway
Administration
(FHWA)

Federal agency – Responsible for the approval of roadway projects
under NEPA and the Transportation Conformity Rule of the CAA. This
includes working with TxDOT and H-GAC in establishing the
transportation plans for the Houston area.

Texas Council on
Environmental
Quality (TCEQ)

State agency – Implements and enforces air quality programs statewide including those pertaining to ambient air monitoring, stationary
source permitting, smoke management, regional haze, and major
source permitting. Also involved in the development of the SIPs in nonattainment areas in Texas. Headquartered in Austin, Texas.

Texas Department of
Transportation
(TxDOT)

State agency – Works with the FWHA and H-GAC to coordinate the
Houston regional components of the transportation plans.
Headquartered in Austin, Texas.

Houston-Galveston
Area Council
(H-GAC)

Local agency – The H-GAC assists the TCEQ in the SIP preparation
process with regards to development of local control strategies for onroad and non-road mobile sources. Takes the lead role in the region’s
highway planning, transit planning, and demonstration of
Transportation Conformity with respect to the CAA. Headquartered in
Houston, Texas.

Houston Airport
System (HAS)

Local agency - Responsible for the overall management of air quality at
Ellington Airport, George Bush Intercontinental Airport, and William
P. Hobby International Airport.

CAA = Clean Air Act; NAAQS = National Ambient Air Quality Standards; NEPA = National Environmental Policy Act; SIP = State
Implementation Plan
Source: KB Environmental Sciences, 2013.

2.2.

Regulatory Standards and Criteria for Air Quality

In order to protect the public health and environmental welfare from the deleterious
effects of air pollution, the EPA has established NAAQS for the following six criteria air
pollutants: CO, Pb, NO2, O3, PM10, PM2.5, and SO2. The current NAAQS are summarized
on Table 2.

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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

Table 2 – National Ambient Air Quality Standards
Pollutant
CO
NO2
O3
Pb
PM2.5

PM10
SO2

Averaging Period
8-hour1
1-hour1
1-hour2
Annual3
8-hour4
Rolling 3-month5
Annual6
24-hour2

NAAQS
9 ppm
35 ppm
100 ppb
53 ppb
0.075 ppm
0.15 µg/m3
12 µg/m3
35 µg/m3

24-hour7
1-hour8
3-hour1

150 µg/m3
75 ppb
0.5 ppm

ppb = parts per billion ppm = parts per million, µg/m3 = micrograms per cubic
meter.
1 Not to be exceeded more than once per year
2 98th Percentile, averaged over 3 years
3 Annual mean
4 Annual fourth-highest daily maximum 8-hr concentration, averaged over 3
years
5 Not to be exceeded
6 Annual mean, averaged over 3 years.
7 Not to be exceeded more than once per year on average over 3 years
8 99th percentile of 1-hour daily maximum concentrations, averaged over 3
years
Source: U.S. Environmental Protection Agency
(http://www.epa.gov/air/criteria.html), 2013.

2.3.

Attainment/Nonattainment Designations

Geographic areas found to be in violation of one or more NAAQS are classified as
nonattainment areas. Nonattainment designations are sometimes severity based (e.g.,
serious, severe, moderate, marginal) which dictates the deadline (i.e., the attainment
year) by which the area must be brought back into attainment of a NAAQS. States with
nonattainment areas must develop a SIP demonstrating how the area will be brought back
into attainment of the NAAQS within designated timeframes. Areas where concentrations
of the criteria pollutants are below (i.e., within) the NAAQS are classified as attainment
areas. Lastly, areas with prior nonattainment status that have since transitioned to
attainment are known as maintenance areas.
The current attainment/nonattainment designations for the area surrounding EFD (i.e.,
Harris County) are listed on Table 3. As shown, the area is presently in marginal
nonattainment of the EPA’s 2008 NAAQS for O3. The area is also still considered severe
nonattainment for the 1997 O3 NAAQS. EPA proposed to revoke the 1997 NAAQS in June
2013 (78 FR 34178) but until this action is published as a final rule in the Federal Register,
both the severe and marginal designations apply in Harris County.

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 Houston Spaceport Environmental Assessment
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In addition, the area is technically designated nonattainment of the now historical 1-hour
O3 standard. After revoking the 1-hour O3 standard, EPA ruled that most areas, including
Harris County, were no longer subject to the 1-hour standard as of 2005. Nonetheless, per
the anti-backsliding provisions of the CAA, the area may still be subject to certain federal
requirements for nonattainment and maintenance areas.1
Table 3 – Attainment Status for the Houston Area
Pollutant
Carbon monoxide (CO)
Lead (Pb)
Nitrogen dioxide (NO2)
Ozone (O3), 1-Hour
Ozone (O3), 8-Hour (1997)
Ozone (O3), 8-Hour (2008)
Particulate Matter (coarse or PM10)
Particulate Matter (fine or PM2.5)
Sulfur dioxide (SO2)

Designation
Attainment
Attainment
Attainment
Severe-17
Severe-15
Marginal
Attainment
Attainment
Attainment

Source: US Environmental Protection Agency Green Book Nonattainment Areas
(http://www.epa.gov/airquality/greenbk/), 2013.

2.4.

State Implementation Plans

The current federally-approved O3 SIP for the Houston area is the Houston-GalvestonBrazoria Eight-Hour (HGB) Ozone Nonattainment Area Reasonable Further Progress
State Implementation Plan Revision (Rule Log 2006-030-SIP-NR), adopted by TCEQ on
May 23, 2007 and approved by EPA in April of 2009 (74 FR 18298).
Since then, the TCEQ has prepared and adopted the HGB Reasonable Further Progress
State Implementation Plan for the 1997 Eight-Hour Ozone Standard (Rule Log 2009018-SIP-NR) and the HGB Attainment Demonstration SIP Revision for the 1997 EightHour Ozone Standard (Rule Log No. 2009-017-SIP-NR). EPA has recently proposed to
approve these SIP revisions (78 FR 55029, 78 FR 55037) and once this approval is
finalized these will become the applicable SIPs for the Proposed Action at EFD.

3. Existing Conditions
Ambient (i.e., outdoor) air monitoring data closest to EFD is disclosed in this section with
the aim of comparing pollutant concentrations in the vicinity of the airport with the
NAAQS. As indicated in Section 1.2 (Project Description), existing airport
operations at EFD, including those of aircraft, ground support equipment (GSE), motor
1

Codified under 40 CFR 51.905, the anti-backsliding provisions of the CAA prevent the rescission of measures or requirements
applicable to areas in which a NAAQS is revoked or relaxed by the EPA, such that select requirements continue to apply to an area
after revocation or relaxation of the NAAQS in question (i.e., the 1-hour O3 NAAQS), if the requirements were applied in the area
based on the area's prior designation.

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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

vehicles and stationary sources, will not change as a result of the Proposed Federal Action.
Accordingly, a baseline emissions inventory of existing operations will not be prepared in
support of the Houston Spaceport EA.

3.1.

Air Quality Monitoring Data

As required by the EPA, the TCEQ has established and maintains a permanent network
of air quality monitoring stations throughout the state. These monitors record
concentrations of pollutants in the ambient (i.e., outdoor) air to gauge compliance with
the NAAQS. Air quality monitoring data collected at the station closest to the Airport for
the period of 2010 to 2012 are shown on Table 4. For ease of reference, the applicable
NAAQS for each monitored pollutant is included. The monitoring station is located 5
miles to the northeast of the Airport. As shown, violations of the 8-hour O3 NAAQS were
registered at the monitoring station during this timeframe, consistent with the area’s
current designation of nonattainment with respect to the 8-hour O3 NAAQS.

4. Operational Emissions Inventory Approach and Methodology
For the Houston Spaceport EA, criteria air pollutant (CAP), hazardous air pollutant
(HAP), and GHG emissions associated with the proposed Spaceport’s operation will be
assessed and pursuant to the NEPA and according to FAA Order 5050.4B 706 f(3).2 The
Proposed Federal Action’s compliance with the General Conformity Regulations of the
CAA (40 CFR Part 93) will also be assessed, the details of which are discussed in Section
6.

2

Federal Aviation Administration. FAA Order 5050.4b- National Environmental Policy Act (NEPA) Implementing Instructions for
Airport Actions. Effective Date April 28, 2006.

Page   7

 Rolling 3-month5
Annual6
24-hour2
24-hour7
1-hour8
3-hour1

NO2

Pb
PM2.5

PM10
SO2

150 µg/m3
75 ppb
0.5 ppm

9 ppm
35 ppm
100 ppb
53 ppb
0.075
ppm
0.15
µg/m3
12 µg/m3
35 µg/m3

8-hour1
1-hour1
1-hour2
Annual3
8-hour4

CO

O3

NAAQS

Averaging
Period

Pollutant
2011

Year
2012

35
1.4
0.001

ND
ND

ND

41
26.6
0.017

8.5
21.3

0.02

47
22.7
0.015

10.1
22.1

<0.01

0.9
1.0
0.9
1.7
1.5
1.2
41.5
40.3
36.8
17.3
15.7
16.6
0.085 0.083 0.085

2010

41
15.6
NA

9.3
21.7

NA

NA
NA
39.5
NA
0.084

Average9

No
No
No

No
No

No

No
No
No
No
Yes

Exceeds
NAAQS

Page   8

ND = no measurement available, NA = not applicable, ppb = parts per billion ppm = parts per million, µg/m3 = micrograms per cubic meter.
1 Not to be exceeded more than once per year
2 98th Percentile, averaged over 3 years
3 Annual mean
4 Annual fourth-highest daily maximum 8-hr concentration, averaged over 3 years
5 Not to be exceeded
6 Annual mean, averaged over 3 years.
7 Not to be exceeded more than once per year on average over 3 years
8 99th percentile of 1-hour daily maximum concentrations, averaged over 3 years
9 Three-year average only reported if applicable to NAAQS evaluation.
Source: U.S. Environmental Protection Agency AIRData – Monitor Data Queries 2013; and U.S. Environmental Protection Agency Air Quality System – Detailed AQS Data, 2013.

Site Name and
Address
(Dir. from EFD)
Houston Deer Park #2
4514 1/2 Durant St.
(5 miles NE)

Table 4 – Ambient Air Monitoring Data (2010 – 2012)

Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

 Houston Spaceport Environmental Assessment
FinalAir Quality Assessment Protocol

The approach for the Houston Spaceport air quality assessment is consistent with FAA
Order 1050.1e, Appendix A, Section 2.1.3 The air quality assessment methodology is
formulated in accordance with the following regulations and guidance and is detailed in
the following sections:
 
 
 
 

4.1.

FAA Air Quality Procedures for Civilian Airports and Air Force Bases 4;
FAA Guidance for Quantifying Speciated Organic Gas Emissions from Airport
Sources 5;
FAA Order 1050.1E, Change 1, Guidance Memo #3 6; and
FAA Final Programmatic Environmental Impact Statement (F-PEIS) for
Horizontal Launch and Reentry of Reentry Vehicles.7

Overall Approach

The overall air quality approach will reflect the Proposed Action described in Section 1.2
and will utilize the methodology outlined in the 2005 F-PEIS. Specific assessment
components include8:
 
 

4.2.

Operation of “Concept X and Concept Z” Reusable Launch Vehicles (RLV) for
commercial space flights (and carrier aircraft in the case of Concept Z); and
Operation of fuel tanker trucks necessary to supply fuel to the RLVs.

Emissions Inventory Methodology

In general terms, an emissions inventory is a quantification of the amount, or weight, of
pollutants emitted from a source (or combination of sources) over a period of time. The
outcome is a product of source activity levels (e.g., RLV operations) combined with
appropriate emission factors (e.g.., grams of pollutant/operation). The results are
segregated by pollutant type (e.g., CO, NOx, VOC, etc.), emission source (e.g., construction
equipment, RLV, facility support equipment, etc.) and project milestone year. The data
are commonly reported in units of tons per year.

Federal Aviation Administration. FAA Order 1050.1E Change 1- Environmental Impacts: Policies and Procedures. Effective Date
March 20, 2006. NOTE: Order 1050.1F was published on August 14, 2013 but is still undergoing public comment, and as of
November 2013 has not been published as a final notice in the Federal Register.
4 Federal Aviation Administration Office of Environment and Energy. Air Quality Procedures for Civilian Airports and Air Force
Bases (with Addendum). September, 2004.
5 Federal Aviation Administration Office of Environment and Energy. Guidance for Quantifying Speciated Organic Gas Emissions
from Airport Sources version 1. September, 2009.
6 Federal Aviation Administration. FAA Order 1050.1E, Change 1, Guidance Memo #3: Considering Greenhouse Gases and Climate
under the National Environmental Policy Act (NEPA): Interim Guidance. Prepared by Thomas Cuddy for Julie Marks. January
12, 2012.
7 Federal Aviation Administration Office of Commercial Space Transportation. Final Programmatic Environmental Impact
Statement for Horizontal Launch and Reentry of Reentry Vehicles. December, 2005.
8 Motor vehicle traffic associated with worker commutes and RLV passenger trips may also occur but are expected to be of nominal
contribution to air quality impacts associated with the Proposed Federal Action.
3

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 Houston Spaceport Environmental Assessment
FinalAir Quality Assessment Protocol

Table 5 identifies anticipated RLV operations by concept vehicle type, along with
emissions that will be considered and atmospheric layer. CAP, HAP and GHG emissions
from Jet A combustion will be considered up to the local mixing height for the Houston
area, which is 3,038 feet based on the nearest upper air meteorological data station
reported to EPA’s Support Center for Regional Atmospheric Modeling (SCRAM). The
local mixing height is defined as the vertical extent in the troposphere above which
emitted pollutants do not mix downward to ground level. According to launch parameters
described in the F-PEIS for the concept vehicles, oxidizer and propellant combustion do
not occur until the RLVs exit the lower troposphere, which extends above the local mixing
height.
Additionally, GHG emissions from propellant and oxidizer combustion during take-off,
launch and landing will be quantified up to the stratospheric level. Ozone Depleting
Substance (ODS) emissions to the stratosphere from Concept X and Z vehicles will not be
addressed because, according to the F-PEIS, neither of these RLV types emit hydrogen
chloride (HCl) or chlorine ions (Cl-) that would lead to significant impacts related to
ozone depletion.
Each concept RLV conducts a powered take-off with the capability to propel the concept
RLV into sub-orbit. The Concept Z RLV consists of the carrier vehicle (e.g., White Knight
Two) as well as its RLV (e.g., SpaceShip Two). The Concept X RLV is estimated to conduct
50 takeoffs and 50 landings per year, combusts Jet A during takeoff, combusts RP-1
propellant and liquid oxygen (LOX) oxidizer during rocket engine launch procedures
(ignited once the vehicle reaches altitude of its operating area), and relies on jet engine
power to assist during landing. The Concept Z RLV is similarly estimated to conduct 50
takeoffs and 50 landings per year, combusts Jet A during takeoff, combusts Hydroxylterminated Polybutadiene (HTPB) propellant and nitrous oxide (N2O) oxidizer during
rocket engine launch of the RLV at altitude (e.g., Spaceship Two), and the RLV carrier
vehicle combusts Jet A upon landing.
Based on the description of the concept vehicles to be used at the Houston Spaceport, and
consistent with the 2005 F-PEIS, emissions to the mesosphere would be negligible to nonexistent. Powered engine operations would not occur in the ionosphere, so assessment of
electron-depleting substances in the F layer of the ionosphere are discounted from the
analysis.

Page   10

 50/50
50/50

Concept X

Concept Z

Yes/No1

Yes

Powered
Landing?

Jet A

N2O
and
HTPB

LOX and RP-1

Utilized Fuels
(by Atmospheric Layer)
LTr
FTr
St
Me Io
Jet A

CAP,
GHG, GHG GHG
HAP

Emissions Considered
(by Atmospheric Layer)
LTr
FTr
St
Me Io
CAP,
GHG, GHG GHG
HAP

Page   11

CAP = Criteria Air Pollutants; FTr = Free Troposphere (3,038 to approximately 32,000 feet); GHG = Greenhouse Gases; H2O2 = Hydrogen Peroxide; HAP = Hazardous Air Pollutants;
HTPB = Hydroxyl-terminated polybutadiene; Io = Ionosphere (264,001 feet and above); LOX = Liquid Oxygen; LTr = Lower Troposphere (up to 3,038 feet); Me = Mesosphere
(163,501 to approximately 264,000 feet); N2O = Nitrous Oxide; ODS = Ozone Depleting Substances; RLV = Reusable Launch Vehicle; St = Stratosphere (32,001 to approximately
163,500 feet)
1 The carrier vehicle would return under jet engine power while the RLV would glide on its return to EFD
Source(s): Federal Aviation Administration Office of Commercial Space Transportation. Final Programmatic Environmental Impact Statement for Horizontal Launch and Reentry of
Reentry Vehicles. December, 2005;
RS&H. Ellington Airport Spaceport Feasibility Study. February 10, 2012.

Annual
Launches/Landings

Concept Type

Table 5 – Reusable Launch Vehicle (RLV) Operational Inputs and Assumptions

Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

Specific methodologies by which CAP, HAP and GHG emissions from the RLVs, as well
as other emissions sources (i.e., fuel trucks, engine testing), are identified and discussed
in the forthcoming sections. As previously stated, normal operations from aircraft, GSE,
motor vehicles and other sources at EFD will not be quantified in an emissions inventory
as these sources are not expected to change significantly due to the implementation of the
Proposed Action.

4.2.1. Criteria Pollutants
Operational emissions of CO, SOx, PM10, and PM2.5, as well as O3 precursor emissions of
NOx and VOC, will be addressed according to the following scope and methods.

4.2.1.1. Inventory Scope
For the air quality protocol, direct and indirect study areas for the Houston Spaceport EA
is shown on Figure 1. A “direct study area” was established for environmental
considerations dealing with more specific, direct impact issues such as wetlands,
floodplains, and biotic communities. The direct study area encompasses approximately
four square miles and includes the Airport property. The direct study area represents the
areas where direct disturbance of area features could potentially occur. For
environmental considerations dealing with broad, indirect impact issues, an “indirect
study area” is used to describe features and assess impact potential. The indirect study
area is based on a large geographic area to assess impacts that may occur in the
surrounding communities, such as impacts to air quality. The indirect study area
encompasses approximately 600 square miles and includes portions of Harris, Brazoria,
and Galveston counties. For CAP emissions, only the component of airspace below the
local mixing height in the Houston Area (3,038 feet) will be considered. As shown on
Table 5, 100 take-offs/launches/landings of both the Concept X and Concept Z vehicles
will be analyzed in years 2015 and 2020.
As noted in Section 4.1, fuel tanker truck emissions and engine testing emissions will
also be considered in the CAP emission inventories.

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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

Figure 1 – Spaceport EA Study Area

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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

4.2.1.2. Models and Methods
RLV Operations
The FAA Emissions and Dispersion Modeling System (EDMS version 5.1.4.1) will be used
to quantify CAP and HAP emissions from RLV Jet A combustion up to the local mixing
height. EDMS provides an emissions estimate for all modes within a Landing/Take-off
(LTO) Cycle, including taxi-out, take-0ff, climb-out, approach, landing, and taxi-in. Based
on known operational characteristics for the Concept RLVs, emissions from these
operational modes will be considered in the inventory of Concept X and Z vehicles. Table
6 summarizes EDMS aircraft surrogate assignments to be used in the CAP emissions
inventory.
Both Concept X and Z craft would taxi under engine power from the hangar to the
Oxidizer Loading Area, for a distance of approximately 12,900 feet. After the oxidizer is
loaded, the vehicles would again taxi to the north end of Runway 17R-35L for a southern
departure, a distance of approximately 6,750 feet.
After the Concept vehicles return to EFD, there are two scenarios to get back to the
hangar:
1. The Concept X vehicle would taxi under jet power a distance of 13,800 feet to the
hangar.
2. The Concept Z carrier vehicle (White Knight Two) would taxi the 13,800 feet to the
hangar. The RLV portion (Space Ship Two) would be tugged/towed by an aircraft
tractor from the north end of Runway 17L-35R back to the hangar.
To convert these travel paths to taxi times, a taxi speed of 17.6 miles per hour will be
applied for engine taxi operations, consistent with information applied within EDMS,
whereas a speed of 7.1 miles per hour will be applied to estimate the component conducted
by the aircraft tractor as if moves the Concept Z RLV back to the hangar9. Based on the
information provided herein, the Concept X will be assigned an EDMS taxi time of 12.7
minutes on departure and 8.9 minutes on arrival. The Concept Z will be similarly assigned
a departure taxi time in EDMS of 12.7 minutes, but will instead be assigned an aircraft
tractor that operates 22.1 minutes per arrival.

9

Manufacturer specifications for a Tug Technologies Model GT50 aircraft tow tractor were consulted to compute this travelling
speed, which represents the arithmetic average speed associated with its six forward-power throttle settings.

Page   14

 BR700-710C4-11 Annular
(2)

PW308A Annular (4)

Concept X

Concept Z

4.1

4.05

Bypass
Ratio

30.71

68.77

Rated Thrust
(kN)
Idle
(Taxi)
Takeoff
Climb Out
Approach
Idle
(Taxi)
Takeoff
Climb Out
Approach

Mode

0.00 16.74 1.29
0.00 14.06 1.29
0.02 8.03 1.29

1.29

1.29
1.29
1.29

0.83
1.06
4.08

3.65

19.52
15.43
7.71

1.29

6.62

0.02
0.02
0.05

1.04
0.92
4.92

4.5

38.21

2.29

31.57

15.00
15.00
2.50

1.7

14.30
12.36
0.35

0.45

Emissions Index (g/kg fuel)
PM
CO
HC NOx SOx
(SN)

Page   15

CO = Carbon Monoxide; HC = Hydrocarbon; kN = kilonewtons; NOx = Oxides of Nitrogen; PM = Particulate Matter; RLV = Reusable Launch Vehicle; SN = Smoke Number; SOx = Oxides
of Sulfur
Source: Emissions and Dispersion Modeling System (EDMS) version 5.1.4.1

Engine Type
(No. of Engines)

RLV
Type

Table 6 – EDMS Emissions Information for Carrier Vehicles

Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

RLV Fueling
EDMS will be used to estimate emissions from the operation of fueling tanker trucks. The
Concept X and Z vehicles would utilize a 175 horsepower diesel fuel tanker truck for Jet A
refueling activities, which according to EDMS default information could operate up to 20
minutes per departure. Additional tanker trucks would be required to transport and
deliver LOX and N2O oxidizers and RP-1 fuel. In the case of LOX, a higher capacity fuel
truck than that normally assigned by EDMS would be required. Table 7 outlines the fuel
tanker truck assignments for each RLV concept type evaluated under the Proposed
Action.
Table 7 – RLV Fuel Truck Assignments
RLV Type

Number
of Trucks
Required

Concept X

3

Concept Z

2

Truck Type

Fuel
(HP)

Contents

Operating Time
per Operation
(minutes)

F750 DART
3,000 to 6,000
gallon
F750 DART 8,000
to 10,000 gallon
F750 DART
3,000 to 6,000
gallon
F750 DART
3,000 to 6,000
gallon

Diesel
(175)

Jet A

20

Diesel
(300)
Diesel
(175)

LOX

20

RP-1

20

Diesel
(175)

Jet A
N2O

20
20

HP = horsepower
Source(s): Emissions and Dispersion Modeling System (EDMS) version 5.1.4.1;
RS&H. Ellington Airport Spaceport Feasibility Study. February 10, 2012.

Engine Testing
Routine jet engine testing is expected to occur at EFD under the Proposed Action to help
ensure the safety of RLV operations. For the air quality analysis, it is estimated that 15
tests for each concept RLV type will be conducted per year.
For jet engine testing, EDMS will be used to estimate testing emissions for engines
specified on Table 6. It is assumed that engines will be tested for seven minutes per
default power setting in EDMS (power settings in EDMS represent seven, 30, 85 and 100
percent of full thrust).

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4.2.1.3. Presentation of Results
Table 8 provides a summary template for the CAP emissions inventory. Emissions of
each CAP, in short tons, will be presented per analysis year (e.g., 2015) and source (e.g.,
support equipment). As discussed in Section 6, estimated emissions of NOx and VOC
will be included in a General Conformity Applicability Analysis whereby the total annual
emissions of these pollutants will be compared against the applicable de minimis
thresholds (i.e., 25 tons per year for NOx and VOC) for a severe O3 nonattainment area.
Table 8 – CAP Emissions Inventory Summary
Source
Concept X RLVs
Concept Z RLVs
Support Equipment
Total
De minimis Threshold
Source
Concept X RLVs
Concept Z RLVs
Support Equipment
Total
De minimis Threshold

2015 Emissions (tons)
CO NOx SOx PM10 PM2.5 VOC

--

25
---25
2020 Emissions (tons)
CO NOx SOx PM10 PM2.5 VOC

--

25

--

--

--

25

Source: KB Environmental Sciences, Inc.

4.2.2. Hazardous Air Pollutants
HAPs are pollutants that do not have established NAAQS but present potential human
health risks from short (i.e., acute) or long-term (i.e., chronic) exposures. FAA’s current
policy is to compute emissions inventories of HAPs for NEPA disclosure purposes only. 10
Toxicity ranking, dispersion analysis, or risk assessments are too speculative to be
appropriate for incorporating into an EA. Therefore, the emissions-inventory approach
described herein is only designed to disclose the types and amounts of HAPs associated
with the Proposed Action.
In September of 2009, FAA released its guidance for quantifying airport-related HAP
emissions from airport sources.11 The guidance provides detailed recommendations on

10

11

Federal Aviation Administration Office of Environment and Energy, Guidance for Quantifying Speciated Organic Gas Emissions
from Airport Sources, September 2, 2009.
Federal Aviation Administration Office of Environment and Energy, Guidance for Quantifying Speciated Organic Gas Emissions
from Airport Sources, September 2, 2009.

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 Houston Spaceport Environmental Assessment
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the preparation of the analysis and references HAPs speciation profiles for airport
emission sources.12

4.2.2.1. Inventory Scope
Calendar year 2015 and 2020 (first year of the proposed license and +5 years for NEPA
analysis) HAP emissions from lower tropospheric RLV operations and fuel truck
utilization will be computed and disclosed.

4.2.2.2. Models and Methods
EDMS emissions of VOC computed for the purposes of the Proposed Action CAP
emissions inventory (see Section 4.2.1.2) will be speciated into individual organic gas
(OG) emissions for the HAP analysis. Based on FAA’s guidance for quantifying airportrelated HAPs, only those OG compounds identified in the CAA as HAPs or included in the
EPA’s Integrated Risk Information System (IRIS) database should be reported in NEPA
documentation.13 The current version of EDMS provides estimates of 45 OG species that
meet these criteria.
Aloft, a major constituent of unburned HTPB is 1,3-butadiene, although high combustion
temperatures during rocket engine operations would likely cause much of the
combustion-related 1,3-butadiene emissions to decompose. High combustion
temperatures associated with rocket engine operations may also cause polycyclic
aromatic hydrocarbon (PAH) formation as the fuel is combusted. The F-PEIS identifies
the Cl- and precursor HCl as HAP emissions of concern from select concept vehicle types,
but as stated in Section 4.2, the RLV concepts to be operated at the Houston Spaceport
do not emit these compounds during rocket operations.
Because HAP emissions from RP-1 and HTPB combustion in the upper troposphere and
stratosphere would not mix to ground level, these emissions will be discounted from the
air quality assessment.

4.2.2.3. Presentation of Results
Table 9 provides a summary template for the HAP emissions inventory. Emissions of
each HAP, in pounds, will be presented per analysis year (e.g., 2015) and emission source
(e.g., RLV Jet Engines).

12
13

A speciation profile is the amount of an individual HAP per the amount of VOC or PM emitted by that emission source.
Federal Aviation Administration Office of Environment and Energy. Guidance for Quantifying Speciated Organic Gas Emissions
from Airport Sources version 1. September, 2009.

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 Houston Spaceport Environmental Assessment
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Table 9 – HAP Emissions Inventory Summary
HAP
1,3-butadiene
2-methylnaphthalene
Acetaldehyde
Acetone
Acrolein
Benzaldehyde
Benzene
Ethylbenzene
Formaldehyde
Isopropylbenzene (cumene)
M & P-xylene
Methyl alcohol
Naphthalene
N-heptane
O-xylene
Phenol (carbolic acid)
Propionaldehyde
Styrene
Toluene

2015 HAP Emissions (pounds)
RLV Jet Engines Support Equipment Total
---

--------------

2019 HAP Emissions (pounds)
HAP
RLV Jet Engines Support Equipment Total
1,3-butadiene
-2-methylnaphthalene
-Acetaldehyde
Acetone
-Acrolein
-Benzaldehyde
Benzene
-Ethylbenzene
-Formaldehyde
Isopropylbenzene (cumene)
-M & P-xylene
-Methyl alcohol
-Naphthalene
-N-heptane
-O-xylene
-Phenol (carbolic acid)
-Propionaldehyde

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 Houston Spaceport Environmental Assessment
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Styrene
Toluene

---

Source: KB Environmental Sciences, Inc.
Note: Gray banding in the table signifies that the HAP is not emitted from the subject emissions source.

4.2.3. Greenhouse Gases
The effect of GHG on climate change is presently a dynamic and emerging topic and will
be addressed as part of the air quality assessment. GHG emissions of carbon dioxide
(CO2), methane (CH4) and N2O associated with the Proposed Action will be quantified
and disclosed per emission source, analysis year, and atmospheric layer. The results will
be expressed in terms of carbon dioxide equivalent (CO2e) emissions using Global
Warming Potentials (GWP) identified by the Intergovernmental Panel on Climate Change
(IPCC).14 GWPs normalize emissions of individual GHG to the atmospheric warming
potential of CO2 and correspond to 21 for CH4 and 310 for N2O
Emissions of water vapor (H2O) will also be quantified and disclosed, however, no IPCCsanctioned GWP has been issued for H2O and accordingly these emissions will not be
quantified as CO2e.
To the extent necessary, a GHG emissions inventory will be conducted following
commonly used and widely accepted guidelines:
•
•

ACRP Report 11, Guidebook on Preparing Airport Greenhouse Gas Emissions
Inventories; and
IPCC Guidelines for National Greenhouse Gas Inventories.

4.2.3.1. Inventory Scope
All emissions sources included in the CAP emissions inventory will also be considered for
GHG evaluation; to the extent those sources are documented to emit tropospheric GHG.
These sources specifically comprise RLVs, fuel trucks, and engine testing. Calendar year
2015 and 2020 activity inputs will remain consistent with the CAP inventory for these
sources. GHG emissions from RLV operations in the upper troposphere and stratosphere
will also be inventoried in accordance with the F-PEIS.

14

Intergovernmental Panel on Climate Change (IPCC). Climate Change 2007: Fourth Assessment Report of the Intergovernmental
Panel on Climate Change. 2007.

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 Houston Spaceport Environmental Assessment
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4.2.3.2. Models and Methods
Lower Tropospheric Emissions
For GHG emissions in the lower troposphere, EDMS will be used to quantify Jet A fuel
consumption (as weight) from the RLV operations and jet engine tests beneath the
atmospheric mixing height, as well as diesel fuel consumption from the GSE.
Fuel weight estimates will be factored against fuel densities of 6.84 pounds per gallon for
Jet A and 7.1 pounds per gallon for diesel to estimate a volume of fuel. GHG emissions
rates, in pounds of GHG per gallon of fuel, will then be applied to the estimated fuel usages
to compute individual GHG emissions. These rates are summarized as follows:

 
 
 

21.095 pounds CO2 per gallon of Jet
A;15
0.0006 pounds CH4 per gallon of Jet
A;16
0.00046 pounds N2O per gallon of
Jet A;17

 
 
 

22.384 pounds CO2 per gallon of
diesel;17
0.00053 pounds CH4 per gallon of
diesel;16
0.00019 pounds N2O per gallon of
diesel16

Individual GHG emissions will be normalized to CO2e using GWPs identified in Section
4.2.3.
Free Tropospheric and Stratospheric Emissions
EDMS information will be consulted to conservatively estimate Jet A fuel consumption
from RLV operations above the mixing height, assuming one hour to climb to the release
altitude with the engines operating at climb out power setting, and one hour for the return
flight with the aircraft engines operating at approach power setting.
GHG emissions from Concept X RLVs as they combust LOX and RP-1 during launch and
landing will be computed according to methods outlined in the F-PEIS. Specifically, it is
assumed that the Concept X RLV will operate similarly to the LV-2 Concept identified in
the F-PEIS in that it consumes approximately 3,204 kilograms of LOX/RP-1 in the
tropospheric phase of launch/landing and 6,546 kilograms during the stratospheric
phase. Emissions weight fractions for CO2 and H2O from the F-PEIS, equaling 0.931 and
0.25, respectively, will be applied to the total fuel consumption to estimate GHG
emissions.

Energy Information Administration (EIA). Voluntary Reporting of Greenhouse Gases Program, Fuel and Energy Source Codes
and Emission Coefficients. http://www.eia.doe.gov/oiaf/1605/coefficients.html. 2008.
16 U.S. Environmental Protection Agency. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2005. April 2007.
15

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 Houston Spaceport Environmental Assessment
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Assessment of SpaceShip Two launch emissions from an environmental assessment
prepared for the Mojave Air and Space Port indicated that “[e]ach launch would use an
estimated 13,000 pounds of N2O and 2,500 pounds of solid organic fuel [i.e., HTPB] for
a total propellant mass of 15,500 pounds.17 The document also cites emissions indices for
these activities (in mass pollutant per unit mass of fuel) of 0.240 for CO2 and 0.100 for
H2O. These fuel consumption estimates and emissions indices will be similarly applied to
Concept Z RLV activities occurring at Houston Spaceport.

4.2.3.3. Presentation of Results
Table 10 provides a summary template for the GHG emissions inventory. Emissions of
applicable GHG, in metric tons, will be presented per analysis year (e.g., 2015), source
(e.g., RLV) and atmospheric layer (e.g., stratosphere).

5. Construction Emissions Inventory Approach and Methodology
The construction requirements for the Proposed Action will involve a variety of air
emissions sources including on- and off-road construction vehicles, machinery and
equipment. These emission sources are associated with the following activities:
• Site preparation and earth-moving;
• Material transport;
• Leveling and grading of project footprint;
• Facilities construction operations; and
• Storage and movement of raw and construction materials.

Impacts from construction activities planned for the Proposed Action will be restricted
to an evaluation of CAP emissions occurring during the construction period (i.e., 2015).
The scope and methodology of the construction emissions inventory is outlined in the
following sections.

5.1.1. Inventory Scope
Construction activities included in the Proposed Action include the improvements
shown on Figure 2, comprising the addition of an RLV hangar and apron space,
construction of connecting taxiways and access roadways, fuel storage tank pads and
loading areas, and fuel truck parking facilities.

17

Federal Aviation Administration. Final Environmental Assessment for the Launch and Reentry of SpaceShip Two Reusable
Suborbital Rockets at the Mojave Air and Space Port. 2012.

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 Houston Spaceport Environmental Assessment
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Table 10 – GHG Emissions Inventory Summary
Atmospheric Layer
Lower Troposphere

Subtotal –
Lower Troposphere
Free Troposphere
Subtotal –
Free Troposphere
Stratosphere

Source
Concept X RLVs
Concept Z RLVs
Support Equipment
Engine Testing

Concept X RLVs
Concept Z RLVs

----

----

Concept X RLVs
Concept Z RLVs

----

----

Subtotal –
Stratosphere
Grand Total
Atmospheric Layer
Lower Troposphere

Subtotal –
Lower Troposphere
Free Troposphere
Subtotal –
Free Troposphere
Stratosphere
Subtotal –
Stratosphere
Grand Total

2015 Emissions (metric tons)
CO2
CH4
N2O
CO2e
H2O
-----

Source
Concept X RLVs
Concept Z RLVs
Support Equipment
Engine Testing

2019 Emissions (metric tons)
CO2
CH4
N2O
CO2e
H2O
-----

Concept X RLVs
Concept Z RLVs

----

----

Concept X RLVs
Concept Z RLVs

----

----

Source: KB Environmental Sciences, Inc.
Note: Gray banding in the table signifies that the GHG is not emitted from the subject emissions source, except in the instance of water
vapor for some sources. Some sources do actually emit water vapor, but it is not quantified in the lower troposphere for this
assessment

Construction is expected to commence and be completed in 2015, representing a
construction period of one full year. Emissions from construction activities noted on
Figure 2 will be estimated based on a projected construction activity schedule, including
the number of vehicles/pieces of equipment, the types of equipment/type of fuel used,
vehicle/equipment utilization rates, and the year(s) construction occurs. For this
assessment, emissions of CO, VOC, NOx, SOx, and PM10/PM2.5 will be evaluated.

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 Houston Spaceport Environmental Assessment
Final Air Quality Assessment Protocol

Figure 2 – Proposed Federal Action Construction Elements

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 Houston Spaceport Environmental Assessment
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With respect to HAPs, according to FAA’s Guidance for Quantifying Speciated Organic
Gas Emissions from Airport Sources:
“Construction activities at airports generally represent a temporary source
of air emissions associated with the site preparation, construction and/or
demolition. Depending on the project requirements, the work can involve
an assortment of both on-road vehicles (i.e., pick-up trucks, dump trucks,
etc.) and non-road (i.e., scrapers, dozers, loaders, etc.) equipment. The
exhaust from these vehicles and equipment contains OGs (including
HAPs).
While it is recognized that construction equipment and some construction
activities (e.g., equipment fueling) result in emissions of HAPs, it is not
currently possible to accurately speciate the OG/HAP emissions of
construction activities due to lack of data.”
Accordingly, quantification of construction-related HAP emissions has been discounted
from this assessment.
To date, FAA has issued guidance on the quantification of GHG from aircraft operations
for NEPA purposes.18 On the other hand, they have not issued guidance or a policy
statement on the calculation and disclosure of construction-related GHG. So,
construction GHG are excluded from the Houston Spaceport air quality analysis.

5.1.2. Models and Methods
On-road Construction Vehicles
To estimate emissions associated with on-road construction vehicles including haul
trucks, vehicles utilized for the purposes of security, escorting and project management,
and personal employee vehicles, annual vehicle miles of travel (AVMT) will be calculated
according to Equation 1 using the following assumptions:
Equation 1
Emission Rate (tons/year) = Emission Factor (grams/mile) * miles per day * days/year *
(453.59/2000 tons/gram)

18

Federal Aviation Administration. FAA Order 1050.1E, Change 1, Guidance Memo #3: Considering Greenhouse Gases and Climate
under the National Environmental Policy Act (NEPA): Interim Guidance. Prepared by Thomas Cuddy for Julie Marks. January
12, 2012.

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 Houston Spaceport Environmental Assessment
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Haul trucks, materials delivery vehicles and other site vehicles specified in the
anticipated construction schedule for the Proposed Action will travel 30 miles per
each round trip (representing the average driving distance to the nearest fill
borrow site).
Employee AVMT will be calculated assuming 30 miles per work day (which is the
approximate round trip distance between EFD and the Houston city center) and
applied to the manpower estimates per construction phase noted in the anticipated
construction schedule.

Emission factors for each on-road construction vehicle will be developed using the EPA
Motor Vehicle Emissions Simulator (MOVES Version 2010b), with inputs specific to the
HGB O3 nonattainment area developed for use in the statewide Trend Emissions
Inventories computed by the TCEQ.19 The Trend Inventories supply input data to MOVES
for the HGB area in terms of vehicle mix, vehicle age, inspection/maintenance programs,
fuel formulations and other parameters. For this assessment, an average speed of 35 miles
per hour, representing the average of posted vehicle speeds in the area, will be adopted
for all on-road vehicles included in the analysis.
Nonroad Construction Equipment
Construction-related emissions associated with the exhaust from heavy nonroad
equipment (i.e., backhoes, bulldozers, graders, etc.) will be estimated according to
Equation 2, using information from the anticipated construction schedule regarding:
the number and types of construction equipment to be used on the project (including fuel
type and horsepower rating); the deployment schedule of equipment (monthly and
annually); and the approximate daily operating time.
Equation 2
Emission Rate (tons/year) = Emission Factor (grams/horsepower-hour) * size
(horsepower) * hours per day * days per year * Load Factor * (453.59/2000 tons/gram)

Emissions factors, in grams of pollutant per horsepower hour of operation, will be
obtained from the Texas NonRoad Model (TexN version 1.6) for construction equipment
operating in the HGB nonattainment area. TexN will be invoked such that all standing
emissions control programs identified in the area SIP, including the use of Texas Low
19

Texas Commission on Environmental Quality (TCEQ). On-road, Mobile Source Trend Emissions Inventories for All 254 Counties
in Texas for 1999- 2030 . Prepared by then Texas Transportation Institute. July, 2011.

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 Houston Spaceport Environmental Assessment
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Emissions Diesel (TxLED), are in effect. Equipment load factor, representing the
percentage of full throttle at which given equipment typically operates, will also be
extracted from TexN for use in Equation 2.
Fugitive Emissions
Fugitive dust emissions from debris loading and other construction activities will be
included in the impact estimate. PM emissions associated with debris loading will be
computed consistent with the methodology outlined by the Midwest Research Institute
(MRI) assuming 0.046 ton of debris would be generated per square foot of material to be
demolished.
To estimate emissions from other site-wide construction activities, a fugitive dust
emission factor of 1.2 tons per acre disturbed per month of construction will be used,
assuming that 25 percent of the construction project area will be be disturbed per
construction month identified on the anticipated schedule.20 PM2.5 will be assumed to
comprise ten percent of the PM10 emissions.21 Erosion control measures and dust
suppression programs are typically formulated to minimize these fugitive particulate
emissions, consistent with the Texas Administrative Code (TAC) at 30 TAC §111.143,
§111.145 and §111.147. A dust control efficiency of 75 percent will be applied to represent
adherence to these measures.22
Evaporative VOC emissions associated with the application of hot mix asphalt on areas
requiring paving (e.g., roadways, parking lots, and taxiways) will be estimated using raw
materials quantities, as well as an emission factor of 0.053 ton of VOC per acre of asphalt
material laid, following methodology outlined by the National Association of Clean Air
Agencies (NACAA).23

5.1.3. Presentation of Results
Table 11 provides a summary template for the construction period emissions inventory.
Emissions of each CAP, in short tons, will be presented per source (e.g., nonroad
equipment). As discussed in Section 6, estimated emissions of NOx and VOC will be used
for a General Conformity Applicability Analysis whereby the total annual emissions of

U.S. Environmental Protection Agency. Compilation of Air Pollutant Emissions Factors (AP-42). Fifth Edition, Volume I Chapter
13: Miscellaneous Sources. 1995.
21 Pace, Thompson G. Examination of the Multiplier Used to Estimate PM2.5 Fugitive Dust Emissions From PM10. Presented at the
Environmental Protection Agency 14th International Emission Inventory Conference. Las Vegas, NV, 2005.
22 U.S. Environmental Protection Agency. Fugitive Dust Background Document and Technical Information Document for Best
Available Control Measures. OAQPS, EPA-450/2-92-004. 1992.
23 U.S. Environmental Protection Agency, Emission Inventory Improvement Program, Asphalt Paving, Chapter 17, Volume III, April
2001, http://www.epa.gov/ttn/chief/eiip/techreport/volume03/iii17_apr2001.pdf.
20

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 Houston Spaceport Environmental Assessment
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these pollutants will be compared against the applicable de minimis thresholds (25 tons
per year for NOx and VOC) for a severe O3 nonattainment area.
Table 11 – Construction Emissions Inventory Summary
Source
Nonroad Construction Equipment
Onroad Construction Vehicles
Employee Vehicles
Asphalt Paving
Fugitive Dust
Total
De minimis Threshold

2015 Emissions (tons)
CO NOx SOx PM10 PM2.5 VOC

---

---

---

--

--

25

--

--

----

25

Source: KB Environmental Sciences, Inc.

6. Clean Air Act Conformity
Considerations for the Proposed Action related to the CAA General and Transportation
Conformity regulations, codified at 40 CFR Parts 51 and 93, are discussed within this
section.

6.1.

General Conformity

Because the Proposed Action occurs in an area currently designated nonattainment for
O3, a General Conformity Applicability Test outlined at 40 CFR §93.153(b) will be
prepared, whereby the CAP operational emissions inventories of the Proposed Federal
Action in both 2015 and 2020 will be compared to applicable de minimis thresholds
established for a severe O3 nonattainment area (i.e., 25 tons per year of NOx and VOC).
Construction period emissions in 2015 will also be included in the General Conformity
Applicability Test.
Exceeding the de minimis thresholds for NOx and VOC is unlikely based on the scope of
the Proposed Action. However, if de minimis thresholds are exceeded for any given year,
a formal General Conformity Determination will be prepared in consultation with EPA
Region 6 and the TCEQ.
The current federally-approved SIP for the purposes of determining General Conformity
of the Proposed Action is the Houston-Galveston-Brazoria Eight-Hour Ozone
Nonattainment Area Reasonable Further Progress State Implementation Plan Revision

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 Houston Spaceport Environmental Assessment
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(Rule Log 2006-030-SIP-NR), adopted by TCEQ on May 23, 2007 and approved by EPA
in April of 2009.24
When comparing to the SIP, analysis year requirements for General Conformity
Determinations promulgated at 40 CFR §93.159(d) comprise the following conditions:
 
 
 

The applicable attainment year for the nonattainment area;
The year of peak emissions associated with the Proposed Action; and
Any year for which the applicable federally-approved SIP contains an
emissions budget.

Based on EPA’s approved reclassification of the Houston area to severe nonattainment
status, the HGB nonattainment area must demonstrate compliance with the 1997 Ozone
NAAQS no later than June 15, 2019.25 Accordingly, the TCEQ has adopted year 2018 as
the attainment year for SIP purposes as it is the last year in the SIP timeframe that
contains a complete ozone season.26
As stated in Section 4.2.1.1, operational emissions associated with the Proposed Action
will be computed for 2015 (i.e., initial year of operations) and 2020 (i.e. initial year plus
five) for the purposes of the EA, years that do not directly coincide with the applicable
attainment year for the 1997 8-hour O3 NAAQS. To make the necessary comparisons at
40 CFR §93.159(d), Proposed Action emissions will be interpolated using the computed
2015 and 2020 emissions inventories.
Additionally, Proposed Action inventory years for both project construction and project
operations fall after the last emissions budget year in the federally-approved SIP (i.e., year
2008). In accordance with 40 CFR §93.162(a), the Proposed Action emissions will be
compared to the last emission budget year in the SIP; in this case, the 2008 emissions
budget for the HGB nonattainment area. Because the federally-approved SIP also
contains an emissions budget for base year 2002, this budget will also be included for
comparative purposes.
In summary, the following comparisons on Table 12 would be made to the SIP in the
event that a formal General Conformity Determination is required for the Proposed
Action.

24

25

26

Approval and Promulgation of Air Quality Implementation Plans; Texas; Reasonable Further Progress Plan, Motor Vehicle
Emissions Budgets, and 2002 Base Year Emissions Inventory; Houston-Galveston-Brazoria 1997 8-Hour Ozone Nonattainment
Area. 74 FR 18298. April 22, 2009.
Clean Air Act Reclassification of the Houston/Galveston/Brazoria Ozone Nonattainment Area; Texas; Final Rule. 73 FR 56983.
October 1, 2008.
Houston-Galveston-Brazoria Attainment Demonstration State Implementation Plan Revision for the 1997 Eight-Hour Ozone
Standard. Project No. 2009-017-SIP-NR. Adopted March 10, 2010.

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 Houston Spaceport Environmental Assessment
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Table 12 – Required Comparisons to the Federally-approved SIP
Approved
Proposed
Federal Resulting
1
Requirement
SIP
Action
Analysis Comparison(s)
2
Year(s)
Year(s)
3
Attainment Year
2008
2018 (Operations)5
2018 Proposed Action to
2008 SIP Year
(2018)

Peak Year4

--

2020 (Operations)

2020 Proposed Action to
2008 SIP Year

Any Other SIP
Emissions Budget
Year

2002, 2008

2015 (Operations and
Construction)

2015 Proposed Action to
2002 and 2008 SIP
Years;

2020 (Operations)
2020 Proposed Action to
2002 SIP Year
40 CFR §93.159(d)
Galveston-Brazoria Eight-Hour Ozone Nonattainment Area Reasonable Further Progress SIP revisions [2006-030-SIPNR] adopted May 23, 2007 and approved at 74 FR 18298 on April 22, 2009.
3 An attainment year inventory is not included in the federally-approved SIP. Per 40 CFR §93.162(a), a comparison to 2008 (i.e., the
latest available SIP budget year) will be made in its place.
4 Peak year refers to Proposed Action only.
5 Operational emissions would be interpolated for interim years of interest for the purposes of determining General Conformity.
1

2 Houston

6.2.

Transportation Conformity

The Transportation Conformity Rule requires that roadway projects deemed “regionally
significant” (i.e., arterials, freeways, etc.) be included in a conforming Transportation
Improvement Plan (TIP) or equivalent document. In the project-level context,
Transportation Conformity applies only to projects funded or approved under U.S.C. Title
23 or the Federal Transit Laws (49 U.S.C. Chapter 53). Houston Spaceport will have no
FHWA or FTA funding; therefore, transportation conformity does not apply to the
project.

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Houston Spaceport Environmental Assessment – Draft

C-36

 SECTION 106 COORDINATION

APPENDIX D

SECTION 106 COORDINATION

Houston Spaceport Environmental Assessment – Draft

D-1

 SECTION 106 COORDINATION

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Houston Spaceport Environmental Assessment – Draft

D-2

 TEXAS HISTORICAL COMMISSION
realplaces telling real stories

6 June 2014

Daniel Czelusniak

Commercial Space Transportation, 
Federal Aviation Administration

800 Independence Avenue, SW
Washington, DC 20591

Re: Pny'ecz? review under Section 706 off/ye National Historic Pneumatic? Act (yr 1 966
Pmpored Homton Spacqbo?, Ellington Airport, HUZIJTOH, Hams Count}, T896615 

Dear Mr. CZClusniak,

Thank you for sending us information on the above-referenced project, a proposed Spaceport facility that
would be licensed by the Federal Aviation Administration  This letter serves as official comment
from Texas? State Historic Preservation Officer, the Executive Director of the Texas Historical
Commission (THC). This is a more formal response following up on our email message to you on April 18
that we concurred with the Federal Aviation Administration?s determination of ?No Historic Properties
Affected? by this project.

THC staff led by Linda Henderson and Brad Jones reviewed the materials and concurred with the ?ndings.
For future spaceport coordination, we would like to work with FAA ahead of time to outline appropriate
project Area of Potential Effect and survey methodology, especially for projects at existing airport facilities.
Because many of Texas? airfields have ties to World War II and the Cold War, in addition to seeing
evaluations on NRHP eligibility on resources outside airport boundaries, we also will need information on
resources within the confines of the airport boundary, evaluated within the context of aviation but also
military history.

Thank you again for coordinating with our of?ce and for helping identify and protect the state?s historic
resources. For questions about our role in the review process or our comments on this project in particular,
please contact us: or 512/ 463?5851.

 

Linda Henderson, Historian
For:
Mark Wolfe, State Historic Preservation Of?cer



RICK PERRY, GOVERNOR MATTHEW F. KREISLE, CHAIRMAN WOLFE, EXECUTIVE DIRECTOR
P.0. BOX 12276 TEXAS 78711-2276 0 512.453.6100 0 512.475.4872 

U.S. Department

of Transportation

Federal Aviation
Administration

MAR 18 .2014

Of?ce of Commerciai Space Transportation 800 Independence Ave, SW.
Washington, DC 20591

Mr. Mark Wolfe

State Historic Preservation Of?cer
Texas Historical Commission

103 w. 16th Street

Austin, TX 78701

SUBJECT: Section 106 Consultation for the Proposed Houston Spaceport at Ellington Airport,
Harris County, Texas

Dear Mr. WOlfe:

In accordance with the National Environmental Policy Act, the Federal Aviation Administration (FAA) is
preparing an Environmental Assessment (EA) to assess the potential environmental impacts of the
Houston Airport System?s proposal to operate a commercial space launch site at the Ellington
Airport (EFD) in Harris County, Texas (see Attachment 1) and offer the site to commercial space launch
vehicle operators for the operation of horizontal take-off and horizontal landing reusable launch vehicles
(RLVs). To operate a commercial space launch site, HAS must obtain a launch site operator license from
the FAA. Under the Proposed Action addressed in the EA, the FAA would: (1) issue a launch site
operator license to HAS for the operation of a commercial space launch site at EFD, (2) issue launch
licenses to prospective launch vehicle operators that would allow them to conduct launches of horizontal
take-off and horizontal landing RLVs from EFD, and (3) provide unconditional approval to modify the
existing Airport Layout Plan to re?ect the designation of a launch site boundary and existing and future
Spaceport facilities and infrastructure.

The action of issuing a launch site operator license and launch licenses, and the unconditional approval to
modify an existing Airport Layout Plan, is considered a federal undertaking under the regulations of the
Advisory Council for Historic Preservation (36 Code of Federal Regulations for
Section 106 of the National Historic Preservation Act. This letter initiates consultation with your office
regarding the proposed undertaking. A description of project activities, the project Area of Potential
Effects (APE), identi?cation of historic properties, and assessment of effect are'outlined below.

Project Activities

HAS proposes that two types of horizontal RLVs would operate at EFD: the Concept vehicle and/or
the Concept vehicle. Under current designs, the Concept vehicle?s size and weight are comparable to
a mid?sized business jet with twin turbofan engines. It would take off and land under conventional jet
engine power. At high altitude (over 50,000 feet), the vehicle would ignite rocket engines to reach
suborbital altitudes. The Concept vehicle is a two?part vehicle, including a carrier vehicle and an
attached RLV. The carrier vehicle would take off under jet engine power and climb to approximately

 

50,000 feet, at which point the RLV would separate from the carrier vehicle and use its rocket engine to
reach suborbital altitudes. The carrier vehicle would make a powered landing like a conventional aircraft.
The concept vehicle would make an unpowered, glide landing. Both RLVs would use common
propellants (fuel and oxidizer) for propulsion, such as conventional et?A ?161, liquid oxygen, and re?ned
kerosene. Attachment 2 shows examples and descriptions of the proposed RLV concept vehicles.

HAS proposes up to 50 ?ights per year at the Houston Spaceport. Initially, RLV ?ights would begin in
2015 and gradually increase up to 50 ?ights per year during the timeframe of the launch site operator
license (expected to be 2014?2019). No launches would be conducted at night (between the hours of
10:00 pm to 6:59 am). The proposed RLV ?ight path would depart EFD to the south and rocket ignition
would occur in the Offshore Warning Areas located over the Gulf of Mexico (see Attachment 3).
Following a success?il suborbital ?ight, the RLV would then return to EFD either under jet power
(Concept X) or in glided ?ight (Concept Z).

The project also involves constructing Spaceport facilities and infrastructure to support operations. The
proposed facilities and infrastructure include {a hangar, hangar access road and parking area, apron,
fencing around the apron, taxiway, propellant truck parking area, and a concrete pad for loading oxidizer.
No new? ?le] farms and/or onsite storage tanks for propellants would be required. Propellants not already
stored at EFD would be stored offsite and delivered to EFD by tanker truck. All facilities and
infrastructure would be constructed within the existing EFD boundary (see Attachment 4).

Area of Potential Effects

In accordance with 36 CFR an APE needs to be established for the proposed undertaking in
consultation with your of?ce. The FAA has determined an APE in consideration of both potential direct
and indirect effects to archaeological and architectural resources as a result of implementing the proposed
undertaking. The proposed APE is de?ned as the area encompassed by the existing Day-Night Average
Sound Level (or DNL) 65 A-weighted decibel (or aviation noise contour (see Attachment 5). The
proposed APE would encompass all potential direct and indirect effects on archaeological and
architectural resources. Although this proposed APE does not account for the additional noise that would
be generated ?'om up to 50 annual RLV launches, based on the existing number of annual ?ights at EFD
(approximately 144,702) and the fact that the RLVs would use jet engines during takeoff and landing (the
Concept vehicle would conduct an unpowered, glide landing), it is unlikely the existing DNL 65 
aviation noise contour would change notably.

The RLVs would generate sonic booms over the Gulf of Mexico during RLV ascent and reentry. During
ascent, the sonic boom would be propagated upwards and would not impact the Earth?s surface and
therefore, would not be heard. A second sonic boom would be generated during RLV reentry, at around
80,000 feet over the Gulf of Mexico. This sonic boom would impact the water surface of the Gulf of
Mexico and would not be heard on land. Therefore, sonic booms were not considered when de?ning the
APE because they would have no potential for effect on historic properties.

For archaeological resources, potential effects would be limited to the area within the APE where ground
disturbance would occur ?'om construction of the hangar, hangar access road and parking area, apron,
fencing around the apron, taxiway, and propellant truck parking area. The oxidizer'loading area is
currently a paved area. For architectural resources, potential effects would extend to the boundary of the
APE. The FAA requests your concurrence on the determination of the APE.

 

Identi?cation of Historic Properties

A review of the Texas Historic Sites Atlas and the National Register of Historic Places (NRHP) online
database revealed no historic properties within the APE. The closest historic property is the Historical
Marker for the Webster Presbyterian Church (see Attachment 5).

Assessment of Effect
There are no known NRHP-listed or eligible historic properties within the APE. Therefore, under the

proposed undertaking, there would be no direct effects from ground disturbing activities associated with
the proposed undertaking.

Increase in noise at the airport would be minimal, and there are no architectural resources eligible for the
NRHP that would be adversely affected by changes to the setting due to noise ?'om the proposed RLV

operations under the proposed undertaking. The FAA requests your concurrence with the ?nding of no
historic properties affected.

Please provide any comments you have regarding the proposed APE and ?nding of effect within 30 days.
If you have any questions or need further information on the projeCt, please contact Mr. Daniel
CzelUsniak, of my staff, at 202-267?5924 or at Daniel.Czelusniak@faa.gov. Thank you in advance for
your input on this project.

Sincerely,



Daniel Murray 
Manager, Space Transportation Development Division

Attachments: 1. Location of Ellington Airport
2. Examples of Concept and Concept Launch Vehicles
3. Proposed Launch Vehicle Flight Path
4. Proposed Spaceport Facilities and Infrastructure
5. Area of Potential Effects

 

Attachment 1. Location of Ellington Airport

 

 

   

 

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Attachment 2. Examples of Concept and Concept Launch Vehicles

 

Concept Vehicle Examples

   
   

 

 

 

 

 

Concept'Z Vehicle Example  

Source. I rgin galactic, 2011

 

 

 

 

Concept Aircraft engine Rocket engine Aircraft engine/glide

 

Concept Aircraft engine2 Rocket engine Glide, no pcwver3

 

 

 

 

Notes:

1 Occurring at approximately 40,000 feet mean sea level

2 - Launch vehicte carried via larger aircraft to designated iaunch area

3 - Carrier vehicle would land under conventional iet aircraft engine power.

 

 

 

 

  

 

 

 

 

In um; i Date .
Houston Spacepon EnwronmentaiAssessment
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IMPROVING YOUR WORLD  Ellington Airport. Houston,Texas

 

 

 

 

 

 

Attachment 3. Proposed Launch Vehicle Flight Path

 

 

 

 

 

Attachment 4. Proposed Spaceport Facilities and Infrastructure

 

      
 
  
 

Hangar
Apron
Taxwvay

 

:3 Oxidizer Loading Area

Oxidzer Storage Tank Pad with
Incompatibie lntrainne Area

RP-1 Truck Parking
Access Roadway and Parking

 

Fence

Proposed Spaceport Beundary

(E?la?ngton Airport Propeny)
Freeway

 

1'   Highway

 

Secondary Road

Housron Spaceporr Envnomnemai 

   

ma. Proposed Action

 

EnglonAirpor'L Houston. Texas

 

Attachment 5. Area of Potential Effect

 

 

SECTION 106 COORDINATION

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Houston Spaceport Environmental Assessment – Draft

D-12

 AIRCRAFT NOISE AND SONIC BOOM METHODOLOGY

APPENDIX E

AIRCRAFT NOISE AND
SONIC BOOM METHODOLOGY

Houston Spaceport Environmental Assessment – Draft

E-1

 AIRCRAFT NOISE AND SONIC BOOM METHODOLOGY

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Houston Spaceport Environmental Assessment – Draft

E-2

 AIRCRAFT NOISE AND SONIC BOOM METHODOLOGY

Houston Spaceport Environmental Assessment – Draft

E-3

 HOUSTON SPACEPORT
AT ELLINGTON AIRPORT

Summary of Aircraft Noise and Sonic
Boom Methodology

Prepared For

City of Houston - Houston Airport System
and

Federal Aviation Administration (AST and AEE)

Prepared By

Version 2.0

 TABLE OF CONTENTS
CHAPTER 1 ............................................................................................................................... 3
1.1

Background.................................................................................................................. 3

1.1.1
1.2

Existing Aircraft Operations................................................................................... 3

Launch Vehicles and Flight Path .................................................................................. 3

1.2.1

Horizontal Reusable Launch Vehicles ................................................................... 3

1.2.2

Proposed RLV Flight Path..................................................................................... 4

1.3

Noise Emissions .......................................................................................................... 7

1.3.1

Aircraft Noise Emissions ....................................................................................... 7

1.3.2

Sonic Booms......................................................................................................... 8

1.4

Proposed Action Noise Analysis Methodology ............................................................. 9

1.4.1

Engine Noise ........................................................................................................ 9

1.4.2

Sonic Boom .........................................................................................................10

LIST OF FIGURES
Figure 1-1

Example Concept X Vehicle ................................................................................ 5

Figure 1-2

Example Concept Z Vehicle ................................................................................ 5

Figure 1-3

Potential Concept X and Z Flight Path to OWA 147C&D ..................................... 6

Figure 1-4

A-, B-, and C- Weighting Functions ..................................................................... 8

Figure 1-5

Concept X and Z Supersonic Profile ..................................................................13

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 1.1

BACKGROUND

The Houston Airport System (HAS) proposes to obtain a Commercial Launch Site Operator
License from the FAA Office of Commercial Space Transportation (AST) for the Houston
Spaceport at Ellington Airport (EFD). This license would enable horizontal operations of
reusable launch vehicles (RLV), thereby positioning EFD to accommodate a variety of potential
launch customers.
As part of the licensing process, the National Environmental Policy Act (NEPA) requires the
FAA to analyze the potential environmental impacts associated with the proposed operation of
commercial launch sites. This appendix provides the methodology for potential noise and
sonic boom impacts related to conceptual RLV operations at Ellington Airport.
1.1.1

Existing Aircraft Operations

There are existing aircraft engine noise emissions as a part of the civil and military operations at
EFD. In 2011, the Airport conducted 114,702 operations. Of these, approximately 61% were
general aviation, 32% military, 5% commuter, and 2% air carrier.1 The large percentage of
military operations is a function of activity by multiple active military and governmental agencies
located at EFD: TxANG, TxARNG, the USCG, and NASA. Together these military and
governmental agencies utilize a variety of jet aircraft at EFD, including F-16, T-38, C-9, and WB57 aircraft, among others.
The FAA’s Terminal Area Forecast indicates total operations, exclusive of spaceport operations,
would equal 114,702 operations in 2015.

1.2

LAUNCH VEHICLES AND FLIGHT PATH

1.2.1

Horizontal Reusable Launch Vehicles

A horizontal RLV is a launch vehicle that utilizes aviation facilities to take off and land. Unlike
vertically launched space vehicles, the operation of horizontal RLVs is similar to traditional
airplanes. The current horizontal RLVs under consideration at Ellington Airport consist of two
specific types: Concept X and Concept Z. The third type, a Concept Y vehicle, is not proposed
to operate from Ellington Airport.
A summary of the key operational characteristics of the Concept X and Z vehicles is shown
below.
Concept X - The Concept X is an all-in-one dual-propulsion vehicle, similar to an airplane. The
Concept X vehicle takes off from a runway using jet power and flies to a designated operating
area and altitude (typically approximately 40,000 feet mean sea level (msl)) before igniting its
rocket engines to reach its apogee in sub-orbit. The Concept X RLV is able to land horizontally
by either restarting its jet engines or by gliding (i.e., unpowered). Figure 1-1 presents an
example Concept X RLV.
Concept Z - The Concept Z RLV is a two-part vehicle consisting of a reusable carrier aircraft
and a reusable or an expendable launch vehicle. The carrier aircraft is powered by jet engines
1

FAA, APO Terminal Area Forecast Detail Report, January 2013, http://aspm.faa.gov/main/taf.asp, accessed
September 2013.
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 and designed/modified to carry the captive launch vehicle to a designated operating area and
altitude (up to 50,000 feet msl), where the two components separate and the rocket engines of
the launch vehicle ignite. The carrier aircraft returns under jet power for a normal aircraft
landing. The launch vehicle may conduct a glide return for a horizontal landing or be expended.
Figure 1-2 presents an example Concept Z vehicle.
1.2.2

Proposed RLV Flight Path

This section describes the proposed flight paths of the concept RLVs under the Proposed
Action. The proposed flight path is depicted for environmental planning purposes and is being
coordinated with applicable agencies.
As proposed, the RLVs would takeoff to the south from Runway 17R-35L at EFD. The
coordinates for the departure and arrival routes were selected to provide a route that both
minimizes the overflight of populated areas and minimizes the impact on existing aircraft routes
in the area. The concept RLVs would fly from EFD to the Offshore Warning Area (OWA) W147C and D (see Figure 1-3).
During navigation along these proposed departure and arrival routes, the Concept X and Z
RLVs are operating in the fashion of a conventional aircraft. Rocket ignition would occur only
within the designated RLV Operating area (i.e., OWA W-147C and D), over the Gulf of Mexico
approximately 130 miles south of the continental U.S.
Figure 1-1
Example Concept X Vehicle

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 Figure 1-2
Example Concept Z Vehicle

Source: Virgin Galactic, 2011

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 Figure 1-3
Potential Concept X and Z Flight Path to OWA 147C & D

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 1.3

NOISE EMISSIONS

This section describes background information associated with aircraft noise emissions and the
generation of sonic booms.
1.3.1

Aircraft Noise Emissions

The primary mechanism of aircraft noise emissions results from air pressure fluctuations
induced from the operation of aircraft during the various phases of flight. While pressure
fluctuations from an aircraft can originate from aerodynamic forces or mechanical systems, the
majority of aircraft noise is the result of engine operation. Jet engines induce a turbulent mixing
of the atmosphere that creates compression and rarefaction of the ambient atmosphere, which
causes air pressure fluctuations. If these fluctuations have the appropriate frequency and are
strong enough, they can be perceived as audible sound.
Aircraft noise emissions are often the most noticeable environmental effect of aviation
operations. As with other environmental issues, the potential impact of noise emissions from
aircraft is a function of a number of interacting variables, including sound level, duration, time of
day, and frequency of occurrence. Quantifying the potential impact of aircraft sound emissions
considers the quantitative aspects of aircraft sound emissions relative to subjective human
perceptions of disturbance.
Human perception of sound pressure fluctuations is described and measured in units of
decibels (dB). The threshold of human perception of sound begins at 0 dB, with 120 dB typically
considered the threshold for physical discomfort. The human ear is capable of hearing the
sound pressure across the frequency range of 20 Hertz (Hz) to 20,000 Hz. To account for the
frequency or pitch of the sound pressure fluctuations, decibels are typically converted to Aweighted decibels. The A-weighting, described in International Standard 61672:2003, is the
frequency metric utilized by the FAA and the recognized frequency adjustment to account for
human response to noise. A–weighting effectively filters out both high and low frequencies to
approximate the sensitivity of the human ear. Impulsive sounds (e.g., sonic booms) typically
utilize C-weighting, which includes a greater range of lower frequencies. Figure 1-4 shows a
comparison of the A- and C- Weighting Functions.
In addition to the noise frequencies, research2 shows that the loudness of individual events, the
number of events during a given period, and the time of day in which noise events occur
influence human perception of, and therefore sensitivity to, that noise. The cumulative effect of
individual sound events on a community over time is calculated with a metric known as the DayNight Average Sound Level (DNL). The DNL takes into account the exposure, duration, time of
day, and number of sound events averaged over a 12-month period.
In 1981, the FAA and EPA determined that the DNL is the appropriate metric to assess noise
impacts on humans. In 1992, the FAA confirmed that determination after finding the DNL metric
accurately predicts those noise levels causing annoyance.

2

Federal Agency Review of Selected Airport Noise Analysis Issues, Federal Interagency Committee on Noise
(FICON) 1992.
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 Figure 1-4
A-, B-, and C- Weighting Functions

Source: Castle Group 2013.

The FAA considers a significant noise impact to occur if analysis shows that a proposed action
increases sound levels in sensitive areas by DNL 1.5 dB or more at or above the DNL 65 dB
exposure level when compared to a no action alternative for the same period (FAA Order
1050.1E, Change 1, Appendix A, Section 14.3).
1.3.2

Sonic Booms

Noise emissions of concept RLVs can result from the generation of sonic booms.
The movement of any aircraft traveling in the atmosphere creates a series of pressure waves
due to the compression of air in front of a moving aircraft. These pressure waves travel ahead
of the aircraft at the speed of sound. When an aircraft’s speed becomes such that it begins to
exceed its own pressure wave, the waves are compressed to a point where a shockwave is
formed. This shockwave is known as a sonic boom, and is created when the aircraft passes the
speed of sound, commonly referred to as Mach 1.
The sonic boom shockwave produces a transient increase in air pressure, known as
overpressure, which is a pressure greater than the ambient atmospheric pressure. Depending
on atmospheric attenuation and absorption, sonic boom pressure fluctuations created by an
aircraft in flight may have the potential to be heard at ground level. Factors influencing the
intensity of the shockwave include vehicle size and weight, altitude, maneuvering, and vehicle
shape. Because the pressure fluctuations contain low frequency sound energy, observers hear
them as a sound similar to a thunderclap.

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 The sound energy associated with sonic booms has the potential for human disturbance. The
impact of impulsive sounds such as sonic booms has been found to correlate with C-weighted
DNL (CDNL).3 The C-weighting used by CDNL emphasizes low frequency sound between 25
Hz and 10,000 Hz. Research4 demonstrates that the human perception of CDNL is related to an
equivalent A weighted DNL.

1.4

PROPOSED ACTION NOISE ANALYSIS METHODOLOGY

The Proposed Action for the licensing process includes up to 50 departures and arrivals per
year of a horizontal reusable launch vehicle. Under the Proposed Action this change in
operations would equal a 0.09 percent increase in total annual operations. This section
describes the methodology to perform a thorough noise impact analysis for the Proposed
Action.
Activities associated with the Proposed Action potentially affecting noise levels include noise
generated during departure, flight, and arrival. This methodology addresses the potential noise
impacts that may occur due to operations of horizontal RLVs at Ellington Airport. The following
subsections describe the methodology of the RLV engine and sonic boom noise emissions of
Concept X and Z vehicles.
1.4.1

Engine Noise

The FAA’s Area Equivalent Method (AEM) is the initial method of quantifying a proposed
action’s potential impact from engine noise. The AEM uses a mathematical procedure to
estimate a change in the area of the DNL 65 noise contour that would occur if the number
and/or type of aircraft operations were to change. According to FAA Order 1050.1E, Change 1,
if the AEM calculations indicate that a proposed action would result in less than a 17 percent
(approximately a DNL 1 dB) increase in the DNL 65 dB contour area, it may be concluded that
there would be no significant impact over noise sensitive areas and that no further noise
analysis is required.5
Concept X Representative AEM Vehicle – As described in Section 1.2, a Concept X vehicle
operating at EFD would take off and depart horizontally. It would then depart from EFD to an
offshore location, where it would climb to a high altitude prior to igniting its rocket engines to
complete its ascent. Upon return, the Concept X vehicle would return for a horizontal landing by
either restarting its jet engines or by gliding.
Based on current information from Concept X vehicle developers, an appropriate representative
aircraft will be utilized in the AEM model to best model the acoustic parameters of engine noise
from the Concept X vehicle.
Concept Z Representative AEM Vehicle – As described in Section 1.2, Concept Z vehicles
consist of a two-part vehicle comprising a reusable carrier aircraft and a reusable or an
expendable launch vehicle. The carrier aircraft is powered by jet engines and designed/modified
to carry the launch vehicle to a high altitude, where the two components detach and the rocket
engine of the launch vehicle is ignited. The carrier aircraft flies back to EFD as a conventional
aircraft under jet engine power. The launch vehicle, which can be either suborbital or orbital,
3
4
5

Assessment of community response to impulsive noise, Journal of The Acoustical Society of America, (1985).
Community Response to High-Energy Impulsive Sounds, Committee on Hearing and Bioacoustics (CHABA) 1996 .
FAA Order 1050.1E, Change 1, Policies and Procedures for Considering Environmental Impacts (2006).

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 completes its operation and either returns to EFD as a glider for a horizontal landing or is
expended.
Based on current information from Concept Z vehicle developers, an appropriate representative
aircraft will be utilized in the AEM model to best model the acoustic parameters of engine noise
from the Concept Z vehicle
1.4.2

Sonic Boom

In order to achieve their desired flight profiles, Concept X and Z vehicles must fly at supersonic
speeds. Therefore, the operation of these vehicles traveling past Mach 1 will create sonic boom
overpressures. The ground area and intensity of the resulting sonic boom depends on a number
of factors, including vehicle geometry, atmospheric conditions, and flight profile trajectory.
To accurately account for these factors and determine the potential impact of sonic boom
generation, PCBoom4, a single-event prediction model, is proposed to be used to predict the
sonic boom footprint for Concept X and Z vehicle operations. PCBoom4, produced by Wyle
Laboratories, has been in use for many years, is utilized by the Air Force Center for Engineering
and Environment, and is widely accepted to determine the specific pattern and amplitude of a
sonic boom footprint.6
Figure 1-5 depicts the proposed flight track for the Concept X and Z vehicles. The red portions
represent the periods of supersonic flight and the yellow arrows show the direction of flight.

6

WR 02-11 Computer Models for Sonic Boom Analysis, Wyle Laboratories (2002)

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 Figure 1-5
Concept X and Z Supersonic Profile

Source: RS&H, 2014

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