3 September 2025
The following remarks were entered into the public record on behalf of CSE by Co-Founder Angelina Reddy regarding the SpaceX Starship-Super Heavy Project at Kennedy Space Center Launch Complex 39A.
Hello, my name is Angelina Reddy.
Today I am representing the Center for Space Environmentalism, a coalition of astrophysicists, environmental scientists, and authors who evaluate space activity along the entire continuum spanning Earth, LEO, and deep-space exploration.
We are grateful to the hard work that went into preparing this EIS and the public comment period here today, thank you very much for this transparency and dedication to providing data that allows the public to weigh in on impacts to their local environment.
We would like to express concern with a noticed trend in incremental, seemingly benign adjustments that result in EISs with a largely different scope from the initial review. For example, more than doubling the launch cadence, as is historically the case with SpaceX Falcon 9 launches, such as at the Cape and Vandenberg.
We would like to particularly highlight that Starship failed 9 out of 10 of its test launches,* and a simple doubling of this data means that 18 failures for 2 successes is a “finding of no significant impact.”
We understand the NEPA evaluation process to encourage re-using similar assessments to save time and processing power. We would appreciate a more direct reference to previous EISs that were used in the research for this one, when they were originally published, and how many launches were within the scope of those previous analyses.
We suspect that what may have constituted a FONSI in the past, that has now more than doubled its scope, would not result in a FONSI if the evaluation was done all over again.
Thank you very much for your hard work again on this subject, and we are very grateful to your work. We would like to highlight that EO 14335 would be very damaging in losing this opportunity for public comment on future space activities that affect local communities and global impact alike.
* We apply strict criteria for determining whether a launch was a success or a failure. The stated goal of the Starship program is the full reusability of all its parts, including the vehicle and booster; see Innman, Horvath & Scott, "SCIFLI Starship Reentry Observation (SSRO) ACO (SpaceX Starship)" (2021). Full reusability was not demonstrated prior to the 10th Starship flight.
Flight 1 (20 April 2023): Uncontrolled spin; failure. The flight termination system activated with the intent to destroy the vehicle immediately, but the vehicle remained intact for more than 40 seconds after activation of the flight termination system. See, e.g., Jonathan O'Callaghan, "Termination Shock", Aerospace America, 1 October 2023.
Flight 2 (18 November 2023): Lost comms; failure. One failed engine caused the booster to explode, and a leak in the aft section of the upper stage caused a combustion event interrupted communication between flight computers, causing full engine shutdown.
Flight 3 (14 March 2024): Booster exploded; failure. During the landing burn ignition, only three engines ignited. The booster was destroyed at an altitude of 462 meters.
Flight 4 (6 June 2024): Partial success, partial failure; engine loss and severe front flap damage.
Flight 5 (13 October 2024): Successful launch and re-entry but after splashdown in the Indian ocean, the booster tipped over and exploded.
Flight 6 (19 November 2024): Partial success, partial failure; booster was emergency-crashed in the ocean after damage to the catch tower during liftoff. Ship 31 sustained flap damage during re-entry.
Flight 7 (16 January 2025): Failure; exploded over the Turks and Caicos Islands.
Flight 8 (6 March 2025): Failure; spun out of control and lost comms.
Flight 9 (27 May 2025): Failure; the ship failed to deploy its payload of eight Starlink simulator satellites, developed a fuel leak, and was passivated before reentry. It broke up over the Indian Ocean.
Flight 10 (26 August 2025): Success, but there was substantial damage to the engine section during descent through the atmosphere.