Sea Launch Limited Partnership (SLLP) Proposal

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Comments on the Environment Assessment
from the
South Pacific Regional Environment Programme (SPREP)

Department of Transport U.S. Federal Aviation Administration Proposed Finding of No Significant Impact (FONSI)


July 27, 1998

The Sea Launch company is a joint venture between United States/ Ukrainian/ Russian/Norwegian partners. The company is based in Norway and organized under the laws of the Cayman Islands. Its ships are registered in Liberia. It has a home port in Long Beach, California, U.S.

According to the Environmental Assessment (EA), Sea Launch proposes to launch commercial satellites from international waters 20 km (12 miles) outside the Exclusive Economic Zone of Kiribati and Christmas Island.

The satellites would be launched from a converted semi-submersible oil rig platform using 1980s Russian Zenit rockets. Each launch would result in 36 tons of carbon monoxide (CO), and 181 tons of carbon dioxide (CO2) being emitted in the lower troposphere.

The two rocket stages, weighing 36 tons and 11.5 tons respectively, and the streamlining fairing, weighing a total of 2 tons, would fall back into the ocean. The rocket stages would sink, but the fairing would float indefinitely.

Unused fuel are approximately 4.5 tons of kerosene for each launch and would form a kerosene slick several square kilometers wide. The rockets called launch vehicles and the satellites would be carried to the launch site on custom-designed vessels built by the Norwegian partner in the joint venture. The company proposes to launch two satellites in 1998 and then six every year for 20 years.

The US Department of Transportation, Federal Aviation Administration, Associate Administrator for Commercial Space Transportation has proposed a Finding of No Significant Impact (FONSI) for the proposal.

The South Pacific Regional Environment Programme (SPREP) has been sent a copy of the Sea Launch EA. SPREP is charged by 22 Pacific island countries and four developed country members to promote cooperation and support protection and improvement of the Pacific environment, and to ensure its sustainable development.

The SPREP Convention to which the United States is a party, states that any assessment of major projects which could affect the marine environment shall be communicated to SPREP which shall make that assessment available to interested parties.

Having studied the EA of the Sea Launch proposal, SPREP has identified several concerns:

There is very little time for comment or for consultation with SPREP’s member countries. Sea Launch customers announced in 1995 (Hughes Aircraft Co.; San Jose Mercury News December 19, 1995) and 1996 (Space Systems/Loral July 15, 1996) that the first Sea Launch liftoff was scheduled for the second half of 1998, yet the Government of Kiribati and SPREP were not informed of the proposal until April 1998.

The draft EA arrived at SPREP on April 30, 1998. Detailed comments are due to arrive by post in the office of the Associate Administrator for Commercial Space Transportation no later than May 26, 1998.

The short time-frame between delivery of the EA and the deadline for comments permits only minimal consultation between SPREP and its member countries.

The Pacific view of developments within the region as reflected by South Pacific Forum decisions is that the region should not be used as a dumping ground for other countries’ wastes.

The Forum has in the past opposed the use of the Pacific environment for potentially harmful actions of other nations such as nuclear testing and the movement of nuclear, and hazardous wastes through the Pacific, and has called on other nations to respect the wishes of its people.

There are potential human safety concerns. The EA notes the Kiribati practice of fishing for ocean fish stocks to provide for nutritional needs. However, while there are plans to warn shipping of launch times, there is no mention of plans to warn Kiribati fishing boats of falling debris or potential kerosene slicks.

The EA fails to provide adequate detail in a number of areas including potential impacts on rare and endangered species, marine mammals and migratory birds. It does not provide detail of the biological environment of the launch sites or the potential debris deposition areas.

The EA provides no details of contingency plans in case of accidental or catastrophic release of pollutants. There is no indication that an Environmental Management System has been developed for the proposal.

Neither is there an indication of whether any independent authority has a compliance role or a role in monitoring the implementation of the proposal. There is no provision for a Marine Pollution Contingency Plan or an Environmental Monitoring Programme.

While the EA holds out the prospect of significant socioeconomic benefits for the community of Long Beach California which would become the project’s home base, there are no socioeconomic benefits for the Pacific in general and Kiribati in particular. Instead, there may be significant environmental and human safety disadvantages which cannot be quantified because the EA does not contain adequate detail.

The proposal to license a launch from an offshore facility in international waters is acknowledged to be without precedent (Section 1.3.3). Yet despite the unusual nature of the proposal the Precautionary Principle has not been followed. On the contrary, in the absence of data it has been concluded that environmental values at the launch site and spent rocket stage disposal sites are low and impacts are likely to be negligible.


The information supplied in the Sea Launch Environmental Assessment of the impacts of the SLLP proposal on the environment is, in the opinion of SPREP, insufficient to permit a Finding of No Significant Impact (FONSI) to be issued.

SPREP would recommend that the proponents be directed to carry out a full and comprehensive Environmental Impact Statement (EIS). This should encompass an Environmental Impact Assessment using the framework of the International Standards Organisation (ISO) 14000 Series Standard Environmental Management System.

SPREP has raised a number of concerns about the Environmental Assessment and today’s meeting is being held to discuss those concerns. SPREP will then report back to its member countries and the South Pacific Forum.

For further information contact Fatu Tauafiafi or Jan Sinclair at SPREP.

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