Bridging Systemic Gaps in Environmental Assessments for U.S. Commercial Rocket Launches

Introduction

In recent years, we have seen rapid growth in the scale and ambitions of the burgeoning space industry, with the number of rocket launches in the U.S. increasing exponentially from around 30 launches in 2019 to over 100 launches by 2023^[1]. Under the National Environmental Policy Act (NEPA), the Federal Aviation Administration (FAA) conducts environmental reviews of all rocket launches to assess the degree of negative environmental impacts they pose. In 2025 and 2026, the FAA completed numerous environmental assessments (EAs) and environmental impact statements (EIS)^[2] covering increased SpaceX operations at Vandenberg Space Force Base^[3], Boca Chica^[4], Cape Canaveral^[5], and the Kennedy Space Center^[6] and several smaller programs with Inversion Space and Varda Space Industries. Collectively, these assessments grant authorization for over one hundred launches per year. The assessments conducted by the FAA provide thorough analyses of localized, ground-level impacts including air quality, water quality, protected species, coastal zones, hazardous materials, noise, and cultural resources, among others. However, while the localized effects are thoroughly assessed, they fail to account for broader, global scope impacts and longer-term, cumulative impacts. Specifically, the EAs do not evaluate the effects of rocket emissions in the stratosphere, the effects of end-of-life deorbiting of their payloads, and the cumulative global impact of these effects, especially as the cadence of rocket launches is set to continue increasing. The omission of these factors and the risks they carry make the FAA’s environmental assessments for U.S. commercial rocket launches structurally inadequate, and require reforms through expanded analytical scope, interagency coordination, and the development of a national programmatic review framework.

Stratospheric Rocket Emissions

The existing framework for FAA EAs evaluates impacts on air quality by comparing a project’s emissions against the National Ambient Air Quality Standards (NAAQS) set by the Environmental Protection Agency^[7] and the most recent assessments have found the emissions of the covered launches to be under the threshold of these standards. However, these studies do not account for the full atmospheric scope of rocket emissions and the unique behavior of those emissions within the upper atmosphere. The physical boundary of any individual assessment is at the discretion of the FAA, but none of the recent assessments extend their analysis to the stratosphere, the layer in which the ozone layer resides. Researchers have estimated that around two thirds of total rocket emissions are deposited above 15 kilometers^[8] and as such are entirely omitted from assessments. Additionally, while rocket emissions byproducts are removed by natural atmospheric processes in the troposphere, the environmental characteristics of the stratosphere mean that the same emission byproducts can be longer-lived. This means that even smaller concentrations of ozone-depleting byproducts like nitrogen oxides, hydrogen chloride, and black carbon can have a greater destructive effect. Research in 2025 quantified the magnitude of this effect, determining that in a conservative scenario of 884 launches globally per year, the ozone layer’s regrowth rate of 0.3% per decade will be reduced by more than half, and that in an ambitious scenario of 2,040 launches globally per year, the regrowth rate is almost entirely offset, preventing the ozone layer from repairing^[9].

In addition to the ozone depleting effects, rocket emissions in the stratosphere could significantly contribute to climate change by amplifying the greenhouse effect. A 2022 study found that due to the longer residence time and greater absorptive efficiency of soot in the stratosphere, black carbon emitted by rockets is approximately 500 times more efficient at heating the atmosphere than black carbon emitted by surface and aviation sources^[10]. Compared against aviation, the radiative forcing of rocket black carbon is 8 times greater than that of all commercial aviation, and despite rockets contributing only about 0.01% of global black carbon emissions, they account for roughly 3.2% of the global total black carbon radiative forcing.

The FAA's methodology of benchmarking rocket emissions against national inventories and omission of stratospheric emissions fails to capture the impact of stratospheric emissions on ozone depletion and the amplification of global warming.

Satellite Deorbiting and Atmospheric Metal Pollution

Whereas FAA EAs have limitations on analyzing the full scope of rocket emissions, the eventual atmospheric disposal of the payloads they deliver falls entirely outside the scope of the assessments. When the operational lifespan of a satellite ends, regulations require the eventual disposal of the defunct satellite through deorbiting^[11]. In standard deorbiting methods, the satellite is designed to burn up as it enters the atmosphere in order to minimize both orbital debris accumulation and potential casualty risk from falling objects. However, as these satellites burn up they are vaporized into aerosols of metallic particles that accumulate within the stratosphere. A NASA study in 2024^[12] states that the deorbiting of a standard 250kg satellite generates around 30kg of aluminum oxide nanoparticles, which could potentially endure in the atmosphere for decades. This poses a significant environmental risk as aluminum oxides catalyze chemical reactions that destroy stratospheric ozone. The exponential growth in the number of satellites scheduled to be sent into orbit makes this environmental effect a rapidly significant concern. Companies like SpaceX and Amazon are seeking to launch over 50,000 new satellites within the next few years that will eventually burn up in the atmosphere as their operational lifespans end. This risk is not just a future concern as analyses of the natural stratospheric sulfate layer have found that metals from deorbited satellites make up 10% of the particles in the layer.

At present, there are no federal agencies that conduct environmental reviews of this impact. Assessments by the FAA evaluate the impact from launches, but not the payloads they carry. The Federal Communications Commission (FCC) licenses satellite operations, but does not evaluate the impact of their disposal.  A review by the Government Accountability Office has called for the FCC to update its environmental review policies to account for this gap in evaluation^[13].

Contrary to this, the FCC put forth a proposal last year to have satellites excluded from NEPA review entirely on the grounds that they constitute extraterritorial activities^[14].

Limited Cumulative Assessment

FAA assessments do include a degree of cumulative evaluation, conducting tiered reviews for multiple launches by a single operator at a single site as well as overlap of localized impacts from launches at nearby launch sites. However, this does not reflect the impacts that launches have on a global scale and does not take into account the full cumulative impacts of a rapidly growing space industry, both on Earth and in the upper atmosphere. The recently issued FAA Order 1050.1G^[7] will reinforce rather than resolve this problem. Made effective July 3, 2025, the new order narrows the required scope of analysis, excluding climate and environmental justice as required subjects^[15]. The order directs the FAA to focus on the effects of the "action or project at hand" and to draw a "reasonable and manageable line" around effects that are geographically or chronologically remote. It also imposes page limits of 75 pages for EAs and 150 pages for EISs, and time limits of one and two years respectively. These reforms are designed to streamline reviews and reduce regulatory delay, but they also formalize the site-specific, single-program scoping approach that makes cumulative atmospheric assessment structurally difficult.

Recommendations

Given the potential of an increased frequency of rocket launches to cause significant environmental harm on a global scale, regulations should be adapted to account for the full scope of their effects. There are several policy reforms that can be adopted to help bridge the gaps that have been identified.

1. Add stratospheric impact categories to FAA significance thresholds

Appendix A of Order 1050.1G defines the significance thresholds governing the content of each EA, with air quality thresholds currently referencing only ground-level NAAQS compliance. Without a defined threshold, even an operator aware of stratospheric impacts has no regulatory basis to include them in a review and no standard against which to measure significance. The addition of thresholds for stratospheric ozone depletion potential and upper-atmosphere radiative forcing would establish an analytical requirement where none currently exists. 

2. Close the deorbiting regulatory gap

Currently, the atmospheric impact of deorbiting satellites is not regulated by either the FCC or the FAA. There are reforms both agencies could take that would close this gap. The FCC could reverse their proposal to exclude satellites from NEPA review and instead expand coverage to address end-of-life disposal impacts. The FAA could reinitiate its withdrawn rulemaking proposal to require operators to submit an Orbital Debris Assessment Plan before each launch^[16] and expand the plan to include analysis of stratospheric metal deposition and ozone chemistry effects. This would allow it to integrate deorbiting impacts into an existing process without creating a new review mechanism. Alternatively, Congress could designate a lead agency for upper-atmosphere environmental review, eliminating the jurisdictional ambiguity that allows both agencies to defer to the other.

3.  Develop a national programmatic EIS for the U.S. commercial launch industry

A programmatic EIS is a NEPA document that evaluates the environmental impacts of a broad federal action, such as a policy, plan, or program, at a high, strategic level across a larger area or region^[17]. These impact statements serve to establish a cumulative baseline against which individual project-level assessments can tier. This type of assessment is already used by departments such as the Bureau of Ocean Energy Management which prepares programmatic EISs for regions like the Gulf of Mexico and the coast of California before issuing offshore energy licenses in those areas^[18]. A national-level programmatic EIS for U.S. rocket launches would provide a unified, strategic assessment of the rapidly expanding commercial launch sector, allowing federal agencies to evaluate cumulative impacts across all major launch sites, vehicle types, and mission profiles rather than addressing them piecemeal through project-specific reviews. By analyzing shared issues such as stratospheric emissions and ozone depletion at a national scale, it would establish a consistent analytical baseline and reduce fragmentation across FAA licensing decisions. This approach would improve transparency and comparability across projects, ensure that cumulative effects of increasing launch cadence are more fully captured, and allow subsequent site-specific reviews to tier off a comprehensive framework, making them more efficient while still addressing localized and globalized impacts.

4. Establish adaptive management triggers

Current approval documents establish mitigation conditions at the time of the Finding of No Significant Impact (FONSI), and each subsequent cadence increase is evaluated through a new, narrowly scoped tiered EA. Incorporating monitoring thresholds into approval documents, not just for atmospheric factors, but for all longer-term impacts, would introduce a feedback mechanism that the current process lacks. For atmospheric factors the monitoring infrastructure is already in place since stratospheric composition is tracked by NOAA and NASA through the Global Monitoring Laboratory^[19] and the Aura satellite mission^[20]. By setting monitoring thresholds and incorporating monitoring data into EAs, we can ensure that they are able to respond to environmental conditions as they develop, rather than relying exclusively on forward-looking projections.

5. Mandate emissions and materials data disclosure

Scarcity of reliable emissions data stands as a significant barrier to modeling launch impacts. Plume measurements remain limited, and most current estimates depend on combustion calculations rather than direct observation. Requiring launch operators to report exhaust composition as a condition of Part 450^[21] licensing would address this deficiency. Satellite operators should similarly be required to disclose materials composition relevant to atmospheric ablation during deorbiting. The structure for this type of reporting can be modeled on the EPA's Toxics Release Inventory^[22], which requires industrial facilities to publicly report releases of specified chemicals.

Conclusion

The current framework for EAs of U.S. commercial rocket launches is increasingly misaligned with the scale, frequency, and complexity of modern space activity. While the FAA’s reviews provide rigorous analysis of localized impacts, their constrained physical and temporal scope leaves critical global and cumulative effects largely unexamined. As launch cadence accelerates and satellite constellations expand, these omissions represent not marginal oversights but systemic gaps with potentially significant consequences for atmospheric chemistry and climate. To bridge these gaps, the NEPA process needs to adapt through targeted reforms, including new analytical thresholds, interagency alignment, and the development of a national programmatic framework. By doing so, regulators can ensure that environmental oversight evolves in parallel with the industry it governs, maintaining both the integrity of environmental protections and the long-term sustainability of the space sector.

Citations

1. O’Connor, M., and K. Curlee. “Shaping the U.S. Space Launch Market.” Center for Security and Emerging Technology, Feb. 2025, cset.georgetown.edu/publication/shaping-the-u-s-space-launch-market/.

2. Federal Aviation Administration. “NEPA Documents.” FAA, www.faa.gov/space/environmental/nepa_docs.

3. Federal Aviation Administration. “Adoption of the Environmental Assessment and Finding of No Significant Impact and Record of Decision for Falcon 9 Cadence Increase at Vandenberg Space Force Base, California.” Office of Commercial Space Transportation, 25 Mar. 2025, drs.faa.gov/browse/excelExternalWindow/DRSDOCID105024331020250325145908.0001.

4. Federal Aviation Administration. “Final Tiered Environmental Assessment for SpaceX Starship/Super Heavy Vehicle Increased Cadence at the SpaceX Boca Chica Launch Site in Cameron County, Texas.” Office of Commercial Space Transportation, Apr. 2025.

5. Federal Aviation Administration. “Final Environmental Assessment SpaceX Falcon 9 Operations at Space Launch Complex 40, Cape Canaveral Space Force Station, Florida.” Office of Commercial Space Transportation, 22 Aug. 2025, drs.faa.gov/browse/excelExternalWindow/DRSDOCID185224271820250829152818.0001.

6. Federal Aviation Administration. “SpaceX Starship-Super Heavy Project at Kennedy Space Center Launch Complex 39A.” Office of Commercial Space Transportation, Jan. 2026, www.faa.gov/space/stakeholder_engagement/spacex_starship_ksc.

7. Federal Aviation Administration. “FAA National Environmental Policy Act Implementing Procedures: Order 1050.1G.” FAA, 30 June 2025.

8. Revell, Laura, et al. “Envisioning a Sustainable Future for Space Launches: A Review of Current Research and Policy.” Journal of the Royal Society of New Zealand, 2 Feb. 2023, pmc.ncbi.nlm.nih.gov/articles/PMC11459831/.

9. Revell, Laura, et al. “Near-Future Rocket Launches Could Slow Ozone Recovery.” npj Climate and Atmospheric Science, 9 June 2025, www.nature.com/articles/s41612-025-01098-6.

10. Ryan, Robert, et al. “Impact of Rocket Launch and Space Debris Air Pollutant Emissions on Stratospheric Ozone and Global Climate.” Earth’s Future, 9 June 2022, agupubs.onlinelibrary.wiley.com/doi/10.1029/2021EF002612.

11. National Aeronautics and Space Administration. “13.0 Deorbit Systems.” NASA, 14 Feb. 2025, www.nasa.gov/smallsat-institute/sst-soa/deorbit-systems/.

12. Sharma, S. “Impact of Spaceflight on Earth’s Atmosphere: Climate, Ozone, and the Upper Atmosphere.” NASA, Technical Memorandum TM-20240013276, Oct. 2024.

13. Government Accountability Office. “FCC Should Reexamine Its Environmental Review Process for Large Constellations of Satellites.” GAO, GAO-23-105005, Nov. 2022.

14. Federal Communications Commission. “Modernizing the Commission’s National Environmental Policy Act Rules.” FCC, 17 July 2025.

15. Auslander, J., et al. “FAA Revamps Its NEPA Procedures.” Beveridge & Diamond, 15 July 2025, www.bdlaw.com/publications/faa-revamps-its-nepa-procedures/.

16. Federal Aviation Administration. “Mitigation Methods for Launch Vehicle Upper Stages on the Creation of Orbital Debris; Withdrawal.” Federal Register, 15 Jan. 2026, www.federalregister.gov/documents/2026/01/15/2026-00680/mitigation-methods-for-launch-vehicle-upper-stages-on-the-creation-of-orbital-debris-withdrawal.

17. Boots, Mark. “Effective Use of Programmatic NEPA Reviews.” Council on Environmental Quality, Executive Office of the President, 18 Dec. 2014.

18. Bureau of Ocean Energy Management. “What Is the Environmental Impact Statement (EIS) Process?” BOEM, www.boem.gov/environment/environmental-assessment/what-environmental-impact-statement-eis-process.

19. National Oceanic and Atmospheric Administration. “Global Monitoring Laboratory.” NOAA, gml.noaa.gov/.

20. National Aeronautics and Space Administration. “Aura Mission.” NASA, science.nasa.gov/mission/aura/.

21. Lindbergh, R. “Commercial Space Launch and Reentry Regulations: Overview and Select Issues.” Congressional Research Service, 23 June 2025.

U.S. Environmental Protection Agency. “Toxics Release Inventory (TRI) Program.” EPA, www.epa.gov/toxics-release-inventory-tri-program.