1

[4910-13] 

Department of Transportation 

Federal Aviation Administration 

Finding of No Significant Impact 

AGENCY: Federal Aviation Administration (FAA), Department of Transportation (DOT) 

 

ACTION: Finding of No Significant Impact 

SUMMARY: The Federal Aviation Administration (FAA) prepared an Environmental 

Assessment (EA) to evaluate the issuance of experimental permits to applicants seeking to 

participate in the Vertical Rocket Challenge and the Lunar Lander Challenge at the X Prize Cup 

during October 2006 and to approve revisions of the Airport Layout Plan at the Las Cruces 

International Airport in New Mexico. The EA, which is hereby incorporated by reference, 

evaluated the potential environmental impacts associated with the proposed action and the 

alternatives to make an informed decision on whether to issue experimental permits and approve 

the Airport Layout Plan modifications. The scope of the proposed action is defined by activities 

associated with the issuance of the experimental permits, specifically the Vertical Rocket 

Challenge and the Lunar Lander Challenge suborbital launch activities regulated by the FAA 

under Title 49, United States Code (U.S.C.), Subtitle IX, Sections 70101-70121, as well as the 

activities associated with the approval of any revisions to the Airport Layout Plan that are 

required to support the X Prize Cup activities. After reviewing and analyzing currently available 

data and information on existing conditions, project impacts, and measures to mitigate those 

impacts, the FAA has determined that issuing experimental permits to the applicants seeking to 

participate in the Vertical Rocket Challenge and the Lunar Lander Challenge at the X Prize Cup 

and approval of the Airport Layout Plan modifications at the Las Cruces International Airport in 

New Mexico would not significantly affect the quality of the human environment within the 

meaning of the National Environmental Policy Act. Therefore, the preparation of an 

Environmental Impact Statement (EIS) is not required, and the FAA is issuing a Finding of No 

Significant Impact (FONSI). The FAA made this determination in accordance with all 

applicable environmental laws. 

FOR A COPY OF THE ENVIRONMENTAL ASSESSMENT: Visit the following internet 

address: http://ast.faa.gov/lrra/comp_coop.htm, or contact Ms. Stacey M. Zee, FAA 

Environmental Specialist, 800 Independence Avenue SW, Room 331, Washington, D.C. 20591. 

You may also send e-mail requests to stacey.zee@faa.gov or telephone (202) 267-9305. 

DATES: The Draft EA was released for public review and comment on August 14, 2006. All 

comments received by September 14, 2006 were considered in the preparation of the Final EA. 

PURPOSE AND NEED: The purpose of the proposed action is to issue experimental permits 

for the operation of reusable suborbital rockets in accordance with FAA’s commercial space 

transportation regulations (Title 49, U.S.C., Subtitle IX, Sections 70101-70121) and to approve 

any revisions to the Airport Layout Plan that are required to support the X Prize Cup activities. 
2

The purpose of the proposed action is to ensure safe and responsible operation of the reusable 

suborbital rockets for applicants seeking to participate in the X Prize Cup Vertical Rocket 

Challenge and the Lunar Lander Challenge and to implement the proposed revisions to the 

Airport Layout Plan in a manner consistent with the safe and efficient operation of the airport. 

The need for the proposed action is to ensure safe commercial and general aviation activities and 

to accelerate the technology developments supporting the commercial creation of a vehicle 

capable of ferrying cargo or humans back and forth between lunar orbit and the lunar surface. 

Such a vehicle would have direct application to the personal spaceflight industry as well as the 

technology development goals of the Defense Advanced Research Projects Agency and the 

National Aeronautics and Space Administration (NASA). In addition, the need supports 

NASA’s mission as directed by the President to return Americans to the moon by 2020 and to 

use the mission as a steppingstone for future manned trips to Mars and beyond. 

PROPOSED ACTION: Under the proposed action, the FAA would issue experimental permits 

to applicants proposing to participate in the Vertical Rocket Challenge and the Lunar Lander 

Challenge, which would authorize the launch of the applicants’ reusable suborbital rockets from 

the Las Cruces International Airport, New Mexico. An experimental permit is valid for one year 

and authorizes an applicant to conduct an unlimited number of suborbital launches from a 

specific location. However, the suborbital launches reviewed in this EA are associated with the 

Vertical Rocket Challenge and the Lunar Lander Challenge events at the X Prize Cup, and the 

Las Cruces International Airport would only allow the permitted applicants to test and launch 

their suborbital rockets for a period of one week prior to and during the X Prize Cup. Under the 

proposed action, the FAA may issue up to five experimental permits for 10 vehicles. Each 

applicant would bring two identical vehicles to compete in both the Vertical Rocket Challenge 

and the Lunar Lander Challenge events. 

Each of the proposed reusable suborbital rockets would be wingless and generally cylindrical in 

shape with a height from 2 to 6 meters (6.5 to 20 feet) and a diameter from 0.4 to 2.9 meters (16 

inches to 9 feet). The suborbital rockets would consist of a single stage rocket with liquid 

propellants and would use inert gases such as helium or nitrogen to provide overpressure for the 

propellants. The fuel and oxidizer combinations associated with the experimental permit 

applications that FAA has received were used to define the range of propellants that may be used 

in the Vertical Rocket Challenge and the Lunar Lander Challenge. As part of the proposed 

action, the FAA also would approve revisions to the Airport Layout Plan that would be required 

to support the X Prize Cup activities. 

Up to nine new launch and landing pads, a new propellant staging pad, and three new access 

roads would be required to support launches of reusable suborbital rockets competing in the 

Vertical Rocket Challenge and the Lunar Lander Challenge. Up to three separate operating areas 

with three pads each would be constructed. Two of the pads in each operating area would be flat 

and featureless for the Vertical Rocket Challenge, and one pad in each area would be a 

simulation of the lunar surface. All of the launch and landing pads would measure 10 meters (33 

feet) in diameter and be circular or octagonal in shape, and the propellant staging pad would 

measure 10 meters (33 feet) by 10 meters (33 feet). All of the new pads would be coated with 

heat-resistant gunnite, which is a mixture of cement, sand, and water. The surface of the pads 
3

would be at or below the level of the runways. The existing concrete pad located south of the 

cross-runways would be used for static test firing. A temporary operation shelter (i.e., a steel 

shipping container) and a 5-kilowatt generator would be located with each set of launch and 

landing pads for a total of three shelters and generators. The generators would operate for up to 

10 hours total during the Vertical Rocket Challenge and the Lunar Lander Challenge. In 

addition, the existing X-Racer propellant loading pad would be expanded from 37 square meters 

(400 square feet) to 149 square meters (1,600 square feet). 

The access roads to each set of the launch and landing pads would be graded gravel roads 

approximately 6 meters (20 feet) wide. The access roads would lead from an existing road to 

each set of three launch and landing pads and would be constructed at the same time as the pads. 

A total of 3,941 square meters (42,380 square feet) of new access roads would be constructed. 

To reduce fire hazard from engine exhaust, a 5-meter (16-foot) area would be cleared around 

each proposed launch and landing pad, and a 20-meter (66-foot) wide corridor would be cleared 

between each set of three launch and landing pads. The pads would be spaced 100 meters (328 

feet) apart for a total area of 4,400 square meters (47,652 square feet). Brush and other 

vegetation would be cleared from this area, and the area would be covered with light paving 

(runway millings) to reduce the fire hazard and the amount of dust generated by high velocity 

rocket engine exhaust. 

ALTERNATIVES CONSIDERED: Alternatives analyzed in the EA include (1) the proposed 

action and (2) the no action alternative. Under the no action alternative, the FAA would not 

issue any experimental permits to the applicants seeking to participate in the Vertical Rocket 

Challenge and the Lunar Lander Challenge and would not approve the revised Airport Layout 

Plan; therefore, there would be no launches of reusable suborbital rockets from the Las Cruces 

International Airport and no construction activities. The nine launch and landing pads, the 

propellant staging pad, and the access roads associated with the Vertical Rocket Challenge and 

the Lunar Lander Challenge would not be constructed, and the expansion of the X-Racer 

propellant loading pad would not occur. Because the FAA would not issue experimental 

permits, the Vertical Rocket Challenge and the Lunar Lander Challenge event would not take 

place; however, all the remaining X Prize Cup events would occur. This would include the 

flights of the X-Racer; however, propellant loading would have to be performed from the 

existing pad.

ENVIRONMENTAL IMPACTS 

Air Quality 

Less than 5 tons (10,000 pounds) combined of particulate matter with a diameter less than 10 

microns (PM10), particulate matter with a diameter of less than 2.5 microns (PM2.5), and fugitive 

dust would be emitted during construction. The operation of the construction equipment would 

emit carbon monoxide (CO), PM10, nitrogen oxides (NOx), volatile organic compounds (VOCs), 

and sulfur oxides (SOx), with PM10 and NOx comprising the majority of the emissions. Because 

of the short construction period (two weeks) and limited number of construction vehicles 

involved in construction (i.e., excavator, grader, dump trucks, and concrete trucks), the emissions 
4

from the operation of such vehicles would be negligible. In addition, the proposed action would 

meet the Best Available Control Measures and erosion ordinances outlined in Doña Ana 

County’s Natural Events Action Plan. 

Because all of the CO would be oxidized to CO2, no NAAQS pollutants would be emitted by the 

reusable suborbital rockets. In addition, no hazardous air pollutants would be emitted by the 

reusable suborbital rockets. The water vapor and CO2 that would be emitted would disperse into 

the atmosphere and would have no impact on air quality. The three 5-kilowatt generators that 

would be operating at each control shelter would emit CO, PM10, NOx, VOCs, and SOx, with 

PM10 and NOx comprising the majority of the emissions. The emissions associated with the 

generators would result in a negligible impact on air quality. The minimal emissions of the haze 

related pollutants associated with the proposed action (i.e., PM10 and PM2.5) would have a 

negligible direct and indirect impact on the visibility at the designated Class I areas under the 

regional haze rule (64 Fed. Reg. 35714, July 1, 1999). 

Biological Resources – Fish, Wildlife, and Plants 

Up to 17,353 square meters (187,624 square feet) of previously disturbed desert scrub within the 

fenced-in boundary of the Las Cruces International Airport would be cleared for the purposes of 

the proposed action. The proposed action would have a negligible impact on the surrounding 

vegetation and wildlife. The vegetation has been subject to ongoing human disturbance 

associated with the active airport. The launch and landing pads would be covered with an 

impervious surface devoid of vegetation, and the area immediately surrounding the launch and 

landing pads, as well as the area between the launch and landing pads, would be cleared of 

vegetation. The wildlife species that exist are tolerant of the disturbances (e.g., noise, aircraft, 

and vehicular movements) and would avoid active construction areas. Adverse effects on birds 

protected under the Migratory Bird Treaty Act would not be likely to occur. No known state or 

federally listed threatened or endangered species would be impacted by the proposed action. The 

area affected by the proposed action would not affect suitable habitat or designated critical 

habitat for any federally listed threatened or endangered species. 

Cultural Resources (including Historical, Architectural, and Archeological Resources) 

The ground-disturbing activities associated with the proposed action would occur within the 

fenced boundary of the Las Cruces International Airport. The locations of all the grounddisturbing activities were surveyed for cultural and historic resources in accordance with the 

requirements of Section 106 of the National Historic Preservation Act and the New Mexico 

Historic Preservation Division. No cultural or historic resources or properties were identified 

during the survey, and the State Historic Preservation Office (SHPO) concurred that there would 

be no adverse effects to properties listed or eligible for listing on the National Register of 

Historic Properties or other cultural resources. In the unlikely event that human remains are 

encountered during site construction activities (excavation), the X Prize Foundation would stop 

construction activities in the area and notify the FAA and the SHPO. The FAA would comply 

with the Native American Graves Protection and Repatriation Act regulations and the National 

Historic Preservation Act as required. 
5

Should the scope of the X Prize Cup change and require additional construction activities, the X 

Prize Foundation would complete additional cultural surveys and submit its findings to the FAA. 

FAA would consult with SHPO and the Ysleta del Sur Pueblo Tribal Council and obtain 

concurrence on the findings prior to approving a revised airport layout plan, which would 

authorize construction. 

Geology and Soils 

The proposed launch, landing, and propellant staging pads would not be anchored into the 

bedrock; therefore geology would not be impacted. The short-term impacts of pad construction 

would include the potential for increased erosion during construction, while the long-term soil 

impacts would include compaction and mixing of soil horizons. The short- and long-term 

impacts on soil from construction would be negligible. Best Management Practices as promoted 

by the New Mexico Water Quality Control Commission would be followed (e.g., the use of silt 

fences, check dams, and earthen dikes) to reduce sedimentation of surface waters and reduce soil 

erosion. Potential propellant spills and releases represent potential impacts on soils in the form 

of soil contamination. Because all spills and releases would be small based on the capacity of 

the reusable suborbital rockets, and such spills and releases would be immediately contained, 

removed, and remediated by trained personnel, resulting impacts would be considered negligible.

Hazardous Materials and Hazardous Waste Management (including Solid Waste, Pollution 

Prevention, and Natural Resources Energy Supply) 

During pre-flight activities, minor amounts of other hazardous materials, such as oils, lubricants, 

and solvents, would be used to prepare the rockets for flight. All hazardous materials would be 

handled, stored, and used in compliance with all applicable regulations. Hazardous materials 

that would be used under the proposed action are similar to materials already handled at the 

airport. The transport, use, or disposal of hazardous materials associated with operations under 

the proposed action would not pose a substantial hazard to the public or the environment. Fuels 

and oxidizers would be stored in separate, secured containers in covered airport hangers. During 

the Vertical Rocket Challenge and Lunar Lander Challenge events, applicant-specific propellant 

trucks would leave the storage area and proceed to the launch/landing pad area and remain there 

(at a safe distance) and would return to the storage area after the applicant completes the event. 

If there were a spill, the applicant’s personnel would be responsible for any necessary 

containment, removal, and remediation. In addition, emergency response and the local fire 

department would be on standby during the X Prize Cup to respond to accidents or fires. 

Applicants would be required to comply with pollution prevention plans and practices in effect at 

the airport. The use of natural resources and energy associated with the proposed action would 

have no impact on energy demands or other natural resource consumption. 

Health and Safety 

Implementation of the proposed action would result in a negligible impact on health and safety. 

All transport of hazardous materials, including fuels and oxidizers, would be in Department of 

Transportation (DOT) approved packages and containers, and such shipments would meet all 
6

applicable and relevant DOT Hazardous Material Regulations (49 CFR Parts 171 to 177). 

Trained ground crew personnel would follow established standard operating procedures during 

fueling operations in accordance with all applicable safety regulations. Spills of hazardous 

materials would be handled by trained ground crew personnel. An emergency response team 

would be available should it be necessary during a release or spill incident. The location of the 

public spectator area would be located more than 1 kilometer (3,281 feet) from the nearest 

launch and landing pads and would be the safety zone designated to contain the effects of a 

failed operation. Each reusable suborbital rocket would have an autonomous and humancontrolled termination system that would be activated should the vehicle leave the designated 

operational area, preventing any errant suborbital rockets, debris, or failed operations from 

reaching the spectator area. In addition, the vehicle operators would be located in a portable 

steel shelter (safety bunker) located near each set of launch and landing pads. Emergency 

response and the local fire department would be on standby during each launch to respond to 

accidents or fires. 

Land Use (including Department of Transportation 4(f) Resources and Farmlands) 

The proposed action would have no effect on the existing land use at the airport or surrounding 

the airport. Implementation of the proposed action would not require the use or alteration of any 

land protected under Section 4(f) of the DOT Act or under the Farmland Protection Policy Act, 

which was confirmed by the U.S. Department of Agriculture Natural Resources Conservation 

Service with their determination that no prime or unique farmland exists at the Las Cruces 

International Airport. 

Noise and Compatible Land Use 

The operation of the rocket engines would result in short-term increases in the level of noise at 

the Las Cruces International Airport above the peak levels associated with the fixed- and rotarywing aircraft stationed at the airport. Other than the spectators and the airport employees, there 

are no sensitive noise receptors near the airport. Because the location of the launch and landing 

pads would be more than 1 kilometer (3,281 feet) away from the spectators and administrative 

area of the Las Cruces International Airport, and the rocket engines would only operate for brief 

periods of time (up to 4 minutes), the elevated noise levels would not be expected to adversely 

affect spectators or employees. The proposed action would not result in an increase in noise in 

excess of the applicable thresholds of significance for noise or land use compatibility. 

Socioeconomic Impacts, Environmental Justice, and Children’s Environmental Health and 

Safety Risks (including Secondary (Induced) Impacts) 

The proposed action would create an influx of no more than 25,000 people for the entire two-day 

X Prize Cup, with no more than 13,000 people per day in attendance. Approximately 230 

employees would be required to host the X Prize Cup, and approximately 250 exhibitors would 

attend the event. Doña Ana County would experience positive impacts on socioeconomics. The 

additional services provided to the spectators and personnel would provide a temporary benefit 

to the local economy because of the increase in the amount of business conducted by the service 

industry, such as hotels, restaurants, and gas stations. The temporary increase in the local 
7

population would not exceed the service capacity of the region in terms of lodging or services 

(i.e., public utilities or emergency care). Because Doña Ana County has a zoning ordinance that 

restricts residential development within a 4-kilometer (2.5-mile) radius of the Las Cruces 

International Airport, there would be no adverse impacts on socioeconomics, environmental 

justice populations, or on children’s health and safety by the proposed action. Because the 

proposed action does not involve major development, it would not involve the potential for 

induced or secondary impacts on surrounding communities. 

Transportation 

Under the proposed action, the influx of up to 13,000 spectators would result in increases in 

traffic congestion on the local roadways around the Las Cruces International Airport; however, 

there would be no notable travel delays associated with travel on the Interstate Highways I-10 

and I-15. The range of average daily traffic on the Interstates (5,000 to 18,000 passenger cars 

and trucks per day) and the increase in traffic associated with the spectators may result in a 

change in interstate level of service from level A to level B, which is a change from a free flow 

condition where individual users are unaffected by the presence of others in the traffic stream to 

a stable traffic stream where individual users begin to notice others. Such a change would be a 

negligible change in the traffic flow on I-10. 

Visual Resources (including Light Emissions and Visual Impacts) 

Implementation of the proposed action would result in no change to the visual resources 

associated with the Las Cruces International Airport. The reusable suborbital launch vehicles 

would remain within 200 meters (656 feet) of the ground, would be similar in size to fixed-wing 

and rotary-wing aircraft that operate out of the airport, and any emission clouds would disperse 

within a short period of time.

Water Resources (including Water Quality, Coastal Resources, Wild and Scenic Rivers, 

Wetlands, and Floodplains) 

Implementation of the proposed action would have no impact on water resources. No streams, 

wetlands, or floodplains are located within the proposed operational area of the reusable 

suborbital rockets, which includes the location of all the proposed launch and landing pads. In 

addition, existing municipal water supply sources would be used for all the X Prize Cup 

activities.

Cumulative Impacts 

Cumulative impacts are “the incremental impact of the actions when added to other past, present, 

and reasonably foreseeable future action regardless of what agency (Federal or non-Federal) or 

person undertakes such other actions.” (40 CFR 1508.7) For this analysis, cumulative impacts 

include impacts from the permitted vehicles and the past, present, and reasonably foreseeable 

future activities that would affect the resources impacted by the events at the Las Cruces 

International Airport. Activities analyzed include the X-Racer flying up to four times per day 

during the two-day X Prize Cup; up to 12 launches of six amateur rockets; up to six rocket 
8

engines being fired at the existing static rocket engine test pad; up to 1,000 model rockets 

launches; the operation of a rocket truck (a pick-up truck with a 2,000 pound-thrust hybrid rocket 

engine mounted on the bed of the truck); the Elevator Games; and the use of additional parking 

areas. The FAA found that the proposed action would have a less than significant impact on air 

quality, biological resources, health and safety, and land use. For the other resource areas, the 

impacts were found to be negligible or non-existent and would not result in a cumulative impact 

when assessed with other past, present, and reasonably foreseeable future activities. 

Air Quality – Cumulative Impacts 

In addition to the air quality impacts discussed under the proposed action, the other X Prize Cup 

activities would result in emissions of criteria air pollutants, hazardous air pollutants (air toxics), 

and air pollutants regulated by New Mexico. The X-Racer rocket engine operation, the operation 

of rocket motors with solid propellant (the amateur rockets), the static firing of rocket engines, 

the operation of the rocket powered truck, and up to 1,000 launches of model rockets would emit 

water, CO2, and criteria pollutants (CO, PM10, PM2.5, NOx, and SOx). In addition, the operation 

of the amateur rockets would result in emissions of hydrogen chloride and aluminum oxide. 

Hydrogen chloride is a hazardous air pollutant regulated by the U.S. Environmental Protection 

Agency (EPA), and aluminum oxide is a toxic air pollutant regulated by New Mexico per 

20.2.72 New Mexico Administrative Code Section 402.B. 

The cumulative total emissions of any individual criteria pollutant (i.e., CO, PM10, NOx, VOCs, 

and SOx) would be less than 2 tons (4,000 pounds), which would readily disperse, resulting in a 

negligible cumulative impact on regional air quality. Because the emissions of aluminum oxide 

and hydrogen chloride would be from the amateur rockets that would be launched from a 

temporary launch pad, the emissions would not be generated from a regulated source, and, 

therefore would not be subject to EPA or New Mexico Regulations. The emissions of hydrogen 

chloride and aluminum oxide would be up to 0.93 kilograms (2.04 pounds) and 1.68 kilograms 

(3.7 pounds), respectively, per launch. This amount of emissions would be from ground level up 

to approximately 914 meters (3,000 feet) above ground level and would readily disperse. 

Because a maximum of 12 launches of amateur rockets would occur over a two-day period and 

the amount of hydrogen chloride and aluminum oxide emitted would be small and would readily 

disperse, the impact on the regional air quality would be negligible. 

The cumulative impact of the emission of all the activities occurring at the X Prize Cup would be 

negligible. The reusable suborbital rockets and the rocket engines that would be operated on the 

test stand would use similar types of propellants resulting in emissions of water and CO2; 

however, the total amount would be less than double that from the proposed action because the 

number of static firings and the duration would be less than the number and duration of the 

rocket engine operations during the Vertical Launch Challenge and the Lunar Lander Challenge. 

In addition, the operation of the static test stand, the Vertical Launch Challenge, and the Lunar 

Lander Challenge would not occur at the same time; therefore, the emissions from one event 

would dissipate prior to the initiation of the next event and a new emission source. 
9

Biological Resources – Cumulative Impacts 

The X-Racer would take off from an existing runway and would maintain a flight plan typical of 

a fixed-wing aircraft operating from the airport and would not represent a new impact on the 

existing biological resources. The rocket truck would operate along the existing apron or runway 

and would not represent a new impact on the existing biological resources. The static testing of 

rocket engines would occur from an existing test pad and would not represent a new impact on 

the existing biological resources. The amateur rocket launches would occur from a temporary 

launch pad placed on an existing road, and the X Prize Foundation is in consultation with the 

Bureau of Land Management (BLM) to obtain the appropriate land use permit for a rocket 

recovery area and access to the area. The landing of the amateur rockets and the off-road access 

to the landing area would result in a negligible short-term impact on vegetation and wildlife in 

the area. The launch of model rockets would occur in a cleared area suitable for launch and 

recovery and would not impact vegetation or wildlife. These activities would result in a 

negligible cumulative impact on biological resources. 

Health and Safety – Cumulative Impacts 

Because the same transportation and operation measures associated with the proposed action 

would be implemented for the other activities occurring during the X Prize Cup, there would be 

no additional cumulative health and safety impacts. In addition, for the Elevator Games that 

involve the use of a laser or microwave beam, the beam would be directed at a specific target 

away from the spectators or any sensitive receptors; therefore, there would be no cumulative 

health and safety impact. 

Land Use – Cumulative Impacts 

Existing cleared areas at the airport or adjacent to the airport will be used for the launch and 

recovery of the model rockets. The X Prize Foundation must obtain written authorization from 

the BLM to use and access BLM land for the landing and recovery of the amateur rockets. 

These actions would have no cumulative effect on the existing land use at the airport or 

surrounding the airport. 

Mitigation 

The environmental impact analysis in this EA found no impacts in excess of applicable 

thresholds of significance for any impact category. Therefore, no mitigation is necessary. 

However, to ensure the health and safety of participants, spectators, and airport staff, the FAA 

recommends that the X Prize Foundation implement the following noise protection measures and 

monitoring during the X Prize Cup: 

 Post noise information posters that inform the public spectators of the potential noise 

hazards. 

 Ensure that noise protection devices (e.g., ear plugs) would be available to the public during 

the X Prize Cup.