WASHINGTON – Viasat has petitioned the Federal Communications Commission to conduct an environmental review of SpaceX’s broadband constellation Starlink, arguing that the satellite system poses environmental risks in space and on Earth.
In a December 22 filing, Viasat formally requested the FCC to conduct a more rigorous environmental assessment or environmental impact statement from Starlink before approving a request from SpaceX to modify its existing license for the system so that it can operate almost 3,000 more satellites in orbit.
Satellite systems have long had what is known as a categorical exemption from the National Environmental Policy Act (NEPA), which requires federal agencies like the FCC to assess the environmental impacts of their actions. This exemption, implemented in the mid-1980s by the FCC, was based on the analysis at the time that launches of individual satellites would have no measurable effects on the environment.
The size of SpaceX’s Starlink system, currently authorized for approximately 12,000 satellites, changes that calculation, Viasat argued in its petition. “But given the large number of satellites in question here, as well as the unprecedented nature of the treatment SpaceX gives them as effectively expendable, the potential environmental damage associated with SpaceX’s proposed modification is significant,” said the company.
“Counting on the Commission’s categorical decades-long exemption to avoid even inquiring on the environmental consequences of SpaceX’s proposed modification would not only violate NEPA, but would also unnecessarily jeopardize the environmental, aesthetic, health, safety and economic interests it seeks to protect and harm the public interest, “continued Viasat (emphasis on original .)
Part of the petition deals with orbital debris. Viasat has been a shrill criticism in the FCC’s archives in recent months about the reliability of Starlink satellites and concerns that satellites that fail to orbit could increase the growing population of debris in LEO. The company cited statistics that claimed a failure rate of up to 7%, although that included many of the original Starlink “v0.9” satellites launched in May 2019 that SpaceX has been deliberately abusing in recent months.
SpaceX countered that its orbit failure rate is much lower, but Viasat argued that the FCC should assess the overall risk of increased collisions as part of an environmental review. “The Commission cannot take SpaceX’s word that the thousands of satellites it is trying to place in a lower orbit will not materially increase the risk of collisions and produce excessive space debris – especially since SpaceX knows this when its satellites collide with another space objects and fragment or fail, he can always launch more, ”he said.
Viasat’s argument for an environmental review goes beyond orbital debris. He says that both the launch and re-entry of Starlink satellites pose environmental risks, from the production of ozone-depleting chemicals by launch vehicles to chemicals released into the atmosphere when the satellites burn on re-entry and debris that reaches the ground.
The petition cites a survey by The Aerospace Corporation on the atmospheric impacts of launches and reentries. At the Autumn Meeting of the American Geophysical Union earlier this month, the organization presented research that concluded that the emergence of satellite megaconstellations could increase the mass of satellites entering the atmosphere from about 100 metric tons per year to up to 3,200 metric tons. .
The aerospace study, however, only found a potential for environmental impacts caused by an increasing number of reentry satellites, and said that further studies of what those impacts might be needed. “Our preliminary work simply suggests that, given the present and predicted increase in large constellations, there is a potential for environmental impact and therefore further studies are recommended,” said William Ailor, technical member of the Aerospace Orbital and Reentry Study Center Corporation. SpaceNews.
A third line of argument for an environmental review is the effect that Starlink will have on the night sky. The petition raised concerns that astronomers have expressed since the first cluster of Starlink satellites launched in 2019 that the constellation could interfere with astronomical observations and could also have cultural impacts.
Satellites in lower orbits, added Viasat, would be brighter. “The Commission’s decision, therefore, will directly affect the amount of light pollution in the environment, placing NEPA’s responsibilities directly on the shoulders of the Commission,” said the company.
Viasat’s petition is not the first attempt to request an environmental review from Starlink. In April, Sens. Tammy Duckworth (D-Ill.) And Brian Schatz (D-Hawaii) asked the Government Accountability Office to examine the FCC’s categorical exemption for satellite systems. He cited in particular concerns about light pollution from an unnamed satellite constellation with a description similar to Starlink. An article published in a legal magazine in January also proposed relying on NEPA in relation to Starlink’s impacts on astronomy.
GAO did not respond publicly to the senators’ request. However, astronomers reported that they are satisfied with the level of cooperation with SpaceX to mitigate the impacts of the Starlink constellation on their observations. This included the incorporation of displays on Starlink satellites to prevent sunlight from reflecting off the satellites and thus reducing their brightness.
“SpaceX is leading the charge in terms of trying to understand these problems and design mitigations on its satellites,” said Tony Tyson, chief scientist at the Vera Rubin Observatory, at a news conference in August about a workshop held earlier this summer on the subject matter.
SpaceX did not comment on the Viasat FCC filing. The company carried out a series of ex parte meetings with FCC staff this month on the proposed modification of their Starlink license, according to the commission’s records, including a request to launch a set of Starlink satellites on an orbital plane synchronized with the sun to take advantage of an “availability imminent polar launch. ”