https://www.space.com/megaconstellations-threat-to-ozone-layer-recovery
Thank you scientists for planting seeds of atmospheric justice. The screenshot is separate from the letter to the FCC.
October 24, 2024
Chief Julie Kearney
Space Bureau
Federal Communications Commission 45 L Street NE
Washington, DC, 20554
Dear FCC Space Bureau Chief Julie Kearney, We should look before we leap.
The number of large satellites in the lowest-level of low earth orbit has increased by 127 times and the overall number of large LEO satellites has increased 12 times in five years, led by SpaceX. The new space race is ramping up quickly: some experts are estimating an additional 58,000 satellites will be launched by 2030. Other plans have been proposed to launch 500,000 satellites to create new mega-constellations that would power satellite internet.
The environmental harms of launching and burning up so many satellites aren’t clear. That’s because the federal government hasn’t conducted an environmental review to understand the impacts. What we do know is that more satellites and more launches lead to more damaging gasses and metals in our atmosphere. We shouldn’t rush forward with launching satellites at this scale without making sure the benefits justify the potential consequences of these new mega-constellations being launched, and then re-entering our atmosphere to burn up and or create debris This is a new frontier, and we should save ourselves a lot of trouble by making sure we move forward in a way that doesn’t cause major problems for our future.
We need a precautionary agency that can regulate the commons of our final frontier, as has been recommended by the Government Accountability Office (GAO). The FCC should follow the GAO’s recommendations and conduct environmental reviews for large constellations of satellites. Regulators should also ask if we really need multiple disposable constellations competing for the same limited space. We can have affordable internet for everyone without surrounding our globe with tens or hundreds of thousands of disposable satellites that could harm our environment. We call on the FCC to:
1. Pause new satellite internet low earth orbit satellite launches until the Federal Communications Commission conducts environmental reviews for mega-constellations.
We shouldn’t rush into deploying an untested and under-researched technology into new environments without comprehensive review. Over just five years Starlink has launched more than 6,000 units and now make up more than 60% of all satellites. The new space race took off faster than governments were able to act. Regulatory agencies review individual licenses and lack the policies in place to assess the total effects of all proposed mega-constellations. Until
national and international environmental reviews can be completed we should stop launching further low earth orbit satellites part of constellations that provide consumer internet connectivity.
The FCC is granting licenses on a first-come, first-served basis but both orbital space and the broadcast spectrum are not infinite. National and international regulators need to develop an unprecedented system of cooperation to share the commons of our final frontier. Until extensive coordination is in place, we shouldn’t let the commercial interests first to launch determine the rules.
2. FCC should end the environmental categorical exclusion of satellites.
In November 2022, GAO released their report, Satellite Licensing: FCC Should Reexamine Its Environmental Review Process for Large Constellations of Satellites. The report found the FCC sidesteps the National Environmental Policy Act’s required environmental review of satellite mega-constellation by claiming a categorical exclusion. Excluding all 24 applications for mega-constellations is absurd given the unprecedented pace at which the FCC is granting licenses. The GAO recommends that the Federal Communications Commission should review whether licensing large constellations of satellites normally does not have significant effects on the human environment. As of May 2024 the FCC has not reexamined their rules and still exclude satellite constellations from environmental review.
That launching 30,000 to 500,000 satellites into low earth orbit doesn’t even warrant an environmental review offends common sense. The GAO found that the FCC doesn’t have a documented reason for deciding mega-constellations are categorically excluded from environmental review. The FCC should immediately begin a comprehensive review process working with experts from academia, the Environmental Protection Agency, NASA, and other federal agencies. This review must consider the total effects of proposed mega-constellations in the context of other internationally proposed constellations—not on a one-by-one basis. The effects on the space environment such as orbital debris, and on the atmosphere, astronomy, climate, aviation, and surface all need to be considered. This review needs to be coordinated with international agencies such as the International Telecommunication Union, and researchers.
Conclusions
New large scale technologies require oversight and study. The long term effects of this massive change to our environment aren’t clear. What is clear is that we can bring the world online without the unknown environmental harms of satellite mega-constellations. The FCC should coordinate closely with the EPA, NASA, and other national and international regulators to require extensive environmental reviews for the new space age. We’re in a short window of time when we can prevent making a mess of space and our atmosphere rather than spend decades cleaning it up.
The new space race doesn’t need to create massive space waste.
Sincerely,
Researchers
Marcel Agüeros Professor of Astronomy Columbia University
Charles Alcock
Professor of Astrophysics
Harvard University, Harvard-Smithsonian Center for Astrophysics
Zachary Andalman Astrophysics PhD Student Princeton University
Robert Antonucci Professor of Physics University of California
Melanie Archipley
Postdoctoral Scholar/Associate Research Fellow
University of Chicago, Kavli Institute for Cosmological Physics
Gaspar Bakos
Professor of Astrophysics Princeton University
Sarbani Basu
William K Lanman Jr. Professor of Astronomy Yale University
William Best
Research Associate in Astronomy University of Texas at Austin
John Bieging
Professor
Steward Observatory, University of Arizona
Will Brennom
Physical Science Technician Harvard-Smithsonian Center for Astrophysics
Timothy Bretl
Professor of Aerospace Engineering University of Illinois at Urbana-Champaign
Warren Brown
Astrophysicist
Smithsonian Astrophysical Observatory
Brian Clark
Assistant Professor of Physics University of Maryland
Rodrigo Cordova
PhD Candidate of Astrophysical Sciences Princeton University
Roohi Dalal
Postdoctoral Fellow in Space Security and Sustainability Outer Space Institute
Edward DeLuca
Senior Scientist, retired
Smithsonian Astrophysical Observatory (SAO)
Nils Deppe Professor of Physics Cornell University
Luke Drury
Professor of Astrophysics (emeritus) Dublin Institute for Advanced Studies
Karolina Dziadura
Astrophysicist
Harvard-Smithsonian Center for Astrophysics
Debra Fischer Professor of Astronomy Yale University
Michael Foley Postdoctoral Fellow Harvard University
Wesley Fraser
Senior Research Officer
National Research Council of Canada
Richard Frazin
Associate Research Scientist University of Michigan
Mark Freeman
Seniors Systems Engineer
Smithsonian Astrophysical Observatory (SAO)
Peter Gallagher
Professor of Astrophysics
Dublin Institute for Advanced Studies
Martin Gaskell
Research Associate in Astronomy and Astrophysics University of California, Santa Cruz
Marla Geha
Professor of Astronomy Yale University
Shy Genel Research Scientist Flatiron Institute
Eden Girma
Graduate Student of Astrophysical Sciences Princeton University
Vayujeet Gokhale Professor of Physics Truman State University
Jean-François Gonzalez
Professor of Astrophysics
Centre de Recherche Astrophysique de Lyon, France
Matthew Goodbred Graduate Student Princeton University
Jordan Goodman
Distinguished University Professor of Physics University of Maryland
Paul Green
Astrophysicist
Smithsonian Astrophysical Observatory
Jonathan Grindlay
Robert Treat Paine Research Professor of Astronomy Harvard Center for Astrophysics
James Gunn
Professor of Astrophysical Sciences (emeritus) Princeton University
Erika Hamden
Associate Professor of Astrophysics, Director of UA Space Institute University of Arizona
Stefan Hofmeister
Associate Research Scientist Columbia University
Andy Howell
Senior Scientist, Adjunct Professor of Physics
Las Cumbres Observatory, University of California, Santa Barbara
Chris Impey
Professor of Astronomy University of Arizona
Theodore Jacobson
Distinguished University Professor of Physics University of Maryland
Moriba Jah
Co-founder, President and Chief Scientist GaiaVerse Ltd.
David Jewitt
Distinguished Professor of Astronomy UCLA
Alexander Johnson Graduate Student of Physics Harvard University
Minkwan Kim
Associate Professor of Astronautics University of Southampton
Changgoo Kim
Research Scholar of Astrophysical Sciences Princeton University
David Kipping
Associate Professor of Astronomy Columbia University
Jürgen Knödlseder
Staff Scientist
National Centre for Scientific Research (CNRS)
David Koplow
Scott K. Ginsburg Professor of Law Georgetown University
Sylvain Korzennik
Solar Physicist
Smithsonian Astrophysical Observatory (SAO)
Vladimir Kradinov
Structural Engineer
Smithsonian Astrophysical Observatory (SAO)
Charles Lada
Senior Astrophysicist, Observational Astronomer Harvard Center for Astrophysics
Lachlan Lancaster
Postdoctoral Fellow in Astronomy and Astrophysics Columbia University
Philip Langill
Associate Professor of Astrophysics, Director of Rothney Astrophysical Observatory University of Calgary
Samantha Lawler
Associate Professor of Astronomy University of Regina
Nicolas Lee
Lecturer, Research Engineer in Aeronautics and Astronautics Stanford University
Yuri Levin
Professor of Physics Columbia University
Cassandra Lochhaas
NASA Hubble Fellow
Harvard-Smithsonian Center for Astrophysics
Abraham Loeb
Frank B. Baird Jr. Professor of Science, Director of Institute for Theory and Computation Harvard University
Thomas Loredo
Senior Research Associate, Lecturer in Astronomy Cornell University
Mordecai-Mark Mac Low
Curator, Professor of Astrophysics American Museum of Natural History
Amber Malpas
Postdoctoral Researcher in Astronomy The Ohio State University
Catherine Manea
National Science Foundation Astronomy and Astrophysics Postdoctoral Fellow Columbia University
Hubert Martin
Project Scientist
University of Arizona, Steward Observatory
Jonathan McDowell
Astrophysicist
Harvard-Smithsonian Center for Astrophysics
Robert McMillan
Research Professor of Astronomy (emeritus), Founder of Spacewatch Project University of Arizona
Shaunak Modak
Graduate Student of Astrophysical Sciences Princeton University
Richard Montgomery
Distinguished Professor of Mathematics (emeritus) University of California, Santa Cruz
Katie Morzinski
Associate Astronomer
University of Arizona, Steward Observatory
Philip Nicholson Professor of Astronomy Cornell University
Alejandro Nunez
Postdoctoral Fellow in Astronomy Columbia University
Aaron Parsons
Associate Professor of Astronomy, Director of Radio Astronomy Lab University of California, Berkeley
Jasmine Parsons
Graduate Student of Astrophysical Sciences Princeton University
Haille Perkins
Graduate Research Assistant in Astronomy University of Illinois Urbana-Champaign
Richard Pogge
College of Arts & Sciences Distinguished Professor of Astronomy The Ohio State University
Mary Putman Professor of Astronomy Columbia University
David Rabinowitz
Senior Research Scientist in Physics Yale University
Peter Rau
Postdoctoral Fellow in Astrophysics Lab Columbia University
Meredith Rawls
Research Scientist in Astronomy University of Washington
John Raymond
Senior Astrophysicist
Harvard Center for Astrophysics
Joshua Reding
Science and Technology Policy Fellow
American Association for the Advancement of Science (AAAS)
Nilton Renno
Professor of Climate and Space Sciences University of Michigan
Massimo Ricotti
Assistant Professor of Astronomy University of Maryland, College Park
Pete Riley
Senior Research Scientist Predictive Science Inc.
Aaron Roodman
Professor of Particle Physics and Astrophysics Stanford University
Bangalore Sathyaprakash
Professor of Physics, Astronomy and Astrophysics Pennsylvania State University
Christopher Shallue
PhD Candidate in Astronomy Harvard University
Julia Shelton
Professor of Physics
University of Illinois at Urbana-Champaign
C K Shum
Professor of Geodetic Science, Distinguished University Scholar Ohio State University
Thomas Smith
Opto-mechanical Engineer
Smithsonian Astrophysical Observatory (SAO)
Paul Smith
Research Professor (emeritus)
University of Arizona, Steward Observatory
David Smith
Professor of Physics
University of California, Santa Cruz
Michael Smutko
Professor of Instruction in Astrophysics and Physics, Director of Dearborn Observatory Northwestern University
Sierra Solter-Hunt Physicist
University of Iceland
Krzysztof Stanek Professor of Astronomy The Ohio State University
Michael Strauss
Professor of Astrophysical Sciences Princeton University
James Sunseri
PhD Student of Astrophysical Sciences Princeton University
Roberto Tejada Arevalo
Graduate Student of Astrophysical Sciences Princeton University
Sarah Thiele
PhD Student of Astrophysics, Junior Research Fellow Princeton University, Outer Space Institute
Remo Tilanus
Research Professor of Astronomy University of Arizona, Steward Observatory
Edward Tong
Receiver Engineer
Smithsonian Astrophysical Observatory, Harvard-Smithsonian Center for Astrophysics
Helena Treiber
Graduate Student of Astrophysical Sciences Princeton University
Scott Tremaine
Professor of Astrophysics (emeritus) Institute for Advanced Study
Tony Tyson
Distinguished Research Professor of Physics University of California, Davis
Melville Ulmer
Professor of Physics and Astronomy Northwestern University
Jatila van der Veen
Adjunct Professor of Astronomy Santa Barbara City College
Frederick Walter
Professor of Physics and Astronomy Stony Brook University
Risa Wechsler
Professor of Particle Physics and Astrophysics, Director of Kavli Institute for Particle Astrophysics and Cosmology (KIPAC)
Stanford University
Benjamin Weiner
Assistant Staff Scientist, Associate Research Professor
University of Arizona, Steward Observatory, MMT Observatory
Farhad Yusef-Zadeh
Professor of Physics and Astronomy Northwestern University
Vivienne Zhang Research Technician Outer Space Institute
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Paul Antonucci
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Physical Science Technician
Smithsonian Astrophysical Observatory (SAO)
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https://agupubs.onlinelibrary.wiley.com/doi/10.1029/2024GL109280
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