Scientists demand FCC test environmental impacts of satellites

updated One hundred and twenty astronomy researchers on Thursday sent a letter asking the Federal Communications Commission (FCC) to end the "absurd" environmental review exemption given to SpaceX's Starlink and other firms launching large constellations of satellites.

The letter [PDF] notes that the FCC was advised in November 2022 by the US Government Accountability Office (GAO) to rethink its environmental review process for satellite swarms. The comms watchdog has been approving applications to launch satellite mega-constellations without considering requirements under the National Environmental Policy Act, the GAO found.

"The environmental harms of launching and burning up so many satellites aren’t clear," the astronomy researchers argue. "That’s because the federal government hasn’t conducted an environmental review to understand the impacts."

The FCC, which has excluded satellite licenses from environmental reviews since 1986, did not immediately respond to a request for comment.

In 2022, there were almost 7,000 satellites in orbit, up from about 800 in 2000, according to the non-profit consumer interest group US PIRG. Presently, there are 10,855 objects orbiting the Earth, according to the website Orbiting Now, 7,736 of which are in Low Earth Orbit (LEO), where satellite mega-constellations generally reside.

SpaceX's Starlink has launched the majority of the orbiting mega-constellation satellites at the moment, more than 6,000 in the past five years (not all of which remain in service). These account for about 60 percent of the total satellite count, says US PIRG.

And many more satellite launches are planned. The 2022 GAO report [PDF] anticipates another 58,000 by 2030, and there are proposals for more than 500,000, from the likes of Amazon’s Project Kuiper, OneWeb, and others.

The problem is that satellites eventually deorbit, burning up in the atmosphere or occasionally crashing to Earth.

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According to a study released last December by Sierra Solter-Hunt, a physicist with aerospace consultancy Astroplane, the amount of deorbiting debris reentering the Earth's atmosphere from 42,000 planned Starlink satellites is predicted to reach about 29 tons of waste per day.

Solter-Hunt suggests this could alter the environment of Earth to the detriment of human health.

"It is known that man-made chemicals can endanger the atmosphere, and the mega-constellations are not just depositing dangerous chemicals, they are depositing huge masses of conductive material," Solter-Hunt said. "It is known that injecting fossil fuels into the atmosphere, originally from below the Earth’s crust, is risking the habitability of Earth."

That launching 30,000 to 500,000 satellites into low earth orbit doesn't even warrant an environmental review offends common sense

But in the absence of any environmental review, there's less data than there should be about the consequences of allowing tons of metals and chemicals from deorbited satellites to enter the atmosphere.

"That launching 30,000 to 500,000 satellites into low earth orbit doesn’t even warrant an environmental review offends common sense," the astronomers state in their letter. "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 is not the first time the FCC has been called upon to give some thought to the environmental consequences of greenlighting so many satellite launches. In August, US PIRG published a report titled "WasteX" focused on the satellite presence of SpaceX's Starlink. Astronomers have also expressed concern about satellite-based light pollution.

Asked whether the ongoing entreaties to the FCC have had any impact, Lucas Gutterman, director of US PIRG's Designed to Last Campaign, told The Register, "In sending this letter, we reached out to Space Bureau Chief Julie Kearney to ask for a meeting to discuss the concerns it expresses. We're continuing to work with experts to bring their concerns to the FCC and lawmakers in [Washington,] DC.

"The space industry has moved faster than the public or regulators were able to keep up and we'll continue to raise the importance of this issue with the public. The speed and scale of the new space race should be a kitchen-table issue, not an esoteric discussion among a small group of industry insiders."

SpaceX did not respond to a request for comment. ®

Updated to add at 1415 UTC on October 25 2024

After this story was published, Gutterman emailed to say, "We've heard back from the FCC and we're excited to meet with them to discuss the concerns expressed in the letter."