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Viasat asks the FCC to conduct an environmental review of Starlink



WASHINGTON – Viasat has asked the Federal Communications Commission to conduct an environmental review of SpaceX’s Starlink broadband constellation, claiming that the satellite facility poses environmental hazards in space and on Earth.

In a December 22 filing, Viasat formally requested that the FCC conduct either an environmental assessment or a more stringent environmental impact statement from Starlink before approving a SpaceX request to change its existing license for the system so that it could operate nearly 3,000 more satellites in lower orbits. .

Satellite facilities have long had what is known as a categorical exception to the National Environmental Policy Act (NEPA), which requires federal agencies such as the FCC to assess the environmental impact of their actions. That exception, implemented in the mid-1

980s by the FCC, was based on an analysis at the time that the launch of individual satellites would not have measurable effects on the environment.

The size of SpaceX’s Starlink system, which is currently authorized for about 12,000 satellites, is changing the calculation, Viasat argued in its petition. “However, given the huge amount of satellites in question here, as well as the unique nature of SpaceX’s treatment of them as efficiently consumable, the potential environmental damage associated with SpaceX’s proposed modification is significant,” the company said.

“Relying on the commission’s decades-old categorical exceptions to avoid itself questioning into the environmental consequences of SpaceX’s modification proposal 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, Viasat continued (emphasis in original.)

Part of the petition addresses orbital debris. Viasat has been a fierce critic in FCC filing in recent months over the reliability of Starlink satellites and concerns that satellites failing in orbit could contribute to the growing debris population in LEO. The company has cited statistics that claimed an error rate as high as 7%, even though it included many of the original “v0.9” Starlink satellites launched in May 2019 that SpaceX has deliberately debilitated in recent months.

SpaceX has counteracted that the failure rate on orbit is far lower, but Viasat argued that the FCC should consider the overall risk of increased collisions as part of an environmental assessment. “The Commission can not take SpaceX’s words that thousands of satellites it seeks to pack in a lower orbit will not increase the risk of collisions and produce too much space debris – especially because SpaceX knows that when their satellites collide with other space objects and fragment or fail, it can always start more, ”it said.

Viasat’s argument for an environmental review goes beyond orbital debris. It claims that both launching and reintroducing Starlink satellites pose environmental hazards, from the production of ozone-depleting chemicals by firing vehicles to chemicals released into the atmosphere when satellites burn up on reintroduction and debris reaching the ground.

The appeal cites research from The Aerospace Corporation on the atmospheric consequences of launches and re-entry. At the autumn meeting of the American Geophysical Union earlier this month, the organization presented research which concluded that the increase in satellite mega constellations could increase the mass of satellites entering the atmosphere from around 100 tons per year to as much as 3200 tons.

However, the Aerospace study only found a potential for environmental impacts caused by an increasing number of new satellites, and said that further studies are needed on what these impacts may be. “Our preparatory work simply suggests that given the current and expected increase in large constellations, there is potential for environmental impact, and further studies are therefore recommended,” William Ailor, a technical fellow at Aerospace Corporation’s Center for Orbital and Reentry Debris Studies, told SpaceNews.

A third line of argument for an environmental review is the effect Starlink will have on the night sky. The petition noted concerns astronomers have expressed since the first cluster of Starlink satellites launched in 2019 that the constellation could disrupt astronomical observations, and could also have cultural consequences.

Viasat added that satellites in lower orbits would be brighter. “The Commission’s decision will thus directly affect the amount of light pollution in the environment and place the NEPA responsibility entirely on the Commission’s shoulders,” the company stated.

Viasat’s petition is not the first attempt to request an environmental review of Starlink. In April, sens asked. Tammy Duckworth (D-Ill.) And Brian Schatz (D-Hawaii) of the Government Offices to investigate the FCC’s categorical exemption for satellite facilities. It specifically cited concerns about light pollution from an unnamed satellite constellation with a description similar to Starlink. A paper published in a law review journal in January also suggested calling on NEPA about Starlink’s impact on astronomy.

GAO has not responded to the senators’ request publicly. However, astronomers have since reported that they are pleased with the level of cooperation with SpaceX to reduce the effect of the Starlink constellation on their observations. This has included the incorporation of visors on Starlink satellites to prevent sunlight from being reflected from the satellites and thus reduce the brightness.

“SpaceX is leading the charges in trying to understand these issues and design attenuations on their satellites,” Tony Tyson, chief scientist at the Vera Rubin Observatory, said at a briefing in August about a workshop held earlier this summer on the subject.

SpaceX has not commented on Viasat FCC filing. The company has held a series of ex parte meetings with FCC staff this month on the proposed modification of the Starlink license, as filed by the Commission, including a request to launch a set of Starlink satellites into a solar-synchronous orbital plane to take advantage of an unspecified “upcoming polar launch availability” . ”


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