CSE comment to the FCC on Blue Origin, LLC's application for 51,600 orbital data centers (ICFS File No. SAT-LOA-20260310-00118)

April 20, 2026

Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

                                                   )

In re: Application for launch and operating authority       )     ICFS File No. SAT-LOA-20260310-00118

   for the Blue Origin orbital data center system       )      via ICFS Electronic Filing

                    )

COMMENTS OF THE CENTER FOR SPACE ENVIRONMENTALISM

The Center for Space Environmentalism (CSE),[1] an international collective dedicated to the ecological stewardship of the orbital environment, appreciates the opportunity to comment on the application by Blue Origin, LLC (hereinafter “Blue Origin” or the “Applicant”). Blue Origin seeks authority to launch and operate a non-geostationary orbit (NGSO) constellation of up to 51,600 satellites to support an orbital data center system known as “Project Sunrise”.[2],[3]

CSE opposes the above-referenced application. This proposal represents a massive expansion of industrial orbital use that threatens the integrity of the Earth-space system. We urge the Commission to apply the Precautionary Principle and reject this application pending a rigorous environmental review.

I. Deconstructing the "sustainable capacity" narrative

The Applicant argues that “Project Sunrise” will serve the public interest by providing “sustainable compute infrastructure” that bypasses terrestrial electrical grids and water supplies.[4] The Applicant claims that by placing satellites in sun-synchronous orbits (SSO), it can harness “near-constant solar power”[5] to deliver “low-carbon compute”.[6]

We contend that this framing is a false trade-off. Shifting the environmental burden of data processing to the upper atmosphere does not “solve” sustainability; it merely exports industrial consequences to the shared global commons. As noted in previous proceedings,[7] the massive launch cadence required for such a constellation results in the significant injection of alumina and black carbon into the atmosphere, which can deplete stratospheric ozone[8] and contribute to radiative forcing of the global climate.[9],[10] The sustainability of the entire Earth-space system must be considered, rather than simply treating orbit as a "green" dumping ground for terrestrial energy demands.

II. Ideological disconnect: AI demand vs. shared public interest

The Applicant claims its system is necessary to meet the “insatiable demand for AI workloads”[11] and will make AI computing “more accessible”.[12] However, space activities should prioritize the benefit of the greatest number of people rather than serving narrow, energy-intensive industrial sectors. The Applicant positions itself as a facilitator of “societal benefit”,[13] yet there is no public mandate that high-scale AI processing should take precedence over the preservation of the orbital environment or the integrity of the night sky.

III. Escalating orbital density and collision risks

The proposal to operate 51,600 satellites in orbital planes between 500 and 1,800 km[14],[15] significantly increases the risk of Kessler Syndrome,[16] a runaway debris cascade that could render Earth's orbit unreachable.[17] Despite these risks, the Applicant requests multiple waivers that undermine public safety:

• Waiver of processing round procedures: The Applicant seeks to bypass rules designed to prevent one applicant from precluding entry by other satellite operators.[18]

• Waiver of milestone and surety bond requirements: The Applicant additionally seeks to bypass safeguards that were specifically established to prevent spectrum ‘warehousing.’[19] 

The Applicant requests a waiver of 47 C.F.R. § 25.112(a) because their Orbital Debris Mitigation Plan is incomplete.[20] The FCC should not grant this waiver. We maintain that a robust bond requirement is essential to ensure commercial actors remain financially accountable for the potential costs of active debris removal or environmental remediation.

Furthermore, the Applicant’s stated 90% success rate for deorbiting satellites at end of mission[21] still results in thousands of derelict objects being left in orbit. A 10% failure of disposal through re-entry leaves up to 5,160 dead and uncontrollable satellites stranded in orbit. As a matter of ensuring the integrity of the orbital environment, this failure rate is unacceptable.

IV. Alteration of the night sky

Every human has a right to an unbroken view of the cosmos, a cultural resource that belongs to everyone.[22] By operating tens of thousands of satellites in Sun-Synchronous Orbits to ensure constant solar illumination,[23],[24] the Applicant risks permanently degrading the night sky. While the applicant mentions “astronomy mitigations” like exterior treatments and solar panel adjustments,[25] the sheer volume of 51,600 objects risks creating a state of “artificial twilight” for human observers. The Commission should consider the aggregate effects[26] of multiple pending applications to operate AI data centers in orbit whose numbers total 1.088 million.[27]

V. Regulatory oversight and the NEPA categorical exclusion

The FCC’s handling of mega-constellation applications is increasingly characterized by a systemic avoidance of its responsibilities under the National Environmental Policy Act (NEPA).[28] The Commission continues to rely on outdated “categorical exclusions” to avoid conducting thorough environmental scrutiny of these massive deployments.[29],[30] The Commission cannot reasonably argue that a plan to place over 50,000 satellites into orbit will have “no significant impact” on the environment. As noted by the Government Accountability Office (GAO), the FCC's failure to update its environmental guidance for satellite constellations represents a critical regulatory blind spot. The Commission must act as a proactive regulator, not a rubber stamp for private commercial ventures.[31]

VI. Conclusion and requested FCC actions

In consideration of the above, we therefore call on the Commission to:

• Mandate a full Environmental Impact Statement (EIS): The Commission must end its over-reliance on categorical exclusions for massive satellite constellations. As outlined in Section V, the current policy represents a critical regulatory blind spot that ignores the aggregate atmospheric and orbital impacts of over 50,000 additional spacecraft.

• Reject all waiver requests: The Commission should not facilitate the rubber stamping of applications by granting waivers for milestones and surety bonds. Maintaining these requirements is the only way to ensure financial and environmental accountability for commercial actors using the shared orbital commons.

• Update environmental guidance: Consistent with GAO recommendations, the FCC must proactively update its NEPA procedures to reflect the realities of the "megaconstellation" era rather than abdicating oversight to private interests.

[1] Center for Space Environmentalism.

[2] Narrative, Blue Origin, LLC, ICFS File No. SAT-LOA-20260310-00118 (filed Mar. 19, 2026), at 1.

[3] Schedule S, Blue Origin, LLC, ICFS File No. SAT-LOA-20260310-00118 (filed Mar. 19, 2026), at 1.

[4] Blue Origin, LLC, Narrative, supra note 2, at 4.

[5] Id.

[6] Id. at 9.

[7] Comments of the Center for Space Environmentalism, Reflect Orbital Inc., ICFS File No. SAT-LOA-20250701-00129, at 1 (filed July 21, 2025).

[8] Laura E. Revell et al., Near-Future Rocket Launches Could Slow Ozone Recovery, 8 Npj Climate & Atmospheric Sci. 1, 1 (2025).

[9] Christopher M. Maloney et al., Investigating the Potential Atmospheric Accumulation and Radiative Impact of the Coming Increase in Satellite Reentry Frequency, J. Geophysical Res.: Atmospheres, Mar. 2025, at 1, https://doi.org/10.1029/2024JD042442; Laura Revell et al., A New Space Race Could Turn Our Atmosphere into a 'Crematorium for Satellites’, The Conversation (Feb. 25, 2026), https://theconversation.com/a-new-space-race-could-turn-our-atmosphere-into-a-crematorium-for-satellites-276366.

[10] Daniel M. Murphy et al., Metals from Spacecraft Reentry in Stratospheric Aerosol Particles, 120 Proc. Nat’l Acad. Sci. U.S.A. e2313374120, at 1 (2023), https://doi.org/10.1073/pnas.2313374120.  

[11] Blue Origin, LLC, Narrative, supra note 2, at 4.

[12] Id. at 5.

[13] Id. at 5.

[14] Id. at 2.

[15] Blue Origin, LLC, Technical Annex, Blue Origin, LLC, ICFS File No. SAT-LOA-20260310-00118, Ex. A (filed Mar. 19, 2026), at A-1.

[16] Donald J. Kessler & Burton G. Cour-Palais, Collision Frequency of Artificial Satellites: The Creation of a Debris Belt, 83 J. Geophysical Res. 2637 (1978) https://doi.org/10.1029/JA083iA06p02637

[17] Hugh G. Lewis & Donald J. Kessler, Critical Number of Spacecraft in Low Earth Orbit: A New Assessment of the Stability of the Orbital Debris Environment, Proc. 9th European Conf. on Space Debris 1 (2025), https://conference.sdo.esoc.esa.int/proceedings/sdc9/paper/305/SDC9-paper305.pdf. This source evaluates a population of nearly 12,000 active spacecraft as of March 2025. It also addresses the "NewSpace" era of large satellite constellations, noting that International Telecommunications Union (ITU) filings now suggest more than 1 million satellites could enter orbit in the near future. See also Andrew Falle et al., One Million (Paper) Satellites, 382 Science 150 (2023). The authors conclude that the LEO environment has reached a tipping point that the 1978 Kessler and Cour-Palais paper only predicted as a future possibility. The authors argue that even if large rocket bodies (historically the main concern) are ignored, the high density of active satellites below 600 km has now pushed those lower altitudes into "runaway" territory for the first time.

[18] Blue Origin, LLC, Narrative, supra note 2, at 8.

[19] Id. at 10.

[20] Id. at 12.

[21] Technical Annex, supra note 15, at A-5 to A-6.

[22] Declaration in Defence of the Night Sky and the Right to Starlight (La Palma Declaration), Starlight Initiative, Apr. 20, 2007, https://fundacionstarlight.org/docs/files/33_english-declaration-in-defense-of-the-quality-of-the-night-sky-and-the-right-to-starlight.pdf.

[23] Blue Origin, LLC, Narrative, supra note 2, at 4.

[24] Blue Origin, LLC, Technical Annex, supra note 15, at A-1.

[25] Id. at A-9.

[26] J. C. Barentine et al., Aggregate Effects of Proliferating Low-Earth-Orbit Objects and Implications for Astronomical Data Lost in the Noise, 7 Nat. Astronomy 252 (2023).

[27] In estimating this number we consider applications SAT-LOA-20260108-00016 (SpaceX, 1 million satellites) and SAT-LOA-20260202-00073 (Starcloud, 88,000 satellites).

[28] 42 U.S.C. §§ 4321–4370m-12; see also C.E.Q. NEPA Regulations, 40 C.F.R. pts. 1500–1508.

[29] Ramon J. Ryan, The fault in our stars: Challenging the FCC's treatment of commercial satellites as categorically excluded from review under the National Environmental Policy Act, 22 Vanderbilt Journal of Entertainment & Technology Law 923 (2020); Elana Rosenberg, Environmental Procedures at the FCC: A Case Study in Corporate Capture, 64 Environment: Science and Policy for Sustainable Development, no. 5-6, 2022, at 17; John Latson, Higher altitudes and higher standards: Why the FCC should require environmental assessments for mega-constellations, 16 Journal of Business, Entrepreneurship & the Law 1 (2023).

[30] While 47 C.F.R. § 1.1306(a) “categorically exclude[s] from environmental processing … Commission actions not covered by § 1.1307 (a) and (b) [that] are deemed individually and cumulatively to have no significant effect on the quality of the human environment,” the Commission has not determined this. We contend that Blue Origin has provided insufficient information in its application to make any such determination.

[31] U.S. Gov't Accountability Off., GAO-23-105005, Satellite constellations: Agencies should improve guidance on environmental reviews (2022).