CSE comment to the FCC on Cowboy Space Corporation's application for 20,000 orbital data centers (ICFS File No. SAT-LOA-20260323-00135)

July 1, 2026

Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

via ICFS Electronic Filing

      )

In the Matter of: Cowboy Space Application  )              ICFS File No. SAT-LOA-20260323-00135

for “Stampede” Constellation                     )

            )

COMMENTS OF THE CENTER FOR SPACE ENVIRONMENTALISM

The Center for Space Environmentalism (CSE)1 submits these comments in strong opposition to the application of Cowboy Space Corporation (henceforth “Cowboy Space” or the “Applicant”) to deploy and operate “Stampede,” a non-geostationary orbit (NGSO) constellation of up to 20,000 satellites designed as in-orbit artificial intelligence (AI) data centers.2 The CSE operates under a foundational mandate that Earth’s orbit is a fragile, shared human environment, not a lawless frontier to be exploited by terrestrial industries seeking to bypass local environmental and zoning regulations. The unprecedented scale of the Stampede constellation fundamentally threatens orbital sustainability, the chemical composition of the upper atmosphere, and the preservation of the night sky for scientific observation.

I. Deconstructing the “greenwashing” of orbital AI computing

In its Legal Narrative, Cowboy Space justifies the Stampede constellation as an environmental solution, claiming that placing “the silicon next to the sunlight” will alleviate terrestrial power and land consumption.3 We fundamentally reject this deeply flawed “greenwashing” of AI computing. Displacing the energy footprint of AI into Low Earth Orbit (LEO) does not eliminate environmental harm; instead, it amplifies it. Recent scientific research published in Earth's Future demonstrates that the black carbon and particulate matter released during the launch and re-entry lifecycle of megaconstellations linger in the upper atmosphere, making them 540 times more effective at altering the climate than comparable ground-based emissions.4 Rather than representing a climate solution, moving data centers to space is the introduction of a high-altitude climate hazard.

II. Escalating orbital density and the Kessler Syndrome threat

The Stampede application proposes launching 20,000 massive computing units into the heavily trafficked 700 to 1,000-kilometer orbital shell.5 Due to the physical volume required for in-orbit data storage, cooling, and processing hardware, the cross-sectional collision risk of these data centers vastly exceeds that of standard communications satellites. Unlike terrestrial data centers that utilize convective cooling, in-orbit computational facilities must rely exclusively on thermal radiation to dissipate the immense heat generated by continuous data processing. This necessitates exceptionally large deployable radiator panels, alongside sprawling solar arrays to meet the high power demands of the servers.

Consequently, the physical footprint and cross-sectional area of a data center satellite are orders of magnitude larger than a standard communications relay. This proportionally escalates its mathematical probability of suffering kinetic impacts from orbital debris. Deploying such a dense and physically massive architecture into this specific LEO corridor drastically accelerates the timeline for Kessler Syndrome, a cascading chain reaction of orbital collisions that could render LEO unusable for generations.6

The CRASH Clock,7 a metric for stress in Low Earth Orbit, has been dropping rapidly since the start of the megaconstellation era. We are almost into the danger zone of this metric, where there is a 10% probability of a collision after 24 hours of loss of control. We note that this metric as published does not take into account fixed nodes as is proposed for the Cowboy Space megaconstellation. These fixed nodes and the single set of inclinations at each altitude that will precess properly to maintain a sun-synchronous orbit, mean that these sun-synchronous terminator orbits are about to become high collision risk. With four companies (SpaceX, Starcloud, Blue Origin, and now Cowboy) so far asking for the exact same set of orbits for hundreds of thousands of satellites with a fast replacement cycle of only 5 years,8 there will constantly be satellites raising and lowering their orbits, crossing through other companies’ orbits. The collision risks here are massive and completely undiscussed in the filing.

III. Technical hazards: OISL web, astronomy and the night sky

Cowboy Space attempts to downplay the constellation's impact on astronomy by relying on an Optical Inter-Satellite Link (OISL) architecture. While the Applicant may argue that horizontal data lasers are invisible from the ground, the reality is that an expansive OISL web poses an existential threat to astronomy across multiple wavelengths and frequency ranges.

To maintain laser links across hundreds of kilometers, OISL terminals utilize highly reflective optical hardware, including dielectric mirrors and tracking gimbals. These physical components catch and reflect sunlight down to Earth. When multiplied across 20,000 satellites, this dramatically increases the constellation's overall albedo, generating streaks that ruin long-exposure optical astrophotography.9

OISL lasers operate in the near-infrared spectrum and diverge over distance. When satellites maneuver or temporarily lose target lock, errant beam spillage sweeping across the field of view of highly sensitive ground- or space-based observatories can oversaturate images, obliterate faint celestial data, and risk permanent damage to expensive sensors.10

Routing the massive data payloads required for AI processing through a dynamic laser web necessitates extensive onboard electronic processing. Recent studies utilizing the Low Frequency Array (LOFAR) telescope have confirmed that the complex electronics in LEO megaconstellations leak “unintended electromagnetic radiation” (UEMR) into bands specifically allocated for radio astronomy, drowning out faint natural radio emissions from the cosmos.11

Furthermore, the Applicant fails to address the devastating impact the constellation’s thermal signature may have on infrared and submillimeter astronomy. To dissipate the immense heat generated by computational processing, these satellites will utilize massive radiator panels that act as brilliant thermal beacons.12 Peaking in the mid-infrared and extending into the submillimeter bands, this continuous blackbody radiation will be visible to sensitive observatories 24 hours a day, entirely independent of solar illumination.13 Passing overhead, a dense grouping of these active thermal sources may saturate highly sensitive cryogenic detectors and introduce catastrophic background noise for facilities attempting to observe the 'cold' universe such as the Atacama Large Millimeter/submillimeter Array (ALMA). While early baseline studies deemed thermal IR impacts “negligible,”14 those calculations were predicated on standard, low-power communication arrays in passive thermal equilibrium, not active, high-power computational facilities requiring stadium-sized radiators. While the filing completely fails to provide any information at all on the expected temperatures of the radiators, it is possible that blackbody radiation from the radiators could even bleed into the optical.

IV. End-of-life hazards: atmospheric chemical modification

The Stampede Tech Annex relies on atmospheric re-entry for the disposal of retired AI computing units.15 This practice is environmentally catastrophic when scaled to 20,000 massive satellites. The vaporization of satellite components, producing massive quantities of aluminum oxides and other metallic ash, injects significant pollution directly into the upper atmosphere. Recent comprehensive modeling confirms that this metallic pollution is rapidly accumulating, creating a high risk of altering the Earth's albedo and decreasing the amount of sunlight reaching Earth's surface. This represents a dangerous form of unintentional global geoengineering.16 These decaying orbital architectures act as potent catalysts for significant stratospheric ozone depletion.17 The FCC must recognize that the upper atmosphere is undergoing an artificial chemical recomposition driven by disposable space hardware.18

The Applicant’s environmental impact narrative severely underestimates the true scale of the Stampede constellation's atmospheric pollution by treating the 20,000-satellite figure as static. According to the Applicant’s own Schedule S, the estimated operational lifetime of these space stations is a mere five years.19 This extraordinarily short lifespan necessitates a staggering replacement rate, requiring Cowboy Space to launch and de-orbit 4,000 massive data centers every single year just to maintain the constellation. This is approximately one multi-ton satellite reentry every two hours. Consequently, the sheer volume of metallic ash and aluminum oxides injected into the upper atmosphere upon re-entry,20 compounded by the black carbon emissions generated by an unrelenting cadence of heavy-lift launch vehicles,21 will be exponentially higher than a static 20,000-satellite constellation implies.

Furthermore, metals from satellite burn-up now outnumber the amount naturally occurring from meteorites in the upper atmosphere.22 This is cause for concern for a large satellite constellation of high-mass objects such as that proposed by the Applicant, as it is unknown how they will break apart in the atmosphere and how many particulates, as a function of size, will linger and catalyze further chemical reactions that are not otherwise naturally occurring. The Commission must evaluate the environmental impact based on this continuous, high-volume churn, not a one-time deployment.

The filing also glosses over the very real ground casualty risk from de-orbiting so many huge satellites. The Applicant states that their objects would have at most a one in 10,000 ground casualty risk from reentries. This means they are openly admitting they could cause two deaths per five-year megaconstellation cycle. This is completely unacceptable.

Given the unprecedented physical volume, mass, and cross-sectional area of these orbital data centers, utilizing “disposal orbits” as a secondary option is entirely unacceptable. Permitting an applicant to park thousands of massive, dead structures in a graveyard orbit indefinitely creates an extreme risk of collisional cascading, pushing the low Earth orbit environment precariously close to the Kessler Syndrome. The Commission must unequivocally reject any orbital debris mitigation plan that leaves the regulatory door open to a catastrophe of this magnitude.

Lastly, the Applicant’s reliance on controlled re-entry into the South Pacific Ocean as a disposal method23 poses severe, unregulated risks to marine ecosystems. International environmental bodies and marine advocates have increasingly warned that the routine dumping of massive spacecraft hardware into the ocean introduces heavy metals and toxic substances, smothers benthic habitats, and exploits a troubling gap in international environmental law regarding high-seas pollution.24

V. Denial of rule waivers

The Applicant further requests a waiver of the standard surety bond requirements.25 The surety bond serves as the Commission’s primary regulatory backstop to ensure that non-geostationary satellite operators remain financially accountable for their systems and do not abandon their hardware in orbit in the event of financial insolvency.26 Given the unprecedented mass, scale, and rapid replacement churn of the proposed 20,000 orbital data centers, the risk of this constellation becoming a massive orbital graveyard if Cowboy Space faces bankruptcy is entirely unacceptable. Waiving strict financial accountability for a system with such profound long-term implications for the low Earth orbit environment would be a dereliction of the Commission’s duty to protect the public interest.

The Applicant’s request for a waiver of the standard surety bond requirements is particularly untenable given the financial position the Applicant has touted in its recent ex parte filing. In its submission, the Applicant has celebrated its significant fundraising success and strong capital position.27 If the Applicant possesses the resources to secure such substantial investment, it undoubtedly possesses the financial capacity to comply with the Commission’s standard regulatory requirements. Granting a waiver in light of these admissions would not only be inconsistent with the purpose of these financial safeguards, but would also effectively socialize the risks of the Applicant’s massive orbital data centers while privatizing the rewards of its fundraising efforts. The Commission should hold the Applicant to the same standard of financial accountability as any other operator, regardless of its perceived market momentum.

Furthermore, the Applicant fails to meet the threshold for a waiver under the Commission’s established public interest standard. Per FCC precedent, an applicant must demonstrate that “special circumstances warrant a deviation from the general rule and that such a deviation will serve the public interest.”28 A self-admitted, well-capitalized entity cannot demonstrate that any such ‘special circumstance’ exists, nor does the evasion of standard financial safeguards serve the public interest; rather, it risks offloading the potential environmental and financial liability of a failed satellite constellation onto the public.

This brazen request for a waiver is made all the more egregious by the Applicant’s complete lack of operational history. Unlike established aerospace operators with proven flight heritage and mature deployment capabilities, Cowboy Space is an entirely unproven entity with zero track record of successful spaceflight operations. The Commission’s surety bond requirements were implemented precisely to protect the public and the orbital environment from speculative or inexperienced ventures that might launch hardware they cannot sustainably manage.29 Granting a financial waiver to a novice operator proposing a constellation of this unprecedented scale is not merely irresponsible; it is fundamentally antithetical to the regulatory purpose of the bond itself.

VI. Evidence of regulatory avoidance in applicant's business model

The Applicant’s recent ex parte communications to the Commission further confirm that the Stampede constellation is not a benign technological advancement, but a deliberate strategy to circumvent terrestrial environmental oversight. In its overview deck, Cowboy Space explicitly contrasts the ‘years’ required for terrestrial data center permitting, which includes essential ‘zoning, land use, power impact studies, water usage disclosure, and thermal discharge management’, with its goal of reaching operation in 'weeks' by bypassing these safeguards in orbit.30

This admission of regulatory avoidance, combined with the Applicant's disclosed design for massive, 60-meter deployable solar arrays and 100m² thermal radiator panels, demonstrates that the Stampede constellation is a distinct class of high-impact industrial facility.31 The Commission cannot justify applying a 1980s-era categorical exclusion intended for small-scale surface facilities to a venture that openly markets itself as a means to escape mandatory terrestrial environmental disclosures. We reiterate our request that the Commission require a comprehensive Environmental Impact Statement (EIS), as the Applicant's own business model is predicated on the evasion of the very environmental protections the FCC is obligated to uphold.

VII. Conclusion and requested FCC actions

The FCC can no longer treat space as an infinite dumping ground. Due to the extreme risks of atmospheric pollution and orbital congestion, the CSE formally requests that the FCC deny the standard categorical exclusion under the National Environmental Policy Act (NEPA) for this application. Relying on a categorical exclusion established in 1986 for surface-level facilities is legally and scientifically indefensible for a 20,000-satellite constellation. As the Government Accountability Office explicitly concluded in a 2022 report, the FCC has failed to adequately justify applying this outdated exclusion to massive modern satellite deployments.32

We request that the FCC heed its own oversight recommendations and require Cowboy Space to submit a comprehensive Environmental Impact Statement (EIS) prior to any licensing consideration.

Respectfully submitted,

John C. Barentine, Ph.D.
Samantha M. Lawler, Ph.D.

on behalf of the Center for Space Environmentalism

Notes

1 Ctr. for Space Environmentalism, https://www.spaceenvironmentalism.org (last visited Jun. 13, 2026).

2 Application of Cowboy Space for Authority to Launch and Operate the Stampede Constellation, FCC File No. SAT-LOA-20260323-00135, Legal Narrative & Exhibit A Tech Annex (filed May 11, 2026), at 1.

3 Application of Cowboy Space, supra note 2, Legal Narrative at 4.

4 Connor R. Barker et al., Radiative Forcing and Ozone Depletion of a Decade of Satellite Megaconstellation Missions, 12 Earth's Future (2026), https://agupubs.onlinelibrary.wiley.com/doi/10.1029/2025EF007229

5 Application of Cowboy Space, supra note 2, Exhibit A Tech Annex at 1.

6 Donald J. Kessler & Burton G. Cour-Palais, Collision Frequency of Artificial Satellites: The Creation of a Debris Belt, 83 J. Geophysical Rsch. 2637 (1978).

7 Sarah Thiele et al., An Orbital House of Cards: Frequent Satellite Close Conjunctions, Acta Astronautica (published online Jun. 19, 2026), https://doi.org/10.1016/j.actaastro.2026.06.023.

8 Application of Cowboy Space for Authority to Launch and Operate the Stampede Constellation, FCC File No. SAT-LOA-20260323-00135, Schedule S at 1, § S1.c (filed Mar. 23, 2026).

9 American Astronomical Society, Impact of Satellite Constellations on Optical Astronomy and Recommendations Toward Mitigations, SATCON1 Report (2020).

10 David A. Koplow, Blinded by the Light: Resolving the Conflict Between Satellite Megaconstellations and Astronomy, 54 Geo. J. Int'l L. (2025).

11 Federico Di Vruno et al., Unintended Electromagnetic Radiation from Starlink Satellites Detected with LOFAR between 110 and 188 MHz, 676 Astronomy & Astrophysics A75 (2023); C. G. Bassa et al., Bright Unintended Electromagnetic Radiation from Second-Generation Starlink Satellites, 689 Astronomy & Astrophysics L10 (2024); D. Grigg, S. J. Tingay & M. Sokolowski, The Growing Impact of Unintended Starlink Broadband Emission on Radio Astronomy in the SKA-Low Frequency Range, 699 Astronomy & Astrophysics A307 (2025).

12 See A. Foster et al., Detection of Thermal Emission at Millimeter Wavelengths from Low-Earth Orbit Satellites, Open J. Astrophys. (2025).

13 S. Caddy et al., Remotely Monitoring the Activity of Satellites from Thermal Infrared Imaging, Proc. Advanced Maui Optical & Space Surveillance Tech. Conf. (2025), at 27.

14 Olivier R. Hainaut & Andrew P. Williams, Impact of Satellite Constellations on Astronomical Observations with ESO Telescopes in the Visible and Infrared Domains, Astron. & Astrophys. (2020), at 1.

15 Application of Cowboy Space, supra note 2, Exhibit A Tech Annex at 11–13.

16 Connor R. Barker et al., supra note 4.

17 S.P. Sharma, Impact of Spaceflight on Earth's Atmosphere: Climate, Ozone, and the Upper Atmosphere, NASA/TM−20240013276 (2024); J. P. Ferreira et al., Potential Ozone Depletion From Satellite Demise During Atmospheric Reentry in the Era of Mega-Constellations, 51 Geophysical Research Letters (2024), https://doi.org/10.1029/2024GL109280.

18 Adam Mann, Metal Pollution From a Rocket Reentry Detected for the First Time, Sci. News (Feb. 25, 2026).

19 Cowboy Space, Inc., Application for Authority to Launch and Operate the Stampede Non-Geostationary Satellite Orbit System, IBFS File No. SAT-LOA-20260323-00135, Schedule S, § S1.c (filed Mar. 23, 2026).

20 Aaron C. Boley & Michael Byers, Satellite Mega-Constellations Create Risks in Low Earth Orbit, the Atmosphere and on Earth, 11 Sci. Rep. 10642 (2021) (detailing the atmospheric accumulation of anthropogenic aluminum and other metallic ash from satellite re-entries).

21 Martin N. Ross & Paul M. Peeters, Space Travel and Climate: The Reality of the "Black Carbon" Problem, 3 Earth's Future 358 (2015) (analyzing the specific climate forcing impacts of black carbon soot emitted by high-frequency rocket launches).

22 Daniel M. Murphy et al., Metals  from Spacecraft Reentry in Stratospheric Aerosol Particles, 120 Proc. Nat'l Acad. Sci. (2023), https://doi.org/10.1073/pnas.2313374120 (finding that the mass of lithium, aluminum, copper, and lead from spacecraft reentry now exceeds the cosmic dust influx of those metals).

23 Application of Cowboy Space for Authority to Launch and Operate the Stampede Constellation, FCC File No. SAT-LOA-20260323-00135, Exhibit A Tech Annex at 11–12 (filed Mar. 23, 2026).

24 U.N. Off. for Outer Space Aff., Safeguarding Space: Issues Note 4 (2026), https://www.unoosa.org/res/oosadoc/data/documents/2026/i/unoosain1_0_html/Safeguarding_Space_Issues_Note_final.pdf. See also Leonard David, NASA Wants to Dump the ISS in the Sea. Experts Say the Plan 'Raises Serious Concerns for Ocean Health', Space.com (Jun. 23, 2026), https://www.space.com/space-exploration/international-space-station/nasa-wants-to-dump-the-iss-in-the-sea-experts-say-the-plan-raises-serious-concerns-for-ocean-health (quoting the President of The Ocean Foundation on the lack of environmental impact assessments for orbital hardware disposal).

25 Application of Cowboy Space, supra note 2, Legal Narrative at 14 (requesting waivers of milestone and surety bond rules).

26 47 C.F.R. § 25.165 (2025) (establishing mandatory surety bond requirements to prevent the warehousing of orbital spectrum and ensure financial accountability for satellite deployment and operation).

27 Letter from Joseph Yaffe, COO & CLO, Cowboy Space Corp., to Marlene H. Dortch, Sec’y, Fed. Commc’ns Comm’n, ICFS File No. SAT-LOA-20260323-00135, at Attachment A (Cowboy Space Overview Deck, June 2026, at 6).

28 Northeast Cellular Telephone Co., 89 F.C.C.2d 1312 (1982) (establishing the standard of review for waiver requests that remains the bedrock of FCC regulatory practice today)

29 See Comprehensive Review of Licensing and Operating Rules for Satellite Services, 30 FCC Rcd. 14713, 14738 ¶ 54 (2015) (emphasizing that the surety bond requirement is vital to deter speculative applications and ensure that only entities with the financial and technical readiness to execute their proposed systems are granted orbital access).

30 Letter from Joseph Yaffe, supra note 27, at Attachment A (Cowboy Space Overview Deck, June 2026, at 11) (noting the company has raised $365 million to date).

31 Letter from Joseph Yaffe, supra note 27, at Attachment A (Cowboy Space Overview Deck, June 2026, at 13).

32 See U.S. Gov't Accountability Off., GAO-23-105005, Satellite Licensing: FCC Should Reexamine Its Environmental Review Process for Large Constellations of Satellites, at Highlights, 2 (2022), https://www.gao.gov/products/gao-23-105005.