4 March 2026
March 4, 2026
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
via ICFS Electronic Filing
In the Matter of: Reflect Orbital Inc.
ICFS File No. SAT-LOA-20250701-00129
The Center for Space Environmentalism (CSE),1 an international collective committed to the ecological stewardship of the orbital environment, appreciates the opportunity to comment on the application by Reflect Orbital Inc. (Reflect Orbital) to launch and operate the EARENDIL-1 satellite.2 CSE opposes the Reflect Orbital application. We contend that its "sunlight-as-a-service" model is a direct threat to the scientific, cultural, and biological integrity of the Earth’s nighttime environment. We therefore urge the Commission to reject this request and instead mandate a full environmental review.
Reflect Orbital frames its mission as a solution for terrestrial energy grids, claiming that orbital mirrors will augment solar power production on the ground.3 We fundamentally reject this framing in part because it obscures substantial environmental externalities of the project. It is a false trade-off and a classic case of "greenwashing" that seeks to relieve terrestrial energy strain by exporting industrial consequences to the upper atmosphere and orbital environment. To maintain a functional constellation with an initial mid-term target of “5K+” satellites by 2030,4 a massive launch cadence would be required, resulting in the significant injection of alumina and black carbon into the stratosphere. These materials are known to deplete stratospheric ozone5,6 and may contribute to ongoing radiative forcing of the global climate.7,8
We reject the premise that terrestrial energy challenges should be addressed by disrupting global atmospheric chemistry and the natural light cycles of our planet. What Reflect Orbital proposes is not innovation; rather, it is merely exporting industrial pollution into the shared global commons of outer space.
What EARENDIL-1 represents isn't a harmless light show. The technical parameters of the present application involve a 18 m × 18 m specular reflector designed to shine sunlight onto the ground with a maintained intensity comparable to full moonlight.9 This is a disaster for ecology.10 Our planet’s biology evolved over billions of years in strict accordance with the natural day-night cycle. Reflect Orbital’s plan to project moving light beams across the landscape threatens to disorient migratory bird species and severely disrupt the foraging behaviors of nocturnal insects responsible for pollinating many of our food crops.11 We cannot afford to treat this mission as an experimental "test"—much less a permanent solution—when the potential for lethal and irreversible damage to our global ecosystems is so significant.
We are also deeply worried about the risks of solar retinopathy: permanent retinal damage for anyone who accidentally looks at these mirrors through binoculars or a telescope.12 Even in cases where there is no direct injury from observing EARENDIL-1, nighttime exposure to reflected sunlight is expected to affect humans in illuminated areas. Effects of this exposure include disruptions to sleep and circadian rhythms, with consequent implications for health and wellbeing.13 Furthermore, the beams of sunlight the Applicant intends to sell to customers could easily be used punitively or as a weapon of war.14 The potential for deployment of offensive or even lethal technology of this kind is clearly not in the public interest.
Beyond visual light pollution, the massive physical cross-section of Reflect Orbital’s 18m x 18m reflector presents a significant risk of specular reflection of radio frequency energy, which can cause 'glint' interference to both terrestrial and satellite-to-satellite communications. Such interference complicates the Commission’s primary mandate of efficient spectrum management and may inadvertently impact sensitive radio astronomy observations in protected bands.15
Space is a human environment, and the CSE believes that every human has a right to a night sky free from artificial glints and industrial shimmer. For thousands of years, humanity has connected to the universe through an unbroken view of the stars. That is a cultural resource that belongs to everyone.16 A constellation of satellites of which EARENDIL-1 is a representative example would appear as moving objects whose numbers and brightness would rival all of the stars visible at once to the unaided eye.17 Diffuse light scattered in the atmosphere between Reflect Orbital’s satellites and ground targets could create a permanent state of "artificial twilight" for human observers, obstructing access to the natural night sky.18 The constellation Reflect Orbital proposes in flying EARENDIL-1 as a prototype risks the irreversible loss of answers to the greatest questions of humanity by blinding our most sensitive telescopes and overwhelming the faint astrophysical signals that define our understanding of the universe. It further stands as an agent of cultural erasure for people whose religious values and ceremony involve access to the night sky.19
EARENDIL-1 represents a physical risk in orbit. It is essentially a giant sail, and its massive cross-section makes it a target for micrometeorites and non-trackable debris. Furthermore, despite Reflect Orbital acknowledging that their propellant tanks may survive re-entry, they are requesting permission for an uncontrolled demise.20 This is the opposite of stewardship.
The Commission should strictly deny any request to waive the surety bond requirement pursuant to the requirements of 47 C.F.R. § 25.165. A robust bond is essential to ensure that Reflect Orbital remains financially accountable for the potential costs of 'active debris removal' or environmental remediation on Earth should their 'uncontrolled demise' strategy result in property damage or hazardous debris. Without this financial safeguard, the public is effectively forced to subsidize the long-term environmental risks of a private commercial venture. The Commission should move away from such regulatory blind spots and toward proactive financial and environmental accountability.21
EARENDIL-1, and the fleet of similar satellites that may follow, represents a clear and present danger to both the terrestrial and space environments. Yet, the FCC continues to hide behind "categorical exclusions" to National Environmental Policy Act (NEPA) requirements in order to avoid environmental scrutiny of such applications.22 The Commission cannot argue that a plan to reflect light from the Sun toward the night side of Earth will have "no significant impact" on the continuum of environment from Earth to outer space. The Commission needs to act like a regulator, not a rubber stamp. It should therefore deny the requested waivers for milestone requirements and surety bonds until a full Environmental Impact Statement is conducted.23
The CSE believes that a sustainable future depends on a healthy and protected space environment. We therefore call on the Commission to reject Reflect Orbital’s application pending thorough and complete environmental review of the proposed action.
References
1 Center for Space Environmentalism, https://www.spaceenvironmentalism.org/.
2 Reflect Orbital Inc., Application for Authority to Construct, Launch, and Operate a Non-Geostationary Orbit Satellite, ICFS File No. SAT-LOA-20250701-00129 (filed July 31, 2025).
3 Reflect Orbital Inc., EARENDIL-1 Narrative, ICFS File No. SAT-LOA-20250701-00129 (filed July 31, 2025).
4 Mission, Reflect Orbital, http://reflectorbital.com (last visited Feb. 28, 2026).
5 José P. Ferreira et al., Potential Ozone Depletion From Satellite Demise During Atmospheric Reentry in the Era of Mega-Constellations, 51 Geophysical Research Letters, no. 11, June 2024, at 1.
6 Laura E. Revell et al., Near-future rocket launches could slow ozone recovery, 8 Npj Climate and Atmospheric Science, no. 1, 2025, at 1.
7 Christopher M. Maloney et al., Investigating the Potential Atmospheric Accumulation and Radiative Impact of the Coming Increase in Satellite Reentry Frequency, 130 Journal of Geophysical Research: Atmospheres, no. 6, 2025, at 1.
8 Santhosh Surendra, Impact of Spaceflight on Earth’s Atmosphere: Climate, Ozone, and the Upper Atmosphere 36 (NASA, Technical Memorandum No. NASA/TM−20240013276, 2024).
9 Reflect Orbital Inc., Application, supra note 2; see also Technology, Reflect Orbital, https://www.reflectorbital.com/ (last visited Feb. 6, 2026) (stating goal of 50,000 reflectors providing "up to 36,000 lux" by 2035).
10 See, e.g., Ariane Silva et al., The effects of artificial light at night on the roosting behavior of a threatened shorebird, 51 Journal of Avian Biology, no. 5, 2020, at 1; Emily K. Fobert et al., Artificial light at night causes reproductive failure in clownfish, 15 Biology Letters, no. 7, 2019, at 20190272; Brett M. Seymoure et al., Connecting artificial light at night to the ecology of nocturnal insects and bats, 59 Integrative and Comparative Biology 1135 (2019).
11 Eva Knop et al., Artificial light at night as a new threat to pollination, 548 Nature 206 (2017); Dirk Sanders et al., A meta-analysis of biological impacts of artificial light at night, 5 Nature Ecology & Evolution 74 (2021).
12 Jack G. Laframboise & B. Ralph Chou, Space mirror experiment: A potential threat to human eyes, 94 Journal of the Royal Astronomical Society of Canada 237 (2000).
13 Jamie M. Zeitzer et al., Sensitivity of the human circadian pacemaker to nocturnal light: Melatonin phase resetting and propagation, 9 Journal of Sleep Research 11 (2000); Lauren K. Davis et al., Health Effects of Disrupted Circadian Rhythms by Artificial Light at Night, 10 Policy Insights from the Behavioral and Brain Sciences 229 (2023).
14 During the Second World War, the Nazi government of Germany planned a future directed energy weapon based on orbiting mirrors. See Brandon J. Weichert, Nazi Germany’s “Sun Gun” weapon might have destroyed the world, National Interest (June 1, 2025), https://nationalinterest.org/blog/buzz/nazi-germanys-sun-gun-weapon-might-have-destroyed-the-world; see also John E. Canady, Jr. & John L. Allen, Jr., Illumination from space with orbiting solar-reflector spacecraft (NASA, Report No. NASA-TP-2065, 1982).
15 Aparna Venkatesan et al., The impact of satellite constellations on space as an ancestral global commons, 4 Nature Astronomy 1043 (2020). While this paper is best known for its "cultural heritage" arguments, it specifically details how the physical presence of massive satellite constellations creates "noise" in the radio spectrum.
16 UNESCO et al., Declaration in defence of the night sky and the right to starlight (La Palma Declaration) (2007), https://meetings.iac.es/preservingskies2017/media/LaPalma2017Declaration.pdf; see also Venkatesan et al., supra note 15.
17 Reflect Orbital Inc., Application, supra note 2.
18 Reflect Orbital Inc., Application, supra note 2; see also Salvador Bará & Fabio Falchi, Artificial light at night: a global disruptor of the night-time environment, 378 Philosophical Transactions of the Royal Society B: Biological Sciences, no. 1892, 2023.
19 Duane W. Hamacher et al., Whitening the Sky: light pollution as a form of cultural genocide, arXiv (2020), https://doi.org/10.48550/ARXIV.2001.11527.
20 Reflect Orbital Inc., Application, supra note 2; Reflect Orbital Inc., EARENDIL-1 Orbital Debris Assessment Report (ODAR).
21 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).
22 Ryan, supra note 21; 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); see also U.S. Gov't Accountability Off., GAO-23-105005, Satellite constellations: Agencies should improve guidance on environmental reviews (2022).
23 Reflect Orbital Inc., Application, supra note 2.