4 March 2026
March 4, 2026
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
via ICFS Electronic Filing
In re: Space Bureau Accepts For Filing SpaceX’s Application For Orbital Data Centers
DA/FCC #: DA-26-113
The Center for Space Environmentalism (CSE),1 a grassroots collective dedicated to the protection of the space environment and the preservation of outer space as a human environment, appreciates the opportunity to comment on the application by Space Exploration Holdings, LLC (SpaceX). SpaceX seeks authority to launch and operate an unprecedented non-geostationary orbit (NGSO) system of up to one million satellites.2
CSE opposes the above-referenced application. As an organization that holds that outer space is worthy of the same respect and long-term stewardship as our terrestrial home, we find this proposal to be the single greatest threat to space sustainability in history. Given the rapid acceleration of human space activities represented by this filing, we urge the Commission to apply the Precautionary Principle to prevent the imminent irreversible harm to the Earth-space system this Application threatens.
The Applicant proposes to deploy one million satellites intended to “operate as orbital data centers”.3 In its application, SpaceX argues that moving data centers into orbit will "significantly reduce the environmental impact associated with terrestrial data centers" by harnessing "near-constant solar power" and bypassing Earth's energy grids.4
This framing is a false trade-off. SpaceX's proposal seeks to "solve" terrestrial land-use and energy strain by exporting the environmental cost of data processing to the upper atmosphere and near-Earth space.5 This approach simply shifts externalities to outer space and solves nothing. We hold that humanity must consider the sustainability of the entire Earth-space system, rather than using space merely as a means to offset unsustainable human activity on Earth.
Furthermore, there are real and imminent concerns about impacts of the proposed constellation on the terrestrial and space environments. With a lifespan of only five years per unit, a million-satellite constellation creates a permanent cycle of launch and reentry.6 This cycle risks turning the mesosphere and stratosphere into an "incinerator dump" for space machinery.7 And facilitating such a massive constellation requires a launch cadence that would introduce unprecedented levels of black carbon (soot) and water vapor into the stratosphere.8 These particles absorb sunlight and warm the stratosphere while depleting the ozone layer, leading to potentially lethal consequences for terrestrial ecologies. At higher altitudes, re-entering spacecraft deposit materials such as alumina into the Earth’s upper atmosphere, which could upset the planet’s thermal balance.9 This has implications for both weather and climate.
Furthermore, satellites that do not demise completely upon re-entry also pose a threat to people and human infrastructure on the ground. Despite SpaceX’s claim of targeted demisability, Starlink satellites have survived re-entry and impacted near populated areas several times.10 Two orders of magnitude more satellites in orbit than exist now will only increase the risk of ground impacts.
SpaceX frames its proposed constellation as a "first step towards becoming a Kardashev II-level civilization";11 that is, one capable of harnessing the full power of its host star.12 This marks a distinct shift in the Applicant’s rhetoric away from its past platitudes about bridging the “digital divide” toward a stance in which it bills itself as the arbiter of what is best for the entire human species. While Starlink provided something of a recognizable public utility argument by offering connectivity to the underserved, this "Orbital Data Center" system is designed for "energy-intensive AI workloads" and "large-scale AI inference".13 There has been no meaningful mandate received from the American or global public that this should be a priority.
The application uses language that views space as an object of human utility first and foremost. The CSE champions the idea that humans are guests in space and must practice minimally invasive space exploration. We believe space activities should maximize benefits to the greatest number of people while preserving the integrity of the space environment, rather than serving the narrow, energy-intensive demands of specialized AI sectors.
SpaceX aims to deploy up to one million satellites in "narrow orbital shells" spanning only 50 km.14 This represents a number roughly 70 times greater than all existing satellites combined.15 This density exponentially increases the risk of “Kessler Syndrome”,16 a runaway chain reaction of debris that could render near-Earth space hazardous to all spacecraft.17 Current space traffic management and space domain awareness systems are not equipped to track or coordinate a million active objects.18 This puts human life and property both on the ground and in space at risk. Yet SpaceX requests waivers from NGSO milestone requirements and surety bonds.19 Self-policing has its limits, and a single malicious or accidental event in such a dense system could disrupt the entire orbital environment, closing access to all operators for months to centuries.20 This includes the prospect that a U.S. adversary could damage or destroy multiple objects in the constellation as a deliberately hostile act of war. As a result, matters of national and international security are at stake in the Commission’s evaluation of this application.
By placing one million satellites in Sun-Synchronous Orbits (SSO) to ensure near-continuous solar illumination,21 SpaceX risks ending the era of dark night skies on Earth. For ground observers, a million satellites would radically transform the night sky, with hundreds or thousands of bright, moving objects visible in every direction all night long.22 Such views will become the norm around the world. If the satellites generate significant debris, the optical and infrared brightness of the diffuse sky background will increase.23 This risks the inability to detect faint astrophysical light from the cosmos beyond and the irreversible loss of answers to the greatest questions humanity has ever asked. Furthermore, the aggregate "unintended electromagnetic radiation" (UEMR) from a million high-power server nodes risks blinding the very telescopes and AI instruments used for scientific discovery.24
SpaceX's infrastructure introduces environmental risks that are not adequately addressed in its application. Its "petabit laser mesh" technology involves a dense network of optical inter-satellite links (OISLs).25 Maintaining line-of-sight laser communication among one million units requires removing anti-reflective visors, which would significantly increase the optical and infrared brightness and visual pollution of the entire constellation.
SpaceX proposes that for satellites where atmospheric reentry is not feasible, they may choose "heliocentric disposal orbits".26 The CSE views this intentional discarding of defunct computing nodes into the Solar System as an act of planetary-scale littering that violates the principle of minimally invasive space exploration. By opting for heliocentric disposal, the Applicant effectively proposes bypassing the regulatory scrutiny and environmental impact assessments associated with atmospheric reentry. With respect to Article IX of the Outer Space Treaty, this practice sets a dangerous precedent for 'out of sight, out of mind' waste management in space and poses a long-term technical hazard to future deep-space missions and the integrity of the celestial environment.27
The CSE believes that a sustainable human future both in space and on the ground depends on a healthy and protected space environment. The FCC’s primary mandate is to act in the "public interest."
We therefore call on the Commission to:
Revisit the "Categorical Exclusion". The Commission must revisit the 'Categorical Exclusion' and mandate a full Environmental Impact Statement (EIS). This study must specifically address the aggregate effects of launch emissions (black carbon and water vapor) on the ozone layer and the cumulative impact of alumina deposits from massive reentry cycles.
Reject all waiver requests. As a matter of safeguarding the public interest, the Commission must not exempt this project from milestone requirements, surety bonds, or information filings.28 The Applicant has failed to demonstrate how a million-satellite constellation that poses unprecedented risks of Kessler Syndrome and 'planetary-scale littering' via heliocentric disposal serves the public interest more than it threatens it.
Halt the "fast-track" approval process. The proposed reduction of comment periods for such a monumental decision will hamper the ability of the American public and organizations representing it from participating and responding.
Require inter-agency review. Given the extreme orbital density and the potential for this system to become a focal point for international conflict, the Commission should formally coordinate with the Department of Defense and the Department of State to evaluate the national security and foreign policy implications of this application.
Establish UEMR and optical/infrared brightness limits. Before any grant of authority, the Commission must establish strict, enforceable limits on unintended electromagnetic radiation (UEMR) and optical/infrared brightness of objects to protect both the human right to an unbroken view of the cosmos and the continued viability of ground-based astronomy.
References
1 Center for Space Environmentalism.
2 Space Bureau Accepts for Filing SpaceX’s Application for Orbital Data Centers, Federal Communications Commission Public Notice, DA 26-113 (rel. Feb. 4, 2026).
3 SpaceX, Narrative, Application for Authority to Launch and Operate the SpaceX Orbital Data Center System, ICFS File No. SAT-LOA-20260108-00016, at 1 (filed Jan. 8, 2026).
4 SpaceX Application Narrative, supra note 3, at 1.
5 SpaceX Application Narrative, supra note 3.
6 Jon Gertner, Scientists Warn of Emissions Risks from the Surge in Satellites, Yale E360 (Dec. 2, 2025), https://e360.yale.edu/features/satellite-emissions.
7 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.
8 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).
9 C. 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 6 (2025).
10 Eleanor Webster, SpaceX Rocket Debris Crashes into Poland, BBC (Feb. 19, 2025), https://www.bbc.com/news/articles/c62z3vxjplpo; Simon Romero, Debris From SpaceX Explosion, Landing in Mexico, Draws Investigation, New York Times (June 26, 2025), https://www.nytimes.com/2025/06/26/us/spacex-explosion-debris-mexico-investigation.html; E. Lapointe, SpaceX Dragon Capsule Debris as Big as a Car Hood Crash-Landed in North Carolina, Business Insider (July 3, 2024), https://www.businessinsider.com/spacex-nasa-need-better-space-debris-models-reduce-impact-risk-2024-7; S. Larson, 2nd Piece of Space Junk Landed on Saskatchewan Farmland in 2024, CBC (Apr. 6, 2025), https://www.cbc.ca/news/canada/saskatchewan/2nd-piece-of-space-junk-landed-on-saskatchewan-farmland-in-2024-1.7502192.
11 SpaceX Application Narrative, supra note 3, at 1.
12 Michael Kan, SpaceX Eyes 1 Million Satellites for Orbital Data Center Push, PCMag (Jan. 31, 2026), https://www.pcmag.com/news/spacex-eyes-1-million-satellites-for-orbital-data-center-push.
13 SpaceX Application Narrative, supra note 3, at 3.
14 Federal Communications Commission, supra note 2.
15 SpaceX Files for 1M Orbital Data Centers in Wild FCC Pitch, The Tech Buzz (Feb. 28, 2026), https://www.techbuzz.ai/articles/spacex-files-for-1m-orbital-data-centers-in-wild-fcc-pitch.
16 Donald J. Kessler & Burton G. Cour‐Palais, Collision Frequency of Artificial Satellites: The Creation of a Debris Belt, 83 Journal of Geophysical Research: Space Physics 2637 (1978).
17 Niek Beekhuizen, D.C. Circuit Sweeps Away Space Debris Argument, BA (Apr. 1, 2023), https://www.americanbar.org/groups/air_space/resources/air-space-lawyer/2023-winter/dc-circuit-sweeps-away-space-debris-argument/.
18 Kan, supra note 12.
19 Federal Communications Commission, supra note 2.
20 The Iridium-33 / Cosmos-2251 collision of 10 February 2009 produced 2,296 catalogued debris fragments with orbital lifetimes of decades to centuries. See, e.g., Hugh Lewis & Donald Kessler, Critical Number of Spacecraft in Low Earth Orbit: A New Assessment of the Stability of the Orbital Debris Environment, Proceedings of the 9th European Conference on Space Debris (2025).
21 Megan Davies, Musk’s SpaceX Applies to Launch a Million Satellites into Orbit, BBC (Jan. 31, 2026), https://www.bbc.com/news/articles/cyv5l24mrjmo.
22 Davies, supra note 21.
23 Miroslav Kocifaj et al., The Proliferation of Space Objects is a Rapidly Increasing Source of Artificial Night Sky Brightness, 504 Monthly Notices of the Royal Astronomical Society: Letters L40 (2021); C. G. Bassa, O. R. Hainaut & D. Galadí-Enríquez, Analytical Simulations of the Effect of Satellite Constellations on Optical and Near-Infrared Observations, 657 Astronomy & Astrophysics A75 (2022); John C. Barentine et al., Aggregate Effects of Proliferating Low-Earth-Orbit Objects and Implications for Astronomical Data Lost in the Noise, 7 Nature Astronomy 252 (2023).
24 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).
25 Federal Communications Commission, supra note 2.
26 Federal Communications Commission, supra note 2.
27 Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, including the Moon and Other Celestial Bodies, art. IX, Jan. 27, 1967, 18 U.S.T. 2410, 610 U.N.T.S. 205; Space Debris Mitigation Guidelines of the Committee on the Peaceful Uses of Outer Space, United Nations Office for Outer Space Affairs (2007), https://www.unoosa.org/pdf/publications/st_space_49E.pdf.
28 Federal Communications Commission, supra note 2.