CSE comment to the FCC on Starcloud, Inc.'s application for 88,000 orbital data centers (ICFS File No. SAT-LOA-20260202-00073)

 Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

via ICFS Electronic Filing

      )

In re: Application for launch and operating    )

authority for the Starcloud orbital data         ) ICFS File No. SAT-LOA-20260202-00073

center system                 )

           )

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 Starcloud, Inc. (hereinafter “Starcloud” or the “Applicant”). Starcloud seeks authority to launch and operate a non-geostationary orbit (NGSO) system of up to 88,000 satellites [2].

CSE opposes the above-referenced application. As an organization that holds that outer space is a human environment worthy of long-term stewardship, we find this proposal to be a significant threat to space sustainability. We urge the Commission to apply the Precautionary Principle to prevent the imminent harm to the Earth-space system this Application threatens.

I. “Greenwashing” of Orbital AI Computing

The Applicant proposes to deploy 88,000 satellites intended to operate as a distributed datacenter for training and operating artificial intelligence (AI) models. Starcloud argues this will reduce the environmental impact of terrestrial datacenters by bypassing Earth’s energy grids and utilizing radiative cooling in space [3]. We hold that this framing is a false trade-off. This approach simply shifts the industrial externalities of datacenters to outer space. Humanity must consider the sustainability of the entire Earth-space system rather than using space to offset unsustainable activity on Earth. Furthermore, while the Applicant claims these satellites are “designed-for-demise” [4], the cumulative impact of thousands of reentering units – even if all of them fully demise – risks altering the chemistry of the upper atmosphere [5], [6].

II. An ideological disconnect: AI demand vs. shared public interest

Starcloud’s system is specifically designed for “energy-intensive AI workloads” [7]. The Applicant claims that space-based datacenters are the “only truly scalable way” [8] to meet the demand for AI computing. The Applicant provides no supporting evidence for this claim. It marks a shift toward a stance in which commercial actors bill themselves as arbiters of what is best for all of humanity. There has been no meaningful mandate from the global public that high-power AI processing should take precedence over the preservation of the orbital commons or protection of the atmosphere. Space activities should maximize benefits to the greatest number of people while preserving the integrity of the environment.

III. Rising orbital density and Kessler Syndrome

Starcloud aims to deploy its 88,000 satellites into “narrow orbital shells” spanning only 50 km each at altitudes between 600 km and 850 km [9]. This extreme density significantly increases the risk of a runaway debris cascade, or “Kessler Syndrome” [10], which could render near-Earth space hazardous to all future spacecraft [11]. Despite these risks, Starcloud seeks to bypass standard safeguards by requesting waivers for processing round procedures and for financial surety bond and milestone requirements. Allowing such a massive deployment without the usual regulatory oversight and financial accountability is not in the public interest.

IV. Fundamental alteration of the night sky

Starcloud specifically requests Sun-Synchronous Orbits (SSO) to ensure “near-continuous power generation” [12] in “average sunlight exposure” [13]. The satellites are designed for deployment in ‘terminator orbits’ with a nominal overpass time of 06:00. By placing 88,000 satellites in orbits designed for maximum solar illumination, Starcloud risks ending the era of dark night skies on Earth. For ground observers, this would radically transform the night sky with bright, moving objects visible throughout the night, blinding sensitive telescopes and disrupting the human right to an unbroken view of the cosmos.

V. Technical Hazards: the Optical Inter-Satellite Link Web

The Applicant’s system will rely “nearly exclusively” on laser links for communications, routing traffic through third-party networks [14]. However, Starcloud also requests authority for “backup” Ka-band radiofrequency communications on a non-interference, unprotected basis [15]. This adds unnecessary complexity and potential electromagnetic interference to already crowded bands.

VI. Conclusion and Requested FCC Actions

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:

1. Revisit the NEPA "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.

2. 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. The Applicant has failed to demonstrate how an 88,000-satellite constellation that poses unprecedented risks of Kessler Syndrome serves the public interest more than it threatens it.

3. 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.

4. 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.

5. 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.

Notes

1. Center for Space Environmentalism, https://www.spaceenvironmentalism.org/.

2. Starcloud, Inc., Application for Launch and Operating Authority for the Starcloud Orbital Datacenter System (filed Feb. 4, 2026).

3. Starcloud Application Narrative, supra note 2, at 1.

4. Starcloud, Inc., Starcloud Orbital Data Center System, Attachment A: Technical Information to Supplement Schedule S, ICFS File No. SAT-LOA-20260202-00073, at 5 (filed Feb. 4, 2026).

5. 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.

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

7. Starcloud Application Narrative, supra note 2, at 2-3.

8. Starcloud Application Narrative, supra note 2, at 2.

9. Starcloud Application Narrative, supra note 2, at 1.

10. 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

11. 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. The authors conclude that the LEO environment has already 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.

12. Starcloud Application Narrative, supra note 2, at 2.

13. Starcloud Application Narrative, supra note 2, at 3.

14. Starcloud Application Narrative, supra note 2, at 1.

15. Technical Information to Supplement Schedule S, supra note 4, at 1.