Washington, DC — The Federal Communications Commission (FCC) is required to consider the environmental impacts of SpaceX’s proposal to launch up to a million satellites into low orbit before approving the company’s application, according to comments submitted to the FCC by Public Employees for Environmental Responsibility (PEER), Dinah Bear, and John Fitzgerald. SpaceX plans to use the satellites to expand the company’s artificial intelligence (AI) infrastructure.

SpaceX’s proposal would result in the deployment of a vast network of AI data centers directly into Earth’s orbit. To put this proposed deployment in perspective, about 14,500 active satellites are currently circling in low Earth orbit. If implemented, this proposal would result in thousands of additional space launches each year, considerable changes to the night sky, and significant increases in the number of satellites reentering the earth’s atmosphere.

In its comments, PEER points to a range of possible impacts from this proposal in the United States, including the emission of huge amounts of artificial light in the sky during the nighttime, the biological effects of artificial night lighting on human health, plants, and animals, and the increase in metals in the upper atmosphere, which studies indicate could be significant enough to alter stratospheric temperatures, ozone coverage, and geomagnetic signals relied on by migratory birds, some of which are highly endangered species, such as the Whooping Crane.

PEER is asking the FCC to conduct a formal environmental review to allow the public to review and comment on the range of environmental impacts in the United States, and alternatives to the proposal, as required by the National Environmental Policy Act (NEPA) and other laws, before approving the plan.

“While this plan may be a big technological leap forward, all we are asking is that the FCC take a good hard look before taking that leap,” said PEER Executive Director Tim Whitehouse, an attorney formerly with the U.S. Environmental Protection Agency. “These actions will unquestionably affect life on our planet and within our borders and must be carefully reviewed and considered.”

In its comments to the FCC, SpaceX did not explain how it will address the array of potential environmental problems with its proposal. Instead, it promises to use a “phased deployment approach for this system to monitor actual atmospheric effects” and to “coordinate proactively with relevant federal agencies…”  Significantly, SpaceX admits that it has yet to even “develop …advanced brightness mitigation techniques for its proposed system” to minimize visual impacts.

“The FCC needs to understand and embrace the value that implementing a robust NEPA process can bring to its own decision making, as well as improving the public’s confidence in the FCC’s independent oversight of this and other controversial proposals,” said Dinah Bear, former General Counsel at the Council on Environmental Quality.

“NEPA requires the FCC to formally assess the dangerous direct effects that a million satellites, each falling back to earth after about five years, will likely have.  Studies already show even a fraction of that number could warm the air over the poles, change the geomagnetic fields that birds use to navigate, while scattering pollutants into the oceans and across the earth. NEPA was enacted specifically so agencies and the public understand these massive risks to the environment well before an agency decides whether to issue a license,” said John Fitzgerald, formerly a Congressional aide, chief counsel at Defenders of Wildlife and Policy Director of the Society for Conservation Biology.

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See FCC call for comments on SpaceX plan

Read PEER’s initial comments

Examine SpaceX response

Compare PEER’s rebuttal to SpaceX

PEER protects public employees who protect our environment, natural resources, and public health. We support current and former environmental and public health professionals, land managers, scientists, enforcement officers, and other civil servants dedicated to upholding environmental laws and values across federal, state, local, and tribal governments.