Washington, DC — The Federal Communications Commission (FCC) should undertake a thorough environmental review before greenlighting a satellite to reflect sunlight back to earth after dark, according to joint comments filed by Public Employees for Environmental Responsibility (PEER) and DarkSky International (DarkSky). Without such a review, there will be no required mitigation measures to lessen light pollution, prevent interrupted sleep cycles and serious damage to eyesight, avoid disrupting astronomy, and other negative side-effects of lighting up the night sky.

A company named Reflect Orbital is seeking FCC approval to launch a prototype satellite with large (50+ meter) mirrors to reflect sunlight to specific locations on Earth after dark. This would allow the company to produce “sunlight on demand,” and illuminate areas up to 5 kilometers wide at intensities several times brighter than a full moon.

The company concedes that it is not certain of what the effects of its operations will be but opposes any prior environmental review of the effects of sunlight on demand in the United States. Based upon how the prototype works, the company then plans to launch a constellation of up to 50,000 satellites over the next nine years.

The company also contends that its orbital activities are not covered by the National Environmental Policy Act (NEPA), a bedrock environmental statute which requires consideration of potential impacts, feasible mitigation measures, and available alternatives before federal actions significantly affecting the environment are taken.  PEER and DarkSky counter that the company is misreading the law.

“NEPA is a law designed to shine a bright light on a proposal before a decision is made – and a bright light is surely something Reflect Orbital should appreciate rather than oppose,” stated PEER Executive Director Tim Whitehouse, pointing out that the company promises that the environmental concerns raised by PEER and others “are being considered, studied, and incorporated” into its technology but does not offer any specifics. “Reflect Orbital should reveal in advance what protective measures it will take and not treat them as corporate trade secrets.”

PEER and DarkSky are asking the FCC to require preparation of, at a minimum, an environmental assessment of the effects of such a satellite on the United States before approving the company’s application.

“Reflect Orbital claims that it wants to study real-world effects and mitigate unintended or undesired side-effects; but that is a reason for the FCC to require an environmental assessment, not an excuse for not doing one,” DarkSky CEO and Executive Director Ruskin Hartley said, noting that federal agencies, such as the U.S. Fish & Wildlife Service, consider dark skies an important but diminishing natural resource. “NEPA does not mandate perfect knowledge before approving an action but does require some degree of forecasting and a reasonable evaluation of potential environmental effects, which should not be too much to ask before embracing new unprecedented levels of light pollution.”

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Look at the value of dark skies

See DarkSky and PEER’s comments on Reflect Orbital plan

Compare Reflect Orbital’s response

Read PEER and DarkSky’s joint rebuttal

Note another big satellite plan now before the FCC

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.