COMPASSE comment on U.S. export control policy regarding satellite signature reduction
Washington, D.C., December 13, 2024
COMPASSE submitted the following in response to a call in the U.S. Federal Register to provide public comments on the proposed rulemaking action “Export Administration Regulations: Revisions to Space-Related Export Controls, Including Addition of License Exception Commercial Space Activities”. This comment was reviewed and approved by the AAS Committee on Astronomy and Public Policy.
Mr. Robert Rasmussen
Office of Defense Trade Controls Policy
U.S. Department of State
Washington, D.C. 20520
Dear Mr. Rasmussen:
Regulatory changes or clarifications to facilitate industry efforts to reduce the apparent brightnesses of satellites, as viewed from Earth, would be a strong benefit to both civil and commercial space parties, particularly those that receive federal funding to conduct space observations.
Over the last several years, members of academia and industry have convened with the intention of adjusting satellites to appear fainter, reaching or out-performing an agreed-upon magnitude limit called “magnitude 7” or “7th magnitude.” This limit lessens interference with amateur scientific activity, wasting of federally funded civil science and damage to space situational awareness (SSA) observations. All of these are threatened by over-bright satellites that disrupt the observational field of view.
Such conversations regarding the brightness limit satellites are supported by international collaborations, such as the IAU CPS. Domestically, several FCC-required coordination agreements between satellite companies and the NSF have contained a commitment to best efforts to make the apparent visual brightness of constellation satellites as faint as possible, with a goal of 7th magnitude, wherein the NSF represents the observatories used by the astronomical community such as ourselves.
Brightness mitigation efforts do not make satellites invisible. 7th magnitude roughly equates to the limit of what can be seen by the naked eye, meaning satellites are still easily visible, though dimmer, when observing through telescopes or binoculars. Allowing industry efforts to reduce apparent magnitude will facilitate current innovation and investments taken by our commercial space colleagues to collaborate with one another as necessary on developing this technology, which is currently in high demand. Furthermore, these successes will significantly lessen the risk of data waste as we increase usage of low earth orbit.
Thank you sincerely for your time, attention, and consideration.
Aparna Venkatesan and Teznie Pugh, Co-Chairs
AAS Committee on Light Pollution, Radio Interference, and Space Debris
Relevant text in the proposed rule:
In addition to the proposed exemptions previously described, the Department also requests public comment on specific regulatory changes or clarifications to facilitate industry efforts to reduce the apparent magnitude, as viewed from Earth, of satellite brightness. Commenters should be cognizant of the Department’s continued need to control signature reduction technologies that provide a critical military or intelligence advantage, including technologies to reduce spacecraft signatures as viewed in, or between, orbits.
We note a small technical issue in the relevant text. The astronomical magnitude scale runs to larger numbers for fainter objects. We wish to facilitate industry efforts to make the apparent magnitude fainter; technically, ” to reduce the apparent magnitude” would make the number smaller and the satellite brighter.