Washington, D.C., February 26, 2025
Innovation, Science and Economic Development Canada
Engineering, Planning and Standards Branch
Senior Director, Space Services and International
235 Queen Street (6th Floor, East Tower)
Ottawa ON K1A OH5
Canada
Re: Canada Gazette, Part I, December 2024, Volume 158, Number 52, Consultation on Changes to Licensing Requirements and Conditions of Licence on Space Debris Mitigation. SMSE-013-24.
To Whom It May Concern:
This comment on Innovation, Science and Economic Development Canada’s (ISED) Consultation on Changes to Licensing Requirements and Conditions of Licence on Space Debris Mitigation (“the Consultation”) is written and supported by Canadian and international professional astronomers, who have signed as individuals at the end of this letter. Our comment is complementary to that provided by the Outer Space Institute, but focuses on responding to the questions posed by the ISED consultation document which relate to dark and quiet skies.
We agree with ISED’s proposed changes to require operators to submit environment assessments as a condition of licencing, and further encourage ISED to consider the inclusion of light pollution estimates and impacts in the those assessments. This should include whether operators have taken any steps to meet the International Astronomical Union’s recommendation to ensure that satellites are no brighter than V=7 mag or V = 7 + 2.5 log10(satellite altitude/550 km), whichever is fainter. We encourage consideration of light reflection and EM emissions from satellites at all altitudes of orbit in the environment assessments provided by NGSO applicants.
We applaud steps toward more careful consideration of collision risks, through requirements for SSA plans, collision probability evaluations, and clear guidelines for operators on collision avoidance maneuver thresholds. We also support prompt removal of satellites at end-of-life, and further advocate for the safe disposal of rocket bodies through controlled reentries, rather than abandoning rocket bodies in orbit and allowing them to reenter uncontrollably. A catastrophic collision on orbit becomes more likely with increasing orbital densities of both active satellites and debris, and avoiding such a collision should be a top priority for any safety plan. Not only would a catastrophic collision cause major safety issues for operational satellites, any increase in large orbital debris adds random glints and flares to astronomy research data and increases background sky brightness, both of which hinder astronomy research worldwide.
We support having NGSO applicants provide additional information on collision avoidance maneuvers, which we hope will include frequent updates to orbits in public databases. Such updates are vital both for SSA and to help large research telescopes avoid pointing at the brightest or most radio-loud satellites. We agree with ISED’s suggestions to require technical assessments of post-mission disposal plans, and further encourage ISED to consider the environmental impacts of ablation in the atmosphere. The current plans for “fully demisable” satellite disposal at end of life require deposition of the entire satellite mass in the upper atmosphere, which overwhelms natural meteoric metal deposition rates when dozens of satellites are disposed of per day – this rough estimate is well within current megaconstellation operation plans. While the full effects are not currently known, initial studies of the possible effects include increased atmospheric opacity, which is detrimental to astronomy research, but much more alarmingly, also suggest ozone depletion. This rapidly increasing source of pollution should be tracked and studied further, and a step toward this is to require operators to disclose expected mass disposition rates into the atmosphere as a condition on licencing.
Comment supported by:
Dr. Samantha Lawler Associate Professor University of Regina, SK, Canada
Dr. Aaron Boley Associate Professor University of British Columbia, BC, Canada