Washington, D.C., September 17, 2025
Before the Federal Communications Commission,
Washington, D.C. 20554
In the Matter of Modernizing the Commission’s National Environmental Policy Act Rules
(WT Docket No. 25-217)
Comments of the American Astronomical Society
The American Astronomical Society (AAS) appreciates the opportunity to respond to this Federal Communications Commission (FCC) Notice of Proposed Rulemaking, which seeks to update the Commission’s National Environmental Policy Act Rules.
The proposal to exclude satellite operations from NEPA review on the grounds that they are extraterritorial activities with effects located entirely outside of the jurisdiction of the United States does not fully account for the substantial, well-documented effects that satellite operations can have within the US. We wish to highlight impacts of satellite operations on U.S. astronomical research as well as atmospheric and ground-level impacts above and within the territory of the United States.
Impacts on Astronomical Research in and by the United States
Individual satellites and satellite constellations, by reflecting sunlight and generating radio-frequency transmissions, can impact astronomical observations, degrading data quality and potentially causing data loss.[1] They may also contribute to increasing night sky brightness,[2] diminishing the efficacy of astronomical observations from ground-based observatories that will now require more telescope time to achieve the same scientific goals. Both intended and unintended radio emissions[3,4] from satellites can disrupt sensitive radio astronomy observations, including those conducted within the National Radio Quiet Zone. Furthermore, increased orbital congestion raises the probability of collisions or debris strikes involving U.S.-operated space telescopes like Hubble,[5] Fermi, Swift, NuSTAR, and the recently launched SPHEREx, putting taxpayer-funded scientific infrastructure at increased risk. There is no commercial alternative, and no replacement waiting, if any of these one-of-a-kind telescopes is damaged or destroyed by debris, meaning that they cannot take on the same maneuver or close encounter risk as commercial satellites crossing their orbits.
Both ground-based and space-based telescopes are the results of decades of U.S. funded planning, research, development, and operational support. Both types of telescopes are already experiencing the contamination of astronomical data by satellites, [6,7,8,9] representing a serious threat to their efficient operation and compromising decades of U.S. investment. The data loss and inefficiencies in astronomical observations as a result of this interference result in a waste of American taxpayer dollars. Because satellites can identically impact facilities on U.S. soil, U.S.-funded facilities located in other countries, and U.S. telescopes in orbit, pre-emptively dismissing the latter two sets of impacts as “extraterritorial” and therefore exempt from NEPA review would be contrived and short-sighted on the part of the FCC.
Atmospheric and Ground-Level Impacts in the United States
Launches of satellites from U.S. territory emit pollutants into the atmosphere with domestic environmental impacts.[10] Satellite reentries can deposit metal vapor into the atmosphere above the U.S. with potential climate and air quality effects.[11] Uncontrolled reentries carry a non-zero risk of debris landing on U.S. soil, with multiple such incidents having taken place over the past few years.[12,13,14] This poses a threat to life and property on the ground as well as the safety of both civilian and military aviation.[15]
To summarize, the effects described above directly manifest in U.S. airspace, on U.S. soil, or in domains (such as radio spectrum) explicitly regulated within U.S. jurisdiction. For these reasons, satellite operations cannot be defined as entirely outside the jurisdiction of the United States. We urge the Commission to clarify that satellite and space-based communications operations with foreseeable domestic environmental impacts remain within the scope of NEPA review.
On behalf of the American Astronomical Society,
Dara Norman, PhD
President, American Astronomical Society
[1] See e.g. the SATCON2 Report Executive Summary: https://baas.aas.org/pub/2021i0205/release/1?readingCollection=b956c163
[2] Kocifaj et al. 2021, Monthly Notices of the Royal Astronomical Society. “The proliferation of space objects is a rapidly increasing source of artificial night sky brightness” https://academic.oup.com/mnrasl/article/504/1/L40/6188393
[3] Bassa et al. 2024, Astronomy & Astrophysics. “Bright unintended electromagnetic radiation from second-generation Starlink satellites.” https://www.aanda.org/10.1051/0004-6361/202451856
[4] Grigg et al. 2023, Astronomy & Astrophysics. “Detection of intended and unintended emissions from Starlink satellites in the SKA-Low frequency range, and the SKA-Low site, with an SKA-Low station analogue.” https://www.aanda.org/articles/aa/full_html/2023/10/aa47654-23/aa47654-23.html
[5] As the recent “Presidential Message on the 35th Anniversary of the Hubble Space Telescope” reminds us, Hubble continues to serve “as a symbol of America’s unmatched exploratory might.” https://www.whitehouse.gov/briefings-statements/2025/04/presidential-message-on-the-35th-anniversary-of-the-hubble-space-telescope/
[6] Karpov & Peloton 2023, Contributions of the Astronomical Observatory Skalnate Pleso. “The rate of satellite glints in ZTF and LSST sky surveys” https://www.astro.sk/caosp/Eedition/FullTexts/vol53no4/pp69-80.pdf
[7] Krantz et al. 2023, Publications of the Astronomical Society of the Pacific. “The Steward Observatory LEO Satellite Photometric Survey.” https://iopscience.iop.org/article/10.1088/1538-3873/acf40c/pdf
[8] Hasan et al. 2022, Astronomy and Computing. “Mitigating satellite trails: A study of residual light after masking.” https://www.sciencedirect.com/science/article/pii/S2213133722000245?via%3Dihub
[9] Kruk et al. 2023, Nature Astronomy. “The impact of satellite trails on Hubble Space Telescope Observations.” https://www.nature.com/articles/s41550-023-01903-3
[10] Sharma 2024, NASA report TM-20240013276 “Impact of Spaceflight on Earth’s Atmosphere: Climate, Ozone, and the Upper Atmosphere.” https://ntrs.nasa.gov/api/citations/20240013276/downloads/NASA-TM-20240013276-V6.pdf
[11] Shutler et al. 2022. Nature Geoscience. “Atmospheric impacts of the space industry require oversight.” https://www.nature.com/articles/s41561-022-01001-5
[12] A piece of a SpaceX rocket fell on a farm in Washington State in 2021. Smithsonian Magazine, 13 April 2021 https://www.smithsonianmag.com/smart-news/after-fiery-display-spacex-debris-landed-washington-farm-180977494/
[13] Pieces of a SpaceX Crew Dragon cargo trunk fell in North Carolina in 2024. Space.com 25 June 2024 https://www.space.com/nasa-confirms-debris-spacex-crew-dragon
[14] The remains of a battery pack from the International Space Station punched through the ceiling and then floor of a home in Florida in 2024. Space.com 24 June 2024 https://www.space.com/space-debris-florida-family-nasa-lawsuit
[15] Wright et al. 2025. Nature Scientific Reports. “Airspace closures due to reentering space objects.” https://www.nature.com/articles/s41598-024-84001-2