March 30, 2026
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the matter of Reflect Orbital Application to construct and launch an NGSO Satellite (ICFS File No. SAT-LOA-20250701-00129)
REPLY COMMENTS OF THE AMERICAN ASTRONOMICAL SOCIETY
The American Astronomical Society1 (AAS), the major organization of professional astronomers in the United States, respectfully submits this reply in response to the consolidated opposition and response to comments (the “Opposition”) filed by Reflect Orbital2 regarding its application to construct, launch and operate the satellite EARENDIL-1 (the “Application”).
The Opposition urges the Commission to dismiss and deny the Petition from AAS on the grounds that the Application is for a single “pathfinder” satellite and any inconvenience will be de minimis, that Reflect Orbital has been engaged in discussions with the astronomical community, and that EARENDIL-1 does not require an Environmental Assessment (EA). However, as we demonstrate below (and in our original Petition), the single proposed satellite still carries potential for significant harm to professional and amateur astronomy as well as to the general public and various natural ecosystems, including an admission in the Opposition that EARENDIL-1 is capable of causing direct harm to individuals. We further show that Reflect Orbital has failed to answer several key questions that would help the astronomical community and the Commission assess the extent of such harm. While we assert that EARENDIL-1 is subject to an EA as a satellite that is aiming to alter the human environment by intentionally providing illumination at night, we urge the Commission to deny the Application even if it does not require an EA, given that the proposed system does not serve the public interest.
The Petition to Deny from AAS should neither be dismissed nor denied because it satisfies the Commission’s threshold requirements and raises issues that warrant substantive review. It presents specific, fact-based concerns tied to the operation of the proposed system, establishes the AAS as a party of interest given its direct stake in access to the night sky, and clearly connects those concerns to the FCC’s public interest standard. This petition also identifies the satellite EARENDIL-1 as a novel class of activity that has not been previously evaluated and raises reasonably foreseeable cumulative impacts. Taken together, that is precisely the kind of circumstance where the Commission should engage on the merits and consider whether further review is required, rather than resolving the matter procedurally or dismissing the concerns as de minimis.
I. A single satellite would still create the potential for significant physical harm to many Americans and American research facilities
While the 50,000 satellite constellation featured on Reflect Orbital’s website would be disastrous for professional and amateur astronomy, human health, and ecology, the single satellite proposed in the Application would still have significant negative impacts on astronomy and the human environment. Indeed, the AAS petition to deny was focused much more on the impacts of a single satellite than is acknowledged by the Opposition. In the Opposition, Reflect Orbital even recognizes the potential for negative impacts from their proposed satellite, stating, “collected data [from the first deployment] will help Reflect Orbital refine its technology to ensure better precision and control, as well as mitigate potentially unwanted effects, should they arise.” There is also recognition that errant light is expected – “To reduce incidental dispersions of light, Reflect Orbital will continuously model and monitor EARENDIL-1 brightness during both the active reflection and passive non-reflection stages.”
The light from EARENDIL-1 will not simply be a de minimis inconvenience. Unlike existing satellites, which produce incidental reflections, the proposed system is designed to introduce targeted, high-intensity illumination into the night sky. Even a single such source, when passing through the field of view of modern astronomical instruments, can saturate detectors and interrupt time-sensitive observations. These effects follow directly from well-understood detector physics and atmospheric scattering. The satellite is expected to be at least as bright as the full moon, which is well known to scatter light over wide areas of the sky and wash out the signals of faint astronomical sources, limiting astronomers’ ability to conduct observations on full-moon nights. In fact, new-moon nights are highly oversubscribed on many astronomical facilities, because many studies – especially of objects with low surface brightnesses – cannot be done when the full moon is in the sky, or sometimes when the moon in any phase is above the horizon at all.
Even though the planned reflection concentrates the reflected sunlight, the sky will be brightened around the EARENDIL-1 beam, requiring telescopes to avoid recording the light from targets during both the passage of the satellite and its halo. As mentioned above, Reflect Orbital itself acknowledges the potential for incidental reflections of light, which would impact astronomical facilities regardless of whether exclusion zones are maintained around them. If EARENDIL-1 inadvertently aims its beam at an observatory, it could easily damage or disable sensitive and expensive detectors, particularly infrared instruments. For example, pointing at Jupiter or Venus (both thousands of times fainter than the expected brightness of EARENDIL-1) can saturate HgCdTe infrared sensors and cause persistence issues that make the sensors unusable for a full night. These detectors are not commodity items; several detector types cannot simply be replaced, and thus their incapacitation would not be merely a de minimis “inconvenience”. As discussed in our Petition, EARENDIL-1 would be brightest just after sunset and before sunrise, which is a critical time for observing and detecting potentially hazardous asteroids that could collide with Earth. Limiting the ability of astronomical facilities to carry out these observations poses a direct threat to ongoing planetary defense initiatives.
The Commission’s public interest standard includes consideration of interference, safety, and unintended impacts on third parties. We are astonished at the Opposition’s argument that damage to human vision will be limited to those citizens using telescopes of only a certain size (12 inches or larger, per footnote 41 of the Opposition). This limit translates to physical risk to a sizable fraction of the amateur astronomy community, as well as astronomy students learning to use telescopes and the professional astronomers teaching them. Moreover, the assertion that harm would only be done to citizens using telescopes that are 12 inches or larger has not been peer reviewed in any way, and is at odds with alternative calculations that imply damage from much lower concentrations of light energy (e.g., by binoculars; see Appendix A). The Opposition’s argument is a direct admission of potential harm, for which coordination and pointing avoidance cannot practically afford mitigation. We note that U.S. military, border patrol, and police use of night vision equipment puts those personnel at particular risk of flash blinding, in addition to the risks to pilots and drivers. For example, the National Transportation Safety Board determined that the 2025 Potomac River mid-air collision occurred in part because the helicopter crew was using night vision goggles, which are subject to washout and “blooming” from bright light sources.3 Again, we take issue with the assertion that these impacts are “de minimis.”
A single satellite with a brightness comparable to the full moon can also impact wildlife and ecological health.4 Artificial light at night is well documented to disrupt a wide range of ecological systems,5 including species that rely on natural light cues at lighting levels comparable to the beam from EARENDIL-1.6 Although the Applicant has emphasized that its service is redirected natural sunlight and not artificial light,7 the introduction of that light into the nighttime environment is unnatural. In the NEPA context, it is the alteration of the environment that matters, regardless of the physical source of the light.8 While the specific effects of a steerable orbital light source have not been studied, the introduction of novel, high-intensity illumination into nocturnal environments presents plausible risks that warrant careful evaluation before deployment. Therefore, the AAS believes that further impact studies are needed before the absence of damage to critical habitats can be asserted and a license can be granted.
The Opposition draws a highly misleading analogy to the International Space Station (ISS). Unlike the ISS, EARENDIL-1 is a steerable reflector aiming to concentrate and redirect sunlight towards the Earth. Reflections from the ISS are passive and unintentional, and more importantly, orders of magnitude fainter than the expected brightness of EARENDIL-1. EARENDIL-1 is expected to be at least as bright as the full moon, which has a visual magnitude of -12.6 (we calculate that its peak brightness will be -14.6 mag). A visual magnitude of -12.6 is approximately 2700 times brighter than an average ISS visual magnitude of -4.9 There is no logical or legal comparison between the intentional focusing of sunlight on the Earth and the incidental reflection of sunlight from a functioning satellite. Reflect Orbital cannot reasonably claim that there will be no negative impact from the Application based on experience with the ISS.
Finally, the Objection states, “To date, the United States—and the Commission in particular—has not adopted any regulations limiting the reflectivity of or resulting from spacecraft.” However, the Commission has required multiple satellite operators to execute coordination agreements with the National Science Foundation (NSF) to minimize impacts to optical and radio astronomy– a precedent of which the AAS is deeply appreciative. These coordination agreements include commitments to reduce the optical brightness of satellites. For example, the SpaceX coordination agreement includes a commitment to “continuing to work to reduce the optical brightness of their satellites to 7th visual magnitude or fainter by physical design changes, attitude maneuvering, or other ideas to be developed.”10 However, Reflect Orbital would not be able to reduce the optical brightness of EARENDIL-1 even if it were to sign a coordination agreement with the NSF, as its proposed use case involves making satellites as bright as possible.
Although Reflect Orbital’s Application seeks authorization for a single satellite, it represents the first instance of a system intentionally designed to deliver artificial daylight at night. The Commission’s decision here will establish a precedent governing future deployments of similar systems at scale and therefore must be evaluated in light of reasonably foreseeable future expansion. Limiting review to a single satellite without adequate consideration of the public interest would fail to capture the cumulative impacts and physical harm caused by this emerging class of systems.
II. Reflect Orbital has failed to address concerns or answer questions from the astronomical community
Reflect Orbital notes “productive” initial discussions with the AAS and other stakeholders; however, in meetings that astronomers attended voluntarily, Reflect Orbital did not meaningfully or adequately answer questions about the properties of its mirror, the impacts of atmospheric scattering, the brightness of the mirror during repointing every 4 minutes, or any meaningful mitigation strategy to avoid damaging or disabling sensitive astronomy equipment, flash-blinding people, or causing permanent eye damage. The AAS has still not received any information, including in the Opposition, about how exclusion zones will be chosen, and how the Applicant plans to avoid these zones in practice. Furthermore, de-tensioning or mechanical failure of the mirror would cause the beam to de-focus and potentially spill light over thousands of kilometers, making exclusion zones useless. The AAS also has not received information about the sites at which EARENDIL-1 will be tested, which is necessary for evaluating what the impacts of this satellite will be.
While its initial discussions with the AAS may have been “productive” for Reflect Orbital, by allowing it to formulate a series of “guiding principles” that create the appearance of cooperation with the astronomy community, these discussions have not been equally productive for the AAS. The lack of meaningful two-way communication and Reflect Orbital’s failure to share essential information, whether through the provision of simulations and data or otherwise, does not give the AAS confidence that our concerns will be addressed through future discussions or partnerships if the Application is approved. Moreover, it appears that Reflect Orbital has also drawn incorrect conclusions from its conversations with astronomers, as shown by the demonstrably false claim on its website that satellites will “reduce light pollution.”
III. An environmental impact assessment is needed for an informed decision by the Commission
In the sections above, we have outlined multiple ways in which EARENDIL-1 could have a significant impact on the human and natural environment. While the Commission has historically applied categorical exclusions under NEPA to satellite licensing11, those exclusions are not absolute. Under NEPA and the Commission’s own rules12, extraordinary circumstances — including novel technologies or previously unexamined environmental effects — require further review.13 We believe that an environmental assessment must be undertaken to quantify the potential impacts of EARENDIL-1 as a novel technology. The FCC, in its recent rulemaking (WT Docket No. 25-217), notes that, “The NEPA statute states broadly that the federal government should seek to preserve the nation’s natural and cultural environment in order to ensure the health, safety, and productivity of the American people.”
Given that the Applicant is explicitly aiming to alter the human environment through the provision of sunlight at night, and that its Opposition includes a direct admission of potential physical harm, we believe an environmental review is warranted. In fact, the Opposition acknowledges that an environmental assessment might be needed for future deployments of satellites by the company, but provides no clear reason why the proposed satellite should be excluded from such an assessment. The current Application constitutes an “extraordinary circumstance” under NEPA because it involves the intentional alteration of the human environment through high-intensity light projection, rather than incidental reflection. Furthermore, the potential for direct physical harm (such as flash-blinding and permanent eye damage) and the cumulative impact of a reasonably foreseeable future expansion to 50,000 satellites create significant environmental risks that cannot be legally disregarded via a blanket categorical exclusion. Current regulatory frameworks were developed for satellite systems whose environmental impacts were incidental to their function. This application represents a categorical shift: environmental impact — specifically, the intentional alteration of the natural night environment — is the product itself. Existing categorical exclusions were not designed to evaluate such systems.
In fact, as outlined above, even a single deployment creates environmental impacts that are not well characterized and may be significant in specific contexts, particularly given the intensity and intentionality of the proposed illumination. Without more details regarding Reflect Orbital’s plan to test EARENDIL-1, we cannot accept the statement that EARENDIL-1 will not be carrying out any activities that would require an EA under Section 1.1307(a) of the Commission’s rules. Even if the intentional illumination of sites by EARENDIL-1 avoids officially designated wildlife areas, wildlife preserves, and critical habitats in its large beam spanning 20 square kilometers, there is no guarantee by the company that errant light will not fall in these areas.
The AAS is not proposing an environmental assessment as an “administrative roadblock” (as suggested by the Opposition14), but rather to quantitatively determine whether the suspected effects of the EARENDIL-1 beam and halo will cause physical harm and damage to public infrastructure or not. Without such a quantitative assessment to determine the risks posed by the proposed satellite, we urge the Commission to deny the Application as a common sense measure to ensure that the proposed illumination does not result in significant harm to humans and wildlife.
IV. The proposed satellite is not in the public interest
The Objection states that the Commission should dismiss or deny claims that are not associated with the requested use of spectrum by the Applicant; however, the Commission has a mandate to ensure that it grants applications that serve the public interest. If a company were to apply for a license to carry out Telemetry, Tracking, and Command (TT&C) for a satellite intentionally producing debris in orbit, the FCC would not be required to grant the license simply because the proposed spectrum use was innocuous. This Application involves the use of spectrum for TT&C of a satellite that has the potential for significant harm to the public in numerous ways, and therefore should not be granted by the FCC.
The proposed satellite will intentionally reflect sunlight to the Earth’s surface after dark, making it fundamentally different from satellites that unintentionally reflect sunlight off their surfaces while providing a different service (e.g. telecommunications). Moreover, EARENDIL-1 will be many, many orders of magnitude brighter than any commercial satellites (for example, EARENDIL-1 would be 10 million times brighter than a typical Starlink satellite with a visual magnitude of approximately +5). As discussed above, even the beam from a single satellite with a brightness similar to that of the full moon has the potential to damage or disable sensitive and expensive taxpayer-funded astronomical equipment, severely flash-blind anyone looking through a small telescope, and disrupt ecological systems. Such impacts, especially the latter two, cannot be easily avoided through the implementation of exclusion zones. It is also unclear how Reflect Orbital can possibly provide prior notification to everyone who happens to be in EARENDIL-1’s zone of illumination, spanning nearly 20 square kilometers, or along the much longer ground track as the satellite repositions itself. Moreover, Reflect Orbital admits in its Opposition that errant illumination is possible from this pathfinder satellite. As noted in our Petition, sudden bright lighting can disrupt the vision of pilots and drivers, posing a serious threat to public safety.
In light of such serious concerns, Reflect Orbital fails to offer a compelling reason why the proposed satellite would serve the public interest. The Objection notes the ability to deploy “innovative satellite technology” and “advancing U.S. leadership in energy research in space” as well as the claim that the public interest would be advanced through “the Application’s contributions to the continued technological and scientific innovation and American leadership in space.” However, this satellite would not be carrying out energy research in space, as Reflect Orbital notes on its own website that only a vast future satellite constellation would lead to any meaningful solar energy generation on Earth. Moreover, any technological and scientific innovation could come at the cost of U.S. scientific leadership in other domains, including the damage to sensitive equipment hosted by both ground-based astronomical facilities, and low Earth orbit telescopes such as the Hubble Space Telescope, which is a hallmark of American leadership in space. The Application Narrative states that Reflect Orbital received over 250,000 applications for service, but these applications were received through a simple online webform to “reserve a spot of light,” with no checks to ensure that requests would not be disturbing anyone else in the service area.
As stated by the Applicant, the sole purpose of the Application is to demonstrate and refine this novel technology in service of the ultimate deployment of multiple units. The Objection’s argument that one satellite is minimally disruptive (which we show to be false in Section I) deflects from the issue that the purpose of the first satellite is to create the conditions for launching a constellation, which would be highly disruptive. The Applicant cannot simultaneously appeal to the public interest that would (allegedly) be served by a larger constellation while arguing that concerns about a larger constellation should be dismissed in the context of its present Application. With no evidence that a single satellite will (by itself) serve the public interest, and ample evidence of its likely negative impacts, the Application for a single pathfinder satellite is effectively an example of spectrum warehousing and should be denied.
V. Summary
The over 1,800 responses submitted during the public comment period on the Application include comments submitted and/or signed by professional organizations collectively representing hundreds of thousands of scientists across the country and the world. These include, in addition to the AAS, the American Geophysical Union, the Ecological Society of America, the Entomological Society of America, the American Physical Society, and the American Physiological Society, among many others. These comments all warn of severe consequences to a range of scientific domains, to human health, and to the environment from Reflect Orbital’s proposed activities. We urge the Commission to recognize why such an unprecedented number and breadth of individuals and groups have taken the time to submit responses in this docket. We are acting on our responsibility as scientists to protect the health and safety of people, animals, the environment, and the research enterprise, while communicating facts, conclusions, and uncertainty honestly, clearly, and transparently.15
While we are very appreciative of the Commission’s practice of requiring satellite operators to execute coordination agreements with the National Science Foundation to protect optical and radio astronomy, and while in this case, a coordination agreement would be helpful in addressing some of our concerns (particularly the potential for the EARENDIL-1 beam to damage sensitive astronomical instruments), it would not address all of our concerns, including potential impacts on and physical harm to amateur astronomers, pilots and drivers, and wildlife. While the Commission may accept the Applicant’s assertion that the impact on the environment of illumination by a single satellite will be minimal, we urge the Commission to instead recognize that risks are not fully understood, could be substantial in specific sensitive areas, and would no doubt become more substantial if the Applicant’s stated intention of deploying a larger constellation became a reality. We emphasize that a license in the public interest urgently requires further impact studies before the absence of damage to critical habitats and human safety can be asserted.
In light of the above, we reiterate that the Application, even for a single satellite, is not in the public interest, and in fact, that satellite could cause real harm to members of the public and public infrastructure (such as astronomical facilities). We therefore urge the Commission to deny the application.
Thank you for your consideration.
On behalf of the American Astronomical Society,
Dara Norman, PhD
President, American Astronomical Society
Appendix A: Calculations of Optical Hazards from EARENDIL-1
The Opposition’s treatment of optical hazards imposed by space mirrors such as EARENDIL-1 is very concerning. First, the calculations in the cited Laframboise and Chou paper16 are themselves correct and self-consistent. To downplay the risks, the Opposition applies radiation thresholds derived from laser exposure testing and then seems to confuse the optical relations for determining an image size with the terms “extended” and “point” sources as used in an energy dissipation sense for the eye (again when considering laser exposure limits). The eye has a resolution of approximately 1 arcmin. For reference, the letters on a Snellen eyesight chart for 20/20 vision have sizes of 5 arcmin (1.5 mrad). The 1.5 mrad threshold for an “extended” image used by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) is the point at which heat dissipation is limited by the size of the illuminated spot. Modest telescopic instruments are able to achieve image magnifications that would exceed the 5 arcmin threshold when viewing EARENDIL-1. Indeed, at a diagonal size of about 25 m, when viewed near zenith, magnifications over 35 will become problematic based on the 5 arcmin threshold cited by the Opposition. Moreover, even modest aperture telescopes of about 10 cm (4 in) are of concern for being able to deliver sufficient energy to a 25-um retinal image to cause damage. The statement by the Opposition that up to a 12 in aperture telescope can be used to view EARENDIL-1 is very concerning, and not backed up by peer-reviewed calculations.
CERTIFICATE OF SERVICE
I, Roohi Dalal, hereby certify that on this 30th day of March, 2026, I have caused a copy of the foregoing Reply Comments to be served as specified upon the parties below:
Jodi A. Goldberg
1200 Seventeenth Street N.W.
Washington, DC 20036
/s/ Roohi Dalal
Roohi Dalal, PhD
Deputy Director of Public Policy
American Astronomical Society
1 The American Astronomical Society webpage: https://aas.org/
2 Consolidated Opposition and Response to Comments of Reflect Orbital (filed March 25, 2026) (the “Opposition”)
3 National Transportation Safety Board, AIR-26-02, Aviation Investigation Report: Midair Collision Over the Potomac River (2026) at 72, https://www.ntsb.gov/investigations/AccidentReports/Reports/AIR2602.pdf (noting that when viewed through night-vision googles “an aircraft with a particularly bright position or landing light may appear to be closer, even if it is actually behind another aircraft”.).
4 M. Czarnecka et al., Colours of the Night: Spectrum-Specific Impacts of Light Pollution on Biota, 31 Global Change Biology e70569 (2025), https://doi.org/10.1111/gcb.70569 (establishing that “even low light levels (< 5 lx) can cause substantial biological disruptions”).
5 DarkSky Int’l, Artificial Light at Night: State of the Science (2025), https://doi.org/10.5281/zenodo.15492393.
6 M. Grubisic et al., Light Pollution, Circadian Photoreception, and Melatonin in Vertebrates, 11 Sustainability 6400 (2019), https://doi.org/10.3390/su11226400 (documenting melatonin suppression in some vertebrate species exposed to artificial light at night with illuminance values 30 times less than that of full moonlight).
7 Consolidated Opposition and Response to Comments of Reflect Orbital Inc., supra note 2, at 4.
8 40 C.F.R. § 1508.1(g) (“Effects or impacts means changes to the human environment from the proposed action or alternatives that are reasonably foreseeable…”); 40 C.F.R. § 1508.1(m) (in which the ‘human environment’ is defined as “comprehensively the natural and physical environment and the relationship of present and future generations of Americans with that environment.”); 42 U.S.C. § 4331(b)(2) (NEPA’s national policy goals emphasize the end result (the quality of the surroundings) rather than the type of pollutant).
9 Note that a lower (including more negative) visual magnitude represents a brighter object.
10 U.S. National Science Foundation. (2023 January 10). NSF Statement on NSF and SpaceX Astronomy Coordination Agreement. https://www.nsf.gov/news/statement-nsf-astronomy-coordination-agreement
11 U.S. Government Accountability Office, GAO-23-105005, Satellite Licensing: FCC Should Reexamine Its Environmental Review Process for Large Constellations of Satellites (2022) (recommending that the FCC review and document whether its categorical exclusion should still apply to large constellations).
12 40 C.F.R. § 1501.4.
13 See, for example, United Keetoowah Band of Cherokee Indians in Okla. v. FCC, 933 F.3d 728 (D.C. Cir. 2019)
14 Consolidated Opposition and Response to Comments of Reflect Orbital Inc., supra note 2, at 8.
15 American Geophysical Union (2017). The Responsibilities and Rights of Scientists. https://www.agu.org/-/media/Files/Share-and-Advocate-for-Science/Position-Statements/AGU-Responsibilities-and-Rights-of-Scientists-Position-Statement-Adopted-2017-1.pdf
16 Laframboise, J. and Chou, B. Ralph. (2000). “Space Mirror Experiments: A Potential Threat to Human Eyes.” Journal of the Royal Astronomical Society of Canada, Vol. 94, pp. 237-240.