April 13, 2026
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
via ICFS Electronic Filing
In re: Application for launch and operating authority for the Starcloud orbital datacenter system (ICFS File No. SAT-LOA-20260202-00073)
COMMENTS OF THE AMERICAN ASTRONOMICAL SOCIETY
The American Astronomical Society1 (AAS), the major organization of professional astronomers in the United States, submits these comments on the request by Starcloud, Inc. (the “Applicant”) to launch and operate a non-geostationary orbit (NGSO) system of up to 88,000 satellites.2
I. Introduction
AAS represents over 8,500 members across the United States, including professional and amateur astronomers. Its mission is “to enhance and share humanity’s scientific understanding of the universe as a diverse and inclusive astronomical community.”3 Both in previous FCC filings4 and in a 2025 statement by its Board of Trustees,5 AAS has articulated the ways in which the ongoing proliferation of large satellite constellations impacts astronomy and the night sky across a range of wavelengths. These include degradation or loss of astrophysical data and, concomitantly, fewer scientific discoveries. These effects represent both a material and an opportunity cost affecting billions of dollars worth of U.S. federal investment in the astronomy research enterprise, and thereby threaten significant harm to the members of our Society.
AAS has endeavored to work proactively with the U.S. commercial space industry to find collaborative solutions to problems through a mixture of voluntary and compulsory actions. Some companies have responded with design changes to their spacecraft that have reduced but not eliminated the aforementioned effects. Following direction by the Commission, some companies have also executed coordination agreements with the U.S. National Science Foundation (NSF) that are intended to make these voluntary efforts more durable.6
While we appreciate fruitful past engagement with satellite operators, the present Application is at odds with a spirit of cooperation and good will. The proposed action in this case involves numerous objects of unspecified but presumably very large size at higher orbital inclinations, which would therefore be visible for longer in the night sky. Their radio emissions, both intended and unintended, would similarly scale with the number of satellites in the constellation, giving rise to an increasingly noisy radio frequency environment that may imperil the radio astronomy service (RAS).
If granted, the regulatory approval the Applicant seeks could undermine decades of federal investment in astronomical facilities as well as the ability of astronomers and the public to enjoy and study the night sky. However, we note that fully and thoroughly assessing all impacts to astronomy would require far more detailed information than that in the filing and more time than the 30 days of the present comment period, and the impacts could indeed be much worse than those we describe here.
II. Impact on Optical and Infrared Astronomy
The sheer scale of the proposed Starcloud constellation, comprising up to 88,000 satellites in discrete, narrow orbital shells,7 presents a challenge to ground-based astronomy that is qualitatively and quantitatively different from any system currently in operation. Of particular concern is the Applicant’s selection of Sun-Synchronous Orbits (SSO) at altitudes between 600 km and 850 km with a nominal 06:00 crossing time.8,9 This “terminator orbit” configuration is designed to maximize solar illumination for the onboard computer hardware, but it simultaneously ensures that the satellites remain illuminated by the sun for more than 99% of their orbital periods.10 It means they will be illuminated throughout the entire night from the perspective of many ground-based observatories. Unlike satellites in lower or different inclinations that enter Earth’s shadow shortly after twilight, the Starcloud constellation will remain a constant source of streaks and artifacts in optical exposures at all hours,11 significantly degrading the quality of data for time-domain surveys and deep imaging12.
For major research facilities like the Vera C. Rubin Observatory, the sheer density of this constellation makes pointing avoidance impossible.13 Furthermore, the application notes that the system will rely on radiative cooling to manage the heat generated by its high-intensity artificial intelligence compute hardware.14 By design, these satellites will function as high-temperature radiators in Low Earth Orbit, creating an aggregate infrared background that threatens to blind sensitive infrared telescopes used for stellar and exoplanet research.15 While the Applicant states a commitment to brightness mitigation, the application lacks any specific technical details or binding requirements to limit thermal radiance to levels that would preserve the utility of the infrared sky for scientific research.
III. Impact on Radio Astronomy
While the Applicant intends to use optical inter-satellite links as its primary means of data transport,16,17 its proposed radio frequency operations present a significant risk to the radio astronomy service. The Applicant seeks authority to use the Ka-band spectrum in the 18.8–19.3 GHz (space-to-Earth) and 28.6–29.1 GHz (Earth-to-space) ranges.18 To facilitate these communications, the satellites will employ high-gain antennas with a boresight gain of 40 dBi for downlink transmissions and 45 dBi for uplink reception.19,20 While it is true that these bands are currently allocated to the fixed-satellite service in the respective directions, the vastly-increased scale of the proposed Starcloud operation will place unprecedented burdens on use of the bands. Compatibility with incumbent users must be studied across the radio spectrum.
The American Astronomical Society is concerned that the aggregate unintended electromagnetic radiation (UEMR) from 88,000 high-power computing nodes will create a new, prohibitive noise floor for radio telescopes.21 The Applicant has also requested a waiver of the Commission’s modified processing round procedures.22 We maintain that such a waiver should not be granted until the Commission performs a comprehensive study of the cumulative interference these satellites will pose to protected radio astronomy bands.23
IV. Atmospheric and Environmental Concerns
The operational lifecycle of the Starcloud constellation introduces long-term environmental hazards that remain unaddressed in the application. Each satellite has an estimated operational lifetime of only 5 years.24 Starcloud proposes atmospheric re-entry as the primary method of disposal for all 88,000 satellites.25,26 At this scale, maintaining the constellation will require de-orbiting approximately 17,600 satellites every year.27 The mass of aluminum and other metallic byproducts deposited into the stratosphere during these frequent re-entries could potentially alter the Earth’s thermal balance.28 Fine alumina particles at high altitudes can nucleate clouds and change the transparency of the mesosphere and stratosphere,29 potentially reducing the scientific output of ground-based astronomical observatories. Despite these risks, the application contains no formal Environmental Assessment regarding the aggregate atmospheric impact of this unprecedented launch and re-entry cadence.30
The Starcloud filing does not resolve the concerns regarding the orbital environment. It is true at any moment that 88,000 satellites would only inhabit a tiny fraction of orbital space, much as it is also true that the number of pixels blocked by a single streak in one image from a large facility like NSF-DOE Vera C. Rubin Observatory is also small. But satellites move very quickly, and small individual impacts do not equal small aggregate impacts. These satellites are travelling at LEO orbital speeds, about 7 km per second, and they will sweep out their orbits in about 90 minutes. Due to the criss-crossing orbits required by their chosen dense orbital configuration and constant orbital adjustments, close encounters (and, ideally, collision avoidance maneuvers) will occur frequently. To claim that one need not worry about orbital crowding is akin to claiming that racecar drivers don’t need to worry about crashing because the few cars that are racing take up very little of the total track area. While Starcloud does discuss interoperability of their collision avoidance systems, we still have concerns about crowding and coordinating the increasingly frequent required stationkeeping and collision avoidance maneuvers by many different operators, which will be critical to ensuring that low Earth orbit remains accessible to all, per U.S. treaty obligations.31
V. The Public Interest and Financial Accountability
The Commission’s public interest analysis must weigh the purported benefits of the Starcloud constellation against the significant and documented harms to the public and scientific community. In this regard, the Applicant’s own application reveals a fundamental conflict between its business model and the preservation of the night sky. Specifically, the applicant admits that its distributed computing system is “not economically viable at scale” without the high-duty cycle solar power provided by the requested sun-synchronous orbit with a 06:00 crossing.32 By the Applicant’s own admission, its financial success is predicated on occupying the very “terminator orbits” that maximize light pollution for ground-based observatories. This suggests that Starcloud has prioritized its internal power-generation costs over the externalized costs to the multi-billion dollar federal and international investment in astronomical research.
Furthermore, the Applicant seeks to evade the standard financial safeguards designed to ensure that large-scale NGSO operators remain accountable for their orbital footprint. The Applicant has requested a waiver of the Commission’s surety bond and milestone requirements.33 It argues that because its radio frequency use is “ancillary” to its computing mission, it should be exempt from the $5 million bond typically required to ensure that satellites are launched and de-orbited according to schedule.34 The American Astronomical Society (AAS) strongly opposes this request. For a constellation of 88,000 satellites, the risk of orbital “squatting” or the abandonment of dead hardware is unprecedented. Financial bonds are a critical tool for ensuring that an operator actually possesses the resources to manage the “design-for-demise” process it describes.
Finally, while the Applicant claims its satellites are designed to ensure the “kinetic energy of any surviving component is less than 15 Joules” upon re-entry,35,36 the sheer volume of de-orbiting events (estimated at 17,600 satellites per year) creates a cumulative statistical risk that the Commission’s current safety thresholds were not designed to handle.37 Granting a financial waiver to an operator proposing such a high-risk, high-volume atmospheric loading cadence is contrary to the public interest and the long-term sustainability of the space environment.
VI. Conclusion
For the reasons stated above, the American Astronomical Society respectfully requests that the Commission deny the Starcloud application in its current form. At a minimum, the Commission should stay its decision until Starcloud provides a rigorous, independently verified study on the aggregate impact of its constellation on the optical, infrared, and radio environments. The preservation of the night sky as a global scientific resource must not be sacrificed for the sake of industrializing Low Earth Orbit.
Thank you for your consideration.
On behalf of the American Astronomical Society,
Dara Norman, PhD
President, American Astronomical Society
1 The American Astronomical Society webpage: https://aas.org/
2 Narrative, In re Application of Starcloud, Inc. for Authority to Launch and Operate the Starcloud Orbital Datacenter System, File No. SAT-LOA-20260202-00073 (filed Feb. 4, 2026), at 1.
3 “AAS Mission and Vision Statement”, https://aas.org/about/mission-and-vision-statement.
4 See, e.g., “Comments of the American Astronomical Society in the Matter of Modernizing the Commission’s National Environmental Policy Act Rules (WT Docket No. 25-217)” https://www.fcc.gov/ecfs/document/10917024428266/1
5 “AAS Statement on Satellite Proliferation” (2025) https://aas.org/about/governance/society-resolutions/satellite-constellations
6 Nat’l Sci. Found., NSF Statement on NSF and SpaceX Astronomy Coordination Agreement (Jan. 10, 2023), https://www.nsf.gov/news/statement-nsf-astronomy-coordination-agreement
7 Narrative, supra note 2, at 1.
8 Narrative, supra note 2, at 1.
9 Technical Attachment, In re Application of Starcloud, Inc. for Authority to Launch and Operate the Starcloud Orbital Datacenter System, File No. SAT-LOA-20260202-00073 (filed Feb. 4, 2026), at 2.
10 Narrative, supra note 2, at 2.
11 See Petition to Deny of the American Astronomical Society, In re Space Bureau Accepts for Filing SpaceX’s Application for Orbital Data Centers, File No. SAT-LOA-20260108-00016 (filed Mar. 6, 2026), at 4.
12 Hainaut, O. Large or bright satellite constellations. Effects on observations, including on the background sky brightness. Astronomy & Astrophysics, in press, 2026.
13 Petition to Deny of the American Astronomical Society, supra note 11, at 4.
14 Narrative, supra note 2, at 1.
15 Petition to Deny of the American Astronomical Society, supra note 11, at 6.
16 Narrative, supra note 2, at 1.
17 Technical Attachment, supra note 9, at 1.
18 Schedule S, In re Application of Starcloud, Inc. for Authority to Launch and Operate the Starcloud Orbital Datacenter System, File No. SAT-LOA-20260202-00073 (filed Feb. 4, 2026), at 1.
19 Technical Attachment, supra note 9, at 2.
20 Schedule S, supra note 18, at 2.
21 Petition to Deny of the American Astronomical Society, supra note 11, at 8.
22 Waiver Requests, In re Application of Starcloud, Inc. for Authority to Launch and Operate the Starcloud Orbital Datacenter System, File No. SAT-LOA-20260202-00073 (filed Feb. 4, 2026), at 1.
23 Petition to Deny of the American Astronomical Society, supra note 11, at 11.
24 Schedule S, supra note 17, at 1.
25 Narrative, supra note 2, at 3.
26 Technical Attachment, supra note 9, at 4.
27 This figure is a calculation based on Starcloud’s total count of 88,000 satellites and their expected five-year satellite lifespan. In Petition to Deny of the American Astronomical Society, we previously noted that such volumes exceed current safety thresholds.
28 Christopher M. Maloney et al., Investigating the Potential Atmospheric Accumulation and Radiative Impact of the Coming Increase in Satellite Reentry Frequency, J. Geophysical Res.: Atmospheres, Mar. 2025, https://doi.org/10.1029/2024JD042442
29 Daniel M. Murphy et al., Metals from Spacecraft Reentry in Stratospheric Aerosol Particles, 120 Proc. Nat’l. Acad. Sci. U.S.A. e2313374120 (2023), https://doi.org/10.1073/pnas.2313374120, at 1. These metallic aerosols are highly effective at acting as ice-nucleating particles, which can lead to the formation of Polar Stratospheric Clouds (PSCs).
30 Petition to Deny of the American Astronomical Society, supra note 11, at 10.
31 Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, including the Moon and Other Celestial Bodies, art. II, Jan. 27, 1967, 18 U.S.T. 2410, 610 U.N.T.S. 205.
32 Technical Attachment, supra note 9, at 2.
33 Waiver Requests, supra note 21, at 3.
34 Waiver Requests, supra note 21, at 3.
35 Technical Attachment, supra note 9, at 5.
36 Orbital Debris Assessment Report (ODAR), In re Application of Starcloud, Inc. for Authority to Launch and Operate the Starcloud Orbital Datacenter System, File No. SAT-LOA-20260202-00073 (filed Feb. 4, 2026), at 8.
37 Petition to Deny of the American Astronomical Society, supra note 11, at 10.