May 19, 2026
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
via ICFS Electronic Filing
In re: Application for launch and operating authority for the Blue Origin orbital datacenter system (ICFS File No. SAT-LOA-20260310-00118)
COMMENTS OF THE AMERICAN ASTRONOMICAL SOCIETY
The American Astronomical Society (AAS), the major organization of professional astronomers in the United States, submits these comments on the request by Blue Origin, LLC, (the “Applicant”) to launch and operate a non-geostationary orbit (NGSO) system of up to 51,600 satellites operating as an orbital data center. AAS opposes this request and asks that the Commission deny the Blue Origin application.
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.” Both in previous FCC filings and in a 2025 statement by its Board of Trustees, 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 largely voluntary 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.
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 study and enjoy the night sky. However, we note that fully and thoroughly assessing all impacts to astronomy would require far more detailed information than is provided 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 Blue Origin constellation, comprising up to 51,600 satellites in discrete, narrow orbital shells, 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 500 km and 1,800 km with a nominal 06:00 crossing time., 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. 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 Blue Origin constellation will remain a constant source of streaks and artifacts in optical exposures at all hours, significantly degrading the quality of data for time-domain surveys and deep imaging.
For major research facilities like the NSF-DOE Vera C. Rubin Observatory, the sheer density of this constellation makes pointing avoidance impossible. Furthermore, the application notes that the system will rely on radiative cooling to manage the heat generated by its high-intensity compute hardware. 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 instruments used for stellar and exoplanet research. 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,, 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., While it is true that these bands are currently allocated to the fixed-satellite service (FSS) in the respective directions, the vastly-increased scale of the proposed Blue Origin system amplifies the risk of spurious emissions in bands that are not allocated to the FSS. Compatibility with incumbent users must be studied across the radio spectrum.
The American Astronomical Society is concerned that harmonic emissions, including fourth-order and higher harmonics that fall within protected radio astronomy bands, and aggregate unintended electromagnetic radiation (UEMR) from 51,600 high-power computing nodes will create a new, prohibitive noise floor for radio telescopes. This potential threat underscores the need for careful design of the downlink signal path to ensure compliance with emission masks not only at and in the vicinity of the fundamental frequencies, but also at harmonic frequencies, and to account for aggregate interference effects. The Applicant has also requested a waiver of the Commission’s modified processing round procedures. 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.
IV. Atmospheric and Environmental Concerns
The operational lifecycle of the Blue Origin constellation introduces long-term environmental hazards that remain unaddressed in the application. Blue Origin proposes atmospheric re-entry as the primary method of disposal for all 51,600 satellites. The mass of aluminum and other metallic byproducts deposited into the stratosphere during these re-entries could potentially alter the Earth’s thermal balance. Fine alumina particles at high altitudes can nucleate clouds and change the transparency of the mesosphere and stratosphere, 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.
The Blue Origin filing leaves concerns regarding the orbital environment. 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. While Blue Origin does discuss interoperability of their collision avoidance systems, we still have concerns about crowding and the challenge of coordinating the increasingly frequent required stationkeeping and collision avoidance maneuvers by many different operators, particularly in the highly sought-after sun-synchronous orbits, which will be critical to ensuring that low Earth orbit remains accessible to all, per U.S. treaty obligations. The assurances in the application are not supported by any details, such as what range of orbital densities of large objects or small debris will be assumed in an era of exponentially increasing numbers.
V. The Public Interest
The Commission’s public interest analysis must weigh the purported benefits of the Blue Origin constellation against the significant and documented harms to the public and scientific community. With 51,600 satellites in highly visible orbits, preservation of access to the dark night sky would become extremely challenging. By the Applicant’s own admission, its technical (and financial) success is predicated on occupying the very “terminator orbits” that maximize light pollution for ground-based observatories. The acknowledgement of planned efforts to reduce the impacts on astronomy is certainly appreciated; however, with the large size, reflectivity, and thermal brightness of these satellites, extraordinary measures would be required to achieve any meaningful mitigation.
Finally, while the Commission’s safety thresholds generally require that the kinetic energy of any surviving component be less than 15 Joules, the Applicant has failed to provide a formal Orbital Debris Assessment Report (ODAR) or specific technical data in its Annex to certify compliance with this standard. We are therefore unable to assess the potential risk to the public posed by the action the Applicant proposes. The sheer volume of de-orbiting events therefore may create a cumulative statistical risk that the Commission’s current safety thresholds were not designed to handle. The AAS is concerned that a potentially risky, high-volume atmospheric loading cadence requires further assurance that the project is not 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 Blue Origin application in its current form. At a minimum, the Commission should stay its decision until Blue Origin provides a rigorous, independently verified study on the aggregate impact of its constellation on the optical, infrared, and radio environments. Astronomers’ past and continued engagement with satellite operators has shown that commercial space and astronomy interests can coexist, but this Application does not reassure us that mitigations to minimize impacts on taxpayer-funded facilities and research have been adequately considered.
Thank you for your consideration.
On behalf of the American Astronomical Society,
Dara Norman, PhD
President, American Astronomical Society