March 9, 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)
PETITION TO DENY OF THE AMERICAN ASTRONOMICAL SOCIETY
The American Astronomical Society1 (AAS), the major organization of professional astronomers in the United States, submits this Petition to deny the request by Reflect Orbital (RO) for authority to construct and launch a new non-geostationary orbit (NGSO) satellite “EARENDIL-1.”
I. Introduction
The AAS represents over 8,500 members across the United States, including both professional and amateur astronomers. Our membership includes leading experts in the astronomical and physical sciences, providing the AAS with the unique technical standing to evaluate the impacts of the proposed EARENDIL-1 mission. See Appendix 1 for a detailed justification of standing.
The AAS asserts that the mission, as proposed, fails to meet the public interest standard required for Commission licensure. While the AAS supports U.S. commercial space innovation, the potential for catastrophic interference with federally funded astronomical research, in addition to potentially serious impacts to human health and the Earth’s environment, outweigh the limited experimental utility of this specific filing. The Commission has a responsibility to protect the integrity of billions of dollars in federal investment used to build and operate facilities that would be negatively impacted by this satellite.
Unlike the passive reflections from standard NGSO satellites, the RO full operational model is designed with the deliberate aim of disrupting the natural dark sky at night. Given that this disruption is the intended outcome, rather than an incidental byproduct, and that even a single satellite threatens to create an immediate and detrimental impact on ground-based optical astronomy, the AAS petitions that this license application be denied. Should the significant long-term risk not be considered obvious prima facie, the AAS further argues that a rigorous impact assessment of the potential far-reaching effects of such redirection of light should be a necessary prerequisite to granting any operational or experimental authority.
Below, we describe the expected effects of the anticipated RO operational model on professional astronomy and amateur astronomy, as well as the potential for light trespass and far-reaching effects on the health of humans and other forms of life.
II. Impacts on Professional Astronomy
An individual RO satellite like EARENDIL-1 is expected to have an optical brightness of at least 2 to 4 times that of the full Moon.2 If objects of this brightness passed through the field of view of a telescope, they would completely overpower the signal from astronomical objects and in many cases saturate the detectors, causing a total loss of the image. In addition, they could also result in a significant extended loss of observing time while highly sensitive detectors recover from the over-illumination before images can be taken again. Astronomy would thus be gravely affected, including critical observations of time-variable phenomena: for which when targets are observed matters as much as which targets are observed. With even a small number of these giant mirrors deployed, mitigation of these effects would require pointing avoidance maneuvers that would be highly disruptive to the scheduling efficiency of observatories; if a significant constellation were deployed, pointing avoidance would become infeasible. In effect, entire regions of the sky would need to be avoided and thus become inaccessible to ground-based astronomy. Although pointing coordination with a limited list of the largest professional telescopes is possible in principle,3 astronomical science is pursued using telescopes with a range of sizes at multiple observatories in numerous sites. The negative impact of artificially projecting sunlight at night would be unavoidable for the scientific enterprise as a whole.
Compounding the impact of the rapid passage through the sky of the orbiting mirrors, reflected sunlight of the resulting intensity will produce a significant halo of light around each satellite because of the scattering properties of the Earth’s atmosphere. For example, immediately adjacent to the sharp edge of the full Moon, the sky is 10,000 times brighter than a dark sky with no Moon. We expect a similar level of brightness surrounding EARENDIL-1. Should an RO satellite mirror be detensioned (as proposed) in the course of routine operations, the distribution of its scattered light would be significantly broader than that resulting from the sharp edge of the mirror in active operation. The area on the ground impacted by the reflected sunlight would therefore be far greater than that for a directly illuminated target. Exactly what area on the sky would be impacted by significant excess light would depend on the direction from which the satellite was viewed and how far below the horizon the Sun was after sunset. However, the period between nautical and astronomical twilight most likely to be impacted (when the Sun traverses 12 degrees to 18 degrees below the horizon) is key for time-critical observations.
EARENDIL-1 (and its scattered light) would be brightest when it is low on the horizon. This attribute translates to elevated impacts on target fields that are low in the sky, which are critical for planetary defense and space situational awareness – i.e., detecting and characterizing near-Earth asteroids that could collide with our planet, and tracking the orbits of satellites and debris for strategic purposes. These are congressionally mandated priorities for NASA and the Department of Defense, respectively. In addition, many time-critical astronomical observations of faint objects would be precluded in significant and critical areas low in the sky after sunset and before sunrise. Specific examples include rare supernovae, merging neutron stars corresponding to sources of gravitational waves, and other transient sources of radiation of unknown origin. Among the facilities that will study such “time domain” phenomena is the newly operational NSF-DOE Vera C. Rubin Observatory, which will issue alerts every night as it detects objects that change in brightness and that can be targeted for urgent follow-up observations with other telescopes. Expected impacts on astronomy also go well beyond the Rubin Observatory: in 2025, the AAS circulated a survey to the community to better understand the anticipated effects of Reflect Orbital’s operational model. Of the 2,024 individual astronomers (professional and amateur) who responded, 80% expected their work to be impacted by a satellite or constellation of satellites like those proposed by Reflect Orbital. Over 45 observatories and scientific societies also indicated they expected their stakeholders to be impacted by such a satellite or satellite constellation, with one observatory citing “decreased productivity, loss of sensitivity due to columns of scattered light, [and] potential damage to detectors” as their main areas of concern.
III. Impacts on Non-Professional Astronomical and Stargazing Communities
The activities proposed by RO would also have severe impacts on amateur astronomy. There are 100,000–200,000 amateur astronomers in the United States, 40,000–50,000 of whom are members of amateur astronomy clubs. Amateur astronomers routinely observe astronomical objects through binoculars or small telescopes. It has been shown that orbital mirrors that reflect solar radiation to the Earth’s surface—with sizes and properties similar to those proposed by RO—can be a serious retinal hazard if viewed with even modest magnification, leading to permanent damage to vision.4 Astrophotographers often use equipment with designs similar to those used by professional astronomers (see Section II) and therefore are also at risk of ruined images/data from RO satellites during their observations.
Finally, bright sweeping beams of light can be distracting and disrupt night vision, causing a potential hazard to drivers and civil and military pilots. The disruption of vision by sudden bright lights in dark environments has already been recognized as a threat to aviation, e.g., in the context of laser strikes.5
IV. Difficulty in avoiding light trespass beyond intended service-area
“Light trespass” can be legally classified in most states as a private nuisance,6 if illumination outside of property lines causes substantial and unreasonable interference with a property owner’s use or enjoyment of their property. RO satellites are intended to provide “sunlight-as-a-service” to paying customers who opt-in to having sunlight reflected onto their properties. However, in order to switch service from one paying customer to another, the RO satellite(s) will have to execute slews, moving beams between two ground targets. During these slews, bright illumination from the RO satellites will pass over many properties that have not opted-in nor consented to this illumination, potentially constituting light trespass. This impact is particularly relevant for stakeholders for whom such illumination would represent “substantial and unreasonable interference,” including professional astronomers at observatory sites (Section II) and amateur astronomers and astrophotographers (Section III), as well as pilots and drivers (Section III). The threat here is exacerbated by the fact that the beam of an RO satellite (like EARENDIL-1) is expected to be at least 5 km in diameter on the ground.7 In developed areas, it is unlikely that all residents who find themselves within a Reflect Orbital beam will welcome or approve of such illumination (particularly in the dark night well past twilight). The level of private nuisance here makes it clear that the service that would be enabled by this proposal is not in the public interest.
A relevant precedent here is 51 U.S. Code § 50911, which prohibits license-holders from launching payloads containing any material to be used for the purpose of obtrusive space advertising, defined as “advertising in outer space that is capable of being recognized by a human being on the surface of the Earth without the aid of a telescope or other technological device.”8 In other words, the intentional projection of light where it is not wanted is considered a form of legal trespass. We note again that each individual RO satellite will have a brightness greater than that of the full moon, and will be easily visible to the human eye without the aid of a telescope.
It is not clear from the filing whether there are any potential engineering mitigations being considered by RO to avoid light trespass during slews, but given the publicly available design constraints, we do not see any way that this outcome can be avoided. Even if Reflect Orbital were to “defocus” the beam, the reflective surface of the satellite would continue to act as a diffuse Lambertian sphere and could easily be bright enough to cause significant disruption of astronomical research activities and stargazing, as well as significant distractions for pilots and vehicle operators. Detailed, publicly available modeling and measurement would be required to support any assertion that meaningful mitigation would even be possible.
V. The health and environmental impacts of artificially extended sunlight
During the day, natural life on Earth experiences significant amounts of blue-wavelength emission from the Sun. When the sun sets, almost all living species on Earth experience natural biological shifts due to changes in perceived light-level and color. For example, the human eye shifts to low-level detecting sensors called rods, and our bodies begin to secrete the hormone melatonin, which regulates our sleep. In 2016, the American Medical Association (AMA) produced a report,9 based on an overwhelming amount of research, indicating that regular exposure to artificial light at night—especially blue-wavelength emission—has serious health implications due to the disruption of our natural human circadian rhythm.10,11,12 A blue spike occurring in the spectra of LEDs (at a wavelength of around 460 nm) coincides with the color of light that suppresses the production of melatonin.13,14 Recent studies have shown correlations between artificial light at night and cancer15, obesity16, hypertension17, and depression.18
The same disruption in circadian rhythm seen in humans due to artificial light at night is witnessed in plants and animals19, with impacts on the ecological balance between native and invasive plants20, pollination21, bird migration22, and diet.23 For example, moths, a significant nighttime pollinator, can only distinguish the colors of flowers under extremely low-level light conditions.24 Additionally, each year it is estimated that one billion birds die from collisions with building windows25, many of which are migratory birds distracted from their normal flight paths by ground-based light sources.
By extending sunlight hours and delivering light during periods of natural darkness, Reflect Orbital’s beam will extend exposure to blue-wavelength emission, compromising the health of living beings within its footprint.
VI. Summary
Considering the severe harm that Reflect Orbital’s NGSO satellite is expected to create for professional and amateur astronomy, as well as the potential for light trespass and significant negative effects on human and environmental health, we assert that the satellite, as proposed, fails to meet the public interest standard required for Commission licensure. We therefore oppose this filing, and urge the Commission to deny this license. If the Commission nonetheless approves the Application, we request that it do so only on the condition that Reflect Orbital carry out a rigorous impact assessment for the lighting proposed in its application, including a demonstration that the satellite will avoid light trespass prior to the commencement of operations.
Thank you for your consideration.
On behalf of the American Astronomical Society,
Joel Parriott, PhD
Interim CEO and Director of Public Policy and External Affairs
American Astronomical Society
Appendix 1: Standing of the American Astronomical Society under Int’l Dark-Sky Ass’n v. FCC, 466 U.S. App. D.C. 504, 106 F.4th 1206 (2024)
Summary
The AAS has associational standing under the Dark-Sky framework because its members (1) suffer direct professional, aesthetic, and recreational injury from reflected orbital light, (2) the challenge is germane to its core scientific mission, and (3) the relief sought doesn’t require individual participation.
Legal Rule
The court applies the standard three-part test for associational standing26 (the Court declined to grant organizational standing), which requires the organization to show:
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“its members would otherwise have standing to sue in their own right;
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the interests it seeks to protect are germane to the organization’s purpose; and
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neither the claim nor the relief requested requires participation of individual members in the lawsuit.”
Because this is a procedural injury case, the standing requirements are somewhat relaxed for the causation and redressability aspects.
Applied to Dark-Sky
I. Dark-Sky submitted declarations from two members describing harm to professional astronomy research, personal enjoyment of stargazing, and public education. The court applied the rule from Friends of the Earth v. Laidlaw, which requires environmental plaintiffs to show injury in fact when they “use the affected area” and their “aesthetic and recreational values” will be lessened by the challenged activity. Dark-Sky’s members are stargazers and astronomers who “use” the sky and whose activities would be inhibited by satellite light pollution.
II. Because this was a procedural injury, Dark-Sky only needed to show the missed procedural step was connected to the substantive outcome. If the FCC performed an environmental review on remand, it could change its position and deny the license, reducing the alleged harms.
III. The environmental challenge was pertinent to Dark-Sky’s organizational purpose of preserving dark skies through public education and responsible lighting practices. Environmental assessments produce exactly the kind of information relevant to an educational organization’s mission.
Notably, the Court stated that individual participation is unnecessary because the claims turned on whether the FCC complied with its statutory obligations, and the relief sought was vacatur and remand–neither involving individualized grievances.
Applied to AAS
I. Like Dark-Sky’s members, AAS members “use” the night sky in a manner recognized by Laidlaw—their aesthetic and recreational enjoyment of the sky is diminished by artificial reflected light. Many AAS members engage in public outreach, amateur observation, and personal stargazing; thus they plainly satisfy the recreational and aesthetic injury framework the D.C. Circuit endorsed.
But the AAS goes further. AAS members don’t just depend on the night sky recreationally or for aesthetic purposes; they depend on it professionally. The injury is concrete, particularized, and ongoing. For the relaxed procedural injury causation/redressability standard, the AAS would only need to show the procedural step (environmental review) was “connected to the substantive result” (license approval). If the FCC were required to conduct NEPA review of reflected orbital light, it could deny the license or condition it differently.
II. The AAS’s mission is “to enhance and share humanity’s scientific understanding of the universe as a diverse and inclusive astronomical community.” Challenging sources of light pollution that threaten the ability to “enhance… humanity’s scientific understanding of the universe” is at the core of what the AAS exists to do. The AAS has already published reports (like the SATCON1 and SATCON2 workshop reports) documenting the impact of satellite constellations on astronomy, demonstrating that this is a central organizational concern, not a peripheral one.
III. Just as in Dark-Sky, the legal question would be whether the FCC complied with its statutory obligations (NEPA review of reflected light impacts), and the relief sought would be vacatur/remand for environmental review. These are institutional legal questions, not individualized grievances.
Conclusion
Under Dark-Sky, the AAS would likely satisfy all three aspects of associational standing. As the Supreme Court explained in Friends of the Earth v. Laidlaw, injury exists when plaintiffs “use the affected area” and their “aesthetic and recreational values” are lessened by the challenged activity. AAS members unquestionably “use” the night sky—both recreationally and professionally—and reflected orbital light diminishes not only their aesthetic and recreational enjoyment, but also their ability to pursue their scientific work.
If recreational stargazers meet Article III’s injury requirement, then professional astronomers whose research is directly degraded by reflected light do as well.
DECLARATION OF JOEL PARRIOT
I, Joel Parriott, declare under penalty of perjury on this 9th day of March, 2026 that:
1. I have read the foregoing Petition to Deny of the American Astronomical Society.
2. This declaration is submitted in support of the Petition to Deny applications in FCC ICFS File No. SAT-LOA-20250701-00129.
3. I am the Interim CEO and Director of Public Policy and External Affairs for the American Astronomical Society, a professional society representing over 8500 members of the astronomical community.
4. The allegations of fact contained in the petition are true to the best of my personal knowledge and belief.
/s/ Joel Parriott
Joel Parriott, PhD
Interim CEO and Director of Public Policy and External Affairs
American Astronomical Society
CERTIFICATE OF SERVICE
I, Roohi Dalal, hereby certify that on this 9th day of March, 2026, I have caused a copy of the foregoing Petition to Deny 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 https://theconversation.com/a-us-startup-plans-to-deliver-sunlight-on-demand-after-dark-can-it-work-and-would-we-want-it-to-264323
3 While the Reflect Orbital website states “We maintain strict exclusion zones for astronomy and sensitive environments,” the AAS has not received any information about what those exclusion zones would be, or how they would be selected and implemented. Reflect Orbital’s FCC application also does not offer any details in this vein.
4 Laframboise, J. and Chou, B. Ralph. “Space Mirror Experiments: A Potential Threat to Human Eyes.” Journal of the Royal Astronomical Society of Canada, Vol. 94, 2000, pp. 237-240. https://articles.adsabs.harvard.edu/full/seri/JRASC/0094//0000241.000.html
5 https://www.faa.gov/newsroom/laser-strikes-aircraft-continue-be-dangerously-high
6 https://www.energy.ca.gov/sites/default/files/2025-11/Restructured_2025_Energy_Code_-_California_Code_of_Regulations_-_Title_24_Part_6_%28For_Information_Only%29_ada.pdf
7 https://www.reflectorbital.com/
8 https://www.law.cornell.edu/uscode/text/51/50911
9 American Medical Association. “Human and environmental effects of light emitting diode (LED) community lighting (CSAPH Report 2-A-16).” 2016.
10 Casiraghi LP, Plano SA, Fernández-Duque E, Valeggia C, Golombek DA, de la Iglesia HO. “Access to electric light is associated with delays of the dim-light melatonin onset in a traditionally hunter-gatherer Toba/Qom community.” J Pineal Res. 2020; 69:e12689. https://doi.org/10.1111/jpi.12689
11 Ayaki, M., Hattori, A., Maruyama, Y., Nakano, M., Yoshimura, M., Kitazawa, M., … Tsubota, K. “Protective effect of blue-light shield eyewear for adults against light pollution from self-luminous devices used at night.” Chronobiology International, 33(1), 2016, pp. 134–139. https://doi.org/10.3109/07420528.2015.1119158
12 Mitsui, K., Saeki, K., Sun, M. et al. “Effects of a violet-excitation light-emitting diode on melatonin secretion and sleepiness: preliminary findings from a randomized controlled trial.” Journal of Clinical Sleep Medicine 20, 2024, pp. 101–109. https://doi.org/10.5664/jcsm.10814
13 Obayashi, K., Saeki, K., Kurumatani, N., & Iwamoto, J. “Effect of exposure to evening light on sleep initiation in the elderly: A longitudinal analysis for repeated measurements in home settings.” Journal of Clinical Sleep Medicine, 7(6), 2011, pp. 657-661. https://doi.org/10.5664/jcsm.10814
14 Lee, S., Matsumori, K., Nishimura, K., Nishimura, Y., Ikeda, Y., Eto, T., & Higuchi, S. “Melatonin suppression and sleepiness in children exposed to blue-enriched white LED lighting at night.” Physiological Reports, 6(24), 2018, e13942. https://doi.org/10.14814/phy2.13942
15 Muscogiuri, G., Poggiogalle, E., Barrea, L., Tarsitano, M. G., Garifalos, F., Liccardi, A., Pugliese, G., Savastano, S., & Colao, A. “Exposure to artificial light at night: A common link for obesity and cancer?” European Journal of Cancer, 173, 2022, pp. 263-275. https://doi.org/10.1016/j.ejca.2022.06.007
16 Mao, B., Luo, C., Li, S., Zhang, J., Xiang, W., & Yang, Y. “Exposure to light at night (LAN) and risk of overweight/obesity, hypertension, and diabetes: A systematic review and meta-analysis.” International Journal of Environmental Health Research, 35(4), 2025, pp. 1003-1017 https://doi.org/10.1080/09603123.2024.2378941
17 Wang, Le-Bing, et al. “Reducing artificial light at night exposure in the urban environment could decrease light pollution-related hypertension in children.” Hypertension Research 48.12, 2025, pp. 3113-3123. https://doi.org/10.1038/s41440-025-02380-z
18 Helbich, M., Burov, A., Dimitrova, D., Markevych, I., Nieuwenhuijsen, M. J., & Dzhambov, A. M. “Sleep problems mediate the association between outdoor nighttime light and symptoms of depression and anxiety: A cross-sectional, multi-city study.” Environmental Research, 220, 2024, pp. 115-126. https://doi.org/10.1016/j.envres.2024.115126
19 Dietenberger, M., Jechow, A., Kalinkat, G., Schroer, S., Saathoff, B., & Hölker, F. “Reducing the fatal attraction of nocturnal insects using tailored and shielded road lights.” Communications Biology, 7, 2024, Article 6304. https://doi.org/10.1038/s42003-024-06304-4
20 Liu, et al. “Plant invasions under artificial light at night.” Trends in Ecology & Evolution, Volume 39(8), 2024, pp. 703 – 705. https://doi.org/10.1016/j.tree.2024.05.005
21 Wilson, A.A. et al. “Direct and Ambient Light Pollution Alters Recruitment for a Diurnal Plant–Pollinator System.” Integrative and Comparative Biology, Volume 61(3), 2021, pp. 1122–1133, https://doi.org/10.1093/icb/icab010
22 Horton, K.G., Buler, J.J., Anderson, S.J. et al. “Artificial light at night is a top predictor of bird migration stopover density.” Nature Communications, 14, 2023, Article No. 7446. https://doi.org/10.1038/s41467-023-43046-z
23 Morelli, F., Tryjanowski, P., Ibáñez-Álamo, J.D. et al. “Effects of light and noise pollution on avian communities of European cities are correlated with the species’ diet.” Scientific Reports 13, 2023, Article no. 4361. https://doi.org/10.1038/s41598-023-31337-w
24 Kelber, A., Balkenius, A. & Warrant, E. “Scotopic colour vision in nocturnal hawkmoths.” Nature 419, 2002, pp. 922–925. https://doi.org/10.1038/nature01065
25 https://www.fws.gov/library/collections/bird-friendly-home-toolkit
26 Ctr. for Sustainable Econ. v. Jewell, 779 F.3d 588, 596 (D.C. Cir. 2015)