Image credit: NOIRLab/@UNOOSA/IAU/Government of Spain/M. Lewinsky

NOIRLab has published The Working Group reports from the recent Dark & Quiet Skies II conference.

NOIRLab is the preeminent US national center for ground-based, nighttime optical and infrared astronomy.

The reports focus on the feasibility of implementing specific measures to mitigate the impact of artificial interferences.

Source: https://noirlab.edu/public/products/techdocs/techdoc051/

About the Document

Excerpt:

7. Scientific access to sky and spectrum
   Scientific access to sky and spectrum is eroding under the relentless pressure of commercial
   development of radio communication technology. Meanwhile, radio spectrum regulators are focused
   on the protection of frequency allocations and have no obvious means to address the biological,
   environmental, and broader scientific concerns that are the subject of the Dark and Quiet Skies
   conferences. Radio spectrum regulators authorize vast mega-constellations that occupy wide swaths
   of the radio spectrum used by radio astronomy while inadvertently reflecting sunlight at levels visible
   to the naked eye, disrupting optical astronomy. The dark and quiet sky threatens to become a nightly
   theater of artificial objects and artificially generated radiation that isolates us from the cosmos.
   The common lesson of all the studies conducted for the Dark and Quiet Skies effort, whether in regard
   to artificial light at night, to reflection of solar radiation by satellites, or to use of satellites for
   radiocommunication, is the principle that artificial radiation of whatever kind should not be
   produced if it is not needed and should not be detectable where it is not used. The radio
   astronomy recommendations embody this principle in the context of radio astronomy and
   implementing them is a critical step in maintaining scientific access to sky and spectrum and the
   Universe.
8. Towards implementation of the recommendations
   Radio astronomy requires portions of the radio spectrum (not constrained to the protected radio
   astronomy bands) to be interference-free, for sufficiently long periods of time, to enable scientific
   discoveries that can advance the human knowledge of the Universe, contribute to planetary defense,
   and create terrestrial reference frames used for global positioning, among many other applications.
   The invaluable work done by administrations and radio astronomy protection groups at the ITU-R,
   should be complemented by the Dark and Quiet Skies proposed work at COPUOS to raise the
   awareness on the vulnerability of radio astronomy to activities in space. The significant effect that
   satellite systems (as a space activity under the mandate of COPUOS) can have on radio astronomy, at
   all frequencies of the radio spectrum, requires urgent attention in this new era of unprecedentedly fast
   developments.
   The radio astronomy working group recommends that the potential impacts of space activities on
   radio astronomy are presented at COPUOS and national delegations are urged to consider these as
   part of the general assessment of environmental impact of any proposed space activity.

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7 OCT 2021 BY JOSHUA SOKOL

On 19 December 2019, Tony Tyson, an experimental physicist at the University of California (UC), Davis, joined a conference call with billionaire Elon Musk that helped shape the fate of starry nights on Earth.

The call was cordial but tense. Seven months earlier, Musk’s company SpaceX had livestreamed a feed of 60 satellites drifting off into space from the bay of one of the firm’s rockets. The satellites, the triumphant first wave of a project called Starlink, were built to beam down broadband internet to every corner of the globe. But as the satellites began to do laps around Earth, people looking up at night saw a string of glinting pearls as bright as the stars in the Big Dipper.

Those five dozen satellites were just the beginning. Starlink already had permission to launch 12,000 satellites, roughly six times the number of active satellites then in orbit. The next year, the company added another 30,000. Other billionaire-backed companies—Jeff Bezos’s Project Kuiper, and OneWeb, funded in part by Richard Branson—were planning comparable space internet swarms, leading to industry forecasts of more than 100,000 satellites in orbit by the end of the 2020s. In the best stargazing conditions, human eyes can perceive about 3000 twinkling stars overhead; if the planned satellites ended up as bright as the first Starlinks, they would fill future summer nights with a comparable number of creeping dots.

Almost overnight, a new arena of environmental conflict opened up. Astronomers weren’t the only ones who saw an existential threat. Environmentalists, amateur stargazers, and Indigenous leaders working to revive astronomical traditions saw an affront to the planet’s dwindling dark skies, an act as vandalistic as carving initials into a tree trunk—in front of the whole world. “From a cultural point of view, it is a desecration,” says Rangi Mātāmua, a Māori cultural astronomer at Massey University, Manawatū.

Read more at https://www.science.org/content/article/satellite-swarms-are-threatening-night-sky-creating-new-zone-environmental-conflict

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“Mega-constellations” from those satellites will be visible to the naked eye, simulations suggest

By Lisa Grossman

Companies like SpaceX and Amazon have launched hundreds of satellites into low orbits since 2019, with plans to launch thousands more in the works — a trend that’s alarming astronomers. The goal of these satellite “mega-constellations” is to bring high-speed internet around the globe, but these bright objects threaten to disrupt astronomers’ ability to observe the cosmos (SN: 3/12/20). “For astronomers, this is kind of a pants-on-fire situation,” says radio astronomer Harvey Liszt of the National Radio Astronomical Observatory in Charlottesville, Va.

Now, a new simulation of the potential positions and brightness of these satellites shows that, contrary to earlier predictions, casual sky watchers will have their view disrupted, too. And parts of the world will be affected more than others, astronomer Samantha Lawler of the University of Regina in Canada and her colleagues report in a paper posted September 9 at arXiv.org.

“How will this affect the way the sky looks to your eyeballs?” Lawler asks. “We humans have been looking up at the night sky and analyzing patterns there for as long as we’ve been human. It’s part of what makes us human.” These mega-constellations could mean “we’ll see a human-made pattern more than we can see the stars, for the first time in human history.”

Read more at https://www.sciencenews.org/article/satellite-mega-constellations-night-sky-stars-simulations

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28 August 2021

There are no binding international laws or regulations in place to protect the night sky.

Does the FCC’s lack of review of commercial mega constellations satellite projects violate the National Environmental Policy Act [NEPA)?

The FCC refused to find that SpaceX’s Major Modification Application “may have” a significant environmental impact:

Viasat sued the Federal Communications Commission in May and asked judges for a stay that would halt SpaceX’s ongoing launches of low Earth orbit (LEO) satellites that power Starlink Internet service.

The US Court of Appeals for the District of Columbia Circuit ruled that “Viasat has not satisfied the stringent requirements for a stay pending court review.” The judges did grant a motion to expedite the appeal, however, so the case should move faster than normal (Final Briefs October 26, 2021).

Filed: 06/14/2021 UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT RESPONSE OF THE BALANCE GROUP (Appellant in No. 21-1128) IN SUPPORT OF MOTION TO STAY PENDING JUDICIAL REVIEW

Excerpts:

With regard to identified potential effects on Earth’s atmosphere from satellite launches and re-entries, the FCC perfunctorily dismissed Viasat’s detailed petition allegations as “insufficient” to determine that additional environmental consideration is necessary under its rules, or that granting SpaceX’s modification application may have a significant environmental impact on the atmosphere or ozone layer. It rejected Viasat’s identification of “unknowns about other complex chemical compounds” as “too vague.”

Though it conceded Viasat is correct in noting that 10 to 40 percent of a satellite’s mass as a general matter does not burn up on re-entry and may reach Earth’s surface, the FCC accepted at face value SpaceX’s statement that its satellites are different. FCC credited SpaceX’s self-serving claim that it has designed its satellites to be “fully demisable upon reentry,” and that “the calculated risk of human casualty from materials reaching the Earth is roughly zero.” [A057]

As to potential impacts on the night sky and astronomy identified by both The Balance Group and Viasat, the FCC credited SpaceX’s vague assertions that “it has been working with astronomers and that its modification will in fact lessen the effect its constellation will have on the night sky,” that it “has been taking measures to darken its satellites,” making them “all but invisible” to the naked eye, and “has been working in close collaboration with the astronomy community.” [A057-59 (quoting SpaceX Opposition)].

The FCC rejected Viasat’s detailed contentions regarding the potential impact of satellite collisions in space, finding that they “failed to set forth in detail reasons justifying or circumstances necessitating environmental consideration of these issues….“

“It must be remembered that the basic thrust of the agency’s responsibilities under NEPA is to predict the environmental effects of a proposed action before the action is taken and those effects fully known.”  https://regmedia.co.uk/2021/06/16/resp_supporting_motion_to_stay.pdf

FCC’s Categorical Exclusion

Since the 80s, satellite systems have had a baked in exemption from the National Environmental Policy Act (NEPA), excluding their businesses from environmental review. Federal agencies can circumvent NEPA  if they are granted a “categorical exclusion” for some or all of their activities—usually by arguing that such activities do not impact the environment and thus do not require review. The FCC has had a sweeping categorical exclusion since 1986 across almost all of its activities—including its approval of space projects—despite other agencies involved in space—most notably NASA—being required to conduct NEPA reviews. Kevin Bell, staff counsel at Public Employees for Environmental Responsibility (PEER), a nonprofit organization that works with government whistle-blowers on environmental issues: “It is a policy that was designed for another time, before large scale space exploration.”

In its reasoning for its categorical exclusion, the FCC states that its actions “have no significant effect on the quality of the human environment and are categorically excluded from environmental processing.”

 “The FCC however has never performed a study showing why commercial satellites deserved to be classified as categorically excluded from review ”

“And the evidence shows that these satellites are having an environmental impact.” https://www.scientificamerican.com/article/the-fccs-approval-of-spacexs-starlink-mega-constellation-may-have-been-unlawful/

VIASAT itself has been accused of attempting competitive harm to support a stay request. In the article “Keep Environmental Red Tape Out of Outer Space” the author points out that VIASAT itself did not perform an environmental assessment under NEPA for its own satellite constellation. The author believes that NEPA Does Not Apply Extraterrestrially. https://www.heritage.org/sites/default/files/2021-08/LM288.pdf

Environmental impact assessment (EIA) screening and scoping of extraterrestrial exploration and development projects

NASA takes the position that potential environmental impacts in outer space, including the Moon, are beyond the scope of NEPA [National Environmental Policy Act] analysis’ (NASA 2008a). The legal frameworks of Belgium and France are exceptions as they require that EIA considers extraterrestrial impacts. Despite the weak and inconsistent legal situation, two areas of space environmental protection have been taken more seriously by the international community, including measures to control levels of man-made space debris and ‘planetary protection’. These are covered internationally by the Inter-Agency Space Debris Coordination Committee’s (IADC’s) space debris mitigation guidelines (IADC 2007, 2014) and the Committee on Space Research’s (COSPAR’s) Planetary Protection Policy (COSPAR 2011). 

Space debris is defined by the IADC as ‘all man made objects including fragments and elements thereof, in Earth orbit or re-entering the atmosphere, that are non functional’ (IADC 2007). These pose a risk to spacecraft due to the high relative speed at which they may be travelling. Given the amount of debris already in orbit and the fact that when pieces collide they can fragment and multiply, there is concern that the number of objects could expand exponentially through ‘collisional cascading’ and thus limit future space activities in some orbits (NASA 2016a).

Ref: Stephen Eric Mustow (2018) Environmental impact assessment (EIA) screening and scoping of extraterrestrial exploration and development projects, Impact Assessment and Project Appraisal, 36:6, 467-478, DOI: 10.1080/14615517.2018.1500092

Environmental Impact Assessment and space activities

Environmental Impact Assessment (EIA), the prior assessment of the possible effects of a proposed activity on the environment, is a common tool for environmental protection and management on Earth today. It was the first major step in the development of impact assessment procedures, which are probably the most obvious examples of an approach that integrates economic, social and environmental considerations. EIA is not a well-established tool in the international law of outer space, however. Despite the peculiarities in assessing the potential impacts of space activities, the premise of this paper is that also this field of human endeavor would benefit greatly from the adoption of EIA procedures and, moreover, such an approach is even becoming vital for the safe and rational conduct of these activities. This is particularly true inasmuch as any adverse environmental impacts of space activities are highly difficult to mitigate once they have materialized.

Ref: L.E. Viikari, Environmental Impact Assessment and space activities, Advances in Space Research, Volume 34, Issue 11, 2004, Pages 2363-2367, ISSN 0273-1177, https://www.sciencedirect.com/science/article/abs/pii/S0273117704003266

University of Edinburgh astronomy professor Andy Lawrence files amicus brief 

Law360 (August 17, 2021, 7:13 PM EDT) — The Federal Communications Commission made a mistake when it gave SpaceX permission to launch thousands of broadband satellites from its Starlink fleet closer to Earth than originally planned without also ordering an environmental review, a group of astronomy professors told the D.C. Circuit.

The number of satellites in low Earth orbit is already making it difficult for astronomers to do their job, and the work is only going to get harder if the FCC continues to allow companies like Elon Musk-linked SpaceX to launch objects into the sky without considering the effect on the environment, the celestial experts argued.

University of Edinburgh astronomy professor Andy Lawrence filed the amicus brief Friday, bringing his two cents to the consolidated set of appeals before the D.C. Circuit, all challenging the FCC’s decision to bless the Starlink launch in a lower orbit. The brief, according to Lawrence, was coordinated with several colleagues at various American institutions.

“Humans have interacted with the night sky for thousands of years,” the brief said. Professor Lawrence is (and the other astronomers are) interested in this case because the commission’s order underlying it has significant potential consequences for astronomy and humans’ access to the sky.

Right now there are more than 4,500 active satellites in what Lawrence calls near-Earth orbital space, but within a decade the professor says that number could grow to 100,000. https://www.law360.com/articles/1412913/profs-tell-dc-circ-spacex-launches-need-enviro-review

SpaceX adding capabilities to Starlink internet satellites, plans to launch them with Starship

On August AUG 19 2021 SpaceX filed an amendment with the Federal Communications Commission that included descriptions of its plan, known as the Starlink “Gen2 System. ”SpaceX has launched 1,740 Starlink satellites to date, with its first generation system beginning launches  in November 2019. Gen2 is planned to have nearly 30,000 satellites in total.

SpaceX says the Gen2 Starlink satellites are heavier and “will be somewhat larger and generate more power than originally” designed.

https://www.cnbc.com/2021/08/19/spacex-starlink-satellite-internet-new-capabilities-starship-launch.html

Sounding the alarm:

(Emphasis added by EMFSA ) If governments and companies around the world do not take urgent action to work together to make space safer, they will one day face a catastrophic collision that knocks out one or more satellites key to their safety, economic well-being or both. Space is a global commons and a global resource. A global organization responsible for — and capable of — managing the flow of space traffic is long overdue. The world must cooperate to avoid a catastrophic space collision.  Governments and companies urgently need to share data on the mounting volume of satellites and debris orbiting Earth. Nature 596, 163 (2021) doi: https://doi.org/10.1038/d41586-021-02167-5

We must consider the impact of satellite constellations, and related future initiatives, on the essential human right to dark skies and on cultural sky traditions across all peoples. We must also include all stakeholders for near-Earth space in the process of developing new policies for space treaties and planetary protection, the consequences of which will reach far beyond this century. Ref: Venkatesan, A., Lowenthal, J., Prem, P. et al. The impact of satellite constellations on space as an ancestral global commons. Nat Astron 4, 1043–1048 (2020). https://doi.org/10.1038/s41550-020-01238-3 https://www.nature.com/articles/s41550-020-01238-3

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The U.S. National Science Foundation commissioned a study by the independent science advisory group JASON to assess the impact of current and planned large satellite constellations on astronomical observations in 2020. The charge for JASON was to:

• Understand the types and numbers of spacecraft planned for launch in the next decade.
• Understand the current regulatory process for commercial launches to Low Earth Orbit, both in the U.S and internationally.
• Characterize the types of interference that spacecraft could have on observations of multiple types, specifically in the optical and infrared wavelength regimes.
• Gather and describe the range of observations currently being made and foreseen for the future.
• Suggest any additional data that should be gathered to better understand the scope of the problem for the future.

NSF commissioned the report as a resource for all stakeholders. The JASON group had broad discretion in constructing its report and identifying relevant issues. The report sets benchmarks and the foundation for discussing the impacts on astronomy at various wavelengths.

NSF is reviewing the report’s findings and recommendations and intends to continue to work with stakeholders on the development of mutual solutions.

Please review the full PDF report.

For more see https://www.nsf.gov/news/special_reports/jasonreportconstellations/

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Jun 30, 2021

Andy Lawrence

This is a short promotional video for “Losing The Sky”, a short non-technical book about the threat to the sky from satellite mega-constellations. You can find the book at Amazon, Apple Books, and Google Play Books. To see a bit more about what the book is all about, go to https://andyxlastro.me/losing-the-sky/ An associated live event, with myself, Catherine Heymans, Brian Eno, and many others, is available here: https://www.youtube.com/watch?v=ESoM3…

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Abstract

The rapid development of mega-constellations risks multiple tragedies of the commons, including tragedies to ground-based astronomy, Earth orbit, and Earth’s upper atmosphere. Moreover, the connections between the Earth and space environments are inadequately taken into account by the adoption of a consumer electronic model applied to space assets. For example, we point out that satellite re-entries from the Starlink mega-constellation alone could deposit more aluminum into Earth’s upper atmosphere than what is done through meteoroids; they could thus become the dominant source of high-altitude alumina. Using simple models, we also show that untracked debris will lead to potentially dangerous on-orbit collisions on a regular basis due to the large number of satellites within mega-constellation orbital shells. The total cross-section of satellites in these constellations also greatly increases the risk of impacts due to meteoroids. De facto orbit occupation by single actors, inadequate regulatory frameworks, and the possibility of free-riding exacerbate these risks. International cooperation is urgently needed, along with a regulatory system that takes into account the effects of tens of thousands of satellites.

Extract:

Companies are placing satellites into orbit at an unprecedented frequency to build ‘mega-constellations’ of communications satellites in Low Earth Orbit (LEO). In two years, the number of active and defunct satellites in LEO has increased by over 50%, to about 5000 (as of 30 March 2021). SpaceX alone is on track to add 11,000 more as it builds its Starlink mega-constellation and has already filed for permission for another 30,000 satellites with the Federal Communications Commission (FCC)¹. Others have similar plans, including OneWeb, Amazon, Telesat, and GW, which is a Chinese state-owned company². The current governance system for LEO, while slowly changing, is ill-equipped to handle large satellite systems. Here, we outline how applying the consumer electronic model to satellites could lead to multiple tragedies of the commons. Some of these are well known, such as impediments to astronomy and an increased risk of space debris, while others have received insufficient attention, including changes to the chemistry of Earth’s upper atmosphere and increased dangers on Earth’s surface from re-entered debris. The heavy use of certain orbital regions might also result in a de facto exclusion of other actors from them, violating the 1967 Outer Space Treaty.

The authors: “there is little recognition that Earth’s orbit is a finite resource, the space and Earth environments are connected, and the actions of one actor can affect everyone. Until that changes, we risk multiple tragedies of the commons in space.”

https://www.nature.com/articles/s41598-021-89909-7

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This document provides recommendations to the Government of Canada and the Canadian Space Agency in response to their call for feedback on the future of Canadian space exploration. The report focuses on how the construction and long-term placement of mega-constellations of satellites into Earth orbit will affect astronomy and the view of the night sky by all peoples, with attention to all Canadians. The broader discussion highlights several environmental concerns associated with the construction and maintenance of these mega-constellations. The eight recommendations here address ways that Canada can play a role in mitigating some of these negative effects through national and international initiatives. In drafting the recommendations, we take the approach that space needs to be developed sustainably. In this regard, we use the Brundtland Report’s definition: “Sustainable development is the development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” Thus, all recommendations here are made with the intent of minimizing the negative consequences of mega-constellations, while also recognizing that their development will continue.

PDF https://arxiv.org/ftp/arxiv/papers/2104/2104.05733.pdf

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