Losing The Sky: Resources

What can we do?

Are we powerless in the face of technological progress, and commercial pressure? I don’t think so. Professional astronomers, astronautics specialists, industry scientists, and others are working hard on technical working groups. Not everybody can help with that, but here are some things everybody can do.

Learn more: key websites

Learn more: key documents

There have been many articles, videos and blog posts on this topic. The book has lots of links you can follow. There are five key definitive reports:

The SATCON-1 report and the SATCON-2 report, based on the results of two conferences and a collection of working groups set up by the US NOIRLab and American Astronomical Society.

The Dark and Quiet Skies report: from a conference and working group set up by the International Astronomical Union. It deals with light pollution as well the satellite problem.

The JASON report: a report covering the debris problem as well as optical and radio astronomy, written by a US government independent science advisory panel.

The first and second GAO reports: The US Government Accountability Office issued two crucial reports in 2022. The first one is a very general Technical Assessment of the potential problems caused by Large Constellations of Satellites. The second report specifically addresses whether the FCC is justified in applying a “categorical exclusion” under NEPA – the issue at the heart of the legal appeal I was involved in – see below.

Technical Articles

There are a number of technical/scientific articles on various aspects (see links in the book), but the one I would recommend most is The Case for Space Environmentalism, led by yours truly. I also strongly recommend this paper by Boley and Byers. A recent conference paper by myself suggests that the most pressing problems are the exponential decrease of the density of objects on the sky, and the rate at which material is re-entering the atmosphere. Another recent paper, by Holter-Hunt, is very scary, suggesting that re-entering material may be creating a conductive shell of plasma dust around the Earth.

Boley and Byers have also recently published a wonderful book called “Who Owns Outer Space”. You can buy the hardback e.g. on Amazon here – but the PDF version is available open access at Cambridge University Press.

Petitions

If you are a professional astronomer, you should sign the Astronomers Appeal, set up by Stefano Gallozzi. As a member of the public, it is more appropriate to sign the Losing the night sky appeal at Avaaz.

Action Against Satellite Light Pollution

This is both a Facebook Page and a public website, with lots of useful information, updated quite often. The Facebook page is a private group but you can of course request to join if you want to follow what is going on.

Write to your local representative

i.e. Member of Parliament, Congress Person etc, letting them know what you think – for example that space should be treated as part of the natural environment, or that you are worried we will end up with space advertising, or whatever. Politicians (in most countries…) take letters from citizens very seriously. They assume that for every person that writes, another thousand feel the same way.

Four messages

Global internet is great, but it doesn’t need to be done this way

No we can’t just fix the streaks in software

Space is getting dangerously crowded

Slow down

Deeper Perspectives

I have also become involved in more nitty-gritty legal and regulatory issues. Here is some information on those activities:

Starlink FCC review 2021

The Federal Communications Commission (FCC) had already approved the Starlink Generation 1 proposal for ~4400 satellites. During 2021, when the fleet was partially implemented, a modified proposal was submitted and reviewed. I took the opportunity as part of that review to submit a letter, arguing that final approval should be indefinitely deferred. This was a drop in the ocean of course, but it was as close as I have to a personal manifesto, so I made it public.

The Legal Appeal to NEPA

In the USA, the National Environmental Policy Act (NEPA) says that federal agencies must undertake an Environmental Assessment if a decision they are considering taking may have an environmental impact. The FCC have always argued that they have a “categorical exemption” and also that NEPA does not apply to space activities. Following the approval of the Starlink Gen-1 system, another satellite company, Viasat, and an environmental organisation known as the Balance Group, appealed in the US Courts of Appeals against the FCC order on the grounds that NEPA should have applied and an environmental assessment carried out. I was approached by Viasat and agree to write an independent “Amicus Brief” in support of their appeal – a kind of expert witness statement – which I did with the help of Meredith Rawls and Moriba Jah, and many more anonymous contributors. This was submitted on August 13th. It is a public document, so I provide it here for anybody who is interested:

Amicus Brief

The Amicus Brief is of course in fairly impenetrable legalese, but it then morphed into the scientific article we published in Nature Astronomy:

The Case for Space Environmentalism

As you may have seen reported in the media, the Court rejected the appeal. Here is the Court Opinion. However, it is important to understand why the appeal was rejected.

The Court ruled that neither party had appropriate “standing” and therefore the Court did not “reach the merits of their claim”.  The idea that a NEPA environmental review should occur in the context of a proposal to the FCC such as the Starlink one, was therefore untested – but in my opinion remains extremely strong. Viasat did not succeed in establishing standing as Environmental Appellants because of the requirement to show injury that is “actual, imminent or certainly impending” rather than “a speculative possibility of future injury”. The Balance Group’s stated injury was deemed to be not backed by sufficiently concrete evidence. Notably, the Court decision does not show that the FCC were correct in choosing to ignore NEPA, only that the appellants did not demonstrate actual injury caused by the order in question. Although an appeal requires actual rather than possible injury, an Environmental Assessment required under NEPA must of course consider injury that may happen to many possible future parties. Furthermore, the wording of the discussion in the Court opinion implies that they did not rule out including the effect of harms arising from activities in orbital space as part of the environmental harms covered by  NEPA.

The NRDC/IDA document. As part of the FCC review of the Starlink Gen-2 proposal (see below) an important submission was made which I think is a key next step in the legal argument over application of NEPA. The submission was made jointly by the National Resource Defence Council (NRDC) and the International Dark Sky Association (IDA), and suggests that the use of “categorical exclusion” by the FCC is illegal, and that they must carry out an Environmental Assessment before approving Starlink Gen-2. You can read their document here. Update: SpaceX filed a rather cross response to the NRDC/IDA document, arguing as forcefully as they can that NEPA does not apply outside the USA, and therefore does not apply to space.

Starlink Gen 2 FCC review: letter writing campaign

In 2022, with Starlink Gen-1 almost complete, the FCC were reviewing the “Starlink Generation 2” proposal, for an extra 30,000 satellites, each of which is ten times more massive than the Gen-1 satellites. The process by which a project such as Starlink or Kuiper etc get permission to go ahead is quite complicated and multi-faceted especially because some of the issues we are concerned about do not yet have a natural regulatory home. For the moment however, the key stage is the review of applications made to the US Federal Communications Commission (FCC). They license the use of radio spectrum for communications for US based projects, which then cascades upwards to the ITU. However, they also require to see some sort of debris mitigation plan, and some of us have been trying to persuade them to consider light pollution as well. In the long term, the FCC probably shouldn’t be the right gatekeeper for such things, but for now its the only game in town.

In principle, such a review is completely open, but in practice only serious space industry folk normally contribute, because the the process is so arcane and the website involved is very cumbersome. It reminds me of that bit in The Hitchiker’s Guide to the Galaxy where it turns out that the Council Consultation regarding the New Bypass is available in a locked cabinet in the basement, behind the door marked Beware Of The Leopard. So with the help of some industry colleagues, I put together a blow-by-blow guide on how to submit a letter. I encouraged people to use my letter as a starting point, but to make sure they put things in your own words, relating it to their own perspective, using their own images, and preferably keeping it short and punchy. This was quite successful, with a variety of professional astronomers, amateur astronomers, and students contributing very interesting and useful submissions. Below is the material I provided to help people:

My Sept 2022 letter to FCC as an example
Blow-by-Blow guide to submitting your own
The full list of submissions

Starlink Gen-2 result

The letter writing campaign did not succeed in stopping Starlink Generation-2 going ahead. In December 2022, the FCC issued an order approving a partial implementation. However, if you have the patience to read the FCC order carefully, you will see that the letters we submitted were taken very seriously, and FCC imposed a condition on SpaceX to liaise with astronomers to minimise issues. So while this wasn’t as good as we hoped, it was part of a positive trend towards taking astronomical genuinely seriously. Sometime soon, the IAU CPS will hopefully issue a statement on how well SPaceX are complying.