Viasat has petitioned the FCC to conduct an environmental review of rival SpaceX's plan for Starlink, arguing that the resulting constellation of thousands of broadband satellites could be hazardous to the Earth's atmosphere, boost the risk of space debris-causing collisions and generate massive amounts of light pollution.

Viasat's ask, explained in this December 22 filing with the FCC, stems from SpaceX's proposal to modify its deployment by lowering the orbital altitude of nearly 3,000 Starlink satellites.

As Space News points out, satellite systems have enjoyed a categorical exemption from the National Environmental Policy Act (NEPA), which requires the FCC and other agencies to assess the environmental impacts of their actions.

Viasat holds that Starlink's plan to deploy thousands of satellites (the FCC has authorized SpaceX to deploy about 12,000 satellites) adds new variables and potential hazards that should obviate that exemption. As a result, Viasat is urging the FCC to deny or defer SpaceX's proposed modification and, at the very least, to prepare an environmental assessment (EA) before acting on SpaceX's application.

The petition emerges as Starlink moves toward the commercial launch of a broadband satellite service that will rely on a constellation of low-Earth orbit (LEO) satellites and will compete with satellite broadband services from companies such as Viasat and Hughes Network Systems that are currently powered by high-orbit, geosynchronous (GEO) satellites. Tests conducted last fall by Ookla found that average speeds for a beta version of Starlink's service delivered 79 Mbit/s down and 13.8 Mbit/s up, much faster than the GEO-based services offered today by Viasat and Hughes.

Environmental concerns

Viasat, which is looking into possible LEO-based systems that rely on far fewer satellites than Starlink's plan, believes that SpaceX's intention to deploy thousands of satellites into low-Earth orbit presents several potential problems.

Among them, the potential for collisions that could generate orbital debris that would further pollute space and release harmful chemicals into the atmosphere.

"The Commission cannot take SpaceX's word for it that the thousands of satellites it is seeking to pack into a lower orbit will not materially increase the risks of collisions and produce excessive space debris — especially because SpaceX knows that when its satellites do collide with other space objects and fragment or fail, it can always launch more," Viasat stated.

Viasat also holds that SpaceX emphasizes satellite replaceability over reliability and safety "simply to advance its own commercial interests."

"Instead of deploying a smaller fleet of environmentally friendly satellites, SpaceX treats its satellites as disposable commodities with little regard for the harmful environmental impacts they may have," Viasat told the Commission. "The launch and re-entry of these satellites is likely to release harmful chemical compounds into the air that could contribute to ozone depletion and to global warming. And given the satellite quantities at issue, there is also a risk that satellites that do not burn up on re-entry could harm humans and the environment."

Responding on Twitter, SpaceX CEO Elon Musk called Viasat's filing a sly move motivated by the competition Spacelink will bring to bear. But he also seemed to forget that Charlie Ergen doesn't run Viasat (Ergen, Dish Network's chairman, is connected to Hughes, which is backing OneWeb's revised plan for a LEO-based service). Musk fixed that in a follow-up tweet directed at Viasat chairman and co-founder Mark Dankberg:

Viasat also asserted that the sheer number of satellites in Starlink's constellation will increase the risk to people on the ground "to an unacceptable level," estimating that 60% to 90% of a satellite's mass burns up during re-entry.

"SpaceX's 4,425 operating low-orbit satellites could cause a casualty (again, based on their originally authorized altitude) on the surface as often as once every 18 years, whereas SpaceX's 7,518 operating very-low-orbit satellites could cause such a casualty once every 9 years," Viasat told the FCC.

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— Jeff Baumgartner, Senior Editor, Light Reading