Reflect Orbital and SpaceX FCC Applications sets off alarms- Comment by March 6, 2026
Why Umpqua Watersheds is engaging on satellite infrastructure
Satellite constellations are rapidly becoming a new form of global infrastructure with measurable on-the-ground environmental effects. Expansion of low-Earth-orbit systems affects migratory birds, nocturnal wildlife, wilderness character, atmospheric conditions, and the visibility of night skies across the same public landscapes UW members steward and rely on for recreation, monitoring, and cultural connection. Federal licensing decisions made by the FCC determine constellation scale, operational standards, and whether cumulative environmental review occurs before deployment. By submitting comments now, UW helps ensure that wildlife impacts, dark-sky values, lifecycle emissions, and Tribal cultural considerations are included in the administrative record. Engagement at this stage preserves UW’s ability to advocate for science-based safeguards, transparency, and programmatic environmental review before constellation expansion becomes effectively irreversible.
Satellites are essentially “Billboards in the sky” but with the inability to turn them off or mitigate their impact to large areas.
These applications treat constellation expansion as incremental engineering rather than system-level infrastructure with cumulative environmental effects.
📌 Reflect Orbital’s application (SAT‑LOA‑20250701‑00129) is currently for a single test satellite
(Earendil‑1) to demonstrate the technology. According to the FCC public notice, the specific application you’re commenting on requests authorization to launch one non‑geostationary orbit satellite to test space‑based reflector technology.
The application proposes a novel low-Earth-orbit satellite system designed to intentionally reflect sunlight toward terrestrial locations during nighttime hours. Unlike conventional satellites, which are visible incidentally, Reflect Orbital’s satellites would purposefully generate moving sources of illumination across broad geographic areas, including migratory corridors, wilderness areas, and culturally significant dark-sky landscapes. The system is intended to create high-altitude, transient beams of light that increase sky brightness at selected locations, effectively extending artificial illumination into areas that currently experience natural darkness. The application includes plans for deployment, orbital paths, and satellite operations but provides limited assessment of potential environmental impacts, such as disruption to nocturnal wildlife, interference with celestial navigation, and effects on plant photoperiod and Indigenous sky knowledge. The proposal represents a departure from traditional satellite design because brightness is a core operational objective rather than an incidental consequence, raising cumulative and ecological concerns that are unprecedented in FCC satellite licensing.
However, broader statements from the company and news outlets indicate that Reflect Orbital envisions building a much larger constellation over time, with plans for:
- about 4,000 reflector satellites by 2030 to provide large‑scale illumination (reflected sunlight) and related services, according to reporting describing the company’s long‑term vision.
- Current FCC filing: 1 satellite (Earendil‑1) proposed under SAT‑LOA‑20250701‑00129.
- Company’s longer‑term constellation plan: approximately 4,000 satellites by around 2030 in sun‑synchronous orbit.
📌The SpaceX application (SAT-LOA-20260108-00016) seeks authorization to expand or modify its existing low-Earth-orbit satellite constellation, which provides broadband connectivity. Unlike the Reflect Orbital proposal, SpaceX’s satellites are not designed to produce intentional illumination, but the expansion increases the total number of visible satellites, contributing to cumulative sky brightness, streak frequency, and potential light pollution across migratory corridors, wilderness areas, and remote landscapes. The application includes plans for satellite deployment, orbital adjustments, and replacement schedules, but provides limited environmental analysis of impacts related to nocturnal wildlife, migratory birds, atmospheric emissions from launches and re-entries, and the potential degradation of dark-sky and cultural resources. While SpaceX emphasizes connectivity and operational performance, the proposed expansion raises concerns about systemic effects on ecological and cultural systems due to constellation scale, cumulative lighting, and lifecycle turnover.
How many satellites are they asking to deploy?
- For SpaceX’s application SAT‑LOA‑20260108‑00016, the number of satellites proposed is up to one million. The FCC’s public notice describing the filing states that SpaceX is seeking authority to launch and operate a brand‑new non‑geostationary satellite system called the SpaceX Orbital Data Center system, which would consist of **as many as 1 000 000 satellites in low Earth orbit (LEO). These spacecraft would operate in multiple orbital shells between roughly 500 km and 2 000 km altitude and are envisioned to serve functions such as distributed data processing and communications capacity in orbit — a much more expansive deployment than the current Starlink broadband fleet. This “up to one million” figure is what the applicant has asked permission for, although it is typical in FCC filings that operators request maximum numbers greater than they ultimately deploy, and the final authorized count may be lower after review and modification.
- In prior related FCC actions, SpaceX also sought authorization for 15 000 additional Starlink satellites beyond its existing network and has current FCC authority for thousands more, but this new SAT‑LOA‑20260108‑00016 filing is notably for a much larger, distinct new constellation proposal.
- Summary
SpaceX’s current SAT‑LOA‑20260108‑00016 application proposes authority for a new LEO satellite system of up to one million satellites — a dramatically larger scale deployment than previously authorized Starlink satellites — representing a significant expansion of orbital infrastructure capacity.
Please Comment on both. Here are the comments submitted on behalf of Umpqua Watersheds
public-comment-on-file-no-sat-loa-20250701-00129 For the Reflect Orbital Application.
public-comment-on-file-no-sat-loa-20260108-00016 For the SpaceX Application.
Darksky.org has some very informative instructions:
Two satellite proposals threaten the night sky — the window to act is now
Public comment period now open
The comment period for the SpaceX proceeding closes on March 6, while the Reflect Orbital comment period closes on March 9. We strongly encourage submitting comments as early as possible.
While the FCC process can seem technical at first glance, we’ve done the hard work to make this as straightforward as possible. With the steps and templates below, you can submit a comment in as little as 15 minutes.
These proposals are being reviewed under separate FCC applications, and comments must be submitted to the correct file number to be considered.
- Reflect Orbital application file number: SAT-LOA-20250701-00129
- SpaceX application file number: SAT-LOA-20260108-00016
We encourage advocates, community partners, and members of the public to submit comments to one or both proceedings.
Step-by-step: How to submit a public comment to the FCC
You can submit comments on one or both proposals by following the steps below. The process is the same for each application; the key difference is the file number you select.
Step 1: Create an FCC CORES account
Go to https://apps.fcc.gov/cores/userLogin.do and click Register to create a free account using your email address. Complete the verification process to activate your account.
Step 2: Log in to the FCC filing system (ICFS)
Visit https://fccprod.servicenowservices.com/ibfs and log in using your CORES username and password.
Step 3: Find the application
Enter the application’s file number in the search box and open the application page.
- Reflect Orbital proposal: SAT-LOA-20250701-00129
- SpaceX proposal: SAT-LOA-20260108-00016
Step 4: Prepare your comment
Write your comment, clearly stating your position. Include your name and contact information, and save the document as a PDF. We’ve provided templates and sample language to help you get started:
Step 5: Upload your comment (important selections)
From the application page, select Pleadings and Comments from the top banner. This may prompt you to log in again using the same credentials. Once logged in, complete the submission form as follows:
- Select No for the Committee filing question
- Choose Comment as the pleading type
- Leave the FRN field blank and enter Responding as an Individual for Company
- Enter your contact information (anonymous comments are not allowed)
- Enter and select the correct file number
Reflect Orbital proposal: SAT-LOA-20250701-00129
SpaceX proposal: SAT-LOA-20260108-00016 - Select No for confidential treatment
- Attach your PDF and label it Public Comment on File No. [file number]
Step 6: Submit and confirm
Click Submit, confirm the success message, and save your receipt for your records.