[rrss]

> nobody knew who/where to contact someone to raise their concerns

SpaceX had to get approval from the FCC to launch these satellites. There was a comment period intended to provide an opportunity to voice these concerns. I looked into this the last time it was in the news (late May?), and could not find any petitions that raised concerns about reflecting light. There were several from other satellite companies requesting that the FCC deny the application based on concerns about increased risks of collision and/or radiointerference with their licensed bands.

[mlyle]

FCC isn't going to reject a radio license based on reflection of unregulated frequencies (light).

But IAU publicly decried satellite constellations in January, months before May-- and this public statement followed literally years of IAU discussions and discussions with SpaceX, etc.

Despite that, years later, SpaceX is only just getting around to taking small mitigation measures now, after two launches.

[rrss]

It wasn't a "radio license." It was an authorization to "construct, deploy, and operate a proposed non-geostationary orbit (NGSO) satellite system comprising 4,425 satellites for the provision of fixed-satellite service (FSS) around the world."

I don't see why the FCC wouldn't consider impact to visual astronomy, when they did consider increased collision risk (also unrelated to any regulated frequencies).

> IAU publicly decried satellite constellations in January, months before May

Can you link to information about this public statement from January? When I google "IAU satellite constellations," I find only https://www.iau.org/news/announcements/detail/ann19035/ from June.

[mlyle]

> It wasn't a "radio license."

It's fundamentally a radio license:

https://www.law.cornell.edu/cfr/text/47/25.114

> when they did consider increased collision risk

Yup, they are supposed to evaluate orbital debris and collision risk, too, 47 CFR 25.114(d)(14). That, and equitable service (for some services) to Alaska/Hawaii are the only non-radio concerns they are permitted by regulation to consider.

[rrss]

> they are permitted by regulation

Where is the restriction to only those concerns? 47 CFR § 25.156 has some pretty vague language about "the public interest, convenience and necessity."

Thanks for pointing out that the FCC is required to evaluate orbital debris and collision risk, but I don't think the FCC is prohibited from considering other concerns (and i might be wrong on that).

[mlyle]

OK, OK, insert "explicitly" in front of "permitted by regulation."

The public comments relate to the adequacy of the application, which is required to address those points.

Yes, users of radio frequency spectrum do have public interest obligations. Thus far, for spacecraft this has been entirely confined to coverage requirements (aka, helping out Alaska when it's not infeasible).

It would be highly unusual-- and likely to be overturned in judicial review-- if the FCC were to decline to issue a radio license because of secondary impacts of the business. (Outside the specific areas where the FCC has been granted oversight-- environmental impacts of radio towers, space debris mitigation, safe operation of radio facilities, etc).