Jeffrey Hall, Constance Walker, Meredith Rawls, Jonathan McDowell, Robert Seaman, Aparna Venkatesan, James Lowenthal, Richard Green, Kelsie Krafton, Joel Parriott, Constance Walker, and Jeffrey Hall

“ The rapid development of efficient and in one case reusable rockets by private-sector companies has made Earth orbit no longer the exclusive realm of national agencies like NASA, and a steadily increasing number of entities is now launching both people and hardware into space. The result is exponential growth in the density and variety of satellites at a wide range of altitudes. As the glowing nighttime landscape on Earth has been transformed over the past two decades, so the sky is now being similarly transformed. ”

“ The federal system of protected lands has grown, and agencies have come to recognize that a naturally dark, star-filled sky is an intrinsic part and critical aspect of the park or wilderness experience. Consequently, an effort to protect the beauty of the skies can, by inference, be considered to require the protection of the astronomical value of the skies. The National Space Traffic Management (STM) Policy articulates the principles for a safe, stable, and sustainable operational space environment. ”

“ But as a community we also need to assess the overall impact, current and future, of satellite trails on our science, and this will require significant simulation efforts. Individual observatories will also want to carry out simulations to assess impacts on their programs. We propose developing software which will create images with simulated satellite trails at various levels of fidelity, as well as software which will automatically assess collections of such images to quantify things like the percentage degradation in source detection efficiency as a function of brightness. ”

“ Affordable broadband is crucial to almost all aspects of 21st century work and life, and some communities welcome satellite broadband. However, we must not assume that LEO satellite constellations are the only option; industry and agencies must develop a meaningful assessment of viable alternatives to satellite broadband, including ground-based fiber, from the perspectives of cost, infrastructure and environmental impact. ”

“ History offers valuable lessons on many issues with satellite constellations including environmental concerns, loss of millenia-old practices, and the painful legacies of colonization. The past century in particular offers ample examples of disruptive technologies that have been developed first and regulated only later, with varying degrees of cost, benefit, risk, and impact, e.g., telephones, trains/ planes/cars, fossil fuels, and the Internet itself. ”

“ The context was to ensure that satellite operators with a sense of corporate responsibility had access to sufficient insight into astronomical concerns, analytical tools and testing, and cross-industry collaboration for information sharing on mitigation techniques to enable them to develop satellite systems mindful of their effect on astronomy. The conclusions do not represent official corporate policy, but rather the continuation of needed technical discussion between industry and the astronomical/dark sky community. ”

“ It is the landscape in which we now live. Tens of thousands of satellites in LEO will inevitably create negative impacts for ground-based astronomy, for ground-based amateur, environmental, and cultural stakeholders, and possibly for space-based interests in comparable orbits, all of which will play out in an arena poorly equipped with policy to manage them. ”

“ We need coordinated international regulation of the satellite constellation industry with oversight and enforcement, in contrast to the current regulatory maze of siloed issues enabling business as usual. Most of the constituencies polled by the Community Engagement WG want industry to slow down until meaningful solutions can be developed in consensus, involving youth and communities. ”

“ The UN report further concluded that the prevention principle creates a duty to undertake an Environmental Impact Assessment prior to engaging in activities which pose a risk of transboundary harm. As established by SATCON1, large satellite constellations create an environmental impact due to the light pollution generated as a result of the reflectivity factor of the spacecraft.
US law also considers the effect of human activity on the natural environment. A defensible argument is that NEPA is intended to cover all of Earth, its orbital environment and all other celestial bodies. ”

“ With compelling operational and economic reasons to make the shift from legacy gas-discharge systems, communities around the world began installing white LEDs as their lighting of choice. In time, the side effects of the vastly increased sky glow and blue-rich spectral distribution of white LEDs became apparent, negatively impacting not only ground-based professional and amateur astronomy but also casual appreciation of the sky, flora and fauna, and human health. ”

“ Operators are recommended, as a first step, to share and publish their experience and lessons learned across the community, in order to build understanding of mitigation design techniques and foster innovation in new concepts. Because the technical and practical inquiry into mitigation techniques is still at an early stage, the Industry Subgroup endorses an outcomedriven focus for any mitigation recommendations and guidelines, rather than overly prescriptive language that stipulates a specific technology or technique. ”

“ While individual satellites can likely be designed to be invisible to the unaided eye, their trails will be easily visible to even entry-level amateur astronomy equipment and will be billions of times brighter than the sensitivity of major research facilities. In addition to the trails, diffuse brightening of the entire natural dark sky by scattering of reflected sunlight from satellites, up to a factor of 2–3 according to some calculations, is an increasingly real possibility. ”

“ The US position has always been that private agencies would not be free to engage in space programs without governmental permission and continuing governmental supervision. A good starting point would be to conduct due diligence concerning the activities of commercial satellite operators, specifically regarding the impact of in-orbit operation of such activities. ”

“ Communities want more information and dialogue. Astronomers and other parties concerned about the impacts of LEO satellite constellations need to engage, listen, share, and act with affected constituencies, government agencies, and cultural, grassroots, and political leaders. Decision-makers and private satellite operators must intentionally invite the voices and groups that have historically been excluded from the power structure and decision-making regarding space activity. ”

“ Because the number of satellites is expected to grow, it is likely that in the near future there will be no place on Earth where these satellites will not be visible crossing the sky. This new type of light pollution is a problem we will have to deal with. ”

“ The Industry Subgroup concluded that satellite operators were more likely to adopt voluntary practices or mitigation tools if they engaged with astronomers early in their project cycle, before spacecraft designs were finalized and when modifications to architectures, spacecraft design or operations could be introduced at less cost or schedule impact. ”

“ Several common themes relevant to the pursuit of astronomy and preservation of the night sky emerged during the discussions leading up to and during the SATCON2 workshop.
4.1. Urgency
Throughout the SATCON2 discussions, recurring points were made about the abruptness and rapidity with which we are now transforming the night sky. A major challenge here is that industry and academia operate on different timescales. Satellite operators are working quickly and nimbly, within the competitive environment of a new frontier of opportunity, to develop and launch their fleets. ”

“ In the era when satellite trails are frequent but not ubiquitous, it will be important to know when particular astronomical targets will be affected by trails and when they are expected to be free of them. PassPredict would use a satellite ephemeris database to check when particular areas of sky will be affected by satellite passes. ”

“ The workshop’s two additional goals were to engage a considerably wider group of stakeholders in the conversations than had been present at SATCON1 and to explore existing policy frameworks, generating ideas for the development of policies capable of addressing an entirely new era in the exploration and use of space.
To this end, we structured SATCON2 in much the same way as SATCON1. We charged four working groups (WGs) to prepare draft reports relevant to the workshop’s goals and to present their findings at the workshop itself. ”

“ Satellite operators must first consult all impacted groups, including the sovereign American Indian/Alaska Native nations and global Indigenous communities before launching satellites. Industry must fully consider the concerns of Indigenous nations, including sovereignty, transparency, written agreements, and jurisdiction of treaties in space. ”

“ Examples of global challenges requiring international collaboration include damage to the ozone layer, for which corrective action has been largely successful, and climate change, for which a global course of corrective action has remained elusive. ”

“ The SATCON2 SOC appreciates the engagement in addressing these issues by the several satellite operators who participated in the workshop, and we hope that this example is followed by other operators entering this arena. We acknowledge that the astronomy community needs an entity tasked to respond to queries from industry promptly and helpfully. ”

“ The Community Engagement WG invested substantial time engaging and facilitating discussions with its diverse member group; continuation of these conversations requires long-term support for individuals specifically tasked to do so. And development of policy requires lengthy deliberation, aided by substantial support and input from legal counsel. ”

“ The group emphasizes that in the end no set of software tools will allow astronomers to fully recover the data affected by satellite trails. The WG recommends that a number of specific software efforts are needed, and while the entire community is expected to contribute, coordination is needed to provide interoperability, end-to-end functionality, documentation and long term support; SatHub will provide a natural home for that effort. ”

“ The National Oceanic and Atmospheric Administration (NOAA) and the US Federal Aviation Administration (FAA) have recently revised their policies to take these STM principles into account, as did the US Federal Communications Commission (FCC) as part of their licensing considerations. There are three implications for licensing requirements. One is the precedent that these agencies can and do consider at least one aspect of in-orbit operations as a condition of licensing. ”

“ Operators should publicly provide orbital solutions every 8 hours or whenever a maneuver happens, whichever is first, and must include reasonable estimates of uncertainties with all orbital solutions. ”