Prof. Sam Lawler
Cowboy Space (I hate their name so much) published their consolidated response a week ago but we just noticed it. We either have 3 days or 8 days to respond now. So... I guess I have to read this shit. Swearing a lot here will get me through it.
A reminder: this is the 4th company that wants to launch fucking enormous "AI data center" satellites into sun-synchronous terminator orbits, giving Earth a ring. This particular company wants 20,000 satellites in one ring.
Prof. Sam Lawler
Sure, completely untested, brand-fucking-new company that has never built or launched a satellite. You can definitely launch 20,000 of the biggest satellites ever built.
Oh apparently their first demo mission is scheduled for OCTOBER 2026? Gosh these guys are fucking unreal. The mission is listed as "power beaming demonstration"
What does that even fucking mean? Guess they're going to fry some birds and maybe some pilots? Hm. Watch for that I guess.
Prof. Sam Lawler
Ok fine time to read the awful document.
First off, they imply they don't have to listen to any of the comments because nobody submitted "service copies, certificates of service, or affidavits" but I'm pretty sure that's just for formal petitions to deny. The American Astronomical Society did all of those things for SpaceX's million sat filing and Reflect Orbital, and it was expensive, hard, and it didn't make a fucking difference. So not doing that again.
Prof. Sam Lawler
Oh gosh I don't know if I can actually read this. "The United States is engaged in a race for AI dominance, and as the terrestrial electric grid is overwhelmed by the demands of new data centers this race is now a race for space dominance as well"
FUCK THIS OUTRIGHT COLONIALIST DOGSHIT. WOW.
"Very little in the record disputes Cowboy Space’s qualifications"
HAHAHA that's because you haven't fucking done ANYTHING!!!
Prof. Sam Lawler
"While one commenter derides Cowboy Space’s approach to data centers as mere 'avoidance' of terrestrial environmental regulation"
Uh yep that was me (via @space_environmentalism)
The rest of that section appears to be greenwashing, IN SPAAAACE!
Prof. Sam Lawler
After modelling this in detail, I can say that that these companies can't even do basic geometry, apparently. They want tens of thousands of satellites to have 24 hour sunlight, so sun-synchronous terminator orbits, baybeeee!
But as Hugh Lewis pointed out (I know, ew, linkedin sorry) https://www.linkedin.com/pulse/sun-always-shines-tv-hugh-lewis-tlkbe/ IT DOESN'T FUCKING WORK unless you're above 1400km altitude. And then you're not in the *magical* low-latency low-altitude zone that these companies actually want for fast comms.
Prof. Sam Lawler
This company also posted an ex parte filing (which means they had a super special extra FCC meeting), their satellites are too fucking huge to even be physically possible. They just can't fucking do this.
My estimate from looking at this ridiculous sketch is 8x60x10m solar panels... that's a reflecting area of 4800 m^2. The International Space Station, the biggest thing in orbit, has a solar panel area of about 3400 m^2.
Prof. Sam Lawler
HAHAHA wow apparently they shouldn't have to provide any kind of debris mitigation plan because they haven't built the satellites yet.
OK but like... why are you filing if you haven't built the fucking satellites yet?? Weren't you complaining earlier about "warehousing" orbits? WHAT ARE YOU FUCKING DOING RIGHT NOW HMMMM??
Then they go on to say that the FCC shouldn't have to think about aggregate collision risk. Just consider one satellite at a time please, ignore the other 19,999
Prof. Sam Lawler
Ooo actual quote "AAS’s concerns are unfounded"
Top-notch gaslighting. Nope the professional astronomers definitely don't know what they're talking about. Ooo it gets better:
"Nevertheless, Cowboy Space commits to coordination with National Science Foundation (“NSF”) and will work to mitigate potential impacts on radio astronomy before they arise."
We totally don't need to do this because there won't be any problems but we'll talk to NSF about the problems that we totally won't have.
Prof. Sam Lawler
The rest of the astronomy section is pure bullshit, unadulterated by any facts or actual information.
"We will definitely work with astronomers, and we definitely won't have any reflections because our satellites are magical, we also won't have any infrared emissions, even though physics says that very hot things emit blackbody radiation. We are cowboys, not bound by mere LAWS OF PHYSICS."
Prof. Sam Lawler
WOW it gets even more whimsical and hand-wavy in the orbital debris section. Actual quote: "Certain commenters raise concerns regarding the extent of the orbital debris mitigation information provided in the application but ignore Cowboy Space’s steadfast commitment to operating
safely."
In other words: "Why won't scientists believe the words that we wrote down without any actual data, information, citations, or sketches?"
Prof. Sam Lawler
Next, they spend a bunch of time saying they totally need a bond waiver. Please ignore all the stuff we said about how much money we're making! We shouldn't have to pay!
And then they go into specifics of saying that @space_environmentalism "mischaracterized" the purpose of a bond: it's not actually to make companies pay for cleanup, it's to avoid over-asking for orbits. Well... they might have a point there, the FCC certainly doesn't give a shit about cleaning anything up.
Prof. Sam Lawler
They make it pretty clear that they are in fact over-asking and also don't intend to actually launch 20,000 satellites in 5 years. So... I guess that's good. But also fucking annoying.
Oh no here's the astronomy section. I'm sure this will be great.
Prof. Sam Lawler
Apparently ALL the opposition letters mentioned how 20,000 bright satellites would absolutely destroy astronomy, so that's nice.
Ok, well, this section is 100% gaslighting, which I expected. "No no no, radio astronomers, you are overreacting! We will totally not clobber your bands and we magically don't have harmonics or unintended radio emissions, despite not having actually ever built a satellite before. Also we'll use lasers to fix everything. Radio astronomers, shut up."
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