FCC Should Require More Stringent Collision Threshold, Says Amazon's Kuiper

Requiring a more stringent collision probability threshold is a “reasonable alternative metric” that's preferable to an aggregate risk framework for regulating satellite constellations, said Amazon-owned Kuiper Systems in a letter posted Thursday in docket 18-313. The higher threshold stems from comments by NASA, the letter said. Amazon will “typically execute maneuvers when the risk exceeds a 1 in 100,000 chance that a collision will occur, a significantly higher safety threshold as compared to the industry practice of maneuvering when risk exceeds 1 in 10,000,” the letter said. The FCC should “adhere to the longstanding practice of assessing collision risk on a per-satellite basis, and to continue to work with other federal, industry, and academic stakeholders on a more stringent per-satellite large object collision risk metric,” said the letter.