OSI Says FCC Should Follow ESA's or France's Lead on Satellite Risk

The FCC should focus on the collective risk that satellite constellations pose instead of looking at the issue on a per-satellite basis, the Outer Space Institute said Monday in docket 18-313. It said the approaches of the European Space Agency or France "would be a considerable improvement" in regulatory clarity and system safety over the U.S. method. The FCC should treat operator claims that satellites will burn up entirely on re-entry skeptically. Instead, the FCC should require evidence of this. Pointing to vaporized metals entering the upper atmosphere by those satellite re-entries, the institute urged the FCC to study the issue "and be prepared to impose suitable mitigations." Any satellite operator exceeding the 100 object-years threshold -- the number of years each failed satellite remains in orbit, added across all the satellites -- should be barred from further deployments until the causes have been addressed, the institute said. It said operators should remove large debris coming from 100 object-years violations.