Amazon sends letter to FCC saying: Reject application of Elon Musk’s Spacex for Space data centers; gives three reasons to dismiss
Elon Musk’s Starlink rival Amazon Leo has sent a letter to Federal Communications Commission (FCC) to dismiss Spacex’s 1 million-satellite proposal for orbiting data centers. Amazon‘s letter goes as far as to claim that the project would take “centuries” to deploy. Amazon’s 17-page filing to the FCC requests for complete rejection of the Starlink proposal. The letter says that Starlink’s application promises no less than a “first step towards becoming a Kardashev II-level civilization” — in other words, a society capable of harnessing the full power of the Sun — while “ensuring humanity’s multiplanetary future among the stars.”Amazon’s letter questions why the FCC is processing SpaceX’s proposal, claiming that “the Commission has long refused to process speculative, conceptual, or otherwise incomplete filings.” “Timing is likewise uncertain: deploying the proposed million-satellite constellation would take centuries, even assuming the availability of all global launch capacity to do so.” Amazon’s letter further argues that granting SpaceX’s application would “worsen matters further, forcing every other operator in low-Earth orbit to plan around a constellation that may never exist,” and spark a scramble to warehouse orbital resources. “At best, the Application appears to be an exercise in publicity and messaging—and at worst, an attempt to stake a priority claim over a vast swath of orbital resources with no genuine intent to deploy,” the filing adds. Here are the three key reasons that Amazon’s letter gives FCC to reject Spacex’s application
1. The Application Lacks Basic RF and Orbital Parameters Required by the Commission’s Rules.
The Commission’s rules require NGSO applicants to specify basic RF and orbital parameters, including beam information, the number of satellites, the orbital planes those satellites will occupy, and how those satellites will be distributed across those planes. SpaceX provides only partial information for three satellites (or 0.0003% of the full system) located in three so-called “representative planes,” while omitting any description of the full constellation it seeks authority to deploy and operate.15 SpaceX omits RF characteristics, explaining that it “intends to operate in many different orbital planes with a range of antenna gains, resulting in a large number of possible combinations of parameters,” and as a result, “[r]ather than provide information for all possible configurations at all altitudes, SpaceX has provided information for satellites in a set of representative planes.”16 Likewise, SpaceX omits crucialorbital information, including the full set of orbital planes it intends to occupy, the number of satellites it proposes to operate in each plane, and even the size of its satellites. As for the altitude of SpaceX’s planned constellation—a key parameter for both RF and physical coordination—the Application states only that the million satellites will operate between 500 km and 2000 km. To this, the Application requests to add 100 km of orbital tolerance at either end of this range, meaning that the million satellites would—or at least could—occupy virtually any and every altitude within low-Earth orbit.The reason the Commission requires this information is simple. For both the Commission and other satellite operators alike, assessing the interference and space safety impact of a new constellation requires a combined understanding of both orbital geometry and RF emissions. This information is particularly important when, as here, the proposed constellation is two orders of magnitude larger than all satellites currently orbiting the Earth. Yet SpaceX’s technical description of its novel and unprecedented system spans little more than three pages—about half the length of its six-page request for various waivers.
2. The Application Fails to Provide Required Space Safety and Sustainability Information
The Application likewise fails to provide meaningful or complete information on how SpaceX’s proposed deployment would operate safely and sustainably—lacking meaningful detail on issues such as conjunction avoidance, reentry hazards, or the host of other certifications, assessments, and demonstrations required by the Commission’s application rules regarding space safety.21 While the Application contains over ten pages of discussion on this topic—longer than the narrative and all other technical discussion combined—the discussion for the most part parrots rule language or rests on vaguely supported assertions regarding compliance with the Commission’s space safety rules. The Application does not contain any detailed assessment of, for example, collision risk with operators in similar orbits, whether any components of the planned data-center space stations will survive reentry,23 or how SpaceX intends to model and reserve fuel to ensure that it can conduct avoidance maneuvers and actively deorbit.SpaceX’s lack of detail on these issues stands in stark contrast to its searching review of the space safety plans of other operators. For example, SpaceX has intensely scrutinized the assessment of collision risk raised by operators in similar orbits—double checking the submissions of Amazon Leo, AST SpaceMobile, and others to ensure that the assessment provided captures all of the possible objects that could affect operations, that the plans of other operators adequately model the conjunction maneuvers necessary given nearby operations within a given orbit, and that operators sufficiently plan for operational issues such as maintaining a sufficient fuel reserve toboth conduct avoidance maneuvers and actively deorbit.25 Yet here, the Application provides no analysis of these issues at all, despite a constellation hundreds of times larger and spanning virtually the entire altitude range of low-Earth orbit. SpaceX’s ability to conduct avoidance maneuvers, likewise, calls for more than rote and little-explained assertions about maneuvering capability. The sheer number of satellites contemplated by the Application would necessitate near‑continuous conjunction‑avoidance maneuvers, at a volume that far exceeds existing warning, response, and coordination capabilities. Managing collision risk at this scale would impose an increased burden on operators ascending, descending, or transiting through SpaceX’s orbital shells. Based on SpaceX’s semi-annual report and the fact that the Application proposes to cover all of low-Earth orbit, the practical effect of a grant would mean any operator seeking to orbit raise a space station anywhere in low-Earth orbit would be required to take on significant operational burdens, increased risk to valuable assets, and the additional cost of maneuvering around SpaceX’s massive constellation.Also lacking is a detailed discussion of disposal orbits. SpaceX simply asserts that it will select disposal orbits associated with passive decay times exceeding 200 years to reach 2,000 kilometers of altitude, with a passive‑decay collision probability of 1 in 100 over a 100‑year period.27 It remains unclear whether SpaceX intends to dispose of these 1 million satellites and their replacements in or beyond geostationary satellite orbit (“GSO”) graveyard orbits, or whether it intends to create a graveyard orbit somewhere between LEO and the geostationary arc. At the scale proposed, this approach implies that collisions in medium earth orbit (“MEO”) with defunct spacecraft could become a regular occurrence, severely degrading the space environment for generations and denying other operators—including U.S. operators—the ability to access new orbits at higher altitudes.Also lacking is any explanation of how SpaceX’s “chosen disposal method” will meet the Commission’s 99% threshold of reliability. To begin with, it’s not clear what the chosen method is at all—the Application identifies several options (disposal in heliocentric orbits, disposal in other orbits above 2,000 km, or atmospheric reentry) but fails to provide any explanation of how it will choose a given strategy for a given orbital shell.30 With respect to the reliability threshold, SpaceX simply asserts that it has “demonstrated” a 99% reliability—presumably referring to the reliability of its existing constellation. But to the extent that SpaceX has designed its data center satellites at all, the design for these satellites will be fundamentally different than the design for its existing fleet of communications satellites. Even at a 99% success rate, this would mean that 10,000 satellites would fail to be safely disposed of—which is more than three times Amazon Leo’s total constellation size and more than the size of SpaceX’s most recent grant of authority to deploy and operate a 7,500-satellite constellation.
3. SpaceX’s System, As Proposed, Is Speculative and Unrealistic
The unprecedented size of SpaceX’s proposed constellation calls for more detail on these and other space safety issues rather than less. Yet the thin technical description in the Application appears to reflect the fact that there is no well-developed plan to deploy. At best, the Application appears to be an exercise in publicity and messaging—and at worst, an attempt to stake a priority claim over a vast swath of orbital resources with no genuine intent to deploy. To begin with, the Application never affirmatively states that SpaceX intends to deploy one million satellites. It seeks authority for “up to” that number—in other words, this figure appears to establish a ceiling without a floor. SpaceX seeks a waiver of any rule that might hold it accountable for deploying a million satellites on any specific timeline.To begin with, the Application never affirmatively states that SpaceX intends to deploy one million satellites. It seeks authority for “up to” that number—in other words, this figure appears to establish a ceiling without a floor. SpaceX seeks a waiver of any rule that might hold it accountable for deploying a million satellites on any specific timeline. This includes requesting a waiver of the Commission’s buildout milestones and surety bond rules, which together wouldestablish a timeline for deploying SpaceX’s million satellites and impose monetary penalties for failure to fully deploy.33 SpaceX itself recently emphasized the importance of both rules in discouraging speculative applications in the Commission’s Space Modernization proceeding.SpaceX likewise notes that it has yet to submit a corresponding International Telecommunication Union (“ITU”) filing for its proposed constellation—an essential prerequisite for securing international priority, but a step that calls for details that the Application does not provide.Together, these omissions strongly suggest that SpaceX does not intend to deploy the system as proposed, but instead seeks to warehouse valuable orbital resources through an application untethered from any realistic deployment plan—precisely what SpaceX told the Commission, in its own words, that the rules must not permit.Full deployment of the proposed constellation is, moreover, impossible within any reasonable timeframe. In 2025—a record-breaking year for global spaceflight—4,526 satellites were launched into orbit worldwide.37 At that pace, deploying one million satellites would take more than 220 years. This assumes every satellite launched anywhere on Earth, by every nation and every operator, was dedicated exclusively to SpaceX’s data center constellation. Thereplenishment math is equally sobering: assuming a five-year satellite lifespan, sustaining a million-satellite constellation would require replacing 200,000 satellites per year—more than 44 times the entire global satellite launch output in 2025, just to keep the constellation at steady state.In sum, SpaceX’s million-satellite deployment appears to be wholly unrealistic, if not impossible, to achieve in the foreseeable future unless there is a significant and unprecedented increase in global launch capacity.
