Learning to Love LEOs ... or NOT!

Viasat Chief Executive Officer Mark Dankberg gave a stirring keynote at the recent Silicon Valley Space Week (SVSW) gathering. He highlighted the arrival of direct-to-device communications between satellites and cellular handsets and the emergence of an industry initiative to facilitate that reality - the Mobile Satellite Services Association (MSSA).

At the same time, though, Dankberg concluded his remarks with a foreboding image of low earth orbit (LEO) satellites plunging from the skies (actually burning up in the atmosphere) by the dozens within a few years. His concerns, lumped under the broad heading of sustainability, left a troubling impression somewhat clouding the sunnier prospect of billions of dollars in new revenue from nascent non-terrestrial network communications applications.

Dankberg was responding to the onset of thousands of satellites in low earth orbit (LEO) designed to deliver Wi-Fi connectivity to individual users, enterprises, governments, militaries, airplanes, trains, ships, and, most recently, handsets rapidly transforming the greater satellite industry which was previously dominated by a handful of operators focused on delivering lower bandwidth solutions from Geostationary (GEO) orbits. LEO constellations, led by SpaceX's 6,000 satellites (and counting), have shifted the industry's focus to multi-orbit solutions along with new collaborations and new expectations.

Fueling the transition to LEO-enabled communications has been the introduction of direct-to-device (D2D) communications for SOS and text messaging from Apple (working with Globalstar), T-Mobile (working with Starlink), Verizon and Google Pixel (working with Skylo), and AT&T (working with AST SpaceMobile). These developments have brought a spotlight to the emergence of non-terrestrial network communications which will enable standards-based, seamless 5G-satellite integration - starting at low bandwidths for emergency communications and texts but evolving toward broadband communications within a few years.

D2D communications is but one manifestation of a rapidly shifting reality which has seen SpaceX delivering satellite-based Internet access for everything from connectivity in remote locations, homes, and combat zones to core enterprise and government applications. The Silicon Valley Space Week (SVSW) gathering captured the moment with multiple speakers describing the ongoing integration of Spacelink-supplied service with existing service provisioning and the expansion of market opportunities - which was in-turn feeding investor interest in the sector.

Viasat has been leading the charge to create a collaborative environment for co-existence between legacy GEO satellite operators and LEO upstarts and startups, such as SpaceX. Viasat was a founding member of the Mobile Satellite Services Association with partners Yahsat, Ligado Networks, Terrestar Solutions, and Omnispace with the stated objective of helping to define relevant 3GPP standards and to aggregate 100MHz of L- and S-band spectrum for D2D and IoT applications.

At stake is a revenue opportunity estimated to represent $30B by 2035, according to GSMA estimates shared by other speakers at SVSW. Also driving interest and demand for satellite-to-cellular integration is the proportion of the world not currently covered by wireless access, estimated by one speaker at SVSW at 80% of the planet's surface. An augmentation of coverage from space appears to be in order.

Dankberg's enthusiasm for D2D and cellular-satellite integration is driven by the need for seamless, interoperability - i.e. satellite roaming. The MSSA is inspired by the need for standards-based devices and infrastructure that enable seamless satellite-cellular roaming thereby enabling enhanced value creation and more acceptable price points.

Dankberg's vision emphasizes that the value of the relevant spectrum and the networks will be enhanced by cooperation and collaboration. MSSA is actively recruiting additional service providers to join the standards-setting and spectrum aggregating process.

It was at this point, though, during the Q&A session after his keynote, that the commentary turned somewhat darker. Asked whether the biggest hurdle to D2D adoption was regulatory, economic, or technical, Dankberg said the biggest issue was regulatory concerns related to national sovereignty and national security posed by global satellite networks. The framework will clearly have to take national borders into account - as is already happening today.

Asked about his concerns that the industry is "heading to a crisis" in LEO Dankberg said:

"If you just look at the articles describing impacts on astronomy, concern about effects on the upper atmosphere due to aluminum oxide.? We are at a point where some time in the next few months we are going to be seeing on the order of 100 satellites decaying into the upper atmosphere every month.

"And then within another couple years it will be 2-300 every month.? Those satellites decaying now are 250 kilograms, the ones being launched to replace them are 750-2000 kilograms.? People haven’t looked at this.? The largest operators looking at 30-40,000 tons refreshed every five or six years – 6-8000 tons a year disintegrating into the atmosphere.? And then the collision risk.? Domestic space eco-systems are being destroyed."

Dankberg's concerns dovetail with those expressed by 100 researchers from multiple U.S. universities in a letter sent to the Federal Communications Commission (FCC) asking for a pause in LEO satellite launches warning of the "environmental harms of launching and burning up so many satellites."

The letter notes Starlink's launch of more than 6,000 LEO satellites (60% of all satellites in orbit) targeting broadband service delivery and the fact that an estimated 58,000 satellites will be in orbit by 2030 - with hundreds of thousands more expected based on plans from SpaceX, Amazon's Project Kuiper, and others.

The letter comes in response to an exclusion granted by the FCC to an environmental review normally mandated by the National Environmental Policy Act (NEPA). The letter calls attention to a General Accounting Office study calling on the FCC to conduct such a review or otherwise justify its exclusion grant.

The letter writers state: "That launching 30,000-500,000 satellites into low earth orbit doesn't even warrant an environmental review offends common sense... The FCC should immediately begin a comprehensive review process working with experts from academia, the Environmental Protection Agency, the National Aeronautics and Space Administration, and other Federal agencies. The review must consider the total effects of proposed mega-constellations in the context of other internationally proposed constellations - not on a one-by-one basis."

The Public Interest Research Group added its own alarmist tone to the discussion stating in an August report:

"At its peak deployment, (Starlink's mega-constellation) will require 29 tons of satellites to enter the upper atmosphere every day" - "equivalent to a car entering our skies every hour."

"The rocket launches needed to maintain these mega-constellations are a huge potential source of pollution themselves, and would release soot in the atmosphere equivalent to 7 million diesel dump trucks circling the globe, each year."

The challenge for these letter writers is the reality that SpaceX is rapidly being joined by Rocket Labs, Amazon's Kuiper and other launch service providers serving a growing population of commercial and governmental customers. Speakers at SVSW noted that as many as 90 governments worldwide are interested in creating their own satellite constellations. Current launches are already booked solid for years even as the available launch capacity continues to grow.

It's difficult to see the FCC trying to stand in the path of this runaway train while China and India are ramping their own launch capacity. Does anyone expect the Trump Administration to prioritize environmental concerns related to space? I'm not holding my breath.