PEER, DarkSky International, the American Bird Conservancy, and Environment America — represented by Earthjustice — filed a formal Application for Review asking the Federal Communications Commission (FCC) to reverse its Space Bureau’s approval of Reflect Orbital Inc.’s Earendil-1 satellite.

Earendil-1 is a commercial satellite that will reflect sunlight back to Earth at night.

The Space Bureau granted Reflect Orbital’s application on July 9, 2026, finding it served the public interest and fell outside the environmental review requirements of the National Environmental Policy Act (NEPA) — the federal law requiring agencies to study the environmental effects of major actions on the United States before granting approval.

Selling Sunlight After Dark

Reflect Orbital’s business model is to sell sunlight at night for uses such as replacing streetlights, extending outdoor work hours, and powering solar arrays. To do this, Earendil-1 will unfold a mirror roughly a tenth of an acre wide at 600–650 km altitude and steer reflected sunlight to chosen spots on the ground. A single Earendil-1 satellite is expected to project a beam roughly 5 km (over 3 miles) wide as it sweeps the ground, with scattered light extending further still.

Although Reflect Orbital’s FCC application covers only this one satellite, the company has called this a “crucial testbed” for a much larger operation, with publicly stated plans to scale up to 50,000 satellites by 2035.

Why This is a Problem

In March, PEER and other groups filed comments with the FCC opposing Reflect Orbital’s original application for approval. In last week’s Application for Review, the groups say the Bureau didn’t adequately address a number of issues, including:

• Eye damage — a DarkSky technical report found the reflected light could be intense enough to injure eyes faster than a person could blink or look away.
• Astronomy disruption — the American Astronomical Society warned that even one pass could saturate telescope detectors and cost extended observing time; roughly 80% of astronomers surveyed in 2025 expected satellite constellations like this one to affect their work.
• Aviation and road safety — the Air Line Pilots Association, representing over 80,000 pilots, said Reflect Orbital’s own safety analysis was inadequate to address glare risk to aircraft.
• Wildlife harm — roughly a third of vertebrates and most invertebrates are light-sensitive at night; the scientific record links artificial light to disrupted migration and breeding, threatening species already protected under the Endangered Species Act.
• Human health — nighttime light suppresses melatonin and disrupts circadian rhythms, with peer-reviewed research tying this to elevated risk of obesity, diabetes, heart disease, and certain cancers.

An Environmental Review is Necessary

Our main request is for the FCC to reverse the Space Bureau’s order and require a full, lawful environmental review — an Environmental Assessment or Impact Statement — before Earendil-1 is authorized to operate at all.

At a minimum, we argue, the FCC needs to place 16 binding conditions as part of its approval, including: an independent scattered-light and sky-brightness analysis; exclusions over national parks, wildlife refuges, and other protected or ecologically sensitive lands; blackout periods during peak bird migration and after midnight; a requirement to get sign-off from affected state, local, and Tribal governments; independent, third-party verifications of the actual beam; and the requirement of a full environmental review before any commercial scale constellation could move forward.

Part of a Bigger Fight Over What’s Allowed in Low Orbit

This filing Application for Review is one piece of a broader push by DarkSky, PEER, and allied groups to get federal regulators to properly review the wave of low-Earth orbit projects before the FCC — including proposals for orbiting data centers.

As companies make plans to launch more than a million data centers into space, the FCC must conduct a thorough review of the risks and impacts of these projects to ensure they are not causing irreparable environmental harm to the United States, and if they are, place conditions on these projects to minimize these harms.

With the space rush on, we must not fall blindly into accepting everything the industry and government tells us. Rather, we must continue to act to make sure federal agencies consider all the risks and impacts of these satellite proposals as part of the approval process.

The Application for Review and mitigations annex are now part of the FCC’s public record (ICFS File No. SAT-LOA-20250701-00129). There’s no set timeline for a ruling from the full Commission.