SpaceX as filed a groundbreaking proposal to launch and operate one million small satellites as a data center in space.

My two immediate reactions: Wow! and Is There Less Than Meets the Eye?

First, the Wow! In the spirit of moving fast and subverting conventional wisdom, SpaceX and Elon Musk have turned the AI and Data Center topography upside down. Launch a massive constellation of small satellites in Low Earth Orbit, and the gravitational pulls from water, electric power, and real estate issues, as well as many unresolved regulatory, international law, and U.S. treaty commitments, evaporate. Poof!

Is this a great country or what?

With this filing, SpaceX proposes to increase the number of orbiting spacecraft from about 12,000 to 1,112,000 (European Space Agency non-space data center forecast of 100,000 satellites by 2030.

LEO orbiting satellites will not deplete any scarce terrestrial resources. Surely Artificial Intelligence applications will get a boost, as will U.S. competition to maintain global technological, military, and commercial space supremacy. At least conceptually, we consumers of data center and broadband service should benefit from faster, better, smarter, cheaper, and more sustainable goods and services.

What’s not to like?

A lot, which leads me to: Is There Less Than Meets the Eye?

While admiring the quest to capture first mover market advantages and public imagination, I hereby throw cold water, aluminum particles and gas from vaporizing space junk, and other inconvenient, but not easily ignored issues, making the project far less than it appears from recent headlines and social network posts.

First, consider the number of exceptions SpaceX wants the FCC to issue. For a summary of the waiver requests, see https://www.fcc.gov/document/sb-accepts-filing-spacexs-application-orbital-data-centers. In simple English, SpaceX wants the FCC to treat the application exclusively and not in the customary filing window where other similar applications would get considered at the same time.

SpaceX also wants exemption from all milestone requirements and deployment obligations, meaning that it has no deadlines and benchmarks to satisfy as proof of ongoing progress toward complete deployment of satellites and the start of service. Contrast that request with Elon Musk’s forecast that the data center in space will reach a critical mass in 30-36 months from now, with more AI space launches than terrestrial expansion within 5 years.

Despite its considerable access to internal and external funding befitting a venture with an estimated value of $1 trillion, SpaceX seeks the waiver of all surety bond requirements and obligations. Lastly, SpaceX wants to work on its ambitious project without disclosing technical details such as channel plans for licensed beams, uplink and downlink beams, command beams, and orbital plane configurations.

If the FCC were to grant such an extensive waiver wish list, SpaceX would have quite limited obligations to disclose how its space data center would operate and whether other competing satellite constellations could share that part of LEO having the right combination of solar power potential and heat discharge.

There is a growing list of chronic and emerging issues that call into question whether space, as enormous as it is, can accommodate 1 million more LEO satellites in relatively close proximity to each other. Space tourism, asteroid mining for scarce minerals, and the colonization of the Moon and Mars will also require shared access. A massive increase in spacecraft, coupled with an expectation that Earth hostilities will have a space surveillance, military, and warfare component, substantially raises the odds for collisions, as well as an increase in toxicity from spacecraft launches and vaporization when falling back to Earth.

The SpaceX grand proposal reminds me of the absolute necessity of having both full disclosure of technical, operational, radio spectrum, and orbital plane usage, coupled with a realistic timeline for starting service. Without these requirements and “skin the game” financial commitments, subject to forfeiture, SpaceX can, in the worst case, propose nothing more than a paper satellite constellation that could chill investment in competing, perhaps less ambitious but more timely and practical projects.

It makes sense to consider the six pages of conditions imposed by the FCC for StarLink’s second-generation broadband network.

If the FCC wants to remain true to its “Open Skies,” pro-competitive ethos, it has to offer flexibility in its processing of innovative service applications, but also guard against ambitious paper satellite proposals designed to preempt competition and corner a market years before the first of one million satellites reaches orbit.