Secure World Foundation has published FCC comments on Cowboy Space Corp.’s application for Stampede, a proposed non-geostationary orbit system of up to 20,000 satellites for orbital data center operations.
The filing builds on SWF’s previous comments on orbital data center applications from SpaceX, Starcloud, and Blue Origin. SWF’s core concern remains the same: these proposals should not be treated as routine satellite licensing matters. They represent a qualitative shift in the scale of proposed constellation operations and raise technical, environmental, and governance questions that extend beyond standard non-geostationary orbit licensing practice.
In its comments, SWF recognizes the role U.S. commercial innovation has played in advancing space capabilities. The filing does not argue against innovation. It argues for regulatory scrutiny that matches the scale and potential impact of the proposed system.
SWF urges the FCC to evaluate Cowboy Space’s application as a precedent-setting, non-routine request and to deny or defer requested waivers until the company provides a sufficient technical record to assess full-scale risks. The filing also recommends system-level analysis and disclosure, including cumulative collision risks, post-mission disposal performance, and aggregate interference effects.
SWF further recommends a phased, demonstration-based authorization approach with strict reporting, transparency commitments, and clear performance benchmarks before any expansion. Because very large constellations raise questions that go beyond any single application, SWF also recommends that the FCC initiate a parallel Notice of Inquiry on externalities and cumulative metrics for systems of this scale.