To ODC or not to ODC: Insight for May 2026
By Alex Shi, Senior Program Analyst and Ian Christensen, Senior Director Private Sector Programs
In the first half of 2026, interest and activity around Orbital Data Centers (ODCs),on-orbit satellite constellations of varying size and design intended to harness solar power in space to meet the anticipated demand for artificial intelligence (AI) and other compute-intensive applications, have moved rapidly from the margins to a key trend in space development. SpaceX. Blue Origin. Axiom Space. Starcloud. Google & Planet. Beijing Orbital Twilight Technology. Nvidia. Announcements of interest and plans in ODCs come seemingly on an ever-increasing cadence.
Interest and Plans for Orbital Data Centers
Table: Known Plans for Orbital Data Centers1
1 Several other US companies such as Axiom Space + Kepler, Sophia Space, and Orbital have also unveiled plans to deploy ODCs, although details on planned size and orbits are not yet available.
2 Numbers based on the reference design explored in a preprint paper. Actual plans may differ.
Some of these plans have (at least theoretically) access to large amounts of capital. SpaceX’s proposed ODC constellation is a key element of the company’s recent initial public offering (IPO) filing. Starcloud raised $170m in its series A, achieving a $1.1B valuation. China’s Beijing Orbital Twilight Technology reportedly has access to $8.4B in credit lines. Yet despite this interest and activity, significant questions remain about technical achievability (in particular around heat dissipation), economic and business viability, and other factors (including launch capacity). ODCs also raise novel questions around space operations, safety, and sustainability, potentially representing a trend more significant than the emergence of very large constellations (e.g. Starlink, Amazon Leo, OneWeb, Spacesail) as a driver of change.
Since January 2026, a number of US-based prospective ODC operators have filed for regulatory approval to develop and deploy their systems with the Federal Communications Commission (FCC). These include SpaceX’s plan for a 1 million-satellite ODC constellation (the first actual mega-constellation); StarCloud’s plan for an 88,000-satellite ODC constellation, Blue Origin’s plan for an ODC constellation of up to 51,600 satellites, and Cowboy Space’s plan for a 22,000-satellite constellation. While these filings do not have a great deal of technical detail on the design and operation of the constellations, they share several key aspects, including the use of optical intersatellite links and transmission to existing communications constellations (e.g. Starlink and the planned TeraWave constellation) as the primary data transmission method, rather than traditional RF spectrum; and the expectation of large solar arrays. Companies seek to begin deployment of these constellations as soon as 2027. In their filings the companies generally seek waivers from FCC requirements around spectrum coordination, request expedited processing, and provide information necessary to satisfy existing space-debris mitigation and post-mission disposal requirements. In general, the argument is made that, in the words of Blue Origin, ODCs are “integral to economic competitiveness, technological innovation, and broad societal benefit."
Space Safety and Sustainability Issues Raised by ODCs
Secure World Foundation filed public comments in response to each of the SpaceX, Starcloud, and Blue Origin ODC filings. In these comments, while we generally recognize the importance of commercial innovation in advancing space capabilities and the resultant benefits, we also argue for taking a cautious approach in the authorization of these new constellations. The current wave of ODC applications represents a qualitative shift in the scale of proposed satellite constellation operations. It is not an incremental expansion of existing LEO operations and licensing practice, but rather it raises novel technical, environmental, and governance considerations. As of May 2026, there are over 15,000 active satellites in orbit; any single ODC application now before the Commission would, if fully deployed, multiply that figure several times over.
While SpaceX, in particular, has developed significant operational expertise in operating large constellations and generally operates the Starlink constellation to the state of the art in operational space safety, many of the other ODC applicants do not have the history and track record of experience in operating satellites (e.g., Starcloud has to date launched just a single demonstration satellite and Blue Origin has not operated its own satellites). Further, it cannot be assumed that operational safety practices will scale automatically alongside the size of a constellation. Nor should it be assumed that worst-case outcomes will occur. Given the novel nature of these constellations, robust technical review is needed.
Authorization requirements should, as a matter of principle, uphold system-level safety beyond individual satellite performance, and ensure that cumulative risks across the constellation remain demonstrably controlled. At the scale of these applications, the distinction between per-satellite compliance and aggregate outcomes becomes critical. A 99 percent post-mission disposal success rate, a 1-in-1,000 per satellite collision risk, and a 1-in-10,000 risk of human casualty from each surviving debris compound quickly over tens of thousands of satellites and may become non-trivial. Existing compliance metrics are not designed for constellations of this size; simply meeting these per-satellite requirements does not ensure that the operations fulfil the safety and sustainability objectives these requirements are meant to achieve.
Approving a constellation of this scale without thorough technical analysis and reporting requirements may have unintended implications for limiting or restricting access for current and future operators. This adds imperative to the need to ensure space safety processes for constellations of this size are fit for purpose. Furthermore, existing regulatory and coodination processes at the ITU and FCC focus on spectrum interference and coordination, and may not adequately address physical congestion or access, especially for systems that intend to rely on optical links and are therefore not completely covered by these coordination processes. The National Aeronautics and Space Administration (NASA) has raised similar concerns across these recent FCC filings. In response to Starcloud’s application, NASA warned that the proposed inter-satellite optical links could “interrupt observations, corrupt radiometric calibration, cause loss of star tracker lock, and […] pose a hazard to sensitive detectors and camera systems”. In response to Blue Origin’s application, NASA observed that the proposed constellation would require “commensurate transparency, technical rigor, and coordination to ensure long-term safety and sustainability of the space environment.
Specifically, large constellations of this scale raise externalities that extend beyond spectrum interference considerations. These include:
- The potential environmental impact of associated increase in launch rates, when deploying constellations several orders of magnitude larger than those previously licensed;
- Aggregate atmospheric and spacecraft ablation effects associated with mass reentry at this scale, which are not yet fully understood; and
- Cumulative impacts on dark and quiet skies and long-term implications for optical and radio astronomy.
In their response to comments filed on their application, SpaceX acknowledges some of these externalities and states intent to start with smaller-scale deployment of the ODC constellation, and to participate in study of potential atmospheric impacts. It is possible that constellations of this size may act to catalyze new approaches to satellite operations and disposal, such as the development of circularity concepts, which would be a positive contributor to space sustainability. SpaceX’s ODC filling included mention of in-space recycling and reuse of satellites. While this is a welcome and positive acknowledgement, it is just a start: more development and elucidation of specific details will be needed.
The Place for ODCs in Regulatory Modernization
These ODC filings are coincident with a set of efforts in the United States to update and make the space regulation system more efficient and responsive to industry activity. In October 2025, the FCC issued a notice of proposed rulemaking (NPRM) entitled “Space Modernization for the 21st Century Notice of Proposed Rulemaking” which seeks to overhaul the Commission's rules and process for licensing satellite and earth station activities, with the intent of improving processing times, certainty and overall efficiency. Industry response to this proposal has been positive, SWF filled a comment which was generally supportive as well, presuming that the process was well-resourced with the appropriate technical expertise. Within the Department of Commerce, the Office of Space Commerce (OSC) has been working to develop a voluntary certification process to provide Mission Authorization for novel space activities, including ODCs. This is in response to an Executive Order and is part of a long-running effort in the US government to address a regulatory gap related to these activities. A proposed “Space Commerce Certification” process was released by OSC in March 2026. Bipartisan leadership of the US House of Representatives Science Committee has issued a letter to the FCC criticizing the modernization NPRM as overstepping the Commission’s authority to regulate space safety. Yet, at the same time, the House has not advanced any legislation to give OSC, or other executive branch agencies, the authority to regulate novel space activities. In March 2026, the FCC issued an NPRM related to spectrum access for “weird space stuff”, which includes some areas of novel space activity that are similar to the OSC mission authorization proposal. However, while this is part of the set of efforts around commercial space regulatory updates, the scope of this NPRM is directly related to spectrum access, not necessarily space sustainability.
The companies filing with the FCC asking for approval of these large and novel ODC constellations generally portray the need for approval as urgent. The applications consistently ask for the Commission to “expeditiously” authorize the activities, arguing that doing so is in the public interest for American industrial international competitiveness and to meet what Blue Origin describes as the “insatiable” demand for AI computing services. SpaceX describes its ODC plans as a necessary step towards “ensuring humanity’s multi-planetary future amongst the stars.”
However, SpaceX’s own filings related to its IPO, filed with a different agency for a different regulatory purpose, tell a somewhat different story. The company’s S-1 pre-IPO filings refer to the early stage nature of ODCs, describing technical complexity, unproven technologies, questions around commercial viability, and possible deployment schedule risk due to possible delays in the Starship launch vehicle development. Other ODC companies face similar challenges. SpaceX’s S-1 also argues that ODCs will face “the harsh and unpredictable environment of space, exposing them to a wide and unique range of space-related risks that could cause them to malfunction or fail."
The technical and market realities of developing ODCs may not align with the perceived urgency to authorize their deployment. Spacecraft failures can occur even for routine satellite missions, and every failure risks adding to orbital debris; at the constellation scales being proposed, the risks and consequences are categorically larger. That, combined with the “significant technical complexity and unproven technologies” that SpaceX itself acknowledges, is reason to ensure that proper technical and regulatory assessment is applied to these novel constellations.
The upswell of interest in ODCs should be looked at as a window for for relevant US government agencies, including the FCC, OSC, the Federal Aviation Authority, and drawing upon the technical expertise of NASA, to convene a coordinated national approach to the authorization of very large constellations, so as to ensure that such assessments adequately address the long-term safety, sustainability, and public interest considerations across the breadth of issues at stake. Now is the time to solve long-standing regulatory coordination and consistency gaps.
In SWF’s comments to the FCC on the ODC filings, we recommend that the Commission initiate a parallel Notice of Inquiry to address very large constellation externalities and cumulative metrics, drawing upon relevant interagency expertise to ensure that future applications of similar scale are evaluated under clear, updated standards. This is because it is imperative that a whole-of-government regulatory and authorization framework, with appropriate technical expertise and capacity, be provided for ODCs. This is foundational to doing this novel activity right and not unduly putting future activity at risk. In the meantime, existing applications must be acted on, but a measured approach is warranted, meaning partial grants, no waivers and phased authorizations as the proper safety and authorizations frameworks are built.
