In an Oct. 9 letter to the FAA and Congress seen by SpaceNews, SpaceX principal engineer David Goldstein said the report relied on “deeply flawed analysis” based on assumptions, guesswork, and outdated studies.

The article contains details.

In 2021, the FAA commissioned the Aerospace Corp., a federally funded nonprofit focused on space, to provide a technical assessment of the rise of LEO constellations and the risks posed to aviation and people on the ground by unplanned and controlled reentries of these satellites and the upper stages that launch them.

Someone from Aerospace mentioned the difficulties in such an estimate, and Goldstein's letter points out more problems.