The attacking bird needs to raise apogee to GEO anyway - after that the plane change is relatively cheap. They might not even raise perigee.
I was replying to a comment where the person was talking specifically about LEO. Interfering with things in geostationary orbit is a whole other question.
I was replying to a comment where the person was talking specifically about LEO. Interfering with things in geostationary orbit is a whole other question.