Modification Exhibit

0097-EX-CM-2017 Text Documents

Sirius XM Radio Inc.

2017-05-19ELS_192239

Sirius XM Radio Inc.
Call Sign WI2XJC
Modification Application


                                        Proposed Modification
                                          Call Sign WI2XJC

Sirius XM Radio Inc. (“SiriusXM”) seeks to modify its experimental radio license issued under
Call Sign WI2XJC. Specifically, SiriusXM requests authority to add two locations to the license
to further experiment with the feasibility of using low power terrestrial repeaters to mitigate
interference, including authority to conduct a product development trial at the new locations.

In the application for Call Sign WI2XJC (the “Initial Application”), SiriusXM sought authority to
experiment with a new low power terrestrial repeater (“Spot Repeater”) to determine whether the
repeater would effectively mitigate interference to SiriusXM satellite radio subscribers created by
wireless transmissions. SiriusXM explained that it is researching methods to resolve
intermodulation interference to its Satellite Digital Audio Radio Service (“SDARS”) receivers
caused by nearby base stations operating on both Advanced Wireless Services (“AWS”) and
Personal Communications Service (“PCS”) spectrum. The license for WI2XJC authorizes
SiriusXM to test Spot Repeaters within a 97 kilometer radius of six different locations. SiriusXM
has begun conducting testing of Spot Repeaters and continues to develop a further understanding
of the potential uses of such repeaters for interference mitigation.

In addition to addressing intermodulation interference, the Initial Application stated “[t]he use of
Spot Repeaters may also be a valuable tool to address interference concerns as AT&T Inc. and its
affiliates (“AT&T”) – the primary license holder in the adjacent Wireless Communications Service
(“WCS”) band – deploys facilities and begins operations in that band.” The Spot Repeaters are
intended to improve subscribers’ reception of SiriusXM services where muting is caused by
interference from nearby wireless transmissions while facilitating broadband providers’ ability to
optimize use of their spectrum for wireless broadband operations. The Commission is well aware
of the continuing efforts made by SiriusXM and AT&T to address interference into the satellite
radio band, including the possibility of co-locating terrestrial repeaters at WCS transmission sites
as part of these efforts.1 SiriusXM included with the Initial Application a letter from AT&T
indicating its support of the proposed experiments.

In the instant modification application, SiriusXM seeks to add two additional locations, each with
an authorized 97 kilometer radius of operation, in the areas around Dallas-Ft. Worth, Texas and
Kansas City, Missouri, to experiment with the use of Spot Repeaters to address interference from
the WCS band at these locations and others currently authorized under the WI2XJC license.
SiriusXM will, similar to its experiments near AWS/PCS base stations, experiment with using the
Spot Repeaters to raise its signal levels near WCS base stations in order to mitigate interference to
SDARS receivers while enabling improved wireless broadband service.

The Spot Repeaters operating under the modified license will operate with the same technical
parameters as authorized under the existing license, including frequencies, RF emission
characteristics, and out-of-band emission limits proposed in the Initial Application. Initial testing

1
    See Sirius XM Radio Inc. Written Ex Parte Presentation, WT Docket No. 07-293 (Feb. 14, 2017).

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Sirius XM Radio Inc.
Call Sign WI2XJC
Modification Application

and operations under the modified license will be conducted in conjunction with AT&T to evaluate
the effectiveness of these Spot Repeaters to mitigate interference from WCS facilities, but
SiriusXM will nonetheless maintain control and responsibility for the repeaters in compliance with
the WI2XJC license. The repeaters in the new locations will be used to deliver redundant services
to SiriusXM subscribers to determine whether and how the repeaters are improving SDARS
reception in the presence of potentially interfering signals. However, just as with SiriusXM’s
existing operations under the WI2XJC license, subscribers will be unaware of the use of the Spot
Repeaters and no subscriber shall be charged any fees associated directly with the Spot Repeaters.
In the Initial Application, SiriusXM noted that some Spot Repeaters may be fed via Internet
Protocol (“IP”) delivery rather than directly by satellite. SiriusXM anticipates the Spot Repeaters
operating under the modified license may, as an alternative to using IP or satellite, receive signals
from other terrestrial repeaters in the SiriusXM network during the experiment.

In sum, SiriusXM has been successfully conducting experiments under Call Sign WI2XJC and
wishes to expand those experiments to two additional locations and to focus additional experiments
at these locations, as well as the currently authorized locations, primarily on mitigating interference
from transmissions in the WCS band (while continuing experimentation with mitigating
intermodulation interference from AWS/PCS stations at the currently authorized locations and
potentially the additional locations as well). SiriusXM submits that the proposed modification will
further the public interest, as well as the Commission’s interests in ensuring that adjacent and
proximate channel licensees are able to operate without interference and helping to optimize
wireless broadband operations.




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Document Created: 2017-05-19 12:10:37
Document Modified: 2017-05-19 12:10:37

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