Attachment Attachment SAT-MOD-20101001-00205

Attachment Attachment

This document pretains to SAT-MOD-20101001-00205 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2010100100205_843658

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of Application by )
)
XM Radio Inc. ) File No. SAT-MOD-__________
) Call Sign S2119
For Modification of the XM-2 License )

APPLICATION OF XM RADIO INC.

XM Radio Inc. (“XM Radio”),1 a satellite digital audio radio service (“SDARS”)

licensee, hereby applies for a modification of the license for its XM-2 spacecraft, Call

Sign S2119, to reassign the satellite from its current orbital position of 85.217° W.L. to

115.25° W.L. and operate it there with a +/-0.1 degree east-west stationkeeping tolerance. XM

Radio seeks to relocate XM-2 to the nominal 115° W.L. orbital position in order to facilitate the

use of XM-2 to provide back-up capacity for XM Radio’s SDARS operations. XM Radio

requests an expanded stationkeeping volume at the new orbital location to permit collocation of

XM-2 with XM-4 and XM-1.

XM-1 and XM-2 are in-orbit spare SDARS spacecraft currently positioned near

85.2° W.L., and XM-4 is one of XM Radio’s primary operational SDARS spacecraft. XM Radio

recently requested authority to relocate XM-4 from 115.0° W.L. to 115.25° W.L. +/-0.1 degree.2

XM Radio will separately be seeking authority to move XM-1 to 115.25° W.L. +/-0.1 degree

following the launch of a new spare satellite, XM-5, to 85.2° W.L. Apart from the relocation and

expanded stationkeeping volume, no other changes in the operation of the XM-2 spacecraft are

proposed.

1
XM Radio is a wholly-owned subsidiary of Sirius XM Radio Inc. (“Sirius XM”).
2
See File No. SAT-MOD-20100722-00165, Call Sign S2616.

A completed FCC Form 312 is attached, and XM Radio incorporates by reference

the technical information previously provided in support of XM-2.3 XM Radio herein provides

updated technical information relating to the proposed modification to the XM-2 license. Grant

of the requested authority will serve the public interest by facilitating safe and efficient operation

of XM-2 in support of XM Radio’s SDARS network.

MODIFICATION

XM-2 was originally assigned to 115.0° W.L and commenced operations at that

location in March 2001. XM-2 was replaced as a primary operational satellite at 115° W.L. in

late 2006, when XM Radio launched XM-4.4 The Commission subsequently granted XM

Radio’s applications to reassign XM-2 along with XM-1 to locations near 85° W.L., where those

satellites operate today as in-orbit spares that can immediately be activated if there is an outage

on either XM-3 or XM-4.5 XM Radio is scheduled to launch XM-5, a new in-orbit spare satellite

assigned to 85.2° W.L., later this month.6

Assuming that the XM-5 launch is successful, XM Radio proposes to return XM-

2 to the nominal 115° W.L. orbital location, collocating it with XM-4. At that location, the spare

spacecraft can immediately be used to restore service in the event of an outage affecting XM

3
The most recent technical information submitted relating to XM-2 is found in File Nos. SAT-
MOD-20070911-00123; SAT-AMD-20071113-00158; and SAT-AMD-20080129-00032, Call
Sign S2119, all grant-stamped on February 14, 2008 (“February 14 Grant”).
4
When launched, XM-2 had an expected useful life of fifteen years. However, as the
Commission is aware, XM Radio’s in-orbit satellites, including XM-2, are Boeing 702 class
spacecraft manufactured by Boeing Satellite Systems International, Inc. (“Boeing”). In late
August 2001, Boeing advised XM Radio of a progressive degradation problem with the solar
array output power of the Boeing 702 class satellites, including XM-2. XM Radio accelerated
the replacement of XM-2 in response to these issues.
5
See February 14 Grant at ¶ 3.
6
See File No. SAT-LOA-20090217-00025, Call Sign S2786, grant-stamped Aug. 31, 2009.

2

recognized that ensuring continuity of service is an important public interest objective.9 The

requested modification will allow XM Radio to operate XM-2 in formation with XM-4 and XM-

1 in the stationkeeping volume bounded by 115.15º W.L. and 115.35º W.L. and will serve the

public interest by permitting XM Radio to optimize use of its satellite assets to ensure service

reliability.

WAIVER REQUESTS

XM Radio requests limited waivers of the Commission’s requirements in

connection with the requested XM-2 license modification. Grant of these waivers is consistent

with Commission policy:

The Commission may waive a rule for good cause shown.
Waiver is appropriate if special circumstances warrant a
deviation from the general rule and such deviation would
better serve the public interest than would strict adherence
to the general rule. Generally, the Commission may grant a
waiver of its rules in a particular case if the relief requested
would not undermine the policy objective of the rule in
question and would otherwise serve the public interest.10

is in a better position to determine how to tailor its system to meet the particular needs of its
customers.”) (footnote omitted).
9
See, e.g., DIRECTV Enterprises, LLC, Request for Special Temporary Authority to Conduct
Telemetry, Tracking and Control During the Relocation of DIRECTV 1 to the 72.5º W.L. Orbital
Location, Order and Authorization, DA 05-1890 (Sat. Div. rel. July 14, 2005) at ¶ 18 (granting
STA to relocate spacecraft to a location where it will replace a satellite with failing solar panels
“will enable DIRECTV to maintain continuity of DBS service to its customers”); DIRECTV
Enterprises, LLC, Application for Authorization to Operate DIRECTV 5, a Direct Broadcast
Satellite, at the 109.8º W.L. Orbital Location, Order and Authorization, DA 05-2654 (Sat. Div.
rel. Oct. 5, 2005) at ¶ 8 (“DIRECTV’s proposal to provide DBS service from this location will
serve the public interest, convenience and necessity in that it will ensure continuity of service to
DIRECTV subscribers”).
10
PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted).

4

Section 25.210(j): Section 25.210(j) of the Commission’s rules specifies that

geostationary space stations “must be maintained within 0.05º of their assigned orbital longitude

in the east/west direction, unless specifically authorized by the Commission to operate with a

different longitudinal tolerance.” 47 C.F.R. § 25.210(j). The Commission has previously

waived this rule based on a finding that allowing an increased stationkeeping volume would “not

adversely affect the operations of other spacecraft, and would conserve fuel for future

operations.”11 In addition, the Commission has waived the rule to allow operation of multiple

space stations in formation within a combined stationkeeping volume.12

The facts here fit squarely within this precedent. As discussed herein, allowing

XM-2 to operate within an increased stationkeeping volume will not harm other operators. The

only satellites with which XM-2’s stationkeeping volume will overlap are other spacecraft in the

Sirius XM fleet. XM Radio will ensure that the satellites’ flight is closely controlled to ensure

their safe joint operation. Furthermore, the proposed operations will not materially affect the

interference environment.

Finally, allowing XM-2 to be flown in formation with XM-4 and XM-1 in an

east-west stationkeeping volume of +/-0.1 degree will result in fuel savings for all three

spacecraft. This will prolong the time during which XM-1 and XM-2 will be available to

provide any needed back-up capacity for XM-3 and XM-4. Under these circumstances, XM

11
SES Americom, Inc. Application for Modification of Satcom SN-4 Fixed Satellite Space
Station License, 20 FCC Rcd 11542, 11545 (Sat. Div. 2005).
12
See SES Americom, Inc., File No. SAT-MOD-20080314-00072, Call Sign S2135, grant-
stamped May 19, 2008 at ¶ 1 (“We agree with SES Americom that increasing the station-keeping
volume of the AMC-4 spacecraft will not adversely affect the operations of other spacecraft, will
conserve fuel for future operations and will facilitate coordinated operation of AMC-4 and
AMC-2 in the same station-keeping range.”).

5

Radio submits that grant of any necessary waiver of Section 25.210(j) will serve the public

interest.

Section 25.283(c): XM Radio also requests any necessary waiver of the

requirements of Section 25.283(c) concerning venting excess propellant and relieving pressure

vessels at end of life. XM-2 is a Boeing 702 model spacecraft and was launched well before

Section 25.283(c) was adopted or even proposed. As described in more detail in the attached

Technical Appendix, the Boeing 702 has four tanks that retain residual pressure at end of life:

two helium tanks sealed following completion of the launch phase, and two tanks containing

xenon propellant that cannot be fully vented at end of life. Given the spacecraft design, it is

physically impossible for XM Radio to vent these four tanks in order to comply with

Section 25.283(c).

Under Commission precedent, grant of a waiver here is warranted. In a number

of recent cases involving both Boeing 702 satellites and other models, the Commission has

waived Section 25.283(c) to permit launch and operation of spacecraft that do not allow for full

venting of pressure vessels at end of life, based on a finding that modification of the space station

design at a late stage of construction would pose an undue hardship.13 In the case of XM-2,

which was launched and operational before the Commission proposed venting requirements,

there is no question of bringing the satellite into compliance with the rule. The Commission has
13
See, e.g., DIRECTV Enterprises LLC, File No. SAT-LOA-20090807-00086, Call Sign S2797,
grant-stamped Dec. 15, 2009, Attachment at ¶ 4 (granting a partial waiver of Section 25.283(c)
for DIRECTV 12, a Boeing 702 model spacecraft, on grounds that requiring modification of
satellite would present an undue hardship); PanAmSat Licensee Corp., File Nos. SAT-MOD-
20070207-00027, SAT-AMD-20070716-00102, Call Sign S2237, grant-stamped Oct. 4, 2007,
Attachment at ¶ 7 (granting a partial waiver of Section 25.283(c) for Intelsat 11 on grounds of
undue hardship). See also Hughes Network Systems, LLC, File Nos. SAT-MOD-20050523-
00106 & SAT-AMD-20060306-00025, Call Sign S2663, grant-stamped June 29, 2006
(authorizing launch and operation of SPACEWAY 3, a Boeing 702 model satellite, without a
Section 25.283(c) waiver).

6

expressly recognized this, holding that a waiver of Section 25.283(c) is justified for in-orbit

spacecraft that cannot satisfy the rule’s requirements. Specifically, in a decision involving the

SES Americom AMC-2 satellite, which like XM-2 was launched before Section 25.283(c) took

effect, the Commission granted a waiver on its own motion. The Commission observed that

venting the spacecraft’s sealed oxidizer tanks “would require direct retrieval of the satellite,

which is not currently possible.”14

The same practical obstacle is present here. Because XM-2 is already in orbit,

XM Radio can do nothing to enable full venting of residual pressure in the helium and xenon

tanks. Given this reality, waiver is clearly warranted; there is no possible public interest benefit

in strictly adhering to the terms of a rule when the licensee is incapable of complying with them.

The record also demonstrates that the inability to vent all residual helium and

xenon will not compromise safe disposal of the spacecraft. Information from Boeing indicates

that the pressure remaining in the tanks will be well below their tolerances, and both the residual

helium and xenon are inert, posing no risk of chemical energy release. Under these

circumstances, grant of any necessary waiver of Section 25.283(c) is consistent with

Commission precedent.

Section 25.114(d)(3): XM Radio requests a limited waiver of

Section 25.114(d)(3) of the Commission’s rules, which requires submission of predicted antenna

gain contours for each transmit and receive antenna beam and specifies that for geostationary

orbit satellites, the information must be provided in a .gxt format. As discussed in the Technical

Appendix, contour maps for operation of XM-2 at the nominal 115º W.L. orbital location are
14
SES Americom, Inc., File No. SAT-MOD-20100324-00056, Call Sign S2134, grant-stamped
June 21, 2010, Attachment at ¶ 8. As a condition of the waiver grant for AMC-2, the
Commission required SES Americom to file information regarding the mass and volume of the
residual oxidizer and the volume of the tank. See id.

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already on file with the Commission, but were submitted before the Commission began requiring

submission of the data in .gxt format.

The Commission has previously waived the requirements of Section 25.114(d)(3)

in similar factual circumstances.15 In acting on these requests, the Commission recognized that

the purpose of the rule is to ensure that adequate information is available to allow evaluation of

the potential for harmful interference.16 Here, in lieu of the .gxt file, XM Radio has provided

alternative data that is sufficient to permit the Commission and any interested party to evaluate

the antenna’s interference potential. Accordingly, XM Radio requests that the Commission grant

a limited waiver of Section 25.114(d)(3).

15
See, e.g., Application of PanAmSat Licensee Corp., File No. SAT-RPL-20061219-00155,
Call Sign S2715, grant stamp dated April 24, 2007 (“Galaxy 17 Grant”) at ¶ 5 (waiving
Section 25.114(d)(3) to allow submission of gain information for omni antenna in non-.gxt
format where manufacturer did not provide .gxt data); see also Spectrum Five, LLC, Order and
Authorization, DA 06-2439, 21 FCC Rcd 14023, 14033 at ¶ 17 (IB 2006) (conditionally
accepting antenna gain information not filed in .gxt format).
16
Galaxy 17 Grant at n.5.

8

CONCLUSION

For the foregoing reasons, XM Radio hereby respectfully requests that the

Commission modify the license for XM-2 to reassign the satellite to 115.25° W.L. and to permit

operations there with a +/- 0.1 degree east-west stationkeeping tolerance.

Respectfully submitted,

XM Radio Inc.

/s/ James S. Blitz
James S. Blitz
Vice President, Regulatory Counsel
XM Radio Inc.
1500 Eckington Place, NE
Washington, D.C. 20002
(202) 380-4000
Karis Hastings
Hogan Lovells US LLP
555 Thirteenth Street, NW
Washington, D.C. 20004
(202) 637-6400

Counsel for XM Radio Inc.

October 1, 2010

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TECHNICAL APPENDIX

1. INTRODUCTION

XM Radio submits this technical appendix in support of its application for a modification

of the license of the XM-2 SDARS spacecraft. XM Radio seeks assignment of the satellite to

115.25° W.L. and authority to operate with a +/- 0.1 degree east-west stationkeeping tolerance.

XM Radio incorporates by reference the technical information previously provided regarding

operations of XM-2,1 and herein provides information that is changing as a result of the proposed

modification.

2. GAIN CONTOURS

XM-2 was originally licensed for operations at 115.0° W.L., and contour maps were

submitted pursuant to Commission requirements in effect at that time.2 The proposal to operate

XM-2 at 115.25° W.L. rather than at 115.0° W.L. will produce no visible change in the gain

contours from the contour maps already on file.

3. LINK BUDGETS AND INTERFERENCE ANALYSIS

With the exception of satellites operated by XM Radio, no satellites within two degrees

of the 115.25° W.L. orbital location operate in either the S-band frequencies XM Radio uses for

service links or the X-band frequencies XM Radio uses for feeder links. XM Radio does not

1
The most recent technical information submitted relating to XM-2 is found in File Nos. SAT-
MOD-20070911-00123; SAT-AMD-20071113-00158; and SAT-AMD-20080129-00032, Call
Sign S2119, all grant-stamped on February 14, 2008.
2
See File Nos. SAT-L/A-19930115-00010; SAT-A/O-19921215-00041; & SAT-AMD-
19950310-00041, granted in American Mobile Radio Corp., 13 FCC Rcd 8829 (IB 1997). XM
Radio is attaching hereto copies of the original contour maps for operation of XM-2 at
115.0° W.L. for the Commission’s convenience.

spacecraft components within the body of the structure, which provides protection from small

orbital debris, and XM Radio has ensured that satellite subsystems have redundant components.

The command receivers and decoders, telemetry encoders and transmitters, the bus control

electronics, and the power subsystem components are fully redundant, physically separated, and

located within a shielded area to minimize the possibility of the spacecraft becoming a source of

debris due to a collision.

Minimizing Accidental Explosions (47 C.F.R. § 25.114(d)(14)(ii)). XM Radio has

assessed and limited the possibility of accidental explosions during and after completion of

mission operations. XM-2 has been designed to minimize the potential for accidental explosions

through propellant leakage and fuel and oxidizer mixing or other means. Propellant tanks and

thrusters are isolated using redundant valves, and electrical power systems are shielded in

accordance with standard industry practices. During the mission, batteries and various critical

areas of the propulsion subsystem are monitored to avoid conditions that could result in

explosion.

After XM-2 reaches its final disposal orbit, its batteries will be discharged, all on-board

sources of stored energy will be depleted, all fuel line valves will be left open, and all active

units will be turned off. XM-2 is a Boeing 702 model, and as the Commission is aware, four

vessels on the spacecraft will retain residual pressure at the satellite’s end of life.4 Two of the

vessels contain helium used to maintain pressure in the propellant tanks during launch. At the
4
See, e.g., Hughes Network Systems, LLC, Amendment to Application for Spaceway 3
Satellite, File No. SAT-AMD-20060306-00025, Call Sign S2663, Narrative at 20-22 (describing
characteristics of SPACEWAY 3, a Boeing 702 model spacecraft, and its inability to vent
residual helium and xenon at end of spacecraft life), grant-stamped June 29, 2006; DIRECTV
Enterprises LLC, Application for Authorization to Launch and Operate DIRECTV 12, File No.
SAT-LOA-20090807-00086, Call Sign S2797, Narrative at 19-21 (helium and xenon tanks on
DIRECTV 12, a Boeing 702 model spacecraft, will retain residual pressure at end of life), grant-
stamped Dec. 15, 2009.

3

that are operational or planned to be deployed at 115.25° W.L. or to nearby orbital locations such

that there would be an overlap with the proposed stationkeeping volume of XM-2.5

During relocation, the moving spacecraft is maneuvered such that it is at least 10 km

away from any nearby satellites when the drift begins or ends and at least 30 km away from the

synchronous radius when the planned drift rate is achieved. Advance notification is given to any

other operators through whose stationkeeping volumes the spacecraft will pass. When de-orbit

of a spacecraft is required, the initial phase is treated as a satellite move, and the same

precautions are used to ensure collision avoidance.

Post-Mission Disposal (47 C.F.R. § 25.114(d)(14)(iv)). The plans for post-mission

disposal of XM-2 from operational orbit are already on file with the Commission.6

5. SCHEDULE S

As discussed above, the proposed modification of the XM-2 license involves

relocation of the spacecraft to the nominal 115° W.L. orbital location, which was XM-2’s

original licensed position. Accordingly, full technical information regarding operation of XM-2

at 115° W.L. is already on file with the Commission.7 The proposal here to offset XM-2 by

0.25 degrees from its original orbital location will not result in any material changes to the

spacecraft’s operating characteristics or to the interference environment. As a result, the

information requested in Schedule S duplicates information that is already on file with the

5
As noted previously, XM Radio’s affiliate, Satellite CD Radio, has a pending application to
launch and operate the FM-6 satellite at 115.2° W.L. See File No. SAT-LOA-20100409-00072.
XM Radio will coordinate with its affiliate regarding the placement and operation of FM-6 at or
near the 115.2° W.L. orbital location.
6
See File No. SAT-AMD-20080129-00032, Call Sign S2119, Amendment Narrative at 3-4.
7
See File Nos. SAT-L/A-19930115-00010; SAT-A/O-19921215-00041; & SAT-AMD-
19950310-00041.

5

Commission concerning the technical parameters of XM-2’s proposed operation. In similar

cases involving requests for slight offsets from the nominal orbital position, the Satellite Division

has not required the submission of a new Schedule S.8 Accordingly, XM Radio is not filing a

Schedule S with this application. XM Radio will nevertheless prepare and submit a Schedule S

upon request of the Commission staff.

8
See, e.g., File No. SAT-MOD-20040405-00076 (PanAmSat request for authority to operate
SBS-6 at 74.05° W.L. rather than 74.0° W.L.).

6

Technical Certification
I, Bridget Neville, Vice President and General Manager for Satellite Engineering
and Operations of XM Radio Inc., hereby certify under penalty of perjury that:
I am the technically qualified person with overall responsibility for preparation of
the technical information contained in this application. I am familiar with the technical
requirements of Part 25 of the Commission’s rules, and the information contained in the
application is complete and accurate to the best of my knowledge, information and belief.

_________/s/___________
Bridget Neville

Dated: October 1, 2010

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Document Created: 2010-10-01 14:45:12
Document Modified: 2010-10-01 14:45:12

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