Attachment opposition

opposition

OPPOSITION submitted by WorldCom Inc

opposition

2001-08-21

This document pretains to SAT-STA-20010724-00064 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2001072400064_456863

coPY FEDERAL COMMUNICATIONS COMMISSION $ Washingto 20ss4 RECEIVED aus 21 200 su6 2 pesomoe xmss "*,on one uorenm In re Application of iB Docket No. 95—91 on g? XM Radio, Inc. Request for Special File No. SAT—STA—20010712—00063 Temporary Authorization and Sirius Satelite Radio, Inc. Request for File No: SAT—STA—20010724—00064 Special Temporary Authority To: Chicf, Interational Bureau OPPOSITION TO STA REQUEST WorldCom. Inc. ("WorldCom"), on behalf of itself and it affliates, hereby submits its Opposition to the above—captioned applications for Special Temporary Authority filed by XM Radio, Inc. (*XM") and Sirius Satelite Radio, Inc. (*Sirius") (the "Applications"). WorldCom is opposed to the grant the Applications as filed because the power levels requested by XM and Sirius for their terrestrial repeaters will interfere with WorldCom‘s operating WCS system in Memphis, Tennessce and planned system in Dallas/Fort Worth, Texas. WorldCom holds numerous WCS licenses throughout the southern United States. Each of these licenses was won, and paid for, at auction.. WorldCom utiizes the WCS spectrum Hicensed to it in a number of markets in the Southeast and is moving toward deploying additional markets in the near future.

1. WorldCom Will Suffer Interference to Its Operations In Memphis Currently, WorldCom is operating a WCS system in Memphis, Tennessee that provides two—way intemet service to customers throughout the Memphis metropolitan area. As set forth in Attachment 1 hereto, the repeaters proposed by both XM and Siius will significantly interfere with WorldCom‘s operating WCS facilies in Memphis. This interference is caused by brute foree overload (also referzed to as "blanketing"), rather than out of band emissions. As a result ofthe high power operations of XMs and Sirius‘s terrestrial repeaters, exclusion zones —zones of unacceptable interference—— are created around the terrestrial repeaters. The size and intensity of such exclusion zones in Memphis are set forth in Attachment 1. WorldCom would not object to repeaters that are limited to a maximum power of 2kW.‘ While a repeater with an output power of 2EW will stll cause some interference to WorldCom‘s Memphis WCS facilities, WorldCom can accept such power levels without serious degradation to its system. As the Commission is well aware, 2kW is the maximum power that WCS licensees mayutlize in order to prevent brute force overload interference to its spectrum neighbors up to 150 MHz away from the WCS spectrum. > WorldCom recognizes the need for terrestrial repeaters to augment the DARS systems; however, the power levels of these terrestral repeaters must be limited so as not to cause unacceptable interference to existing or planned WCS facilitis. ! See Technical Exhbit oStephen Daughery ? gee 47 CiR. 55 21.908, 74 935 " See Amendmentofthe FCC‘s Rule o Esablih Part 27, the Wireless Conmunications Servce, 12 FCC Re. 3077, 397046 (1997)

2. Proposed WCS Systems Must Be Protected WorldCom plans to deploy WCS facilites in the Dallas®Fort Worth metropolitan area. Ithas not been decided precisely how the WCS spectrum will be utilized due to the lack of certainty regarding interference protection from the DARS terrestrial repeaters. A number of the sites from which the system will operate have alreadybeen identified. WorldCom engineers reviewed the STA requests of XM and Sirius as they relate to WorldCom‘s planned WCS operations. The blanketing interference caused by either XM or Sitius alone is serious; the interference caused bythe combined operation of XM and Sirius would be devastating. The exclusion zones created by the proposed XM and Sirius repeaters will cover a great majority of the Dallas/Fort Worth area. See Attachment 2, which also shows the currently planned WorldCom sites for its WCS system. As one can see, the prospect for serving this area utlizing WCS spectrum is dismal. If the proposed repeaters are authorized at the power levels applied for in the Applications there is very litle area thatis not affected bybrute force overload." 3. Notification Process If the FCC is to grant an STA for any of these repeaters, WorldCom believes that a notification process between the DARS licensees and the WCS licensees must first be established. Without coordination, it would be impossible to launch a viable system in Dallas‘Fort Worth or other WorldCom markets due to the interference environment. Both XM and Sirius acknowledge that if any interference is experienced, upon * See Atachment2.

notification they will immediately tum off the offending repeater." Rather than wait for unacceptable interference to disrupt WCS and/or DARS: operations, WorldCom recommends a process by which the WCS licensee gives the DARS licensee 30 days advance notice of commencement of operations in a market, whereupon the DARS Hicensees would have 30 days to power down all of the repeaters in that market to 2kW. Thus, both operators would have time to adjust their systems without experiencing any disruption of service totheir customers. It is imperative that any grant of the Applications be conditioned on interference free operation and coordination with WCS licensees. Therefore, WorldCom urges the FCC to not grant the Applications as filed Respectfully Submitted, WORLDCOM, INC. Director, Covernment RegulatoryAffairs WorldCom Broadband Solutions, Inc. 8521 Leesburg Pike Viena, VA 22182 (705) o1s—0780 August 21, 2001 ‘ See XM STA File No.SAT—STA—20010712:0006at 2. and Sirus STA Fil No. SAT—STA— 200010724—00064 ap3.

Exhibit 1 Technical Narrative This Technical Narrative describes the calculation and illustrations of predicted interference from XM Radio, Inc. ("XM") and Sirius Satellite Radio, Inc. ("Sirius") SDARS repeaters to WorldCom, Inc. ("WCOM®) receivers using the WCS spectrum to provide digital two—way services Customer Premise Equipment (CPE) WCOM has found that the typical CPE receivers available from vendors have a 1 dB compression point ofapproximately +14 dBmW. This is the RF levelat the input to the receiver that will cause saturation and brute forceoverload of the receiver‘s signal demodulation circuitry.. This signal level referenced to the frontend of the 32 dB (typical) gain low noise amplifier (LNA) is —18dBm. Allowing 6 dB backoff to account for the digital signal peakcto—average ratio, 10 dB backoff to insure optimum linearity of the amplifers, and 17 dB (typical) antenna gain, the RF level in front of the CPE antenna that will cause the CPE receiver to saturate is —51 dBmW. Higher gain antennas, up to 24 dB, are typically used for CPE further distant from hub sites. In this case, the interference level in front of the CPE anterna becomes ~58 dBmW. WCOM has prepared an analysis of the predicted RF emissions from the proposed XM and Sirius repeaters utilizing an EDX Engineering utilty, which uses a Free Space + RMD propagation model. The predicted RF levels are compared to the levels in front of the antenna at potential WCOM customer sites. The sites are assumed to be 25 feet above ground level, although some of WCOM‘s business customers may use antennae mounted on buildings up to 250 feet. Although there is obviouslymore potential for line« of:site to CPE receivers mounted higher, this analysis uses the more conservative 25 foot level. Attachments 1 and 2 hereto demonstrate the predicted interference from the proposed XM and Sirius SDARS repeaters in WCOM‘s Memphis and Dallas/Ft Worth markets. Areas of interference that exceed ~51 dBmW are depicted. The interference regions extend up to 5 milesin front of the interfering emitters. Any WCOM CPE receiver oriented in the direction of the emitters will experience unacceptable interference. As is depicted in the graphic, at least 4 proposed SDARS sites in Dallas/Ft Worth and 1 site in Memphis are located very near, if not co—located with, WCOM hub sites; nearly all the interference regions depicted in this case would cause WCOM‘s CPE receivers to experience brute forceoverload.

Hub Receivers .. WCOM‘s proposed hub receivers in the WCS spectrum have sensitivities and gains similar to the CPE receivers. The hub antenna would normally be installed much higher above ground level than CPE receivers and, therefore, be much more likely to have a line—of—site path from SDARS repeaters installed in the same market. The same RF level. —51 dBmW, a the hub antenna input could cause the hub receiver to experience brute force overload. As depicted in Attachments 1 and 2 hereto, WCOM hubs in the Memphis and Dallas/Ft Worth markets are predicted to experience the brute force overload problem. Statement of Engineer Thisstatement was prepared by the undersigned who is the Director of Engineering Analysis at WorldCom Broadband Solutions,Inc. He holds an MS degree in Electrical Enginecting. .L angely 1 declars thatshe foregoing is true and correct tothe best of my knowledge. en Daugherty Director, Engineering Analysis WorldCom Broadband Solutions, Inc.

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CERTIFICATE OF SERVICE 1. _De—el Shorter . hereby certify that the foregoing Opposition to STA Request was served this 21st. dayof August , 2001, by depositing a trie copythereof with the United States Postal Service, first class postage prepaid, addressed to: *Mr. Bruce Franca Acting Chief Office of Engineering and Technology Federal Communications Commission 445 12" Street, SW, Room 7C—153 Washington, DC 20554 *Ms. Jane Mago General Counsel Federal Communications Commission 445 12" Street, SW, Room $—C723 Washington, DC 20554 *Mr. Sam Feder Senior Legal Advisor Office ofthe Honorable Kevin J. Martin Federal Communications Commission 445 12" Street, SW, Room 8—C302 Washington, DC 20554 *Mr. Adam Krinsky Senior Legal Advisor Office of the Honorable Gloria Tristani Federal Communications Commission 445 12Street, SW, Room $—B115 Washington, DC 20554 *Mr.Peter Tenhula Senior Legal Advisor Office ofthe Chairman Federal Communications Commission 445 12" Street, SW, Room 8—B201 Washington, DC 20554

*Mr. Bryan Tramont Senior Legal Advisor Office ofthe Chairman Federal Communications Commission 445 12" Street, SW, Room B—A204 Washington. DC 20554 *Ms. Lauren Van Wazer Interim Legal Advisor Office ofthe Honorable Michael J. Copps Federal Communications Commission 445 12" Street, SW, Room $—A302 Washington, DC 20554 *Mr. Ronald Netro Senior Engineer Policy Division Federal Communications Commission 445 12" Street, SW, Room 3—C163 Washington, DC 20554 *Mr. Chris Murphy Senior Legal Advisor Office of the Bureau Chief Federal Communications Commission 445 12" Street, SW, 6—C754 Washington, DC 20554 *Mr. Ronald Repasi Chief Satellite Engineering Branch International Bureau Federal Communications Commission 445 12" Street, SW, Room 6A—505 Washington, DC 20554 *Ms. Rosalee Chiara Deputy Chief Satellite Policy Branch Satellite and Radiocommunication Division International Bureau Federal Communications Commission 445 12° Street, SW, Room 6—A521 Washington, DC 20554

*Mr.Jim Burtle Chief Experimental Licensing Branch Electromagnetic Compatibilty Division Office of Engineering & Technology Federal Communications Commission 445 12" Street, SW, Room 7—A267 Washington, DC 20554 Mr. Douglas Brandon Vice President — Federal Affairs AT&T Wircless 1150 Connectiout Avenue. NW. 4" Floor Washington, DC 20036 Mr. Donald Brittingham Manager, Wieless Policy Verizon Wireless 1300 Street, NW Suite 400W Washington, DC 20005 Mr. Carl Frank Attommey Wiley, Rein & Fielding 1776 K Street, NW Washington, DC 20006 Mr. Michael Hamra Director Regulatory & Governmental Afairs Metricom, Inc. 1825 I Street, NW, Suite 400 Washington, DC 20006 Ms. Karen Possner Vice President Strategic Policy Bell South 1133 21" Street, NW Suite 900 Washington, DC 20036

Mr. Bruce Jacobs Attomey Shaw Pitman 1255 23" Street, NW, 8" Floor Washington, DC 20037 Mr. Robert Briskman Technical Executive Sirius Satellite Radio, Inc. 1221 Avenue of the Americas New York, NY 10020 Mr. Lon Levin Senior Vice President 1500 Eckington Place, NE Washington, DC 20002 *Mr. Donald Ableson Federal Communications Commission 445 12° Street, SW, Room 6—C754 Washington, DC 20554 *Mr. Tom Sugrue Chief Wireless Telecommunications Bureau Federal Communications Commission 445 12" Street, SW 20554, Room 3—C252 Washington, DC 20554 *Mr. Julius Knapp Chief Policy and Rules Division Office of Engineering and Technology Federal Communications Commission 445 12" Steet, SW, Room 8—C723 Washington, DC 20554 *Mr. Bryan Tramont Senior Legal Advisor Office of the Honorable Kathleen Q. Abernathy Federal Communications Commission 445 12" Street, SW, Room 8—A204 Washington, DC 20554

*Mr. David Furth Senior Legal Advisor Wireless Telecommunications Bureau Federal Communications Commission 445 12" Street, SW, Room 3—C252 Washington, DC 20554 *Mr. Paul Margie Legal Advisor Office ofthe Honorable Michael J. Copps Federal Communications Commission 445 12" Street, SW, Room 8—A302 Washington, DC 20554 *Dr. Robert Pepper Chief Office of Plans and Policy Federal Communications Commission 445 12° Street, SW, Room 7—C347 Washington, DC 20554 * VIA HAND DELIVERY


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Document Modified: 2005-09-28 14:44:30
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