Attachment response

response

REPLY submitted by Total RF Marketing Inc.

response

2005-05-26

This document pretains to SAT-STA-20050418-00086 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2005041800086_434644

aNSrEcre | | May 26 2 5 FCC— MAILRCOM May 19, 2005 Marlene H. Dortch, Secretary Federal Communications Commission Office of the Secretary 445 12" Street, SW Washington, DC 20054 JUM 0 1 2005 ‘ Policy Branch Re: STA Request of XM Radio temationalBureay SAT STA 20050418—00086 Dear Ms. Dortch, Enclosed please find Response and Objection ofTotal RF Marketing, Inc. to Request by XM Radio, Inc. for Special Temporary Authority filed with the Intemational Bureau on April 18, 2005, Public Notice was promulgated on April 22, 2005. Please file and docket. If you should have any questions please fell free to give me a call Very traly yours, CBLW_ Fr eth General Counsel Enclosure FFler am amepican neive aehcaiem pa ion>n

Before the FEDERAL COMMUNICATIONS COMMISSION INTERNATIONAL BuREAU Washington, D.C. In the Matter of Request ofXM Radio, Inc. for :. 1B DocketNo. NefTetmporary Authority : SAT STA 20050418—00086 Received Communications Commission RESPONSE AND OBJECTION OF TOTAL RF MARKETING, INC. TO REQUEST BY XM RADIO, INC. FOR SPECIAL TEMPORARY AUTHORITY 1. On April 18, 2005 XM Radio, In.,(XM) filed with the Commission a Request for Special Temporary Authority to operate a terrestrial repeater at each PGA golf event this season beginning in June. 2. n its Application XM requests permission to install what it describes as a "low power" repeater at each Course on the PGA Tour beginning in early June 2005 and continuing thereafter through the remainder ofthe season — into December 2005. These repeaters would operate (according to the STA application) at a maximum effective radiated power of 2,000 watts‘. 3. Respondent, Total RF Marketing, Inc. (Total RF) is a supplier ofwireless broadcastinfrastructure and communications facilities to the broadcastindustry, other commercial enterprises and local, state and federal governments. We have been in operation for over fourteen (14) years and while providing services worldwide maintain our headquarters outside ofPhiladelphia, Pennsylvania. We ' While this may constiute ‘low power" within the ambit ofXM‘s primary service,at a PGA event where the host broadcaster relies upon wireless microphones and wireless video systems broadcasting at a power level of 250 millwwats, it is similar to likening a tsunami o a wave in a bathtub. There is no doubt whatsoever thatthis evel ofradiated power willsimply overwhelm and render immediately useless each and every wircless broadeast device being utlized on that golfcourse.

have enjoyed the privilege ofsupplying our equipment and RF enginecring services at such events as the Olympics (each one since Barcelona in 1992) and essentially every major professional golfevent (PGA and LPGA) in the United States. Total RF has, for over a decade, provided wireless audio and video services and equipment for the National Broadcasting Company‘s (NBC) coverage of Professional GolfAssociation (PGA) events. Given our experience and continuing involvement in the broadcast of Professional Golf we are preeminent within the industry in covering these types of events. Our knowledge of and association with the sport as well as the methodology ofts broadcast afford us an unparalleled competency to adjudge the effects secondary to a grant ofXM‘s Request A preliminary engineering analysis of the impact ofa localized XM Radio transmitter on the ability ofTotal RF (or any similar broadcaster) to receive and distribute multiple, on—course, video signals at a NBC golf event has been undertaken. Our findings and conclusions indicate that the consequence of permitting XMs requested operation would be to render the entire broadeast infrastructure immediately inoperable. The RF receiving system in use by Total (or any similar company) at a typical golf eventis stractured around the utilization of multiple receive sites. These sites are deployed over the entire golf course in a manner so as to maximize broadcast coverage. Each receive site consists of a low gain antenna(s) feeding an RF converter box. ‘The converter box is configured to accept multiple RE signals from the on—course transmitters and then feeds them to a central demodulation Jocation (truck). Due to the already over crowded (and finite number of) sub—band frequencies available to broadcasters (and to make the on—course signals all work concurrently) the current system configuration employs individual channelflters at the truck location. The receive system, by its very nature, must be broadband in order to accommodate the multiple number of different 2 GHz signals. Each one of these signals could be active at anytime (or all ofthe time) during the telecast of the

event. All must be available at all times for use during the broadcastitself. Therefore, the only filter that can be employed at the remote reccive site is a broad band—pass filter that will reject only out ofband signals. On—course digital TV signals typically range from ~90 dBm to —40 dBm at each remote antenna location. Analog TV signals may range from ~70 dBm to more then—30 dBm. In the context ofthese types ofbroadcasts (golf) Total generally operatesit‘s transmit radios at 250 mw or less with 10 db directional antennas, (ERP 2.5 watts). Even at this low power level we occasionally see our own signals overloading the receive antennasites (depending on the proximity ofthe transmitters to the receive locations). 10. Ta 2,000—watt effective radiated power XM Radio transmitter operating at 2332 to 2345 MHtz is assumed, it would produce an E—Field of0.245 Volte/Meter at 1000 meters. A 5 dBi gain anterna immersed in that feld would deliver a 33 dBm signal to the input ofthe RF converter box. On the golf course, a signal of this magnitude would reduce the sensitivity of each RF converter box by approximately 30 dB due to the effects ofdesensitivity and overload.This would render the entire system uscless for the reception ofon—course video signals 11. Simply put, there is no doubt whatsoever that the installation ofrepeaters ofthe nature described in the XM Request will substantively harm, and perhaps destroy, the ability ofthe host broadcaster to televise the event to the public. ‘The Request must be denied as its grant would occasion interference that would render the operation ofother licensed facilities uscless, 12. Further, in addition to the clear deleterious effects on licensed operators such as Total RF and NBC, Total RF requests that the Commission deny the Application as it obviously constitutes a request that is neither "special" nor "temporary" and is one that will have a patently destructive effect upon the broadcast operation of Hicensces at these events. a "The STA request notes that te repeater would be lcated on the course. This means (almost invariably) thatth transmittr willbe much closer then the 1000 meters assumed here and that accordingly the disruptive effects willbe substantilly greater

13. While the Commission possesses the legal ability to grant temporary authority in extraordinary circumstances — that authority extends only where such temporary operation is in the public interest and where delay (or denial)in the requested operation would prejudice the public interest. As was recognized by the Commission in the "XM Radio STA Order" cited in XM‘s Request® the "Commission‘s rules govering satellit facilities, specifically Section 25.120,7 permit special temporary authorization under extraordinary [emphasis added] circumstances" stating that "convenience to the applicant, such as marketing considerations... will not be deemed sufficient for this purpose."" 14. 1t is exactly that form ofconsideration (XM‘s own particular commercial concems and marketing considerations) that constitutes the singular genesis of XM‘s request 15. XM apparently wishes to address the reception concems ofitssubscribers who are part ofthe "gallery" at a PGA event. It seeks to address the reception issues experienced by perhaps a handful (literally) of ts current subscribers to the detriment of(again literally) millions of viewers ofthe televised coverage ofthe event. 16. Further, XM incredibly secks Special Temporary Authority to expand its marketing efforts by providing, for short—term daily rental, ts radios to members ofthe gallery. These are individual commercial issues that fall well outside of the parameters for the grant ofSpecial Temporary Authorization. 17. Every host broadcaster of a PGA event (who in alllikelihood is providing coverage ofthe PGA event to millions of over the air and cable viewers) relies upon a plethora of wireless broadeast devices to provide that coverage. Wireless microphones and wireless video cameras are particularly susceptible to interference and signal degradation. 47 U.S.C. Section 309(D * XMRadio,Inc., Applicationfor Special Temporary Authorityto Operate Sutelite Digital Audio Service Complimentary Terrestrial Repeaters, Order andAuthorization, DA 012172 (released September 17, 2001). * Supra, paragraph 5, and 47 CER. § 25.12000) * Exaetly how this expansion ofXM‘s business enterprise fils to constifute /ocal programming and thus violte and be directly contrary to XM‘s broadeast Kicense is unknown.

18. It must be understood that interference during the broadcast of a live television show is much more then an inconvenience. Interference can and does deny the audience with the event coverage they desire and reasonably expect. Its oceurrence is not something that is amenable to correction after the fact. Where it occurs, the harm has been done, the coverage adversely impacted and the damages to that broadcast areirreparable. The simple possibility of"on air" interference of a live feed (video or audio) will generally result in the avoidance ofthe feed itself. This severely limits the coverage opportunities and viewpoints available to a director — and therefore to the viewing public. 19. The Request ofXM must be dismissed outright by the Commission as it falls well outside ofthe parameters requisie to such a "Special Temporary" request (as there is nothing "special" nor "temporary" about the request"). . Respectfully Submitted. Total RE Marketing, Inc. General Counsel . In fact, XM informs the Commission thatit will be secking reperitve STA‘s for this particular operation — there willbe nothing "temporary" about this application. See: XM Requestfor Special Temporary Authoriy, dated April 18, 2005, page 2, footnote 4.

Before the FEDERAL COMMUNICATIONS COMMISSION INTERNATIONAL BUREAU Washington, D.C. In the Matter of Request of XM Radio, Inc. for : 1B Docket No. Special Temporary Authority : saT STA 20050418—00086 CERTIFICATION OF SERVICE 1, Fred Fellmeth, Esquire, herewith certify that T did on the 19" day ofMay 2005, cause a true, correct and complete copy ofthe attached Response and Objection filed in this case to be served on all Counsel and/or unrepresented parties. Service was made by first—class mail, postage prepaid to such individuals on this date. Fred Fellmeth, Esquire May 19, 2005


Document Created: 2005-06-01 16:29:14
Document Modified: 2005-06-01 16:29:14
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