Attachment ex parte

ex parte

Ex PARTE PRESENTATION NOTIFICATION LETTER

ex parte

2006-11-03

This document pretains to SAT-STA-20061013-00119 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2006101300119_534596

EX PARTE OR LATE FILED HARRIS, 1200 EIGHTEENTH STREET, NW WASHINGTON, DC 20036 WILTSHIRE & Tel 202.730.1300 rax 202.730.1301 ETi WWW.HARRISWILTSHIRE.COM ATTORNEYS AT LAW FILED/ACCEPTED 3 November 2006 NoV —3 2006 Ex Parte Office af the Secretary Ms. Marlene Dortch Secretary Federal Communications Commission 445 12"" Street, S.W. Washington, DC 20554 Re: Requestfor Special Temporary Authorityfor 30 days; SAT—STA—20061002—00114 Requestfor Special Temporary Authorityfor 180 days; SAT—STA—20061013—00119 Dear Ms. Dortch: On 2 November 2006, undersigned counsel representing XM Satellite Radio met with Emily Willeford, advisor to Chairman Martin, in connection with the above—noted requests for STAs. In this meeting, I asked that the Commussion promptly grant XM‘s request for a thirty—day STA and put its request for a 180—day STA on public notice. More specifically, I noted the following: 1. While there are many variances between the XM repeater network "as built" and the existing STAs, the network is smaller, less powerful and causes less potential interference than what the FCC authorized. For example, XM was authorized to build almost 1200 repeaters — yet it built only about 800. Similarly, XM was authorized to build over 100 high—power repeaters, yet it built a relative handful; predominantly building low—power repeaters instead. In addition, many of the "variances" arose because XM decided to use sectorized antennas instead of omni—directional antennas, and (all else being equal) sectorized antennas generally have less interference potential than omni—directional antennas. 2. Granting the 30—day STA will restore robust service to tens of thousands of consumers whose service on a number of major roadways has been degraded by the remedial actions XM has taken to reduce the number of variances while the STA requests are pending. It will also assure that XM can provide robust service to a/l/ of its seven million consumers while the 180—day STA and the final rules for SOARS repeater networks are being considered by the Commission. 3. The XM repeater network "as built" has not caused a single case ofknown interference and granting the 30—day STA will cause no interference to anyone.

4. Granting the 30—day STA would be entirely without prejudice to the ongoing rulemaking on the final rules for SDARS repeater networks or the ongoing negotiations between SDARS operators and WCS licensees. Please let me know if you have any questions about this filing. Sincerely yours, ~Sesu \\A?.e.% Scott Blake Harris Counsel to XM Satellite Radio Co: Emily Willeford


Document Created: 2006-11-08 11:08:55
Document Modified: 2006-11-08 11:08:55
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