Attachment Grant

Grant

DECISION submitted by IB,FCC

grant

2007-09-20

This document pretains to SAT-STA-20070907-00121 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2007090700121_593801

                                                                                                               Approved by OMB
                                                                                                                      3060—0678

Date & Time Filed: Sep 72007 10:59:12:123AM
File Number: SAT—STA—20070907—00121
Callsign:

                                          FEDERAL COMMUNICATIONS COMMISSION
                               APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                       FOR OFFICIAL USE ONLY


  APPLICANT INFORMATION
Enter a description of this application to identify it on the main menu:
 Sirius Satellite Radio Request for 30 day STA to operate SDARS repeaters and signal boosters at trade shows
1. Applicant


            Name:        Sirius Satellite Radio Inc.      Phone Number:                   212~584—5100

            DBA Name:                                     Fax Number:                     212—584—5353

            Street:      1221 Avenue of the Americas      E~Mail:

                         36th Floor
            City:        New York                         State:                          NY

            Country:     USA                              Zipcode:                        10020        —
            Attention:   Mr. Patrick L. Donnelly




                                                                                                        <s6t—Sip.rooyogoytor
                                                                                                  Call Sign    _ Grant T)rsmmq \”K?W\S?:,


          Application of Sirius Satellite Radio Inc. for Special Temporary Authority
                           IBFS File No. SAT—STA—20070907—00121

Special temporary authority (STA) IS GRANTED to Sirius Satellite Radio Inc. (Sirius) to
operate an indoor terrestrial repeater with an Effective Isotropically Radiated Power (EIRP) of
up to 200 watts (average) and up to five indoor repeaters with EIRP of up to 0.0001 watts at the
International Boat Builders‘ Exhibition and Conference (IBEX) in Miami Beach, FL, from
October 10—12, 2007, and at the SEMA automotive specialty products trade show in Las Vegas,
NV, from October 30—November 2, 2007, according to the technical parameters specified in its
application, subject to the following conditions:

 1. Any actions taken as a result of this STA are solely at the applicant‘s own risk. This STA
     shall not prejudice the outcome ofthe final rules adopted by the Commission in IB Docket
     No. 95—91;

     Operation of the terrestrial repeaters authorized pursuant to this STA is on a non—interference
Do




     basis with respect to all permanently authorized radiocommunication facilities. Sirius shall
     provide the information and follow the process set forth in paragraphs 14 and 17 in 16 FCC
     Red 16773 (Int‘l Bur. 2001) and 16 FCC Red 16781 (Int‘l Bur. 2001), as modified by 16
     FCC Red 18481 (Int‘l Bur. 2001) and 16 FCC Red 18484 (Int‘l Bur. 2001);

     The terrestrial repeaters are restricted to the simultaneous retransmission ofthe complete
Lo




     programming, and only that programming, transmitted by the satellite directly to SDARS
     receivers;

     The terrestrial repeaters shall comply with Part 1 of the Commission‘s rules, Subpart I —
     Procedures Implementing the National Environmental Policy Act of 1969, including the
     guidelines for human exposure to radio frequency electromagnetic fields as defined in
     Sections 1.1307(b) and 1.1310 of the Commission‘s rules;

     The out—of—band emissions of the terrestrial repeaters shall be limited to 75+log(EIRP) dB
     less than the transmitter EIRP;

     Sirius will maintain full ownership and operational control of the terrestrial repeaters;

     Sirius will immediately shut down the terrestrial repeaters upon a complaint of interference,
     upon direction from the Comumission, or upon finding that the repeaters have not been
     properlyinstalled;

     This STA is effective October 3, 2007, and will expire in 30 days thereafter, or on the date on
     which permanent rules governing repeater operations become effective, whichever occurs
     first.

     This authorization is not one relating to an "activity of a continuing nature" for purposes of
     Section 1.62 of the Commission‘s rules and Section 558(c) of the Administrative Procedure
     Act. Continuation of operations beyondthe_termthis utho %ggn will                  require: prior
     affirmative authorization by the FCC. ;                       *   %        — JTéqzc CHQ"




                                             Ofendtions


2. Contact


             Name:         Mr. Patrick L. Donnelly               Phone Number:                        212—584—5100

             Company:      Sirius Satellite Radio Inc.           Fax Number:                          212~584—5353
             Street:        1221 Avenue of the Americas          E—Mail:


             City:         New York                              State:                               NY

             Country:       USA                                  Zipcode:                             10020      —

             Attention:                                          Relationship:                        Same


   (If yourapplication is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
  3. Reference File Number or Submission JID
 4a. Is a fee submitted with this application?
@ If Yes, complete and attach FCC Form 159.          If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
C Governmental Entity        C Noncommercial educational licensee
C) Other(please explain):

4b. Fee Classification    CXW — Space Station (Non—Geostationary)

5. Type Request


 «3 Change Station Location                          3 Extend Expiration Date                        i Other


6. Temporary Orbit Location                                                 7. Requested Extended Expiration Date


8. Description   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)

     Sirius Satellite Radio requests Special Temporary Authority for 30 days to operate
     terrestrial repeaters and signal boosters at trade shows between October 8,                                             2007   and
     November 2,       2007.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject     @ Yes           3 No
to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988,
21 U.S.C. Section 862, because of a conviction for possession or distribution ofa controlled substance. See 47 CFR
1.2002(b) for the meaning of &quot;party to the application&quot; for these purposes.


10. Name of Person Signing                                                   11. Title of Person Signing
Patrick L. Donnelly                                                         Exec. VP, GC, and Sec‘y

12. Please supply any need attachments.
  Attachment 1: Attachment, Exhibits                Aftachment 2:                                      Attachment 3:



          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


                                            Attachment

       Sirius Satellite Radio Inc. ("Sirius"), pursuant to 47 C.F.R. § 25.120,‘ hereby requests
Special Temporary Authority ("STA") for 30 days to operate in its licensed frequency band
(2320—2332.5 MHz) (1) low—power satellite DARS repeaters with an Effective Isotropically
Radiated Power ("EIRP") of 200 watts; and (2) signal boosters with an EIRP of 0.0001 watts that
have previously been approved for use in retail stores, These low—power repeaters and signal
boosters will be utilized at various trade shows on various dates between and including October
8, 2007 and November 2, 2007. Sirius intends to operate the repeaters and signal boosters
independently — i.e., Sirius will not operate them in conjunction with XM Radio, Inc., the other
satellite DARS licensee.

        The repeaters and boosters will be used by Sirius to carry out equipment and service
demonstrations at trade shows across the United States for periods not to exceed six days
(including two days prior to the official start of each trade show for set—up and testing activities).
Due to blockage from walls and ceilings, it is often difficult to provide quality reception of
SDARS satellite and even terrestrial signals inside of trade showvenues, which often do not
have line—of—sight views to receive Sirius® signal. These difficulties with providing coverage
inside the venues require radios to be displayed with hard wire connections, which limits the
locations within a trade show venue that Sirius can set up its displays, creating difficulties for
trade show organizers and Sirius. Because trade show venues typically consist of a large, often
multi—level space, Sirius anticipates that the use of both a repeater and one or more (but fewer
than five) strategically placed boosters will be necessary to ensure full coverage of each trade
show. Accordingly, grant of the requested STA to use these repeaters for these limited periods
will serve the public interest.

Technical Information. In Exhibit A, Sirius provides a list of technical parameters, locations, and
dates for the trade showrepeaters it seeks to operate pursuant to this STA. Sirius has included
the following information: (1) event; (2) event date; (3) event location (specifying the center
longitude and latitude of each trade show venue); (4) market; (5) antenna type: (6) antenna
beamwidth; (7) total EIRP; and (8) approximate maximum height Above Ground Level (AGL).
Sirius will operate its signal booster(s) at the same events, dates, locations, and markets specified
in Exhibit A. Exhibit B lists the technical parameters for the signal boosters, which are identical
to those previously approved by the Commission foruse in retail stores." Specifically, Sirius has


!      Concurrent with this STA request, Sirius is filing an application for a 180—day STA to
operate repeaters and signal boosters at trade shows from November 7, 2007 to February 18,
2008.

2      See Sirius Satellite Radio Inc. Requestfor Special Temporary Authority to Operate In—
Store Signal Booasters in the Satellite Digital Audio Radio Service, File No. SAT—STA—
2003041 1—00075 (grant stamp with conditions issued June 26, 2003) ("2003 In—Store Booster
Application"). In the 2003 application, Sirius also provided an interference analysis for the
signal boosters that are the subject of this application. See id., Exhibit C. That interference
analysis is incorporated by reference herein, as permitted by 47 C.F.R. § 1.10009(c)(2). On June
5, 2003, Sirius further supplemented the application with a sample link budget for the signal
boosters. See Letter from Robert D. Briskman to Marlene H. Dortch, Secretary, FCC, Re: Sirius


    Ms. Marlene H. Dortch
    September 7, 2007
    Page 2

    included the following information: (1) antenna type; (2) antenna beamwidth; (3) total EIRP; and
    (4) approximate maximum height Above Ground Level (CAGL"). Exhibits C and D provide RF
    exposure analyses for each individual trade show, and demonstrate that any human
    radiofrequency exposure that might occur is well belowacceptable limits.

    Interference Considerations. Sirius does not anticipate that the repeaters and boosters at these
    trade shows will cause harmful interference to other radio services. Because Sirius has exclusive
    use of its licensed frequency band," there is no potential for in—band interference. Moreover, the
    repeaters will operate at 200 watts, well belowthe threshold EIRP of 2000 watts that Wireless
    Communications Service ("WCS") licensees have identified as acceptable to avoid any
    interference with their services. Sirius has also previously demonstrated that the proposed
    boosters will not cause adjacent band interference to WCS operations." In addition, the repeaters
    and boosters will only be used for a limited time, further eliminating any opportunity for
    interference. Therefore, Sirius does not anticipate that these repeaters and boosters will cause
    blanketing interference to any WCS receivers.

    Ownership and Control ofRepeaters. Sirius will own each repeater and booster installed at a
    given venue and will retain full operational control of these repeaters and boosters. Sirius will
    also be responsible for installation of each repeater and/or booster.

Public Interest Considerations. Prompt grant of this STA will promote the continued success of
satellite radio and thereby serve the public interest. The demand for SDARS radios by the public
has continued to increase over time. Accordingly, Sirius has begun attending trade shows and
conventions where it provides demonstrations ofits equipment to consumers. Without repeaters
and boosters to overcome signal blockage within the venues, however, Sirius cannot undertake
real—time demonstrations ofits equipment, especially demonstrations of the full mobility of
SDARS service. These repeaters and boosters will provide clear signal reception within these
venues for these demonstrations, and will eliminate any need for a hard wire connection.

Sirius understands that its operation of these repeaters and boosters under STA is on a secondary,
non—interference basis. While Sirius does not anticipate any interference, should interference
occur, it will cease operation of the interfering repeater and/or booster until such interference can
be eliminated.




(Continued . .)
Satellite Radio Inc. Request for STA to Operate In—Store SDARS Signal Boosters, File No. SAT—
STA—20030411—00075 (filed June 5, 2003). The link budget is also incorporated by reference
herein.

3          47 C.F.R. §25.202(a)(6) (stating the 2320—2345 MHz band is allocated exclusively for
SDARS).

*          2003 In—Store Booster Application at 4 and Exhibit C.


 Ms. Marlene H. Dortch
 September 7, 2007
 Page 3

 Certifications. Sitius acknowledges that the conditions imposed in the 2001 Order granting
 Sirius‘ request for STA to operate terrestrial repeaters® will continue to apply to any repeaters
 authorized as a result of this application. Sirius further certifies that its operation of signal
 boosters at trade shows will comply, as applicable, with the "Micro—Repeater STA Conditions"
 that the Commission imposed on Sirius in granting the June 26, 2003 STA to operate 5,000 in—
 store signal boosters. Specifically, Sirius certifies the following:

 (1)    Sirius will operate the repeaters and trade showsignal boosters at its ownrisk, and such
        operation shall not prejudice the outcome of the final rules adopted by the Commission
        in GEN Docket 95—91;


(2)     Sirius will operate the repeaters and trade showsignal boosters on a non—interference
        basis with respect to all permanently authorized radiocommunication facilities;

(3)     The repeaters and trade show signal boosters will be restricted to the simultaneous
        retransmission of the complete programming, and only that programming, transmitted by
        the satellite directly to SDARS receivers;

(4)     Where applicable, coordination of the repeaters and trade showsignal boosters will be
        completed with all affected Administrations prior to operation, in accordance with all
        applicable international agreements including those with Canada and Mexico;

(5)     The repeaters and trade show signal boosters will comply with Part 17 of the
        Commission‘s rules — Construction, Marking, and Lighting of Antenna Structures:;

(6)     The repeaters and trade show signal boosters will comply with Part 1 ofthe
        Commission‘s rules, Subpart I — Procedures Implementing the National Environmental
        Policy Act of 1969, including the guidelines for human exposure to radio frequency
        electromagnetic fields as defined in Sections 1.1307(b) and 1.1310 of the Commission‘s
        rules;

(7)     The out—of—band emissions of the repeaters and trade showsignal boosters will be limited
       to 75+log (EIRP) dB less than the transmitter EIRP;

(8)    Sirius will operate the repeaters and trade showsignal boosters according to the technical
       parameters provided in this application:

(9)    Sirius will maintain full ownership and operational control of each repeater and trade
       show signal booster; and




        Sirius Satellite Radio Inc. Application for Special Temporary Authorityto Operate
Satellite Digital Audio Radio Service Complementary Terrestrial Repeaters, Order and
Authorization, File No. SAT—STA—20010724—00064, DA 01—2171 (Sept. 17. 2001).


Ms. Marlene H. Dortch
September 7, 2007
Page 4

(10)   Sirius will immediately shut down any repeater and any, or all, trade show signal boosters
       upon a complaint of interference, upon direction from the Commission, or upon finding
       that a repeater or trade show signal booster has not been properly installed.


                                         exaerra




Sirius Trade Shows / Events
                              Location
                                °          No c Of Setors
                                                    orse    Antornanenna TIype   AM@mS   onemation Downtit h.   Longtude 9 Lattude y AntennaATC!72 Height (let
                                                                                                                                                    000(420
                                                                                                                i


                                         EXHIBIT B

Attached is the following information for each of the trade showsignal boosters Sirius
seeks to operate pursuant to this STA.

       (1)   antenna type;
       (2)   antenna beamwidth:
       (3)   total EIRP; and
       (4)   approximate height Above Ground Level (AGL)



City            Antenna Type              Antenna          EIRP Total in    Height AGL
                                          Beamwidth        Watts
Various         Antenna Specialists        75 degrees      0.0001           <50 feet
                XMSSRO23 WR

The transmitted carriers have a center frequency and frequencystability identical to the
received SDARS satellite or terrestrial carriers. Frequency accuracyis controlled by the
satellite or terrestrial repeater and not by the booster.


EXHIBIT C


                                RF Exposure Analysis

   International BoatBuilders‘ Exhibition & Conference (IBEX) 2007
                           October 10—12, 2007
             Miami Beach Convention Center, Miami Beach, FL


This technical addendum is to support the STA request for IBEX 2007. This event is
being held at the Miami Beach Convention Center in Miami Beach, FL. A low—power
transmitter and signal booster will be used to provide coverage at the event.

1. RF Exposure Analysis for Low—Power Transmitter

The transmitter set up for the show is ilustrated in the figures below:




                                                               HALL B




                                                   Tx Antenna

                                                               HALLC




         VSAT and GPS ©
         on the roof                             Transmitter




Figure 1, Diagram of Main hall


                                     Floor to Tx              Floor to
               Tx Antenna            antenna= 30ft |         ceiling = 35ft




Figure 2. Main Exhibit hall


To establish the RF exposure environment for this request the following process has been
used to establish that there is no general population exposure over the allowed limit:

   1. The location of the antenna and the transmission parameters have been
      established. The antenna is placed 30 feet above the show floor as seen in Figure
       2. A 20 watt (average), 90 watt (peak) powertransmitter is used. Together with
       the assumed length and type of cable feeding the antenna (which is omni
       directional) and the type and gain of the antenna used, this leads to an effective
       isotropically radiated power (EIRP) of 200 watts (average) and 900 watts (peak).
       This calculation is summarized in Tablel. The transmitter operates at 2.32625
       GHz which is the carrier frequencyallocated to the Sirius repeater network. At
       this frequency the FCC has established a limit of 1 mW/square centimeter for
       general population exposure (OET 65).
       Using the calculation methods described in OET 65 and the EIRP‘s derived as
       described in "1" a calculation is made of the power density at various distances
       from the antenna for both the average and peak powers involved. The distance of
       23 feet was chosen as the minimum distance criteria for exposure by taking the
       height of the antenna (30 feet) and subtracting a 7 foot allowance for the height of
       any individuals who may be present on the show floor. This distance represents
       the closest point that a member of the general population could approach this
       repeater antenna. Table 2 summarizes the results of the normal calculation (using
       the formula Power Density=EIRP/(4*II*R*2) from OET 653) and also a more
       conservative formula which takes into account reflection (the formula PD=
      2.56*EIRP/(4*II*R*2) ) also from OET 65. In order to provide a comprehensive



                                  Sirius Satellite Radio
                                                                                         bo


        view, values are included separately for the regular case (average and peak power
        based ) and for the reflective case (peak power based).

    Summary
    Using a very conservative approach the calculated RF exposure levels from the
    proposed installation are well within the stated limits defined in OET 65. Several
    worst case assumptions were made as follows:

    1. No allowance was made for the significant reduction in power density that will
       occur due to the attenuation of the antenna pattern at the location immediately
       under the antenna, the location to which the minimum distance of23 feet applies.
       No allowance was made in the case of peak level calculations for the fact that
       these levels occur a very small fraction of the overall time of transmission.
       The maximum transmitter power of 20 watts was used although in practice Sirius
       has determined that the transmitter will be operated at a level at or below10 watts
       which will provide adequate margin for the demonstrations involved.
       There is no access to the ceiling area where the antenna is mounted except with a
       construction lift.
       The highest level of exposure, involving the potential for additive reflection and
       peak level EIRP was used as the exposure criteria.


Table 1. Transmit chain loss budget


                                         Average |Average      |Peak      Peak
                                         (waits)    (dBW)      (watts)    (dBW)
              Transmitter output power           20       13.0         90       198.5
              Cable Loss (db)                                2                      2
              Antenna gain dBi (max)                        12                    12

              EIRP (max)                       200.0        23.0    900.0       29.5

The effective isotropic radiated power (EIRP) is calculated by taking the transmitter
output power, subtracting the cable loss and adding the antenna gain.

The peak power is determined by applying the peak to average factor of the OFDM
waveform to the average power of the transmitter. This peak level occurs less than
1/1000"" of the time for the Sirius waveform for this transmitter type.


Table 2. Calculations for power density

       Power Density = EIRP/(4piR*2) (Equation 4 page 19 of OET 65)
       Power Density adjusted for reflection = 2.56*Power Density (Equation 7, page 21
       of OET 65)




                                   Sirius Satellite Radio
                                                                                        u>


As can be seen from this table, even under very conservative transmission assumptions,
the general population exposure limits are not exceeded at the worst case location.


                    Power
       Radial       Density      Power density Peak power
       Distance     (Average)    }(Peak)          density with
       from Antenna|mW/square |mW/square           |2.56 multiplier
       (Feet)       om           cm               (Max reflection)
                 23      0.03343         0.15043              0.38510
                 28      0.02256         0.10150              0.25984,
                 33      0.01624         0.07307,             0.18707)
                 38      0.01225         0.05511              0.14108
                 43      0.00956         0.04304              0.11018
                 48      0.00768         0.03454,             0.08842
                 53      0.00630         0.02833              0.07252
                 58      0.00526         0.02366              0.06056
                   63       0.00446            0.02005         0.05133
                   68       0.00382            0.01721         0.04406
                   73       0.00332            0.01493         0.03823
                   78       0.00291            0.01308         0.03348
                   83       0.00257            0.01155         0.02957
                   88       0.00228            0.01028         0.02631
      [            93|      0.00204            0.00920         0.02355
                   98       0.00184            0.00829         0.02121
                  103       0.00167            9.00750         0.01920
                  108       0.00152            0.00682         0.01747
                  113       0.00138            0.00623         0.01595
                  118      0.00127             0.00572         0.01463
                  123      0.00117             0.00526         0.01347
      [__         128)     ___0.00108          0.00486         0.01243
                  133      0.00100             0.00450         0.01152
                  138      0.00093             0.00418         0.01070
                  143      0.00086,            0.00389;        0.00996
                  148      0.00081             0.00363         0.00930
                  153      0.00076             0.00340         0.00870




                                      Sirius Satellite Radio


2. RF Exposure Analysis for Signal Booster

The set up of the signal booster in the meeting room is illustrated in the figures below:




                    T




                        Rx                          Cable and in—
                        antenna                     line amplifier
                        on roof



Figure 3. Diagram of meeting rooms




                                  Floor to
                                  ceiling = 25 ft               Floor to Tx
                                                            .   antenna =
                                                                18 ft




Figure 4. Meeting room

To establish the RF exposure environment for the signal boosters the following process
has been used to confirm that there is no general population exposure over the allowed
limit:

       1. The transmit antenna is placed 18 feet above the meeting floor as seen in
          Figure 4. A 0.0001 Watt EIRP signal booster identical to boosters that have
          previously been approved for retail stores is used. The booster operates at
          2320—2332.5MHz which is the carrier frequency allocated to the Sirius



                                   Sirius Satellite Radio                                   5


            repeater network. At this frequency the FCC has established a limit of 1
            mW/square centimeter for general population exposure (OET 65).

        2. Using the calculation methods described in OET 65 and the EIRP‘s described
            in "1" a calculation is made of the power density at various distances from the
            transmit antenna, The distance of 11 feet was chosen as the minimum distance
            criteria for exposure by taking the height of the antenna (18 feet) and
            subtracting a 7 foot allowance for the height of any individuals who may be
            present on the show floor. This distance represents the closest point that a
            member of the general population could approach this transmit antenna. Table
            4 summarizes the results of the normal calculation (using the formula Power
            Density=EIRP/(4*II*RA2) from OET 65) and also a more conservative
            formula which takes          into account    reflection (the formula PD=
            2.56*EIRPM4*II*RA2) ) also from OET 65. In order to provide a
            comprehensive view, values are included separately for the regular case and
            for the reflective case.

    Summary
    Using a very conservative approach the calculated RF exposure levels from the
    proposed installation are well within the stated limits defined in OET 65. Several
    worst case assumptions were made as follows:

        1. No allowance was made for the significant reduction in power density that
           will occur due to the attenuation beyond the 3 dB antenna beamwidth.
        2. The highest level of exposure, involving the potential for additive reflection
           was used as the exposure criteria.


Table 3. Signal Booster specifications

                    Antenna Type         Antenna Beamwidth Total EIRP in Watts
               Antenna Specialists
               XMSSRO23WR                      75 degrees         0.0001



Table 4. Calculations for power density

   e   Power Density = EIRP/(4piRA2) (Equation 4 page 19 of OET 65)
   e   Power Density adjusted for reflection = 2.56*Power Density (Equation 7, page 21
       of OET 65)

As can be seen from this table, even under very conservative transmission assumptions,
the general population exposure limits are not exceeded at the worst case location.




                                       Sirius Satellite Radio                            6


                       Power Density
Radial       Power     with 2.56
Distance     Density   multiplier
from Antenna\mW/square |(Max
(Feet)       cm        reflection)
          11|   0.000000073]   0.00000019
          12|   0.000000061)   __0.00000016
          13}   0.000000052]   0.00000013
          14}   0.000000045|   0.00000012
          15)   0.000000039]   ___0.00000010
          16)   8.000000035)___0.00000008
          17)   0.000000031}___0.00000008
          18}   0.000000027|   0.00000007
         19     0.000000024)   0.00000006
         20)    0.000000022)   0.00000006
         21|    0.000000020]   0.00000005
         22|    0.000000018]__0.00000005
         23}    0.000000017}   0.00000004
         24)    0.000000015)   0.00000004;
         25)    0.000000014)   0.00000004
         26|    0.000000013]   0.00000003
         27)    0.000000012)   __0.00000003
         28)    0.000000011}   0.00000003
         29)    0.000000011|   __0.00000003
         30|    0.000000010|___0.00000003
         31|    0.000000008|   0.00000002
         32)    0.000000008]   0.00000002
         33)    0.000000008]   0.00000002,
         34|    0.000000008)   0.00000002
         35|    0.000000007}   0.00000002




                     Sirius Satellite Radio


EXHIBIT D


                             RF Exposure Analysis

                               2007 SEMA Show
                       October 30 — November 2, 2007
                        Las Vegas Convention Center
                                 Las Vegas, NV




This technical addendum is to support the STA request for 2007 SEMA Show. This event
is being held at the Las Vegas Convention Center in Las Vegas, NV. Two low—power
transmitters and a signal booster will be used to provide coverage at the event.


RF Exposure Analysis for Low—Power Transmitter

The transmitters set up for the show are iflustrated in the figures below:
                                         Transmitter
                 x
                 s   —   VSAT and GPS on roof                                             Tx Antenna
 PARADISE Roap




                                                         Floor to Tx        Floor to
                                                       antenna = 35ft    ceiling = 40ft




                                        Figure 2. North Main Exhibit hall




                                                Sirius Satellite Radio                                 2


        Transmitter
                                                 VSAT and GPS antenna on roof

         Tx Antenna




            Floor to Tx         C           Floor to
          antenna = 35ft            "1   ceiling = 40ft




Figure 4.Central Main Exhibit hall



       Sirius Satellite Radio
                                                                        ue


To establish the RF exposure environment for this request the following process has been
used to establish that there is no general population exposure over the allowed limit:

    1. The locations of the antenna and the transmission parameters have been
       established. The antennas in both locations are placed 35 feet above the show
       floor as seen in Figure 2 and Figure 4. A 20 watt (average), 90 watt (peak) power
       transmitter is used. Together with the assumed length and type of cable feeding
       the antenna (which is omni directional) and the type and gain of the antenna used,
       this leads to an effective isotropically radiated power (EIRP) of 200 watts
       (average) and 900 watts (peak). This calculation is summarized in Table 1. The
       transmitter operates at 2.32625 GHz which is the carrier frequency allocated to
       the Sirius repeater network, At this frequency the FCC has established a limit of 1
       mW/square centimeter for general population exposure (OET 65).

   2. Using the calculation methods described in OET 65 and the EIRP‘s derived as
       described in "1" a calculation is made of the power density at various distances
       from the antenna for both the average and peak powers involved. The distance of
       28 feet was chosen as the minimum distance criteria for exposure by taking the
       height of the antenna (35 feet) and subtracting a 7 foot allowance for the height of
       any individuals who may be present on the show floor. This distance represents
       the closest point that a member of the general population could approach this
       repeater antenna. Table 2 summarizes the results of the normal calculation (using
       the formula Power Density=EIRP/(4*II*RA2) from OET 65) and also a more
       conservative formula which takes into account reflection (the formula PD=
       2.56*EIRP/(4*II*R*2) ) also from OET 65. In order to provide a comprehensive
       view, values are included separately for the regular case (average and peak power
       based ) and for the reflective case (peak power based).




                                  Sirius Satellite Radio                                 4


    Summary

    Using a very conservative approach the calculated RF exposure levels from the
    proposed installation are well within the stated limits defined in OET 65. Several
    worst case assumptions were made as follows:

    1. No allowance was made for the significant reduction in power density that will
        occur due to the attenuation of the antenna pattern at the location immediately
        under the antenna, the location to which the minimum distance of 28 feet applies.
       No allowance was made in the case of peak level calculations for the fact that
       these levels occurs a very small fraction of the overall time of transmission.
       The maximum transmitter power of 20 watts was used although in practice Sirius
   o




       has determined that the transmitter will be operated at a level at or below 10 watts
       which will provide adequate margin for the demonstrations involved.
       Access to the ceiling area where the antenna is mounted is restricted only to
       convention electricians and installation crews.
       The highest level of exposure, involving the potential for additive reflection and
       peak level EIRP was used as the exposure criteria.


Table 1. Transmit chain loss budget

                                   Average        |Average       |Peak          Peak
                                   (watts)        (dBW)          (watts)        (dBW)
        Transmitter output power             20           13.0             90           19.5
        Cable Loss (db)                                      2                             2
        Antenna gain dBi (max)                              12                            12

        EIRP (max)                      200.0           23.0          200.0            29.5




The effective isotropic radiated power (EIRP) is calculated by taking the transmitter
output power, subtracting the cable loss and adding the antenna gain.

The peak power is determined by applying the peak to average factor of the OFDM
waveform to the average power of the transmitter. This peak level occur less than
1/1000" of the time for the Sirius waveform forthis transmitter type.




                                   Sirius Satellite Radio                                      5


Table 2. Calculations for power density

   e   Power Density = EIRP/(4piRA2) (Equation 4 page 19 of OET 65)
   e   Power Density adjusted for reflection = 2.56*Power Density (Equation 7, page 21
       of OET 65)


As can be seen from this table, even under very conservative transmission assumptions,
the general population exposure limits are not exceeded at the worst case location.


        Radial         Power          Power             Peak power
        Distance       Density        density           density with
        from           (Average)      (Peak)            2.56 multiplier
        Antenna        mWi/square     mWi/square        (Max
        (Feet)         cm             cm                reflection)
                  28      0.02256           0.10150            0.25984
                  33      0.01624           0.07307            0.18707
                  38     0.01225            0.05511            0.14108
                 43      0.00956            0.04304            0.11018
                 48      0.00768            0.03454            0.08842
                  53     0.00630            0.02833            0.07252
                  58     0.00526            0.02366            0.06056
                 63      0.00446            0.02005            0.05133
                 68      0.00382            0.01721            0.04406
                 73      0.00332            0.01493            0.03823
                 78      0.00291            0.01308            0.03348
                 83      0.00257            0.01155            0.02957
                 88      0.00228            0.01028            0.02631
                 93      0.00204            0.00920            0.02355
                 98      0.00184            0.00829            0.02121
                103      0.00167            0.00750            0.01920
                108      0.00152            0.00682            0.01747
                113      0.00138            0.00623            0.01595
                118      0.00127            0.00572            0.01463
                123      0.00117            0.00526            0.01347
                128      0.00108            0.00486            0.01243
                133      0.00100            0.00450            0.01152
                138      0.00093            0.00418            0.01070
                143      0.00086            0.00389            0.00996
                148      0.00081            0.00363            0.00930
                153      0.00076            0.00340            0.00870
                158      0.00071            0.00319            0.00816




                                    Sirius Satellite Radio


2. RF Exposure Analysis for Signal Booster

The set up of the signal booster in the meeting roomis illustrated in the figures below:

                                           Rx antenna on                            Cable and in—line
                                                  roof         ~—>.                     amplifier




                                            Tx antenna




                                              M            1i! tnet l h: 9

                                    CRoentro| 4
                                            C4 Entrance




                                                                             o8
                                Fioor to
                                ceiling = 15 ft                       Floor to Tx
                                                                      antenna =




                                Figure 8. Meeting room

To establish the RF exposure environment for the signal boosters the following process
has been used to confirm that there is no general population exposure over the allowed
limit:


                                  Sirius Satellite Radio


        1. The transmit antenna is placed 12 feet above the meeting floor as seen in
           Figure 6. A 0.0001 Watt EIRP signal booster identical to boosters that have
           previously been approved for retail stores is used. The booster operates at
           2320—2332.5MHz which is the carrier frequency allocated to the Sirius
           repeater network. At this frequency the FCC has established a limit of 1
           m W/square centimeter for general population exposure (OET 65).

           Using the calculation methods described in OET 65 and the EIRP‘s described
           in "I" a calculation is made of the power density at various distances from the
           transmit antenna. The distance of 5 feet was chosen as the minimum distance
           criteria for exposure by taking the height of the antenna (12 feet) and
           subtracting a 7 foot allowance for the height of any individuals who may be
           present on the show floor, This distance represents the closest point that a
           member of the general population could approach this transmit antenna. Table
           5 summarizes the results of the normal calculation (using the formula Power
           Density=EIRP/(4*II*RA2) from OET 65) and also a more conservative
           formula   which    takes into     account   reflection (the formula      PD=
           2.56*EIRP/(4*II*R*2) ) also from OET 65. In order to provide a
           comprehensive view, values are included separately for the regular case and
           for the reflective case.

   Summary
   Using a very conservative approach the calculated RF exposure levels from the
   proposed installation are well within the stated limits defined in OET 65. Several
   worst case assumptions were made as follows:


          No allowance was made for the significant reduction in power density that
          will occur due to the attenuation beyond the 3 dB antenna beamwidth.
          The highest level of exposure, involving the potential for additive reflection
          was used as the exposure criteria.


Table 5. Signal Booster specifications

                    Antenna Type      Antenna Beamwidth Total EIRP in Watts
              Antenna Specialists
              XMSSRO23WR                   75 degrees          0.0001



Table 6. Calculations for power density

       Power Density = EIRP/(4piR*2) (Equation 4 page 19 of OET 65)
   &   Power Density adjusted for reflection = 2.56*Power Density (Equation 7. page 21
       of OET 65)



                                    Sirius Satellite Radio                              8


As can be seen from this table, even under very conservative transmission assumptions,
the general population exposure limits are not exceeded at the worst case location.

                                              Power
             Radial                           Density with
             Distance         Power           2.56
             from             Density         multiplier
             Antenna          mWisquare       (Max
             (Feet)           cm              reflection)
                          5   0.000000354       0.00000081
                          6   0.000000246       0.00000063
                          7   0.000000180       0.00000046
                          8   0.000000138       0.00000035
                          9   0.000000109       0.00000028
                         10   0.000000088       0.00000023
                         11   0.000000073       0.00000019
                         12   0.000000061       0.00000016
                         13   0.000000052       0.00000013
                         14   0.000000045       0.00000012
                         15   0.000000039       0.00000010
                        16    0000000035        0.00000009
                        17    0.000000031       0.00000008
                        18    0.000000027       0.00000007
                        19    0000000024        0.00000006
                        20    0.000000022       0.00000006
                        21    0.000000020       0.00000005
                        22    0.000000018       0.00000005
                        23    0.000000017       0.00000004
                        24    0.000000015       0.00000004
                        25    0.000000014       0.00000004
                        26    0.000000013       0.00000003
                        27    0.000000012       0.00000003
                        28    0.000000011       0.00000003
                        29    0.000000011       0.00000003
                        30    0.000000010       0.00000003
                        31    0.000000008       0.00000002
                        32    0.000000009       0.00000002
                        33    0.000000008       0.00000002
                        34    0.000000008       0.00000002




                                   Sirius Satellite Radio



Document Created: 2007-09-20 15:07:26
Document Modified: 2007-09-20 15:07:26

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