Attachment Grant

Grant

DECISION submitted by IB,FCC

grant

2007-12-12

This document pretains to SAT-STA-20071205-00170 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2007120500170_610176

                                                                                                                 Approved by OMB
                                                                                                                        3060-0678

Date & Time Filed: Dec 5 2007 1:24:45:970PM
File Number: SAT-STA-20071205-00170
Callsign:
                                        FEDERAL COMMUNICATIONS COMMISSION
                              APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                      FOR OFFICIAL USE ONLY



Enter a description of this application to identify it on the main menu:
Sirius Satellite Radio Request for STA to operate a repeater at the Yamaha Dealer Event at the CES trade show January 5-1 0,2008
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:   Mi. Patrick L. Donnelly




1


                           Application of Sirius Satellite Radio Inc.
                              for Special Temporary Authority
                           IBFS File No. SAT-STA-20071205-00170

        Special temporary authority (STA) IS GRANTED to Sirius Satellite Radio, Inc. (Sirius)
to operate an indoor terrestrial repeater with Effective Isotropically Radiated Power (EIRP) of
200 watts, and up to five very low power indoor terrestrial repeaters with an EIRP of 0.0001
watts, from January 5,2008 to January 10,2008, in Las Vegas, NV, according to the technical
parameters specified in its application, subject to the following conditions:

1. Sirius will operate the repeaters at its own risk. This STA shall not prejudice the outcome of
   the final rules adopted by the Commission in IB Docket No. 95-9 1.

2. Operation of the terrestrial repeaters authorized pursuant to this STA is on a non-interference
   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
   Rcd 16773 (Int’l Bur. 2001) and 16 FCC Rcd 16781 (Int’l Bur. 2001)’ as modified by 16
   FCC Rcd 18481 (Int’l Bur. 2001) and 16 FCC Rcd 18484 (Int’l Bur. 2001).

3. The terrestrial repeaters are restricted to the simultaneous retransmission of the complete
   programming, and only that programming, transmitted by the satellite directly to SDARS
   receivers;

4. 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 l.l307(b) and 1.1310 of the Commission’s rules;

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

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

7. Sirius will immediately shut down the terrestrial repeaters upon a complaint of interference,
   upon direction from the Commission, or upon finding that the repeaters have not been
   properly installed;

8. Sirius is granted 30 days from the date of the release of this authorization to decline the
   authorization as conditioned. Failure to respond within that period will constitute formal
   acceptance of the authorization as conditioned.

9. 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 beyond the term of this authorization will require prior
   affirmative authorization by the FCC.



                                                                      C:ilI Sign                 Grant Date   1qfy/Q7
                                                                      (or otlicr irlcnt iiicr)
                                                                                                 Tcrm Ihtcs    .   .

                                                1    GRANTED


    2. Contact

                 Name:         Mr. Patrick L. Donnelly               Phone Number:                       212-584-5100
                 Company:      Sirius Satellite Radio Inc.           Fax Number:                         2 12-584-5353
                 Street:           1221 Avenue of the Americas       E-Mail:
                               36th Floor
                 City:         New York                              State:                               NY
                 Country:          USA                               Zipcode:                            10020      -

                 Attention:                                          Relationship:                       Same


      (If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
    tpplication. Please enter only one.)
      3. Reference File Number or Submission ID
         4a. Is a fee submitted with this application?
    @     IfYes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
    0 Governmental Entity 0 Noncommercial educational licensee
    0     Other(p1ease explain):

    lb. Fee Classification CXW - Space Station (Non-Geostationary)
    ;. Type Request


    Q      Change Station Location                      Q    Extend Expiration Date                     @   Other


    1.   Temporary Orbit Location                                               17. Requested Extended Expiration Date




2


    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 to operate a terrestrial
         repeater and signal boosters at the Yamaha Dealer Event at the CES trade show in Las
         Vegas, NV from January 5, 2008 to January 10, 2008.




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


     Attachment 1: Attachment & Exhibit                Attachment 2:                                     Attachment 3:

I
              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 3 12(a)(l)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).




3


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1,1995,44 U.S.C. SECTION 3507.




4


                                           Attachment

        Sirius Satellite Radio Inc. (“Sirius”), pursuant to 47 C.F.R. 9 25.120,’ hereby requests
Special Temporary Authority (“STA”) to operate in its licensed frequency band (2320-2332.5
MHz) (1) a low-power satellite DARS repeater 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. This low-power repeater and the signal boosters will be
utilized at the Yamaha Dealer Event at the CES trade show in Las Vegas, NV. Sirius intends to
operate the repeater and signal boosters independently - i.e., Sirius will not operate them in
conjunction with XM Radio, Inc., the other satellite DARS licensee.

        The repeater and boosters will be used by Sirius to carry out equipment and service
demonstrations at CES for six days, January 5-10,2008 (which includes two days prior to the
official start of the 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 show venues, like the Rio Convention Area, 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. Accordingly, grant of the
requested STA to use this repeater for this limited period will serve the public interest.

Technical Information. In Exhibit A, Sirius provides the technical parameters, location, and dates
for the trade show repeater 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 the 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 boosters at the same event, dates, location, and market specified in
Exhibit A. Exhibit B lists the technical parameters for the signal boosters, which are identical to
those previously approved by the Commission for use in retail stores.2 Specifically, Sirius has
1
       Because Sirius is requesting STA for less than 30 days, the Commission can grant this
application without placing it on Public Notice. 47 C.F.R. 5 25.120(b)(4).
2
        See Sirius Satellite Radio Inc. Request for Special Temporary Authority to Operate In-
Store Signal Boosters in the Satellite Digital Audio Radio Sewice, 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. 3 1.10009(~)(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
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.


Ms. Marlene H. Dortch
December 5,2007
Page 2

included the following information: (1) antenna type; (2) antenna beamwidth; (3) total EIRP; and
(4) approximate maximum height Above Ground Level (“AGL”). Exhibit C provides a RF
exposure analysis for the trade show, and demonstrates that any human radiofrequency exposure
that might occur is well below acceptable limits.

Interference Considerations. Sirius does not anticipate that the repeater and boosters at this trade
show will cause harmful interference to other radio services. Because Sirius has exclusive use of
its licensed frequency band,3 there is no potential for in-band interference. Moreover, the
repeater will operate at 200 watts, well below the 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 operation^.^ In addition, the repeater
and boosters will only be used for a limited time, further eliminating any opportunity for
interference. Therefore, Sirius does not anticipate that the repeater and boosters will cause
blanketing interference to any WCS receivers.

Ownership and Control of Repeater. Sirius will own each repeater and booster installed at the
venue and will retain full operational control of the repeater 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 of its equipment to consumers. Without repeaters
and boosters to overcome signal blockage within the venues, however, Sirius cannot undertake
real-time demonstrations of its equipment, especially demonstrations of the full mobility of
SDARS service. The repeater and boosters requested in this application will provide clear signal
reception within the venue for these demonstrations, and will eliminate any need for a hard wire
connection.

Sirius understands that its operation of this repeater and associated 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.

Certzjications. Sirius acknowledges that the conditions imposed in the 200 1 Order granting
Sirius’ request for STA to operate terrestrial repeater? will continue to apply to any repeaters
3
    47 C.F.R. tj 25.202(a)(6) (stating the 2320-2345 MHz band is allocated exclusively for
SDARS).
4
        2003 In-Store Booster Application at 4 and Exhibit C.
5
        Sirius Satellite Radio Inc. Application for Special Temporary Authority to Operate
Satellite Digital Audio Radio Service Complementary Terrestrial Repeaters, Order and
Authorization, File No. SAT-STA-20010724-00064, DA 0 1-2171 (Sept. 17,2001).


Ms. Marlene H. Dortch
December 5,2007
Page 3

authorized as a result of this application. Sirius further certifies that its operation of signal
boosters at this trade show 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:

        Sirius will operate the repeater and trade show signal boosters at its own risk, and such
        operation shall not prejudice the outcome of the final rules adopted by the Commission
        in GEN Docket 95-91;

        Sirius will operate the repeater and trade show signal boosters on a non-interference
        basis with respect to all permanently authorized radiocommunication facilities;

        The repeater 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;

        Where applicable, coordination of the repeater and trade show signal boosters will be
        completed with all affected Administrations prior to operation, in accordance with all
        applicable international agreements including those with Canada and Mexico;

        The repeater and trade show signal boosters will comply with Part 17 of the
        Commission’s rules - Construction, Marking, and Lighting of Antenna Structures;

        The repeater and trade show signal boosters will 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 l.l307(b) and 1.1310 of the Commission’s
        rules;

        The out-of-band emissions of the repeater and trade show signal boosters will be limited
        to 75+log (EIRP) dB less than the transmitter EIRP;

        Sirius will operate the repeater and trade show signal boosters according to the technical
        parameters provided in this application;

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

        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.


                                                                                                        EXHIBIT A




          Event                  Event Dates          Market            Location         No Of Setors        Antenna Type         Antenna
                                                                                                                                 Beamwidth   Orientation Downtilt       EiRP)   Longitude(W)   Latitude (N)   Antenna Height (feet)
                                                                                                                                                                        Watts
                                                                                                                                                                    ~




CES - Yarnaha Dealer Event   January 7 - 10,2008   Las Vegas, NV   Rio Convention Area        1          Mobile Mark OD12-2400     Ornni         0          0           200     115-11-13.1    36-07-04.9              45


                                       EXHIBIT B
Attached is the following information for the signal booster 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
Las Vegas,     Antenna Specialists        75 degrees       0.0001              50 feet
NV             XMSSR92 3WR

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


EXHIBIT C


                                RF Exposure Analysis

                2008 International CES - Yamaha Dealer event
                            Rio Convention Area
                                Las Vegas, NV

This technical addendum is to support the STA request for the 2008 International
Consumer Electronics Show (CES) - Yamaha Dealer event. This event is being held at
the Rio Convention Area in Las Vegas, NV. 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 illustrated in the figures below:




                                                                      7
Figure 1. Diagram of Main hall


                                   antenna   =   30ft




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) 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 Tablel. 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
      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


                                  Sirius Satellite Radio                                2


       the formula Power Density=EIRP/(4*rI*RA2) from OET 65) and also a more
       conservative formula which takes into account reflection (the formula PD=
       2.56*EIRP/(4*H*RA2) ) 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).

   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 23 feet applies.
   2. 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.
   3. 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 below 10 watts
      which will provide adequate margin for the demonstrations involved.
   4. There is no access to the ceiling area where the antenna is mounted except with a
      construction lift.
   5. 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
                                                                        I



             ~ E I R P(max)             I       200.01     23.01   900.01     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/(4piRA2) (Equation 4 page 19 of OET 65)


                                  Sirius Satellite Radio                                 3


       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.

                   Power
       Radial      Density       Power density Peak power         Worst Case
       Distance    (Average)     (Peak)          density with     Safety Margin
      from Antenna mW/square mW/square           2.56 multiplier over exposure
       (Feet)      cm            cm              (Max reflection) standard (times)
                23      0.03343         0.1 5043          0.38510           2,59672
                28      0.02256         0.10150           0.25984           3.84845
                33      0.01624         0.07307           0.18707           5.34562
                38      0.01225         0.05511           0.14108           7.08822
                43      0.00956         0.04304           0.11018          9.07626
      I         481     0.007681        0.034541          0.088421      ~ 11.309731
                53      0.00630         0.02833           0.07252         13.78865
                58      0.00526         0.023 66          0.06056         16.51300
                63      0.00446         0.02005           0.05133         19.48278
                68      0.00382         0.01721           0.04406         22.69801
                73      0.00332         0.01493           0.03823         26.1 5867
                78      Om 00291        0.01308           0.03348         29.86477
                83      0.00257         0.01155           0.02957         33.81630
                88      0.00228         0.01028           0.02631         38.01327
                93      0.00204         0.00920           0.02355         4 2.4 5 568
                98      0.00184         0.00829           0.02121         47.14352




                 143      0.00086         0.00389          0.00996          100.37879
                 148      0.00081         0.00363          0.00930          107.52101
                 153      0.00076         0.00340          0.00870          114.90866




                                  Sirius Satellite Radio                                 4



Document Created: 2007-12-12 14:50:08
Document Modified: 2007-12-12 14:50:08

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