Attachment letter

letter

LETTER submitted by WCS Coalition

letter

2007-12-20

This document pretains to SAT-STA-20071219-00178 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2007121900178_616407

” , WILKINSON ) BARKER) KNAUERL L P ) 2300 SUITE N 700 STREET, NW WASHINGTON. DC 20037 TEL 202.783.4141 FILED/ACCEPTED FAX 202.783.5851 DEC 2 0 2007 w w w . w b kl a w . c a m P A U LJ . S I N D E R B R A N D Federal Commonicatioqs Commaon ps[nderbrand@wbklaw.com Office of the Secketary December 20,2007 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, SW Washington, DC 20554 Re: Requests OfXM Radio Inc. For 30 Day and 180 Day Special Temporary Authorizations Regarding Digital Audio Radio Service Terrestrial Repeater - File Nos. SAT-STA-20071214-00175 and SAT-STA- 20071219-00178 Dear Ms. Dortch: I am writing on behalf of the WCS Coalition in regard to the above-referenced requests by XM Radio Inc. (‘‘XM”) for 30 day and 180 day special temporary authorization (“STA”) to operate what appears to be a new type of Digital Audio Radio Service (“DARS”) terrestrial repeater system in Vienna, VA. Because of ambiguities in XM’s applications, it is unclear exactly how the indoor rebroadcast system proposed by XM will operate. The WCS Coalition fears that XM may intend to receive signals directly off air, amplify those signals with a broadband amplifier and then retransmit them without benefit of the filtering necessary to assure that Wireless Communications Service (“WCS”) transmissions in all or part of the 2305-2320 MHz and 2345- 2360 MHz bands are not also received and retransmitted by XM. If these fears prove accurate, XM’s activities will present a substantial threat of interference to WCS operations, since the signals in the WCS band being retransmitted by XM will inevitably interfere with the reception of signals being transmitted by the adversely-impacted WCS licensee. Moreover, if XM contemplates using a broadband amplifier, there is no indication in the application that XM has incorporated some form of anti feedback mechanism to assure that it will not become a broadband noise source if the coupling between the receiver and retransmit antennas is not sufficient to avoid oscillation. And, there is no indication that the indoor device proposed by XM will filter out-of-band emissions to a level that produces no harm to nearby WCS subscribers.

BARKER) WILKINSON ) K N A U E RL L P Marlene H. Dortch December 20,2007 Page 2 The WCS Coalition appreciates that that any STA granted to XM will require XM to cure interference it causes to future WCS operations. However, the WCS Coalition is also p a f i l l y aware of XM's continued insistence in IB Docket No. 95-91 that all repeaters authorized by STA be grandfathered from compliance with permanent DARS repeater rules, while at the same time it seeks to be relieved of its absolute obligation under the STA to cure any interference.' This position by XM forces the WCS Coalition to object to a grant of the instant applications until XM provides further evidence that WCS signals will not be retransmitted by the proposed new repeater system. The WCS Coalition is hopeful that in response to the Second Further Notice of Proposed Rulemaking released earlier this week in IB Docket No. 95-91 the Commission will adopt permanent DARS terrestrial repeater rules that reasonably protect WCS operations from interference caused by DARS repeaters constructed pursuant to STAs. However, because it will be several months until the Commission can act, the possibility remains that absent this objection, WCS licensees may find themselves without recourse as to XM's proposed new repeater system- Should you have any questions regarding this submission, please contact the undersigned. - Respecthlly submitted, Paul J. Sinderbrand Counsel to the WCS Coalition cc: Stephen Dual1 (via email) Alyssa Roberts (via email) Shabnam Javid (via email) James S. Blitz (via email) ' See, e.g. Letter from James S. Blitz, XM Vice President, Regulatory Counsel, et al. to Marlene H. Dortch, FCC Secretary, IB Docket No. 95-9 1 , at 9- 10 (filed Oct. 19,2007). ' I


Document Created: 2007-12-27 13:46:30
Document Modified: 2007-12-27 13:46:30
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