Attachment grant

grant

DECISION submitted by IB,FCC

grant

2008-02-05

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

IBFS_SATSTA2007121900178_620176

Approved by OMB 3060-0678 Date & Time Filed: Dec 19 2007 3:10:50:733PM File Number: SAT-STA-2007 1219-00 178 Callsign: I 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: Request for Special Temporary Authority to Operate a Very Low Power Repeater in Vienna, Virginia for 180 Days 1. Applicant Name: XM Radio Inc. Phone Number: 202-380-4000 DBA Name: Fax Number: 202-380-4981 Street: 1500 Eckington Place, NE E-Mail: james.blitz@xmradio.com City: Washtngton State: DC Country: USA Zipcode: 20002 - Attention: James S. Blitz CaIl S i (orotber identifier) _- "=Dates - - 1 GRANTED hernational Bureau

Application of XM Radio Inc. for Special Temporary Authority IBFS File No. SAT-STA-20071219-00178 Special temporary authority (STA) IS GRANTED to XM Radio Inc. (XM Radio) to operate one indoor terrestrial repeater in Vienna, VA, with an Effective Isotropically Radiated Power (EIRP) of up to 0.5 watts (average) for 180 days effective February 6,2008, 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 XM Radio’s own risk. This STA shall not prejudice the outcome of the final rules adopted by the Commission in IB Docket No. 95-91; 2. Operation of the terrestrial repeater authorized pursuant to this STA is on a non-interference basis with respect to all permanently authorized radiocommunication facilities. XM Radio 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 repeater is restricted to the simultaneous retransmission of the complete programming, and only that programming, transmitted by the satellite directly to SDARS receivers; 4. The terrestrial repeater shall comply with Part 1 of the Commission’srules, Subpart I - Procedures Implementing the National Environmental Policy Act of 1969, including the guidelines for human exposure to radio frequency electromagnetic fields as defiied in Sections l11307(b)and 1.1310 of the Commission’s rules; 5. The out-of-band emissions of the terrestrial repeater shall be limited to 75+log(EIRP) dB less than the transmitter EIRP; 6. XM Radio will maintain full ownership and operational control of the terrestrial repeater; 7. XM Radio will immediately shut down the terrestrial repeater upon a complaint of interference, upon direction from the Commission, or upon finding that the repeaters have not been properly installed; 8. 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. 9. XM Radio 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. GRANTED International Bureau 1 -

!. Contact Name: James S. Blitz Phone Number: 202-380-4000 Company: XM Satellite Radio Inc. Fax Number: 202-380-4981 1 Street: 1500 Eckington Place NE E-Mail: james.blitz@xmradio.com City: Washington State: DC Country: USA Zipcode: 20002 - 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 Ipplication. 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). 3 Governmental Entity 0 Noncommercial educational licensee 3 Other(p1ease explain): .b. Fee Classification CRY - Space Station (Geostationary) 1. Type Request 0 Change Station Location 0 Extend Expiration Date @ Other I.Temporary Orbit Location 7. Requested Extended Expiration Date 2

i I 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.) XM Radio Inc. (XM) requests Special Temporary Authority (STA) to operate one very low power terrestrial repeater (less than 2kW EIRP) at a new XM office site in Vienna, Virginia for 180 days pursuant to the technical parameters listed in Exhibit A. 9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject @ Yes to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti-Drug Act of 1988, 0 No 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002@)for the meaning of "party to the application"for these purposes. 10. Name of Person Signing James S. Blitz I11. Title of Person Signing Vice President, Regulatory Counsel Attachment 1: STA Request Attachment 2: Attachment 3 : WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Title 18, Section 100l), AND/OR REVOCATION OF ANY STATIONAUTHORIZATION (U.S. Code, Title 47, Section 312(a)(l)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503). 3 I

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for t h s collection of information is estimated to average 2 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission,AMD-PERM, Paperwork Reduction Project (3060-0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to jboley@fcc.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember -You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060-0678. 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. 4

James S . Blitz XM SATELUTE RADIO Vice President, Regulatory Counsel XM SATELLITE RADIO 1500 Eckington Place, NE Washington, DC 20002 imes.blitz@xmradio.com P: 202-380-1383 F: 202-380-498 i December 19,2007 Via IBFS Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: XM Radio Inc. Request for 180-Day Special Temporary Authority to Operate A Very Low Power Repeater in Vienna, Virginia Dear Ms. Dortch: Pursuant to Section 25,12O(b)(2) of the Commission’s rules, 47 C.F.R. $25.120(b)(2), XM Radio Inc. (,,XM), a Satellite Digital Audio Radio Service (;‘SDARS”) licensee, hereby requests 180-Day Special Temporary Authority (“STA”)to operate in its licensed frequency band (2332.5-2345 MHz) a very low-power repeater (not exceeding 0.5 watts average EIRP) in Vienna, Virginia.’ XM seeks authority to operate this new very low power repeater at an office building located at 2650 Park Tower Drive, Vienna, VA (the “2650 Building”), to which XM will locate some of its employees. Many employees that XM intends to locate at the 2650 Building are part of XM’s Listener Care team, who will be directly involved in the resolution of subscriber complaints. As such, these individuals need to receive a quality XM signal at their desks in order to perform their jobs of assisting XM subscribers.2 The 2650 Building is a large one and XM will occupy two entire floors and part of a third floor of the building. Due to the building’s size and physical limitations, as well as limitations imposed by XM’s sublease, it would be impractical for Xh4 to provide adequate service to these employees using either hard-wire connections or through other existing STA authorizations that XM holds. Rather, a very low power repeater is the only practical solution for providing service I O n December 14,2007, XM filed a request to operate the same repeater under a 30-Day Special Temporary Authority pursuant to Section 25. I20(b)(4) of the Commission’s rules. See File No. SAT-STA-20071214-00175. Given the technical parameters of this proposed facility, it will not be capable of serving members of the general public or XM subscribers located outside of the 2650 Building. I I 1500 KKlNGTON PLACE, NE WASHINGTON DC 20002-2164 P 2O2-380-4OoO F 202-380-4500 1 XMRADIO COM 7 -1 “mr- r- . --- ,. * .--- __I_c_I-Lx - ”^__ _-_ .”-“-I_<.“II ll-”.* -- ”

Ms. Marlene H. Dortch December 19,2007 Page 2 to XM employees at the 2650 Building. Under this configuration, rather than receiving signal from a terrestrial repeater, a mini repeater (containing the receiver, transcoder and upconverter of a terrestrial repeater) located in the 2650 Building would receive XM’s signal directly from an XM satellite. The mini-repeater, which would not radiate at all, would transmit the signal directly to a very low power repeater via coaxial cable. The repeater would then amplify the signal via an external amplifier and retransmit the signal via one or more omnidirectional antennas, at a power level not exceeding 0.5 watts average EIRP. The Commission has recognized that SDARS operators require terrestrial repeaters to provide high-quality service nati~nwide.~ Consistent with this policy, in September 2001,the Bureau granted XM an STA to operate a nationwide network of terrestrial repeater^.^ In the years since, the Bureau has granted XM additional STAs to operate its terrestrial repeaters, pending issuance of final rules governing the deployment and use of repeaters.’ Public Interest Considmations. Grant of the STA will serve the public interest by providing quaiity service to XM employees at the 2650 Building, who in turn will be able to provide better customer service assistance to XM subscribers. Moreover, the STA will promote the continued success of satellite radio because the very low power repeater will eliminate the need for hard- wire connections which in this case could cause significant physical disruption to the leased office space. Without this very low power repeater, XM could not provide the signal quality that its listener care employees require. Technical Informationfor Very Low Power Repeater. The following technical information pertaining to the repeater is provided in Exhibit A: (1) antenna type; (2) antenna orientation; (3) 3 See Establishment of Rules and Policies for the DigitaI Audio Radio Satellite Service in the 23 IO-2360 MHz Frequency Bund, Report and Order, Memorandum Opinion and Order, and Further Notice ofProposed Rulemaking, 12 FCC Rcd 5754,5770 37 (1997). 4 See XM Radio, Inc., Application for Special TemporaryAuthority fo Operate Satellite Digital Audio Radio Service Complimentary Terrestrial Repeaters, Order and Authorization, 16 FCC Rcd. 16781 7 18 (2001) (‘XMSTA Order”). 5 See, e.g., XM Radio, Inc.; Request for Special Temporary Authority to Operate Additional Salellite Digital Audio Radio Service Terrestrial Repeaters, Order and A ufhorization, 19 FCC Rcd, 18140 (2004) (granting XM an STA in File No. SAT-STA-20031112-00371, effective Sept. 15,2004); Public Notice, 2002 FCC Lexis 5670 (rel. Oct. 30,2002) (granting XM an STA in File No. SAT-STA-20020815-00153, effective Sept. 30,2002); Public Nolice, 2003 FCC Lexis 4803 (rel. Aug. 29,2002) (granting XM an STA in File No. SAT- STA-20030409-00076, effective June 26,2003). XM has filed applications to renew its STAs, and those renewal applications are pending before the Commission.

Ms. Marlene H. Dortch December 19,2003 Page 3 average EIW; (4)height above ground level (“AGL”); and ( 5 ) antenna downtilt. The specification sheet for the antenna is attached as Exhibit B. lnferference Considerufions. The very low power repeater will not cause harmful interference to other radio services. Because XM has exclusive use of its licensed band, there is no potential for in-band interference. Moreover, this repeater will operate at a power level not exceeding 0.5 watts average EIRP, which is well below the 2000 watts EIRP threshold identified by the WCS Coalition as a potential interference Accordingly, XM does not anticipate that operation of the new repeater will cause any interference for WCS operators or any other entity. To the extent XM’s original 2001 STA requires it to coordinate with affected Wireless Communications Services C‘WCS’’) licensees prior to operating any repeater: XM is sending a copy of this STA application to counsel for Horizon Wi-Com, LLC (“Horizon”) in satisfaction of this coordination requirement.* Ownership and Control of Repeaters. X M will own the very low power repeater and it will be responsible for its installation and operation. XMSTA Order 7 12 (“The comments from WCS licensees express concern about blanketing interference from DARS repeaters that operate with an Equivalent Isotropically Radiated Power (EIRP) above 2 kW.”). The WCS Coalition has said that it will defer from objecting to STA requests that propose operations of no more than 2,000 watts EIRP, even if they do not specify peak or average EIRP, provided that grant of the STA (i) is conditioned on operation on a non-interference basis; and (ii) is subject to the condition that the issue of peak versus average EIRP will be addressed in the pending DARS rulemaking (IB Docket No. 95- 91). See Letter from Paul J. Sinderbrand, Counsel to the WCS Coalition, to Ms. Helen Domenici, FCC, File No. SAT-STA-20061207-00145 (filed March 19,2007). XM agrees to these conditions. See XM STA Order T[ 14. Despite the Bureau’s statement in theXMSTA Order (at 7 14) that it expects “WCS licensees to provide a schedule or as much advance notice as possible of when their stations are to be pIaced in operation,” XM has not received information directly from any WCS licensee regarding plans for WCS deployment in these markets. However, XM’s own review of Commission files show that Horizon has certified that it operates a WCS station in the Washington, D.C. market, Call Sign KNLB315, File No. 0003045282 (filed May 29,2007). It is not clear from Horizon’s certification whether its base station is receiving transmissions from CPE or whether it is engaged in transmit-only operations. If only the latter, potential interference to the Horizon base station is not an issue. In any event, XM has conducted an interference analysis and determined that this repeater site will not create interference to Horizon’s operating WCS site.

Ms. Marlene H. Dortch December 19,2007 Page 4 CerfiJicaiiuns. Xh4 certifies that it will operate the very low power repeater subject to the conditions and certifications set forth in the XM STA Order granting XM's September 2001 request for STA to operate terrestrial repeaters. Granting this request will not alter XM's obligation to protect authorized radiocommunicationsfacilities from interference, and it will not prejudice the outcome of the Commission's ongoing rukmaking pertaining to the deployment and operation of terrestrial repeaters. XM hereby certifies that no party to this application is subject to a denial of Federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988,21 U.S.C. 5 853(a). XM is submitting payment to the Federal Communications Commission in the amount of Seven Hundred Ninety Dollars ($790.00) -- the filing fee applicable to requests for STAs for geostationary (,,,SO) satellite^.^ Please direct any questions regarding this matter to the undersigned. Vice President, Regulatory Counsel j/ f cc: Stephen Duall, FCC Alyssa Roberts, FCC Shabnam Javid, FCC Thomas Gutierrez, Lucas Nace Gutienez & Sachs (Counsel for Horizon Wi-Corn) See International and Satellite Services Fee Filing Guide (October 2006).

Exhibit A Technical parameters for repeater Antenna Type Antenna Beamwidth EIRP Total in Watts Omni Antenna (YDI 300 degrees 0.5 Model #2408) and External Amplifier (CPL Model #O 1027997-00) I

Exhibit B Antenna Specification Sheet for repeater

ModelA2412—0 » 12 dBi gein » Ho downitt « §" beamwidih Model!AZM12—1 » 12 dBigain + 3° downtit .« 5° beamwidth Hodet A2408 (onm1) AZM2ZO (Gamh AMAZD (orniy TBW Port Number 203—900008—001 202—900004—0014 203—900003—0014 Electrical ~ Frequency Renge: 2400 to 2500 GHz 2400 to 2485 GHz 2.400 to 2485 GHz Forward Galn: 8 us _ 12 dBi 142 dBi _ vewr: «Z1 <21 «Z4 Polarcation _ Verlical Vestical Vertical Beamidth: dagrees d 5 dagrees with . 25 6 3 degrees downtitt Mechanical | — Terminatiorg N4ype Femaie N—ype Female | Naype Female ""’“'A‘““‘ for 1—2.6 in O.B. for 1—2.6 in O.0. for 1—2.5 in O.D. emm;;»m,': i in/ 16 in 1i /58 5in 111756 4, 5in Weight —2bs 3 Ths & oz 3 tba 8 oz & 'F"“,Affiedai 8.sg & 04584 t 0.45 sq i WindSurvivel: 125 mph 125 raph 125 moh Radome .} Heevy—duty white UV inhibited fberglass radome seal with intemal copper etements SposiScalions subjeottochange asthoednolike Apr2005—01 8000 Lee Highway, Falls Church VA 22042 990 Almanor Avenue, Sunnyvale, CA 94085 Tel: (703) 205—0600 Fax: (703) 205—0610 Tel: (408) 617—8150 Fax: (408) 617—8151 Sales: 1—885—297—90900 wwwderabaam.com Salas: 1—800—654—7060 T

SPECIFICATIONS 'me I sheet I Of Class Size DWG. NO. Rev 57982 I A I 01027997 6 NEXT ASSEMBLY USE0 ON REV DESCRPTlON EO OAT€ APPR S-bandGenW 6 EagrRke A01104 7/29/00 EA0 I 1 t I I 0 1027997 S-band Solid State Intermediate Power Amplifier - UNLESS OTHERWISE }CONTRACT NUMBER- I I MATERIAL: I DIMENSIONS ARE tN INCHES I m. I 1 SPEC. NO. DEC: 1PL C .02 Chk - FINISH: 3PL f .005 I FRAC * 1/64 Appd W n adlvrtv&& WGfldeg { SUR Mpd customer Pppmvpl

__ 1.0 GENERAI,DESCRtanOXy This specificationdefines the performance requirements for a solid state htegmted attenuator/amplifierused 85 a driver ( i i e d b t e power amplXer) in a klystron high power amplifier system. UnIess steted otherwise. at1 specificalions apply ova the whole fi-equency passband. The high power amplifier system is designed fix use 89 the transmitter in SDARS systems (satellite digital audio d o system). 2.0 pF PERFORMANCI$ 21 Frequency Passband 2.322 to 2.343GHz 2.2 POWWOutput at - 1 dB Compr. +32dBrn m h 2.3 Third Order Intercept H2dBm 2.4 Noise Figure 7dB m a 2 5 Gain (st Rated Output) 24dB (min.) 2.6 Gain (Small Signal) 2AdB (min), 28dB (msx.) 2.7 Gaia Variation vs Freq. O.l& max 2.8 Gain Slope v9 Freq. 0.05dBIMHz ma. over any 1 M H z 2.9 VSWR, Output 1.5:1 max. 210 VSWR,lnput 1-53 max. 2.1 I VSWR, Lotid 1.3:l max. to meet speciftcations 2.12 AM/PM Conversion O.S"/dB max at +25dBm 2.I3 Spurious (relative to +25dBm in-band) -8OdBc max, 2.2-2.4GHz -6OdBc max, 2.0-2.2GHz,2.4-18GHz 2.34 Harmonics (r",3*, 4', 5") -40dBc rnax when operated at +25di3m in- band 2.15 Group Delay (rjpple across the band) 0.5 us pk to pk max. 2.16 Gain Stability vs Time - 0.1 ds max.124 hours at 20°C f 2°C after 20 min. warmup.

SPECIFICATIONS -Cage Sheet Of Class SnS DWG. NO. 1 Rev ma2 i A I 01027997 1 6 2.17 Gain Stability w Temperature Stay within 1.O dB (total) over &e operating temperature range and within 0.5 d8 (tototal) betwctn +25 to +50"C. Applies aftes20 minutes ""up. 2.18 Stability wrt Load VSWR The ampEer output shall be unconditionally stable up to 2: 1 VSWR output koading 2.19 RFOffhewrtDCOfftime User will switch "OFF"the i 1 S VDC power, vie solid state switch to ground, to inhibit RF output ofthe amplifier. RF output power level must decreaseby at least 30 dB within 2 5 micFoseconds after removal of i t 5 M>C power. Ifthis requirement cannot be met, vendor must quote cost ofbuilt-in P N switch $witch to be controlledby +15V signal. S8- fivm the switched +lSVDC, *lSvM: @ 1 W each is available to b i i the PIN switch. 3.0 - E R DC POWER 3.1 Power Input, for RF +IS VDC at 1.4A m a x NOTE: 15 VDC supplied to SSiPA may contain transients and noise. Vendor must furnish bdt- in protection and/or regvhrs to insure isolation and regulation. 4.1 Size %Fig. 1 4.2 RFConnectors Type SUA Female 4.3 DCConnector Molex 03-06-1023 %socket receptacleon twisted pair 4" flyins lead. Wi cheap wmcctor is readily available b m Digi-Key and other dishibutos.

1 I SPECIFICATDONS 'age code sheet Of 1 Class Size DWG.NO. Rev ma2 t A 01027997 6 5.0 ENVIRONMENTA& The ampiifier shall meet specified performmce under my combinationof environmental conditions, listed below. COWWON OPERATlONAI, NON-OPJ5RATIONAf, 5.1 Temperature, ambient -10"Cb+6O0C -20°C to 165°C 5.2 Altitude l0,Ooo feet 40,000 feet 5.3 Relative Humidity 95% non-condensing 95% mn-condensing 5.4 Shock, Vibration Benign TranspartatiOn 6.0 TesUlnformitionRcauhmenh Vendor will suppfy max brrseplate te.mper&re allowed. Vendor to supply a dimensioned drawing that also shows where. on the baseplate waste power is being dissipated and where the max baseplate temperatun is &m CPI win use this infomation to design a suitabIe heatsink. Vendor will supply a first article test report with supporting data for prototype quantity units to verify compliance to the following sactiOnS. These tests are intended to provide CPI with B level of confidence in the perfwmsnce and reliability of the product -Akl specifidma in Section 2.0 at +30°C. 2.7 and 2.8 should be tested at the power specified in 2.2, and at +25dBm as a minimum. -Ail spm~cationsin StCtiOa 3.0 inchtding a description of interrid protection fw transients and noise. -Section 5.1 -for operation, themttrics of performance will be sections 2.1,2.2,2.5, and 2.7. Once the unit has p ached theEmaI equiliirium at the t e m p e m extremes, testingmust fast 12 hours. Maximm baseplate temperaturedmhg the test should be reported. -Section 5.4 - either test tbe design, or ifthere is fidd histay, provide MTBF numbus in lieu of tests. zfenvimmnental stass screening or highlr ao~elwstedtife testing has been performed on tbis design to prove reliability, those test results should be submitted. i

Sheet Of Class Site DWG. NO. Rev SPECIFICATIONS ‘Ode 57982 A 01027997 6 For the production order, vendor will supply a test report for each unit with the folIowing parameters (actual data needs to be provided, a Pasflail checklist with no supporting data is not acceptable): 2.1 Frequency Passband 2.2 Power output at -1 dB Compr. 2.3 Third orda Intercept 2.4 NoiseFigure 2.5 Gain (atRated output) 2.6 Gain (Small Signal) 2.7 Gain Variation vs Freq. 2.8 Gain Slope vs Freq. 2.9 vswR,oatput 2.10 VSWInpUt 2.1 2 AE*4/pM Conversion 2.13 Spuriaus 2.14 Harmoaios 2.15 &up Delay (ripple across tlxe band) 3.1 DC cumntDraw 4315VDC

.. ..-....-. .... ......-.. I __ . _ ._..__.-, -. 1

WILKINSON BARKER) ) 2300 N STREET, NW SUITE 700 WASHINGTON, DC 20037 TEL 202.783.4141 FILED/ACCEPTED FAX 202.783.58 5 1 DEC 2 0 2007 www.wbk1aw.com PAULJ . SINDCRBRAND Federal Cornrnunicatioqs Commission pslnderbrand@wbklaw.com otflce of the Sedetary December 20,2007 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, SW Washington, DC 20554 Re: Requests Of XM Radio Inc. For 30 Day and I80 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 suflicient 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.

B A) R K E R )K N A U E R L L P WILKINSON MarIene H. Dortch December 20,2007 Page 2 The WCS Coalition appreciates that that any STA granted to Xh4 will require Xh4 to cure interference it causes to future WCS operations. However, the WCS Coalition is also painfully 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, whiIe 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 M e r 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 XMs proposed new repeater system. Should you have any questions regarding this submission, please contact the undersigned. - Paul J. Sinderbrand Counsel to the WCS Coalition cc: Stephen Dual1 (via email) Alyssa Roberts (via email) Shabnarn Javid (via email) James S. Blitz (via email) ' See, e.g. Letter fkom James S. Blitz, XM Vice hesident, Regulatory Counsel, et al. to Marlene H. Dortch, FCC Secretary, IB Docket No. 95-91, at 9-10 (filed Oct.19,2007).

. . . 1 W I L K I N S O N ) B A R KKENRA) U E RL L P 2300 N STREET, NW SUITE 700 WASHINGTON, DC 20037 TEL 202.783.4141 FAX 202.783.5851 www.wbk1aw.com PAULJ. SINDERBRAND psinderbrsndewbklaw.com January 8,2008 FILED/ACCEPTED Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, SW Washington, DC 20554 Re: Requests OfXM Radio Inc. For 60 Day and 180 Day Special Temporaly Authorizations Regarding Digital Audio Radio Service Terrestrial Repeater - File Nos. SAT-STA-20071214-00175 and SAT-STA- 20071219-00178 Dear Ms. Dortch: On December 20, 2007, I wrote on behalf of the WCS Coalition expressing concerns regarding the above-referenced requests by XM Radio Inc. (“XM”) for 60 day and 180 day special temporary authorization (“STAY’)to operate a new type of low-power Digital Audio Radio Service (“DARS”) terrestrial repeater in Vienna, VA. Last Friday, XM amended these applications to provide both additional information and new certifications regarding the manner in which this new repeater will operate. In light of this new information and the new certifications made by XM, the WCS Coalition hereby withdraws its opposition to XM’s request for STAs that will allow the installation of this single low-power repeater in Vienna, VA. Attachment 2 to XM’s amendments suggests that XM ultimately intends for repeaters of this sort to proliferate. This is neither the time nor the place to debate the rules and policies that should govern wider deployment of similar devices. It must be noted, however, that the WCS Coalition’s willingness to withdraw its opposition to the above-referenced applications is expressly premised on XM’s installation of just a single device at a single location that is known to the WCS Coalition in advance and that is under XM’s direct control. The WCS Coalition reserves the right to object should XM propose to deploy additional devices of this type.

\ WILKINSON ') B A R K E R ) K N A U E RI L L P I Marlene H. Dortch January 8,2008 Page 2 Should you have any questions regarding this submission, please contact the undersigned. Respecthlly s e i t t e d , c Pail 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)


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