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2008-02-28

This document pretains to SAT-STA-20080215-00047 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2008021500047_624063

                                                                                                                   Approved by OMB
                                                                                                                          3060-0678

Date & Time Filed: Feb 15 2008 6:46:02:296PM
File Number: SAT-STA-200802 15-00047
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 Inc. Request for STA to operate a repeater at a Chrysler Video Demonstration in Auburn Hills, MI (February 28
2008 to March 2 1,2008)
1. Applicant

           Name:        Sirius Satellite Radio Inc.      Phone Number:                     212-584-5100
          DBA Name:                                      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:    Mr. Patrick L. Donnelly




1


         Application of Sirius Satellite Radio Inc. for Special Temporary Authority
                          IBFS File No. SAT-STA-20080215-00047

Special temporary authority (STA) IS GRANTED to Sirius Satellite Radio Inc. (Sirius) to
operate a terrestrial repeater with an Effective Isotropically Radiated Power (EIRP) of up to 200
watts (average) at the Chrysler headquarters in Auburn Hills, MI, during the period of February
28, 2007, through March 21, 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 the applicant’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. 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 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’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 1.13 10 of the Commission’s rules;

5. The terrestrial repeater shall comply with Part 17 of the Commission’s rules - Construction,
   Marking, and Lighting of Antenna Structures;

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

7. Sirius will maintain full ownership and operational control of the terrestrial repeater;

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

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.


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:
                              36 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
2pplication. 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).
Q       Governmental Entity      Q   Noncommercial educational licensee
Q       Otherblease explain):

lb. Fee Classification CXW - Space Station (Non-Geostationary)
                                                                                      ~




5. Type Request

    Q   Change Station Location                       Q     Extend Expiration Date                        Other


3. Temporary Orbit Location                                                    7. 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 at a Chrysler Video Demonstration in Auburn Hills, MI from February 28, 2 0 0 8 to
       March 2 1 , 2 0 0 8 .




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(b) for the meaning of "party to the application" for these purposes.


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


    Attachment 1: Exhibits                         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 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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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


                                           Attachment

        Sirius Satellite Radio Inc. (“Sirius”), pursuant to 47 C.F.R. $ 25.120,’ hereby requests
Special Temporary Authority (“STA”) to operate in its licensed frequency band (2320-2332.5
MHz) a low-power satellite DARS repeater with an Effective Isotropically Radiated Power
(“EIRP”) of 200 watts.2 The low-power repeater will be utilized at a Chrysler Video
Demonstration in Auburn Hills, MI. Because the date of this event is uncertain, Sirius requests
STA from February 28,2008 to March 21, 2008; however, Sirius will only operate the repeater
for three days (two days for set-up and testing activities and one day for the demonstration).
Sirius intends to operate the repeater independently - Le., Sirius will not operate it in conjunction
with XM Radio, Inc., the other satellite DARS licensee.

         The repeater will be used by Sirius to carry out equipment and service demonstrations at
an event for Chrysler executives at Chrysler’s Corporate Headquarters in Auburn Hills. Due to
blockage from walls and ceilings, it is often difficult to provide quality reception of SDARS
satellite and even terrestrial signals inside of certain venues, such as Chrysler’s Corporate
Headquarters, which often do not have line-of-sight views to receive Sirius’ signal. These
difficulties with providing coverage inside the venues require equipment to be displayed with
hard wire connections, which limits the locations within a venue that Sirius can set up its
displays, creating difficulties for organizers and Sirius. This demonstration will enable
Chrysler’s representatives to experience the full benefits of SDARS, particularly Sirius’ Backseat
TV service. 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 a list of technical parameters, including the
location and dates for the 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 venue); (4) market; (5) antenna type; (6) antenna beamwidth; (7)
total EIRP; and (8) approximate maximum height Above Ground Level (AGL). Exhibit B
provides an RF exposure analysis for the repeater and demonstrates that any human
radiofrequency exposure that might occur is well below acceptable limits.

Interference Considerations. Sirius does not anticipate that the repeater at this demonstration
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

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. $ 25.120(b)(4).
2
       To the extent this application is opposed, Sirius hereby requests that this proceeding be
designated “permit-but-disclose” for purposes of the Commission’s rules governing ex parte
communications. 47 C.F.R. $ § l.l200(a) and 1.1206.
3
     47 C.F.R. 5 25.202(a)(6) (stating the 2320-2345 MHz band is allocated exclusively for
SDARS).


Ms. Marlene H. Dortch
February 15,2008
Page 2

interference with their services. In addition, the repeater will only be used for a limited time,
fbrther eliminating any opportunity for interference. Therefore, Sirius does not anticipate that
the repeater will cause blanketing interference to any WCS receivers.

Ownership and Control of Repeaters. Sirius will own the repeater installed at the venue and will
retain full operational control of the repeater. Sirius will also be responsible for installation of
the repeater.

Public Interest Considerations. Prompt grant of this STA will promote the continued success of
satellite radio and serve the public interest. Sirius plans to demonstrate its services in order to
better inform Chrysler executives of available equipment and services. In particular, Sirius will
demonstrate its Backseat TV service, which is being offered in certain 2008 Chrysler vehicles.
Without the repeater to overcome signal blockage within the venues, however, Sirius cannot
undertake real-time demonstrations of its equipment, especially demonstrations of the fbll
mobility of SDARS service. This repeater will help 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 the repeaters under the 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 until such interference can be eliminated.

CertiJications. Sirius acknowledges that the conditions imposed in the 200 1 Order granting
Sirius’ request for STA to operate terrestrial repeaters4 will continue to apply to any repeaters
authorized as a result of this application. Specifically, Sirius certifies the following:

(1)   Sirius will operate the repeater at its own risk, and such operation shall not prejudice the
outcome of the final rules adopted by the Commission in IB Docket 95-9 1;

(2)    Sirius will operate the repeater on a non-interference basis with respect to all permanently
authorized radiocommunication facilities;

(3)    The repeater 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 repeater 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 repeater will comply with Part 17 of the Commission’s rules - Construction,
Marking, and Lighting of Antenna Structures;


4
        Sirius Satellite Radio Znc. Application for Special Temporary Authority to Operate
Satellite Digital Audio Radio Service Complementary Terrestrial Repeaters, Order and
Authorization, File No. SAT-STA-200 10724-00064, DA 0 1-2171 (Sept. 17,200 1).


Ms. Marlene H. Dortch
February 15,2008
Page 3

(6)    The repeater 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;

(7)     The out-of-band emissions of the repeater will be limited to 75+log (EIRP) dB less than
the transmitter EIRP;

(8)     Sirius will operate the repeater according to the technical parameters provided in this
application;

(9)    Sirius will maintain full ownership and operational control of each repeater; and

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


                                                                                                                  SIRIUS SATELLITE RADIO INC.
                                                                                                                           EXHIBIT A




                                                                                                                                                                                         Sector1                           Coordinates
           Event                      Event Dates               Market                   Location                         No Of Setors              Antenna Type         Antenpa    Orientation Downtilt   EiRP    Longitude (W) Latitude (N)   Antenna Height (feet)
                                                                                                                                                                        Beamwidth                          Watts

Chrysier Video Demonstration February 28 — March 21, 2008   Aubum Hitls, mt CNYS!er LLC World Headquarters 800
                                                                               Chrysler Drive, Auburn Hills, MI
                                                                                                                               1                Mobile Mark ©D12—2400     Omni          0          0       200      831347.8      42—39—14.8             25


EXHIBIT B


                                RF Exposure Analysis

                         Chrysler Video Demonstration
                       Chrysler LLC World Headquarters
                               Auburn Hills, MI


This technical addendum is to support the STA request for the Chrysler Video
Demonstration. This event is being held at the Chrysler Headquarters in Auburn Hills,
MI. A low-power transmitter will be used to provide coverage at the event.

1. RF Exposure Analysis for Low-Power Transmitter

The transmitter set up for the demonstration is illustrated in the figures below:




                                                     Q
                                                        / ::Etenna
                                                               telescoping
                                                               aerial




           Roof of multi level parking deck




Figure 1. Diagram of transmitter setup




                                    Sirius Satellite Radio                              2


Figure 2. TX Antenna setup


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 mounted 25 feet above the roof 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
      18 feet was chosen as the minimum distance criteria for exposure by taking the
      height of the antenna (25 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 an individual could approach this repeater antenna. Table 2
      summarizes the results of the normal calculation (using the formula Power
      Density=EIRP/(4*ll*RA2) from OET 65) and also a more conservative formula
      which takes into account reflection (the formula PD= 2.56*EIRP/(4*II*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).




                                  Sirius Satellite Radio                                3


   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 18 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 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




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
l/lOOOth 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)
       Power Density adjusted for reflection = 2.56"Power Density (Equation 7, page 21
       of OET 65)




                                  Sirius Satellite Radio                                4


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
           Distance  (Average)          (Peak)
        from Antenna mW/square
      I
            (Feet)       cm
                      0.05458
                      0.03343          0.15043              0.38510        2.59672
                      0.02256          0.10 150             0.25984        3.84845
                      0.01624          0.07307              0.18707        5.34562
              38      0.01225          0.05511              0.14108        7.08822
              43      0.00956
              48      0.00768
              53      0.00630          0.02833              0.07252        13.78865
              58      0.00526
              63      0.00446          0.02005       I      0.05133    I   19.48278
              68      0.00382
              73      0.00332
              78      0.00291          0.01308              0.03348        29 36477
              83      0.00257
                      0.00228
                      0.00204
                      0.OO 184
              103     0.00167          0.00750              0.01920        52.07681


                        0.00127        0.00572              0.01463        68.34928
                                       0.00526              0.01347        74.2643 1
                        0.00 108       0.00486              0.01243        80.42477
                        0.00 100       0.00450              0.01 152       86.83068
                        0.00093        0.00418       I      0.01070    1   93.48202
            143         0.00086        0.00389              0.00996        100.37879
                        0.00081        0.00363              0.00930        107.52101
      I     153     I   0.00076        0.00340              0.00870        114.90866




                                   Sirius Satellite Radio                                5



Document Created: 2008-02-28 14:34:08
Document Modified: 2008-02-28 14:34:08

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