Attachment grant

grant

DECISION submitted by IB,FCC

grant

2009-03-17

This document pretains to SAT-STA-20081205-00222 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2008120500222_700688

                                            FEDERAL COMMUNICATIONS COMMISSION
                                  APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                          FOR OFFICIAL USE ONLY
I                                                                                                                         I

  APPLICANT INFORMATION
Enter a description of this application to identify it on the main menu:
Request for Special Temporary Authority to Operate Very Low Power Repeaters and Signal Boosters at Indefinite Locations
    1. Applicant

               Name:        Sirius XM Radio Inc.             Phone Number:             2 12-584-5 100
               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:   Patrick L. Donnelly


            Application of Sirius XM Radio Inc. for Special Temporary Authority
                         IBFS File No. SAT-STA-20081205-00222

Sirius XM Radio Inc. (Sirius XM) is granted special temporary authority (STA) for a period of 180 days
to operate indoor terrestrial repeaters with an effectively isotropically radiated power (EIRP) (average) of
(1) up to 10 watts and (2) up to 0.0001 watts at trade shows and other indoor locations, such as
automobile industry promotional events, press and marketing events, and investor relations events. This
authorization is subject to the Commission's rules, the operational and technical parameters specified in
Sirius XM's application, and 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. 95-9 1;

2. Operation of the terrestrial repeaters is authorized pursuant to this STA on a non-interference basis
   with respect to all permanently authorized radiocommunication facilities;

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. Where applicable, coordination of the operations of the terrestrial repeaters shall be completed with
   all affected Administrations prior to operation, in accordance with all applicable international
   agreements including those with Canada and Mexico;

5. 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, 47 C.F.R. €j  €j l.l307(b) and 1.1310;

6. The out-of-band emissions of the terrestrial repeaters shall be limited to 75+10log(EIRP) dB less than
   the transmitter EIRP;

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

8. Sirius XM 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;

9. Sirius XM 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.

10. This action is taken on delegated authority pursuant to 47 C.F.R. 5 0.261 and is effective upon
    release. Petitions for reconsideration under 47 C.F.R. €j 1.106 or applications for review under 47
    C.F.R. 5 1.115 may be filed within 30 days of the date of the Public Notice announcing this action.


r

    2. Contact

                 Name:        James S. Blitz                        Phone Number:                        202-380-4000
                 Company:     Sirius XM Radio Inc.                 Fax Number:                           202-380-498 1
                 Street:      1500 Eckington Place NE              E-Mail:                               j ames.blitz@xmradio.corn


                 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
    application. Please enter only one.)
      3. Reference File Number or Submission ID
       4a. Is a fee submitted with this application?
    (Bs) 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      0 Noncommercial educational licensee
    Q   Other(p1ease explain):

I4b. Fee Classification CXW - Space Station (Non-Geostationary)




    6. 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 XM Radio Inc. (Sirius) requests Special Temporary Authority to operate very low
       power terrestrial repeaters (less than 10 watts EIRP) and signal boosters (less than
       0.0001 watts EIRP) at indefinite locations for one hundred eighty 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   e Yes           0 No
to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti-Drug Act of 1988,
2 1 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
James S. Blitz                                                             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 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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4


SIRIUS XM


                                            December S , 2008

Via fBFS
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street. S.W.
Washingtoti, D.C,205.54

        Ke:     Sirius XM Radio Inc.
                Request for 1SO-Day Special Temporary Authority to Operate
                Very Low Power Repeaters and Signal Boosters at Indefinite Locations

near M s . Ilortch:

Pursuant to Section 25. I20(b)(3) of the Commission's rules, 47 C.F .R. $ 25. I20( b)(21, Sirius XM
Radio Inc. ("Sirius XM"), a satellite radio licensee in the Satellite Digital Audio Radio Service,
hereby requests 18O-Day Special 7'emporary Authority ("S'TA") to operate in its licctiscd frequency
band ( i ) very low power terrestrial repeaters with an Eflective Isotropicdly Radiakd fJcwer
(+*EfKP")o f up to 10 watts and (ii) signal boosters with an EIRP of up to 0.0001 watts that have
prcviousl? heen approved for usc in retail storcs and other indoor locations. 'I his npplicalion seeks
autlwritj-to operate these very low power repeatcrs and sigiial boosters in connection with both thc
Sirius tiequency band (2320-2332.5 M H r ) and the XM Radio Inc. (-'XM"') frequency band (2332.5-
2245 ~ I H L ) . ' Sirius XM expects to optr'ratu t l w x very low power repcaters arid sigtial boosters at
e w i i t ~i i r \.xim.isvenues, at locations and on h e s that cannot yet be identified, liir a period of 180
days alter grant of this request?


Ms. Marlene ki. Dortch
December 5,2008
Page 2


The International Bureau previously grantcd a 1 SO-day S?A requcst filed by Sirius Satellite Radio
Inc3 (“‘Sirius”) to operate very low power repeaters and signal baosters at various temporary
automobile industry promotional events, press and marketing events, investor relations events?and
trade shows at specified locations and dates.‘ The only difference between that application and thc
instant request i.; that iw specific locations art: identified herein. The Bureau has previously given
XM authority to operate very low power repeaters and signal boosters at similar events and shows
at indefinite locations rind dates.‘

The Wireless Communications Services Coalition (“WCSCoalition”) has stated that it has no
objection to the operation of repeaters mid boosters at trade shows provided that operatiails arc
temporary in nature, operations are at low power levels, the satellite radio licensee cornnits to
operate the repeaters and boosters on a non-interference basis, and the satellite radio Iicensee
acknowledges that construction of these facilities is at its own risk?’ At discussed herein, Sirius Xh4
satisfies all of these conditions.

The Commission has recognized that sate1lite radio operators require tcrrcstrial rcpeaters to providc
high-quality service natiunwide.’ Consistent with this policy, in September 200 1, the Bureau
granted Sirius XM temporary authority to operate a nationwide network of terrestrial repeaters?




    operating by January 13, 2009. In the event that the Cotnmissiotz cannot grant the instant STA
    by January 13, 2009. Sirius XM may need to file a similar application for a 30-day Sl’A prior to
    that date.
    Sirius is the predecessor to Sirius XM. prior to the merger with XM.
    See Sirius Satellite Jliadio Inc., File No.                           (granted August 13. 2008).
                                                   SA’T-STA-20C)805li0-00117
                                (granted May I 7. 2007 )( tfic ”XM 2007 Trade Show S l ’ h ” ) .
    See SAT-S-iA-3oo7(~232-OC)01;6
    See Letter from Paul Sinderbrand, C’ounscl for the N’C‘S Coalition. to John Giusti, Acting C‘hiel,
    International t3urcriu, FCC, File No. SAT-STA-2006 12 1 1-00147; SAT-S’I’A-2006121 I-00 138
    (December 14- 2006 ).
                          of Ridcs uund Polkies.fiir thi. I)igircr/ - I d i o R d i o IYtitellite service^ in /tic#
    SLV ~:f’i~ihlishr~iL’rli
    23 10-2360 M i k Frr~qricrncy~  Bund%Report ~ i n dO d w . 1Zknznmmlum Opkiati irritl O r - i k i . . c r r i d
    F24rrher. ,Votici>of I’ropo.wJ RuImrjking. 12 FCC Rcd 5754, 5770 11 -37 (1 997).
    See Sirius Satcllitc ! < a J t c ~Inc., Application for Special ‘I emporary Authority to Opcratc
    Satellite Digital ;\ucfii\ R d i o Service Complimentary T’el-rcstrial Repeaters, Order aiid
    Authorization. 10 I X C ’ ICcd. 16773,B 18 (2001) (’Sirius S 1’A(.)rder‘*);XM Radio, Inc.,
    Application tiir Special ‘T ernporary Authority to Operate Satcll itt. Digital Audio Radio Scr\ icc
    CoinpIimentarj ‘I t’ricstrial Repeaters. Order arid Aiithori~Lition.     16 FCC‘ Rcd. 1678 1. (1 18
    (2001) (“XMSTt\ Order**).


Ms. Marlene 1-1. Dortch
December 5,2008
Page 3


The Bureau has subsequently granted Sirius XM additional S'TAs to operate terrestrial repeaters.
pending issuance of final rules governing the deployment and use of repeaters,'

         Rrques,!-fizrSTA. Sirius XM will use the very low power repeaters and signal boosters for
which it seeks authority to operate hercin to demonstrate equipment and service at temporary evcnts
in various venues across the United States, such as automobile industry promotional events. press
and marketing events, investor relations events, and trade shows. In many cases, Sirius XM expects
that it will. not know the locations and dates o f the events covered by this S'I'A with sufficient lead
time to prepare individual S'I'A requests and obtain authorization without expcditcd processing by
the Cornmission 'I'he objective of this w q i w f is to simplify t l x administrative process fiir
supporting these events for the Commission and Sirius XM. Accordingly, Sirius XM herein
requests STA to operate the very low powcr repeaters and signal boosters at indefinite locations.
The operation of w r y 10% power repeaters and signal boosters at each event will not excced a
period of 10 consecutive days (including operation prior to the official start of each event for set-up
and testing activities) except for automotive industry trade shows wherc the repeaters could be in
operation up to 20 consecutive days. Sirius XM expects to operate very low powcr rcpcaters and
signal boosters pursuant to this S'f'A at no more than 10 events in any consecutive 30 day period.

         Due to blockage from walls, ceilings, and other structures, it is often difficult to providc
quality reception o f SDAKS satellite and even terrestrial signals at certain venues. which may not
have tine-of-sight views to receive Sirius XM's signal. The difficulties with providing coverage at
certain venues require radios to be diq-da) uci with hard wire connections. which limits the locations
within a venue at which Sirius XM can sct up its displays. thcrcby creating difficulties for event
organizers as well as for Sirius XM. Hecause some venues consist o f a large, oftcn multi-lcvei
space. Sirius Xbl anticipates using one or niore (but no more than six) very low power rcpcaters at
cach cvcnt. Depending on the ventic Sirius XM may also use one or more (hit. iio tnorc than three)
strategically placed signal boosters. The optimal number of very Iow power repeaters and signal
boosters will be chosen to cnsiirc full coverage of each event. Accordingly, grant of this STA to
iisc ttiesc very low power repeaters ;imf signal boosters for the limited periodh recliiested hcrcin will
serve the public interest.
__._I             _   _   I   _   ~   -   l   -   _   l   _   _   I   _   _   _   _




Q
    S w , e.g. Sirius StJtellitc Radio IHC. Kc yrrcst f a ;tirdifj, Specid ~ k r n p n i r y,-I
              I                                                                       I      ~rr fhoviiy io C)J)crciic
    '-1 dditiotml Satellite Digital .4 udio R d o Serr*ic.eTerresfrial Reputc.cv. O d c r rriid
                             ~ , FCC Rcd. 18140 (2003)(granting Sirius an S'I'A in Fife No. SAT-STA-
    . . I z h w i z ~ i t i o19
    2003 1 106-00370, effective Sept. 1 5. 2004. Since that time, thc Comnnission has extended the
    STA several times. pending the issuitlice of final rules governing the use of satcllite DARS
    terrestrial repeaters. I n September 2U04 the Cornmission granted Sirius a iiew S'I'A to operate
    for 180 days or until the Commission issues f'ind rules governing the tise ot'satellite DAKS
    tcrrcstrial repeaters. See Siriirs % / d hRcrtlio    ~         iiw.Reytirsi lo ,hioclifi+S ) c ~ i c ~Tt,~mporiwy
                                                                                                           l
    - 1 i d w i t y io Opercrie ScJ!vIJiic> I XS 7 i J i w . y t r i dRepeuhxs. O?-dwum/ ,-I i i / / i w i x ~ i o i i I, 9 FCX
    Rcci 18149 (2004). Sirius timel tiled an application for renewal o f this ST,\ 011 March 1, 2005.
    SLY File No. SAT-STA-2005030 1 -O(N~53a'1'0 date, the Commission has n o t acied on this
    a p p 1ic ation.


Ms.Marlene 13. Dortch
December 5,2008
Page 4



        Technical lnjormufionjbr' b'e~?Low Power Repeaiers. Enclosed as Exhibit A is the
following technical infbrmntion pertaining to the very low power repeaters: ( I ) antenna type; (2)
antenna beamwidth; (3j total EIRP; (4) approximate maximum height ACL; and (5) antcnna
specification sheets.

        Technical h$brinurion-JiwSignal Boosters. Enclosed as Exhibit R are the technical
parameters for the signal boosters, which are identical to the parameters previously approved by the
Bureau for use in retail stores and other indoor locations.io Specifically. Sirius XM has included
the following information for these signal boosters: ( 1 ) antenna type; (2) antcnna hcam\vidth: (3)
total ETRP; and (4) approximate maximum height A G L

        T'echnicul hfi~rzution011 E1WE conipliunce. Enclosed is Exhibit C showing compliance
with Part 1 of the Commission's rules. Subpart I - Procedures linplenicnting the National
Environmental Policy Act of 1969, including the guidelines for human exposure to radio Crequency
electromagnetic fields in Sections I. 1307(b) and 1.13 I O of the Commission's Rules. This analysis
uses worst case conliguration parameters for Very 1,ow Power Repeaters and Signal Boosters and is
valid for all deployments under this STA.

        1,ocr;rtionhfill-mution. Given that the locations and dates o f the events at which Sirius XM
will operate very low power repeaters and signal boosters pursuant to this STA arc oftcn riot known
until shortly before the event takes places, it is impractical for Sirius XM to provide precise location
information in this application. Accordingly, to the extent necessary. Sirius XM herein requests
waiver under Section 1.3 ofthe Rules, 47 C.F.R. 1.3, ofthe requirement that it provide "full
particulars of thc proposed operation'' with this application for STA.' Moreover, given that the
locations and d'ttes ofthe events will not bc known until shortly k h r e an event takes placos. it
would be impractical and wastefiii of the Commission's resources for Sirius XM tcr seek authority
every time it proposed to operate very low power repeaters and signal boosters at a new venw.
Sirius XM notcs thtit the Bureau did not require Iocatir~nsand dates ofoperation for ttic C O I W in-
store signal hoostcrs that XM and Sirius were authorized t o operate in June 200.5.'' the 5000
                ---.-I
                     I_    ---
                         _-_-
*') See XM Radio Itrc., Request for Special Temporarj Authority, File No. SA-I'-STA-200?0409)-

    00076 (grantcd June 23, 2003) ("lrt,Z.ISigmtl R n o . s / c SIX*).
                                                                ~    Exhibit C of'that applieatioii.
    provided an intcrf'ercnceanalysis for the signal buostcrs that are the subject of this npplicatioii.
    Sirius XM incorporates this interference anal) si3 t 7 ~refkrence. On June 5, 2003. Xbf further
    supplemcntcd the application with a sample link budget for the signal boosters. ,Set. Letter from
    1,011 C. Ixvin. SM.to Marlene H. Dotzch, Sccretarq'.E'('(:, File No. SA'l'-S'I'A-200;0.I~)~-~007~
    (filed June 5 . 2003). The link budgct is also incorporated by reference herein. S w d v t l XM
    Radio Jnc.. Filu Yo. SA1'-S'i'A-20050712-00 145 (granted January 18, 2007) ("Indoor thoster
    S'I'A").
'I   37 C.F.R. 21. I30(:1).


Ms. Marlene €1. Dortch
December 5, 2008
Page 5


additionai such in-store boosters the two companies were authorized to operate in January 2007,'3
or the 5000 indoor boosters that XM was authorized to operate in January 2007.'4

        Intet-firence Considerutions.The very low power repeaters and signai boosters have a very
low probability of interference to other radio services. Because Sirius Xh;l has csclusivc use of its
iicerised frequency band." there is no potential for in-band interference. In addition, the very low
power repeaters will opcratc at a maximum EiIKP of 10 watts within tho center 4 to 5 hil€Izof each
of Sirius XM's individuaily licensed 12.5 MHz frequency bands. well below the threshold EIRP o f
2000 watts identified by the adjacent WCS licensees as a potential mterf'erencc concern. I'hc
adjacent-band WCS licensees are permitted to operate base stations at a power lcvcl of 2000 watts
EIRP and therefore must bc able to withstand potential interference from such operations. With
respect to the signal boosters, Sirius XM has previously demonstrated that these signal boosters will
                                                                 '
riot cause ad-jacent band interference to WCS operations.* There has also been no documented
interference since Sirius XM began using these same signal boosters and very low power repcaters
to support similar events and venues. Accordingly. Sirius XM does not anticipate that these very
low power repeaters and signal boasters will cause interference to any WCS receivcrs.

        This facility for which authority is requested herein will operate at a power level well under
2.0 kilowatts, which is below the threshold identified by the 7tt'CS Coalition as a potential
interference concern." Accordingly, Sirius XM does not anticipate that operation of the ncw


   See XM Radio Inc., File No. SAT-STA-~0030409-00076(granted June 26,2003); Sirius
   Satellite Radio Inc., File No. SAT-STA-200304 1 1-000'75 (granted June 26- 2003 ).
   See XM Radio Inc.. File No. SA C'-STA-20020601-00113 (granted January 18, 2007); Sirius
   Satellite Radio Inc., File No. S~\-I'-S?A-200506Ol-OOI
                                                        14 (granted January i 8. 2007).
   See indoor Booster STA.
    47 CI.F;.R. fj 25.202(a)(6) (thc 320-2345 MHz band is allocated csclusivcly for SI>ARS).
   Set. srtp-u note 3: see LIISCI ,\W Ktrdio. Iw.. Applicu/iorrjbr S ~ m ~ irli.tnpot+c.rt:t
                                                                             ul             Airfhority t o
   Operate Sutelhk Digital '4 titr4jo Rndio Service ('omplimentcri:r*'ii.r.r.c~t.icrlRt-peaters, Order ~ n d
   Airfhorisafion,DA 01-2172, at ?! 12 ( r d . September 17, 200 I (-',\7! Rtrcfic, STA Order.") (,*'The
   comments from WCS I icensecs c:spress concern about blanketi tiy interference from DARS
   repeaters that operate with an Equivalent Isotropicalty Radiated h c i cr (EIRY) above 2 kW").
    .LU&YignalBnosttcr STA at LJshibit C.
    Siriirs ,ST4 C1r.cr'c.r. fi 1 2 ( T h e commonts from UT'S Xiccnsees express concern about bianketing
    interference from DARS rcpxtcrs that opcratt with an Equivalent f sotropically Radiated Power
    (EIRP) abovc 2 kW."). The \!'(.-'h ('oaiition has said that it nd6 ciclft'r lroni objccting t o S'1A
    requests that propose operaticm of no more than 2.000 watts EIKI'. cwn ifthey do net specify
    peak or average ERE3, providd that grant of the STA (i) is conditioned on operation on a non-
    interference basis: and (ii 1 is d ? j c c t to the conditicrn that the i s s w ut' pcnh vcrsiis avcrage EIKP
    will he addressed in tkc pending LIARS rulernakitig (IB Docket No. W-91). .See Lettcr froxii


Ms. Marlene I-€. Dortch
Ikccmber 5,2008
Page 6


repeater will cause m y interference to WCS operators or any other entity. To the extent Sirius'
original 200 1 S?'A requires it to coordinate with affected Wireless Communications Scrvices
("WCS",>licensees prior to operating any repeatcr,j9 the Bureau also stated that it expected "WCS
licensees to provide a schcdulc or as much advmw notice as possible of when their stations are to
he placcd in operation." Id. 'To date, Sirius XM has not received infomiation from ;i~iyWC'S
licensee regarding their plans for WOS deployrncnt. llowcver, in the event that prohibited
interference does occur. Sirius will cease operation of this facility until any such interference can be
eliminated. Sirius XM's Kcpeater Control Center (2O2-529-7Q 12) is available on a continuous
basis to receive such reports of any suspected interference and take immediate corrective action.

       Chvnership and Confi-olqf k y Low Power Repeaters nnd Sipal Bonsfet=c. Sirius XM will
own each very low power repeater and signal booster operated at a given venue and will retain full
operational control of each very low power repeater and signal boostcr. Sirius XM will also be
responsible for installation of each very low power repeater and signal booster.

         Public hteresf C7onsi&rations. Prompt grant o f this STA will promote the continued
success of satellite radio and thereby serve the public interest. The demand for SDAKS radios by
the pubtic has continued to increase over time. Accordingly, Sirius XM participates in events at
various venues where it provides demonstrations of its equipment and service, such as automobile
industry promotional events, press and marketing events, investor relations events, and trade shows.
Grant of-this STA w7ill serve the public intcrest because the very low power repeaters and signal
boosters will allow for adequate reception of Sirius Xhil's satellite radio service at venues where
satellite radio signals may be attenuated due to blockagc from tvalls, ceilings, or other structures.
Without these very low power repeaters and signal boosters to overcome signal blockage within the
venues, however, Sirius XM cannot undertake real-time demonstrations of its equipment and
service. especiailj demonstrations of the full mobility of WARS service. These ver) low pc-iwcr
repeaters and signal boosters will provide clear signal reception within these venues for these
dcrnanstrat i ons.

          The need to provide high-quality satellite radio service for our business pat-tncrs. equipment
suppliers. potential customers. and others at these vei~ut'sprovides the extraordinar) circumstances
justif>.ingthis SrrArequest.") As the Bureau rccognizcd when it granted the origirial Sirius ST'A in
2001, this terrestrial repcater network enables Sirius XLMto provide "high quality radio signals to
 iistetiers iii at-cilsthat have limited radio service." continuous radio coverage for i n d i k iciuals o n


Ms. Marlerie If, Dortch
December 5,2008
Page 7


long-distance trips, and "[d Jiverse program formats, including educational, ethnic and religious
programming.''2

           C,'ertlficafions. Sirius .XM acknowledges that the conditions imposed in the Siriirs Rcrdio S I 4
I1rtl't)r granting Sirius-s request for STA to operate terrestrial rcpenters wit1 continue to apply to any
repeaters authori;rxd as a result of this application. Specifically, Sirius certifies tho following:

        (1) Sirius X M will operate the very low power repeaters and sigrml boosters at its own risk,
        and such operation shall not prejudice the outcome ofthe h a 1 rules adopted by the
        Commission in G E N Docket 95-91;

        (2) Sirius XM will operate the very law power repeaters and signal boosters on a non-
        interference basis with respect to all permanently authorized radiocommunication facilities:

        (3) The very l o u r power repeaters and signal boosters will be restricted to the simultaneous
        rctrarismission of the complete programming. and only that programming, transmitted by
        the satellite directly to SDARS reccivcrs:

        (4) vtrherc applicable, coordination of the very low power repeaters and 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:

        ( 5 ) The very Imv power repeaters and signal boosters will comply with Part I 7 of the
        Commission's rulcs -- Construction, Marking. and Lighting of Antcnna Structures:

        (6) The very \OM. p o w t repeaters and signa! boosters \ d l comply with Part 1 of the
        Commission's riiIc5. Subpart I - Procedures Implement Ing the National Environmental
        Policy Act of 1909, i ticluding the guidelines for Iiuman exposure to radio frequency
        electromagnetic fields as defined in Sections I . 1307(h ) atid 1.13 10 of the Conmission's
        rules;

        (7) 'The out-oF--h;ind ettiissions of the very low p w c r rc'pcatcrs and signal boosters will be
        limited to 7S+1 Olog (IWW) dB less than the transmitter FTlW;

        (8) Sirius XM tvill tipcrate the very ltow power repeaters and signal boosters according to the
        technical parameters provided in this application:

        (9) Sirius X,M will maintain full ownership and opcrationat ccnntrol of each very low pokver
        repeater and signd hwster; rind


h4s. Marlene [I. Dorteh
December 5,2008
Page 8


         ( 1 0 ) Sirius XM will immediately shut down any very low power repeater and any signal
         boaster upon a complaint of interference, upon direction from the Commission, or upon
         finding that a very low power repeater or signal booster has not becn propcrly installed.

Granting this request will not alter Sirius XU'Sobligation to protect authorized
radiocommunications facilities from interference. nor will it pre.j udice the outcome o F the
Commission's ongoing rulemaking pertaining to the deployment and operation of terrestrid
repeaters.

Sirius XM hcreby certifies that no party to this application is subject to a denial of'Federa1 henetits
pursuant to Section 5301 o f tho Anti-5rug Abuse Act of 1988, 21 IJ.S.CI. $ 85.3(+

In connection with this application, Sirius XM is submitting payment to the Federal
Communications Commission in the amount of Two Thousand SWCRHundred Twenty-Five
Dollars { $2725.OO) -- the filing fee applicable to requests for S'T'Asfor non-geostationary
("Nc~so")satellites.22

Please direct any questions regarding this matter to the undersigned.


                                                 very truly yours.




                                                  :ice Preside&, Regulatory Counsel

cc:      Stephen Duail, F'CC                 d




           -   .. _.


      Stv Internationaf and Satellite Senices bee Filing Guide (October 2006).


                                           Exhibit A

                      Technical Parameters for Trade Show Repeaters

Below is the fbllocving technical information for the trade show repeaters:

       (1 ) antenna type:
       (2) antenna beamwidth;
       ( 3 ) total ETKP; and
       (4) approximate height Above Ground Level (AGL)
       (,5)antenna specification sheets


                                                                                    OD Series Omni Antenna
                                                                                For WLAN, Video and Data Systems
                                                                                     3 dBi, 6 dBi, 9 dBi & 12 dE3i antennas
                                                                                     provide uniform omni coverage

                                                                                R
                                                                                !    Unique design allows economical build out

                                                                                     Mounting kit includes all hardware needed

                                                                                I Reflector option provides directional
                                                                                     beamshaping & increased performance


The OD Series Antennas are optimized for use in a wide                              female N connector. Optional models include pigtail cable
variety of wireless systems. Typical uses include WLAN                              with connector, For ISM, Part 15 compliant connectors are
access points or bridge (802.-lIblg), and surveillance                              available (reverse polarized), please consult factory.
transmitters.

These antennas consist of a collinear array with elements                            Model Numbers
stacked vertically. Unique phasing cancels out-of-phase                              Man!!-&!! E-WS.ME&J          E&!! 4-ati-Qm
current distribution, improving system performance. This                             003-2400      2400-2485      3 dBi    WMN, ISM, Video
design maintains an omni pattern in the horizontal plane.                            006-2400      2400-2485      6 dBi    WlAN. ISM, Video
The OD Series are free space antennas; no ground plane                               OD9-2400             9 dE3i
                                                                                                   2400-2485               WLAN. ISM, Video
is required.                                                                         0012-2400 2400-2485 12 dE3i           WUN, ISM, Vidao

An option for the OD series is a reflector kit that beam                             For pigtail cable options arid special frequencies, pleass
shapes the omni pattern into a directional cardioid shape.                           consult factory fwr latsst model numbers and
This can result in improved directional gain, and isolation                          configurations.
for reduced interference.
                                                                                     QatiQ-Q-s                         Madel
The low profile black radome (1" diameter) makes the                                 Add-on kit for 6 dBi models       QDR6-Kit
antennas durable and rugged. They can withstand the                                  Add-on kit for 9 dBi models       ODRS-KI1
harshest environments of snow, wind, rain and ice. The                               Add-on kit fur 12 dBi models      ODR?2-Kit
feed assembly is made of precision machined aluminum                                 Rev TNC with 9 ft Csblo option    add -PTA to OD rnadei
components and IS trridited for weather protection. The                              Rev BNC with 4 fl. Cable option   add -PT2 to OD t ~ ~ d e l
antennas comes with all the hardware needed to install it
to a mast. The OD antennas normally terminate with a

  Specifications
  Frequency & Gain:                                See above                          LengthWeight:
  Bandwidth @2:1 VSWR:                             see above                               3 dSi Models    16 inches, 1 5 t,.;
  Nominal Impedance:                               50 o#?Fns                               6 dBi Models    39 Inches, I .5 ftrs
  Max. Power (continuous):                         tu0 watts                               9 dBi Models    27 rnches, 2.0 tbs
  VePalcalBeamwidth (-3dSpoint):                                                         3 2 dBi Model     41 ~nches,2.5 tbs
            3 dBi M&el                             55 degrees                         OD Series Interface: N female connector
            6 dSi Mode0                            25 degrees                         Mounting Kit:        Mast mount kit incitrded
            9 dSi Mobel                            t 4 degrees                        Mounting Dimensions: Use mast up to 2'' 30
     12 d8i Madel                                   7 degrr;e,s                       Material:            Polycarbnate with Li/urnrnum
  Wind loading (flat plate equiv.):                30-40sg, inches                                         body, fiberglass radome on
  Rated Wind Velocity:                             100+ mph                                                0012 with altrt-riirikiit?tmdy
  Lightning Protection:                            External suggested                 Optjons;             Reflector Oyhsn Kit
  Antenna Diameter.                                I", main mast                                           Pigtail Cable Optrtm
   -   __ - .- -    - .
                   __.       ... ..-.
                                    .   - _ _ _ _ _ _ _ _ _ __ _ ._ _   -   .
                                                                                                           Part 15 Reverse Connectors
  US Office & tfeacic,uar:ers: 3900-6River Road, Schiller Park. 1L 6077G Tel: 800-648-2800or 847-671-6690 Fax 847-671-6715
  UK Office 106 Ancpsey Business Park, Hednesford, Staffs VVSIt? 5Nq UK Tel: (444) 1543-878343Fax- (+44! 1
              V:sit 01.r W F page
                              ~   at ww.mabilernark.com. Sper:ffirrihms subject to change without notice (2/200:?I
                                                                                                                                            35


.+& J ~ w -s!,:yit-~
            ~
ML.?-\..a.,LC.;w
                       ~ Y W ~ JwWd w n   de
                                          ~    1TM.~,”~ae-s&-~wn.~    c5 -   *     -   *    <     w    p     p
                                                                                                                    A p ZOWQ?
                               UrX*ghWZIPY                                                                       &....&Val?~P-


8000 Lee Highway, Falls Church VA 22042                                          990 Alrnanor Avenue, Sunnyvale, CA 94085
Tet (703) 205-0600 Fax: (703) 205-0610                                              Tek (408) 6f7-815P Fax: (408) 617-8151
Salies: 1-888-297-9O9O                                      www.terabearn.com                         Sales: 1-800-664-7060


4     Directional Panets
      The WISP directional panel antennas are designed to provide mam'rnum gain at 2.4 GHz fregwndes. With a
      VSWR of less than 1 .&I,all models prwide efficient and stable performance across the band. These robust
      antenm are designed for outdoor applications.
      General Specifications:
           Directional panel antennas
       Radome Materiaif
         UV stable plastic
       Polarization:
         Lfnear, VertkallHorizontaC
       Nominal impedance:
         50 Ohms
       VSWR:
         .1*6:1
       Maximum Power input:
         20 watts
       Cable:
         It" R G W U with attached fernate.. connectar
       MountingMethod:
           Mast mount included
       Temperature Ranse:
         -4O'C to t.7O-C
      Features and Benefits:
            Patented printed circuit board desfgn. Best performance-tcq v i c e ratio.
            Attractfw, low profile UV stable housing. 8tmds weti with indoor and outdoor environments where aes-
            thetic considerationsare Important.

       9    Comer exft RG-58/U pighit design. Perm%sthe panel to &e mounted in vertical or horizontal polarity.

       -    Adjustable mounting brackets fa- outdm mount.fng. Provide maximum flexibility for outdoor mstallatlons.




                          Frontal Wind
                            Lczadfng
             lksdtdfi      @IOO_!yh-          %-Eenrkns        Weight             Inducted Mount                  Cable
       WIW40C9M?tF          9.3 Ibs.      5.;" x 4.7" x 1.5" 0.5 Ua. idwrioutdoa articu!ating mcunt            $2- RGSIIIU
       WiW#13PTtJF          27.9 I&.      8.8" x 8.1" Y 1.6" 1.2 U s . heavy duty aftdoor djlistilble rnount   12" R G W U
    -+WlSK%OtaPrrrF          89 lbs.     15.1"' x 13.9" x 1.9" 3.9 Lbs, Heavy duty outdm adjtatable m n t      12" RG58IU

       PCTEL Antenna Products Group, fnc.                       ORDER (800)323-9122                       http://www.rnaxrad.com   427


i




                                           MSP24018PTNF E l e r 2 t h Cut




    430 PCTEL Antenna   Pt0ducX.S Group, Inc.     ORDER (800)323-9122       http://www.maxrad.com


                                                           Exhibit €3

                                         Technical Parameters for Signal Boosters

    Below is the following information for the signal boosters.

              (1) antenna type;
              (2) antenna beanwidth:
              (3) total EIW: and
              (4) approximate height Above Ground I.evel (AGL)

    --1_1--_----------..---
         _       I




i   Antenna Type

                              _I
                               _ -
                                 --
                                  --
                                   -c-      _ r -   ----

    XMSSR923WR



    The transmitted carriers have a center frequency and frequency stability identical to the received
    SDiZRS satellite or tcrrestrial carriers. Frequency accuracy is controlled by thc satcll itc or terrestrial
    repeater and not by the signal booster.


                                                Exhibit C

                                       RF Exposure Compliance

This technical addendum supparts tho request for 1 80-Day Special Temporary Authority to Operatc
Very LQWPower Repeaters and Signal Boosters at Indefinite Locations.

1. RF Exposure Analysis for Low-Power Transmitter

'The typical transmitter set up for a trade venue is illustrated in the figures below:

                                   Figure 1: Diagram of Exhibit hall




                    t                                                              Ir


    Figure 2: Main Eshibit hall
"


                                                   .   --
,

         .   I




    1.


    2.

    3.

    4.



                 ce 1: Trrmsmit chda loss budget




                 I


                               Power      .                  ,
                 Radial       Density |Power                Pesk power        Worst Gase
           . |Distance from} (Average)    (Peak}            denaity with     Safety Margin
                Antenna      mWiequare|       mWisquare    2.68 multiplier:| over

                               0.




2. RF Exposure Analysis for Signal Booster

Thetypical setup ofthe signal booster is illustrated in the figures below:

                                Figure 3: Diagram of meeting rooms




                                                Tx antenna




                                                          Cabte and in—
                                                          line amplfifier
                               Rx
                               antenna
                               on roof


Summary




          i


        2. The highest level ofexposure, involving the potential for additive reflection was used as
           the exposure criteria.


                               Table 3: Signal Booster si)eciflcations

                         Antenna Type       Antenna Beamwidth | Total EIRF in Walts
                      Antenna Specialists
                        XMSSR923WR              75 degraes            0.0001


                              Table 4: Calonlations for power density

    e   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 ofOBT 65)

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



                        Radial         Power       with 2.56      |Worst Case Safoty
                       Distance       Density      multiplier        Margin over
                          |         mWisquare           .        exposure standard




                                                                        1
                                                                     51070516
                                                                     5411884



Document Created: 2009-03-17 10:45:29
Document Modified: 2009-03-17 10:45:29

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