Attachment STA Request SAT-STA-20091030-00115

Attachment STA Request

This document pretains to SAT-STA-20091030-00115 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2009103000115_774726

SIRIUSRADIO
XM INC.
1500 Eckington Place, N.E.
Washington, D.C. 20002
Tel: 202-380-4000
Fax: 202-380-4500
www.sirius.com www.xmradio.com

October 30, 2009

Via IBFS
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

Re: Sirius XM Radio Inc.
Request for 180-Day Special Temporary Authority
For Two New Low Power Repeaters in Puerto Rico

Dear Ms. Dortch:

Pursuant to Section 25.120(b)(2) of the Commission’s rules, 47 C.F.R. § 25.120(b)(2), Sirius XM
Radio Inc. (“Sirius XM”), a satellite radio licensee in the Satellite Digital Audio Radio Service,
hereby requests 180-Day Special Temporary Authority (“STA”) for two new low power terrestrial
repeaters in Puerto Rico, each with an Effective Isotropically Radiated Power (“EIRP”) of up to
2000 watts.1

Last month, the Commission granted Sirius XM STA to operate multiple repeaters in Puerto Rico.2
One of those repeaters -- PR01-01 in San Juan -- is to be the anchor site for the repeater network
that Sirius XM is constructing in Puerto Rico. The PR01-01 site has been constructed and began
providing commercial service. Shortly thereafter, Sirius XM was notified by the landlord of the
building on which this repeater is located that a planned replacement of four 12’ chillers on the roof
(used in connection with the building’s central cooling system) would require equipment lifting
devices to be operated on the rooftop, in the vicinity of the transmit antennas, for the duration of
that project. Sirius XM believes that the persons controlling these devices may be exposed to
unacceptable levels of RF radiation if the PR01-01 repeater were to transmit at its currently
authorized height. However, by conducting tests pursuant to our experimental license, Call Sign

1
On October 23, 2009, Sirius XM filed a request to operate one of these two repeaters under 60-
Day Special Temporary Authority pursuant to Section 25.120(b)(3) of the Commission’s rules.
See FCC File No. SAT-STA-20091023-00112. That request remains pending.
2
See Sirius XM Radio Inc., Order and Authorization, IBFS File No. SAT-STA-20081027-00210
(Int’l. Bureau, Sept. 11, 2009).

Ms. Marlene H. Dortch
October 30, 2009
Page 2

WF2XDO, OET File No. 0326-EX-PL-2009, Sirius XM has confirmed that relocating the two
omni-directional antennas only six feet higher than the STA height will eliminate the potential for
excessive levels of RF radiation exposure to those workers. Sirius XM has completed an MPE test
report showing this result and will retain that report in its files

Anticipating the commencement of construction on the rooftop and to avoid this potential RF
hazard, Sirius XM has discontinued providing service using the PR01-01 repeater and herein
requests authority to increase the antenna height from 260 feet to 266 feet. In the instant
application, Sirius XM also requests authority to increase this repeater’s power from 1000 watts to
2000 watts EIRP.

The second repeater -- identified as PR04-01 – is located in Bayamon, Puerto Rico. Sirius XM
herein requests authority to change the height of this repeater from 196 feet to 181 feet. This
application seeks to make no other change to this second repeater other than this minor decrease in
height, which Sirius XM finds to be necessary for contractual purposes.

The Commission has recognized that SDARS operators require terrestrial repeaters to provide high-
quality service nationwide.3 Consistent with this policy, in September 2001, the Bureau granted
STAs to Sirius XM to operate a nationwide network of terrestrial repeaters.4 In the years since, the
Bureau has granted Sirius XM additional STAs to operate terrestrial repeaters, pending issuance of
final rules governing the deployment and use of repeaters.5

3
See Establishment of Rules and Policies for the Digital Audio Radio Satellite Service in the
2310-2360 MHz Frequency Band, Report and Order, Memorandum Opinion and Order, and
Further Notice of Proposed Rulemaking, 12 FCC Rcd 5754, 5770 ¶ 37 (1997).
4
See Sirius Satellite Radio, Inc., Application for Special Temporary Authority to Operate
Satellite Digital Audio Radio Service Complimentary Terrestrial Repeaters, Order and
Authorization, 16 FCC Rcd. 16773 ¶ 18 (2001) (“Sirius STA Order”). XM Radio, Inc.,
Application for Special Temporary Authority to Operate Satellite Digital Audio Radio Service
Complimentary Terrestrial Repeaters, Order and Authorization, 16 FCC Rcd. 16781 ¶ 18
(2001) (“XM STA Order”).
5
See, e.g., Sirius Satellite Radio Inc.; Request to Modify Special Temporary Authority to Operate
Additional Satellite Digital Audio Radio Service Terrestrial Repeaters, Order and
Authorization, 19 FCC Rcd. 18140 (2004) (granting Sirius an STA in File No. SAT-STA-
20031106-00370, effective Sept. 15, 2004. Since that time, the Commission has extended the
STA several times, pending the issuance of final rules governing the use of satellite DARS
terrestrial repeaters. In September 2004, the Commission granted Sirius a new STA to operate
for 180 days or until the Commission issues final rules governing the use of satellite DARS
terrestrial repeaters. See Sirius Satellite Radio Inc. Request to Modify Special Temporary
Authority to Operate Satellite DARS Terrestrial Repeaters, Order and Authorization, 19 FCC
Rcd 18149 (2004) (“2004 STA Grant Order”). Sirius timely filed an application for renewal of
this STA on March 1, 2005. See File No. SAT-STA-20050301-00053. To date, the
Commission has not acted on this application. See also, XM Radio, Inc.; Request for Special

Ms. Marlene H. Dortch
October 30, 2009
Page 3

Public Interest Considerations. Granting the instant STA will serve the public interest by ensuring
the ability of Sirius XM subscribers in Puerto Rico to receive high quality satellite radio service.
As to the change in the PR01-01 site requested in IBFS File No. SAT-STA-20081027-00210,
granting the instant STA will serve the public interest by allowing Sirius XM to minimize the
disruption of service to San Juan residents and will eliminate the possibility of excessive RF
radiation exposure to workers replacing equipment on the building’s roof.

Technical Information for the New Low Power Repeaters. The following technical information
pertaining to the repeaters is provided in Exhibit A: (1) antenna type; (2) antenna orientation;
(3) average EIRP; (4) height above ground level (“AGL”); and (5) antenna downtilt.6 Exhibits B
and C consist respectively, of Google™ satellite images and topographic maps showing the location
of the proposed facilities. The specification sheet for the antennas to be used by the repeaters is
attached as Exhibit D.

Interference Considerations. As proposed in this STA, the repeaters will operate at an average
EIRP of less than 2000 watts. Because Sirius XM has exclusive use of its licensed band, it is highly
unlikely that this low power repeater will create interference to other licensees. To the extent Sirius
XM’s original 2001 STAs require it to coordinate with affected Wireless Communications Services
(“WCS”) licensees prior to operating any repeater, Sirius XM is not aware of any operational WCS
facilities in Puerto Rico.7 Moreover, as the Bureau acknowledged in granting Sirius XM’s original
repeater STA requests, the WCS licensees have confirmed that operating terrestrial repeaters at an
EIRP of 2 kW or less is not an interference concern.8 However, if prohibited interference does
occur, Sirius XM will cease operation of the repeater until such interference can be eliminated.9

Temporary Authority to Operate Additional Satellite Digital Audio Radio Service Terrestrial
Repeaters, Order and Authorization, 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 Notice, 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 remain pending.
6
For purposes of Sirius XM’s repeater STA applications, “antenna downtilt” refers to an
antenna’s mechanical downtilt, without reference to any electrical downtilt built into the
antenna.
7
See Sirius STA Order ¶ 14 and XM STA Order ¶ 14. Despite the Bureau’s statement in the XM
STA Order (at ¶ 14) and Sirius STA Order (at ¶ 14) that it expects “WCS licensees to provide a
schedule or as much advance notice as possible of when their stations are to be placed in
operation,” Sirius XM has not received information directly from any WCS licensee regarding
plans for WCS deployment in these markets. Moreover, Sirius XM’s own reviews of
“substantial service” filings do not show any operational WCS stations in this market.
8
XM STA Order ¶ 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.”). Moreover, in March 2007, the WCS Coalition said that it will defer

Ms. Marlene H. Dortch
October 30, 2009
Page 4

Ownership and Control of Repeaters. Sirius XM will continue to own the repeaters and it will be
responsible for the repeaters’ installation and operation.

Certifications. Sirius XM certifies that it will operate the repeaters subject to the conditions and
certifications set forth in the Sirius STA Order and XM STA Order granting Sirius XM’s September
2001 requests for STAs to operate terrestrial repeaters. Specifically, Sirius XM certifies the
following:

(1) Sirius XM will operate these repeaters at its own risk, and such operation shall not
prejudice the outcome of the final rules adopted by the Commission in GEN Docket 95-91;
(2) Sirius XM will operate these facilities on a non-interference basis with respect to all
permanently authorized radiocommunication facilities;
(3) The facilities 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 facilities 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 facilities will comply with Part 17 of the Commission’s rules – Construction,
Marking, and Lighting of Antenna Structures;
(6) The facilities 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 1.1307(b)
and 1.1310 of the Commission’s rules;
(7) The out-of-band emissions of the facilities will be limited to 75+10log (EIRP) dB less
than the transmitter EIRP;

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 (March 19, 2007). XM agrees to these
conditions.
9
The design of these repeaters includes several automated shutdown mechanisms that are
triggered in the event of equipment major malfunctions. The transmit chain also includes a
transmit output coupler which feeds a self-monitoring system detecting any transmission
anomalies. Any such anomalies are automatically reported back to Sirius XM’s National
Repeater Control Center (202-380-4725), which is available on a continuous basis to receive
any reports of any suspected interference and take immediate corrective action.

Exhibit A

Technical parameters for repeaters

SITE SITE ANTENNA ANTENNA ANTENNA TOTAL
ANTENNA ANTENNA
CITY LATITUDE LONGITUDE ORIENTATION HEIGHT DOWNTILT AVERAGE
NUMBER TYPE
(N) (W) (AZIMUTH) (FT. AGL) (DEGREES) EIRP(W)
PR01-01
San Juan, PR 66-03-32 18-25-28 TA-2350-DAB N/A 266 0 1000
(Sector 1)
PR01-01
San Juan, PR 66-03-32 18-25-28 TA-2350-DAB N/A 266 0 1000
(Sector 2)
PR04-01
Bayamon, PR 66-08-43 18-23-48 SA2500-090X-16 225 181 0 2000
(Sector 1)
PR04-01
Bayamon, PR 66-08-43 18-23-48 SA2500-090X-16 315 181 0 2000
(Sector 2)

Exhibit D

Antenna Specification Sheet for Repeaters

Document Created: 2009-10-30 13:59:08
Document Modified: 2009-10-30 13:59:08

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