Attachment STA Request SAT-STA-20091109-00118

Attachment STA Request

This document pretains to SAT-STA-20091109-00118 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2009110900118_777952

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

November 9, 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 to Operate
Eight New Low Power Repeaters at Various Locations

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”) to operate multiple low power
terrestrial repeaters in its licensed frequency band, each of which has average Effective
Isotropically Radiated Power (“EIRP”) of up to 2000 watts. Specifically, this application seeks
authority to operate one new low power repeater in the former Sirius Satellite Radio Inc. (“Sirius”)
frequency band (2320-2332.5 MHz) and seven new low power repeaters in the former XM Radio
Inc. (“XM”) frequency band (2332.5-2345 MHz).

The Commission has recognized that SDARS operators require terrestrial repeaters to provide high-
quality service nationwide.1 Consistent with this policy, in September 2001, the Bureau granted
STAs to Sirius XM to operate a nationwide network of terrestrial repeaters.2 In the years since, the
1
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).
2
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”).

Ms. Marlene H. Dortch
November 9, 2009
Page 2

Bureau has granted Sirius XM additional STAs to operate terrestrial repeaters, pending issuance of
final rules governing the deployment and use of repeaters.3

Public Interest Considerations. Grant of the STA will serve the public interest by enabling Sirius
XM to provide quality service to subscribers throughout the United States. Without these low
power terrestrial repeaters, Sirius XM cannot provide the signal quality that its subscribers expect.

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.4 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. The new low power repeaters will each 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 these new low power repeaters 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,5 Sirius XM is sending a copy of this STA

3
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
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.
4
For purposes of Sirius XM and XM Radio repeater STA applications, “antenna downtilt” refers
to an antenna’s mechanical downtilt, without reference to any electrical downtilt built into the
antenna.
5
See Sirius STA Order ¶ 14 and XM STA Order ¶ 14.

Ms. Marlene H. Dortch
November 9, 2009
Page 3

application to Horizon Wi-Com LLC (“Horizon”) in satisfaction of this coordination requirement.6
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.7 However, if prohibited interference does occur, Sirius XM will cease
operation of the new repeaters until such interference can be eliminated.8

Ownership and Control of Repeaters. Sirius XM will own the new low power repeaters and it will
be responsible for their installation and operation.

Certifications. Sirius XM certifies that it will operate the new low power 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:

6
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.
However, Sirius XM’s own review of Commission files shows that Horizon has certified that it
operates a WCS station serving the New York City metro area, Call Sign KNLB312. It is not
clear from the certification whether the base station is receiving transmissions from CPE or is
engaged in transmit-only operations. If only the latter, potential interference to the base station
is not an issue. In any event, Sirius XM has conducted an interference analysis and determined
that its proposed repeaters will not create any interference concern for Horizon’s operating
WCS site beyond any concerns that may exist from Sirius XM’s existing repeaters in the
vicinity, none of which have been the subject of any interference complaints from WCS
licensees or users.
7
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
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). Sirius XM agrees to
these conditions.
8
These repeaters’ design 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.

Ms. Marlene H. Dortch
November 9, 2009
Page 4

(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 facility will be limited to 75+10log (EIRP) dB less
than the transmitter EIRP;

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

(9) Sirius XM will maintain full ownership and operational control of these repeaters; and

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

Granting this request will not alter Sirius XM’s obligation to protect authorized
radiocommunications facilities from interference, nor will it prejudice the outcome of the
Commission’s ongoing rulemaking pertaining to the deployment and operation of terrestrial
repeaters.

Sirius 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. § 853(a).

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)

Las Vegas, NV LVX010A 36-08-09 115-09-069 EMS FR90-17-00NVL 180 350 2 2000

Alpine, NJ NYC005A 40-57-39 73-55-22 TA2304-2-DAB (90) 0 247 0 2000

TA2304-2-DAB-H
Neptune, NJ NYC010A 40-13-45 74-05-25 180 300 0 2000
(120)

Riverdale, NY NYC013C 40-52-58 73-54-41 TA2304-2-DAB (90) 40 155 0 2000

Manhattan, NY NYC035A 40-51-18 73-55-38 TA2304-2-DAB (90) 45 200 4 2000

Fort Lee, NJ NYC056E 40-51-17 73-58-17 TA2304-2-DAB (90) 20 227 0 2000

New Rochelle,
NYC098A 40-54-43 73-46-56 TA2304-2-DAB (90) 0 180 0 2000
NY
Sirius 28-12 TA2304-2-DAB-H
Westwood, NY 40-59-26 74-01-48 330 102 2 2000
(Sector 1) (120)

Exhibit D

Antenna Specification Sheets for Repeaters

Document Created: 2009-11-09 13:43:09
Document Modified: 2009-11-09 13:43:09

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