Attachment Extension Request

This document pretains to SAT-STA-20091207-00139 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2009120700139_785934

SIRIUS XM
                  RADIO INC.
1500 Eckington Place, N.E
Washington, D.C. 20002
Tel: 202—380—4000
Fax: 202—380—4500
www.sinius.com waww.xmradio.com


December 7, 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 Extension of 180—Day Special Temporary Authority to Operate
                 New Low Power Terrestrial Repeaters at Various Locations
                 File No. SAT—STA—20090410—00042

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 ("SDARS"), hereby requests extension of the above—referenced Special Temporary
Authority ("STA") to operate in its licensed frequency band multiple low power terrestrial
repeaters, each of which has average Effective Isotropically Radiated Power ("EIRP") of up to
2000 watts. Specifically, the application sought authority to operate 23 new low power repeaters
in the former Sirius Satellite Radio Inc. ("Sirius") frequency band (2320—2332.5 MHz) and two
new low power repeaters in the former XM Radio Inc. frequency band (2332.5—2345 MHz).
Sirius XM requests that the Commission renew this STA for a period of180 days or until the
Commission issues a blanket license for these repeaters. Absent renewal, this STA is scheduled
to expire on December 15, 2009.‘

Sirius XM currently operates these repeaters pursuant to the STA granted by the International
Burcau on June 18, 2009, File No. SAT—STA—20090410—00042. Sirius XM has not changed

        Because this request is timely, pursuant to Section 1.62 of the Rules, this STA will
continue in effect without further action by the Commission until such time as the Commission
shall make a final determination with respect to this request. See 47 C.F.R. § 1.62.


Ms. Marlene H. Dortch
December 7, 2009
Page 2


technical parameters for the repeaters since the original grantof the STA and is not herein
requesting modification of any of those parameters. Renewing this STA will serve the public
interest by enabling Sirius XM to continue providing quality service to subscribers throughout
the United States. Without these low powerterrestrial repeaters, Sirius XM cannot provide the
signal quality that its subscribers expect.

Sirius XM has been using the repeaters authorized in the above—referenced STA for 180 days and
is not aware of any incidents where the equipment has caused any interference to other radio
services. Sirius XM emphasizes that the repeaters operate at a power level of not more than
2000 watts and at a level which is unlikely to cause any interference. As the Bureau
acknowledged in granting Sirius XM‘s original repeater STA requests, and the WCS licensees
have confirmed, operating terrestrial repeaters at an EIRP of 2000 watts or less does not pose
interference concerns.

Sirius XM will continue to comply with the conditions the Commission imposed in granting the
above—referenced STA to operate the repeaters. These conditions and the technical parameters of
the repeaters have provided sufficient protection to other radio services. Therefore, prompt grant
of Sirius XM‘s extension request will allow for the continued reception ofthe SDARS signal by
subscribers across the country.

Sirius XM hereby certifies that no party to this application is subject to a denial of Federal
benefits pursuantto Section 5301 of the Anti—Drug Abuse Act of 1988, 21 U.S.C. § 853(a).

Sirius XM is submitting payment to the Federal Communications Commission in the amount of
Two Thousand Eight Hundred Sixty Dollars ($2860.00) —— the filing fee applicable to requests
for STAs for non—geostationary ("NGSO") satellites."



    2 See XM Radio, Inc., Application for Special Temporary Authority to Operate Satellite
Digital Audio Radio Service Complimentary Terrestrial Repeaters, Order and Authorization, 16
FCC Red. 16781 «[ 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, evenif
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.

*   See International and Satellite Services Fee Filing Guide (February 2009).


Ms. Marlene H. Dortch
December 7, 2009
Page 3


Please direct any questions regarding this matter to the undersigned.


                                                     Very
                                                        truly yours,



                                                    amesSBlitz
                                                   1ce President, Regulatory Counsel


ce:    Stephen Duall, FCC International Bureau
       Jay Whaley, FCC International Bureau
       Sankar Persaud, FCC International Bureau



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Document Modified: 2019-04-20 15:57:04

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