Attachment STA Request

This document pretains to SAT-STA-20100211-00025 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010021100025_799850

SIRIUSRADIO XMINC. 1500 Eckington Place, NE. Washington, D.C. 20002 Tel: 202—380—4000 Fax: 202—380—4500 wnwisitius.com www.xmradio.com February 8, 2010 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 New Low Power Repeaters in New York City 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 two new 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 one new low power repeaters in the former XM Radio Inc. ("XM") frequency band (2332.5—2345 MHz). The two repeaters will be co—located at the same site. The Commission has recognized that SDARS operators require terrestrial repeaters to provide high— quality service nationwide.‘ Consistent with this policy, in September 2001, the Bureau granted STAs to Sirius XM to operate a nationwide network ofterrestrial repeaters." In the years since, the ‘ See Establishment ofRules 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 ofProposed Rulemaking, 12 FCC Red $754, 5770 4 37 (1997). 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 Red. 16773 4 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 Red. 16781 " 18 (2001) ("XM STA Order").

Ms. Marlene H. Dortch February 8, 2010 Page 2 Bureau has granted Sirius XM additional STAs to operateterrestrial repeaters, pending issuance of finalrules governing the deployment and use of repeaters." Public Interest Considerations. Grant ofthe STA will serve the public interest by enabling Sirius XM to provide quality service to its subscribers in New York City. 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 orlentatlon (3) average EIRP; (4) height above ground level ("AGL"); and (5) antenna downtilt." 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 antennasto 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 ofits 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 priorto operating any repeater," Sirius XM is sending a copy ofthis STA * 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 Red. 18140 (2004) (granting Sirius an STA in File No. SAT—STA— 20031106—00370, effective Sept. 15, 2004. Sincethat time, the Commission has extended the STA several times, pending theissuance of final rules governing the use ofsatellite 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 ofsatellite DARS terrestrial repeaters. See Sirfus Satellite Radio Inc. Request to Modify Special Temporary Authority to Operate Satellite DARS Terrestrial Repeaters, Order and Authorization, 19 FCC Red 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.; Requestfor Special Temporary Authority to Operate Additional Satellite Digital Audio Radio Service Terrestrial Repeaters, Order and Authorization, 19 FCC Red. 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. 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. See Sirius STA Order 14 and XM STA Order $ 14.

Ms. Marlene H. Dortch February 8, 2010 Page 3 application to Horizon Wi—Com LLC ("Horizon") in satisfaction of this coordination language. 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.‘ However, if prohibited interference does occur,Sirius XM will cease operation of the new repeaters until such interference can be eliminated." Ownership and Control ofRepeaters. Sitius 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 subjectto 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: © 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 stationsare 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—onlyoperations. 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 repeatersin the vicinity, none of which have been the subject of any interference complaints from WCS licenseesor users. XM STA Order 4| 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 requeststhat 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 theissue 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. These repeaters‘ design includes severalautomated shutdown mechanisms that aretriggered 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 anomaliesare 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 February 8, 2010 Page 4 (1) Sirius XM will operate these repeatersat its own risk, and such operation shall not prejudice the outcome ofthe 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 simultancousretransmission of the complete programming, and only that programming, transmitted by the satellite directly to SDARS receivers; (4) Where applicable, coordination ofthe 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 ofthe 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 ofthese 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 ofthe Commission‘s ongoing rulemaking pertaining to the deployment and operation ofterrestrial repeaters. Sirius XM hereby certifies that no party to this application is subject to a denial of Federalbenefits pursuant to Section 5301 ofthe Anti—Drug Abuse Act of 1988, 21 U.S.C. § 853(a).

Ms. Marlene H. Dortch February 8, 2010 Page 5 Sirius XM is submitting paymentto 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." Please direct any questions regarding this matter to the undersigned. tzlg/ Very yours, ames B)f 8. // Vice President, Regulatory Counsel ce Stephen Duall, FCC International Bureau Jay Whaley, FCC International Bureau Sankar Persaud, FCC International Bureau Rajendra Singh, Horizon Wi—Com LLC (rsingh@tvllc.com) Thomas Gutierrez, Lukas Nace Gutierrez & Sachs(gutierrez@feclaw.com) * See International and Satellite Services Fee Filing Guide (February 2009).

Exhibit A Technical parameters for repeaters site site ANTENNA ANTENNA ANTENNA ToTAL city AUmnea Latit Loneatrupe "ary* ORIENTATION HEIGHT DOWNTILT AVERAGE upe (w) (aZIMUTR) (PT.AGL) (DEGREES) EIRP(W) (N) New York ny City, Sitins Sector2728 1 ap.4.97 73159155 $A2500—090%—16 270 116 1 2000 Now York ny Cityo $00e2738 Sector 2 unssy rnsoss DBSO2HG2SN—S ans 116 2 2000 Now Nolktiln. SMMTLL* Sector 1 [déaner| messes $A2500—090X—16 270 116 1 2000 New York NY City, XMNYCOS7K Sector 2 ao.45.97 73.50.55 DBsozHG28N—S ans 116 2 2000

Exhibit B Google*"Satellite Image of Repeater Location Sirius 27—28 and XM NYCOSTX

Exhibit C Topographic Map of Repeater Location Sirius 27—28 and XM NYCOSTX Ni 4s y 7 s uo t

Exhibit D Antenna Specification Sheets for Repeaters

% DB992HG28N—S 2300—2500 MHz 16 dBi DATENNA!" DEcIBEIs'» High Gain Flat Panel Array MaxGain"" * High Gain Array idealfor point to point and CPE applications. + Designed for user to change polarization from vertical to horizontal with simple bracket change. [ Azimuth s (Horizontal) f & Standard Installaton Wall Ll Mount Elevation (Vertical) Installtion with optional DB390—ROTATE bracket for adjustable polarization. Electrical Mechanical Frequency: 2300—2500 MHz Weight: 2.7 los (1.2kg) Gain: 16 08i Wind Area: 0.8 i(0.07 m) Azimuth BW: 20° Wind Load: 32 of(142N) (at 100 mph) Elevation BW: 20° Max. Wind Speed: 125 mph (201 km/h) Polarization: horizontal or vertical Radiators: PCB Vertical Upper Back Panel: Auminum Side Lobe: 1808 Radome: ABS Front—to—Back Ratio: 250B Mounting Hardware: Galvanized Steel Cross Pole Ratio: <17 48 Color: Gray vswa: 151 . F Max. Input Power: 100 Wats Mounting Options Lightning Protection: Allmmetal parts are grounded. Standard: Welmountbraot Connector: N—Female Optional; Pipe mount with rotating head, DB390—Rotate 8635 Stemmons Freeway * Dallas, Texas U.S.A. 75247—3701 Dallas/Ft.Worth Area Tel: 214.631.0310 » Fax: 214.631.4706 Toll Free Tel: 1,800.676.5342 » Fax: 1.800.229.4706 www.decibelproducts.com Ennmnaietoed 099271—000 01028 dbtech@decibelproducts.com 150001 Complant

SA2500—090X—16 —GS" Decibel® ANDREW. DualPol® Antenna Base Station Antennas w Broadband Sector Antenna ideally suited for WiMax applications m High performancein a small, lightweight package m Superior front to be ack ratio ® Rugged reliable design se Frequency (MHz): 2300 — 2700 Polarization : 445° Gain (dBd/dBi) : 14.5716.6 Azimuth BW (Deg.): 90 Elevation BW (Deg.): 56 Beam Tilt (Deg.): 2 USLS® (dB): 18 Front—To—Back Ratio® (dB) : 34 Isolation (dB) : >30 VSWeR : <141 PIM3 @ 2 x 20w (dBc): —140 Max. Input Power (Watts) : 80 impedance (Ohms): 50 Lightning Protection : DC Ground Notes: Antenna mount is included with antenna Weight : 3.9 kg (8.7 Ib) Dimensions (LXWxD) : 1,219 x 165 x 84 mm (48 x 6.5 x 3.3 in) Max. Wind Area : 0.10 m# (1.1 f ) Max. Wind Load (@ 100 mph) : 271.7 N (61.1 lor) Max. Wind Speed: 241 km/h (150 mph) Hardware Material : Stainless Stee! CGonnector Type : N — Type Female (2, Bottom) Color : Light Gray Standard Mounting Hardware : 602030WM Andrew Corporation Fax: 214.631.4706 * Incicates Typical 2601 Telecom Parkway Toll Free Tel: 1.800.676.5342 arBr2oo7 Richardson, Texas U.S.A 76082—3521 Fax: 1.800.220.4706 Tel: 214.631.0310 wmw.andrew.com dbtech@andrew.com Information correct at date ofissue but may be subject to change without notice

sb SA2500—090X—16 Decibel® ANDREW. Desipous antentie Base Station Antennas AZIMUTH PATTERN _ELEVATION PATTERN o PR l2 o £> EPCAE \* 20 BMAC\ 2‘:“3‘3""’% Freq: 2500 MHz, Tilt: 2 Freq: 2500 MHz Tilt: 2 Andrew Corporation Fax: 2146314706 *~ Indicates Typical 2601 Telecom Parkway Toll Free Tel: 1.800.676.5342 Richardson, Texas U.S.A 75082—3521 Fax: 1.800.220.4706 werzcor Tel: 214.631.0310 www andrew.com dbtech@andrew.com information correct atdate of issue but may be subject to change without notice.


Document Created: 2019-04-26 08:46:20
Document Modified: 2019-04-26 08:46:20
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