Attachment STA Request SAT-STA-20100623-00142

Attachment STA Request

This document pretains to SAT-STA-20100623-00142 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010062300142_824085

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

June 23, 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
For Two Low Power Repeaters in Baltimore, Maryland

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 180-Day Special Temporary Authority (“STA”) for two low power
terrestrial repeaters, each with an Effective Isotropically Radiated Power (“EIRP”) of up to 2000
watts, in Baltimore, Maryland. Specifically, this application seeks authority to operate one low
power repeater in the former XM Radio Inc. (“XM”) frequency band (2332.5-2345 MHz) and one
low power repeater in the former Sirius Satellite Radio Inc. (“Sirius”) frequency band (2320-2332.5
MHz). Sirius XM requires STA so that it can promptly return these repeaters to operation and
minimize the disruption of service to the public.1

1
On June 21, 2010, Sirius XM filed a request to operate 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-20100621-00140. That request remains pending. The Commission
recently adopted formal rules for satellite radio terrestrial repeaters. See Amendment of Part 27
of the Commission's Rules to Govern the Operation of Wireless Communications Services in
the 2.3 GHz Band; Establishment of Rules and Polices for the Digital Audio Radio Satellite
Service in the 2310-2360 MHz Frequency Band, Report and Order and Second Report and
Order, FCC 10-82 (released May 20, 2010) (the “May 20 Order”). The May 20 Order
authorizes the International Bureau “to continue to grant STAs for new or modified repeaters …
[until] any permanent authorization to operate SDARS repeaters becomes effective.” Id. at
Para. 264.

Ms. Marlene H. Dortch
June 23, 2010
Page 2

The Commission has recognized that SDARS operators require terrestrial repeaters to provide high-
quality service nationwide.2 Consistent with this policy, in September 2001, the Bureau granted
STAs to Sirius XM to operate a nationwide network of terrestrial repeaters.3 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.4

Public Interest Considerations. Sirius XM recently discontinued operations on these co-located
Baltimore, Maryland repeaters upon discovering minor discrepancies between the authorized site
parameters and the specifications of the repeaters as constructed. This STA corrects those
parameters and will reauthorize the two sites to allow the prompt resumption of service in the
Baltimore area. Without these repeaters, Sirius XM cannot provide the signal quality that its
subscribers have come to expect.

2
See May 20 Order. See also, Establishment of Rules and Policies for the Digital Audio Radio
Satellite Service in the 2310-2360 MHz Frequency Band, Report and Order, 12 FCC Rcd 5754,
5770 ¶ 37 (1997).
3
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”).
4
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.

Ms. Marlene H. Dortch
June 23, 2010
Page 3

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.5 Exhibits B
and C consist respectively, of Google™ satellite images and topographic maps showing the location
of the proposed facilities. The specification sheets for the antennas to be used by the repeaters are
attached as Exhibit D.

Interference Considerations. As proposed in this STA, these 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 these low power repeaters will create interference to other licensees.6 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 sending a copy of this
STA application to Horizon Wi-Com LLC in satisfaction of this coordination requirement.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

5
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.
6
In the May 20 Order, the Commission determined “that SDARS terrestrial repeaters can operate
at an average EIRP of 12 kw with maximum PAPR of 13 dB without causing harmful
interference to WCS base station receivers.” May 20 Order at Para. 243.
7
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 Washington, DC metro area, Call Sign KNLB315. 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.
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
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.

Ms. Marlene H. Dortch
June 23, 2010
Page 4

operation of the repeaters until such interference can be eliminated.9

Ownership and Control of Repeaters. Sirius XM will 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 facility will be limited to 75+10log (EIRP) dB less
than the transmitter EIRP;

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. . In the May 20 Order, the Commission concluded “that SDARS terrestrial
repeaters can operate at an average EIRP of 12 kw with maximum PAPR of 13 dB without
causing harmful interference to WCS base station receivers.” Id. at Para. 243.
9
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.

Exhibit A

Technical Parameters for Repeaters

SITE SITE ANTENNA ANTENNA ANTENNA TOTAL
ANTENNA
CITY LATITUDE LONGITUDE ANTENNA TYPE ORIENTATION HEIGHT DOWNTILT AVERAGE
NUMBER
(N) (W) (AZIMUTH) (FT.AGL) (DEGREES) EIRP (W)

Baltimore, MD WDC401B 39 -17 -14 76-36-52 TA2350-DAB- T2 0 537 0 2000
Sirius 03-11
Baltimore, MD 39 -17 -14 76-36-52 EMS FR90-17-00NVL 45 525 0 2000
Sector 1
Sirius 03-11
Baltimore, MD 39 -17 -14 76-36-52 EMS FR90-17-00NVL 315 525 0 2000
Sector 2

Exhibit D

Antenna Specification Sheet for Repeaters

Document Created: 2010-06-23 11:59:38
Document Modified: 2010-06-23 11:59:38

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