Attachment STA Extension Reques

This document pretains to SAT-STA-20100624-00145 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010062400145_824274

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


June 24, 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 Extension of 30—Day Special Temporary Authority to Operate a
                 Low Power Terrestrial Repeater in Arlington, Virginia for 30 Days
                 File No. SAT—STA—20100518—00103

Dear Ms. Dortch:

Pursuantto Section 25.120(b)(4) of the Commission‘s rules, 47 C.F.R. § 25.120(b)(4), 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 a low power terrestrial repeater in
Arlington, Virginia with an Effective Isotropically Radiated Power ("EIRP") of up to 2000
watts.) Specifically,the application sought authority to operate one new low power repeater in
the former XM Radio Inc. ("XM") frequency band (2332.5—2345 MHz). Sirius XM requests
renewal of this STA for a period of 30 days or until the Commission issues a blanket license for



*       The Commission recently adopted formal rules for satellite radio terrestrial repeaters.
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." See Para. 264.


Ms. Marlene H. Dortch
June 24, 2010
Page 2

repeaters used in connection with satellite radio. Absent renewal, this STA is scheduled to
expire on June 27, 2010. 2

Sirius XM currently operates these repeaters pursuant to the STA granted by the International
Bureau on May 28, 2010, File No. SAT-STA-20100518-00103. Sirius XM has not changed
technical parameters for the repeater since the original grant of 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 in Arlington,
Virginia.

Sirius XM has been using the repeater authorized in the above-referenced STA for over 30 days
and is not aware of any incidents where the equipment has caused any interference to other radio
services. Sirius XM emphasizes that the repeater operates at a power level of not more than
2000 watts. 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. 3

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

2
       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.

3
        See 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 ¶ 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. 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.” May 20 Order at Para. 243.


Ms. Marlene H. Dortch
June 24, 2010
Page 3



Please direct any questions regarding this matter to the undersigned.


                                                         ery truly yours,


                                                    AfU     |0
                                                    J ames S. Blitz
                                                     ‘Vice President, Regulatory Counsel


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



Document Created: 2010-06-24 10:49:29
Document Modified: 2010-06-24 10:49:29

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