Attachment STA Request SAT-STA-20100716-00161

Attachment STA Request

This document pretains to SAT-STA-20100716-00161 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010071600161_829639

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

July 15, 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 60-Day Special Temporary Authority
For a Terrestrial Repeater in Baltimore, Maryland

Dear Ms. Dortch:

Pursuant to Section 25.120(b)(3) of the Commission’s rules, 47 C.F.R. § 25.120(b)(3), Sirius XM
Radio Inc. (“Sirius XM”), a satellite radio licensee in the Satellite Digital Audio Radio Service
(“SDARS”), hereby requests 60-Day Special Temporary Authority (“STA”) for one terrestrial
repeater having an Effective Isotropically Radiated Power (“EIRP”) of below 12 kw in Baltimore,
Maryland.1 Specifically, this application seeks authority to operate one repeater in the former Sirius
Satellite Radio Inc. (“Sirius”) frequency band (2320-2332.5 MHz) at 4900 watts on each of two
sectors. Sirius XM requires STA so that it can increase the power of this repeater back to the level
at which it operated prior to June 2010, in order to minimize the disruption of satellite radio service
to the public.

1
Under Section 25.120(b)(3), the Commission may grant this application for a 60-Day STA
without placing it on Public Notice. 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.” Id. at Para. 264.

Ms. Marlene H. Dortch
July 15, 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 The May 20 Order adopted those final
rules, although the rules have not become effective and also remain subject to reconsideration and
review by the Commission and the courts.

Public Interest Considerations. In June 2010, Sirius XM discontinued operations on this repeater
due to minor discrepancies between the authorized site parameters and the specifications of the
repeater as constructed. Pursuant to STA, Sirius XM reauthorized operations at lower power in
order to promptly return service to the public. See FCC File No. SAT-STA-20100621-00140
(granted June 25, 2010). Sirius XM now seeks to return this repeater to operation with the power
level at which it previously operated -- 4900 watts EIRP, on each of two sectors -- in order to

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
July 15, 2010
Page 3

provide its subscribers in the Baltimore, Maryland area with the same quality of satellite radio
service as they received prior to June 2010.

Technical Information for the Repeater. The following technical information pertaining to the
repeater is provided in Exhibit A: (1) antenna type; (2) antenna orientation; (3) average EIRP;
5
(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 sheets for the antennas to be used by the repeater is attached
as Exhibit D.

Interference Considerations. As proposed in this STA, this repeater will operate at an average
EIRP of 4900 watts. Because Sirius XM has exclusive use of its licensed band, and because this
repeater previously operated at this power level without causing any interference, it is highly
unlikely that this repeater 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 requirement7 However, if
prohibited interference does occur, Sirius XM will cease operation of the repeater until such
interference can be eliminated.8

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
This repeater’s 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

Ms. Marlene H. Dortch
July 15, 2010
Page 4

Ownership and Control of Repeater. Sirius XM will own the repeater and it will be responsible for
the repeater’s installation and operation.

Certifications. Sirius XM certifies that it will operate the repeater 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 this repeater 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 this repeater according to the technical parameters provided in
this application;
(9) Sirius XM will maintain full ownership and operational control of this repeater; and
(10) Sirius XM will immediately shut down this repeater 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 radio-
communications facilities from interference, nor will it prejudice the outcome of the Commission’s
ongoing rulemaking pertaining to the deployment and operation of terrestrial repeaters.

(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 Repeater

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)
Sirius 03-11
Baltimore, MD 39 -17 -14 76-36-52 EMS FR90-17-00NVL 45 525 0 4900
Sector 1
Sirius 03-11
Baltimore, MD 39 -17 -14 76-36-52 EMS FR90-17-00NVL 315 525 0 4900
Sector 2

Exhibit D

Antenna Specification Sheet for Repeater

Document Created: 2010-07-16 10:03:37
Document Modified: 2010-07-16 10:03:37

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