Attachment Extension Request

This document pretains to SAT-STA-20100907-00190 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010090700190_838711

SIRIUS XM
                  RADIO INC.

1500 Eckington Place, N.E.
Washington, D.C. 20002
Tel: 202—380—4000
Fax: 202—380—4500
www.sirius.com www.xmradio.com


September 7, 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 180—Day Special Temporary Authority to Operate
                 Very Low Power Repeaters and Signal Boosters at Trade Show Events
                 File No. SAT—STA—20100303—00039

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 (i) very low power terrestrial
repeaters with an Effective Isotropically Radiated Power ("EIRP") of up to ten watts and (ii)
signal boosters with an EIRP of up to 0.0001 watts that have previously been approved for use in
retail stores and other indoorlocations.‘ Sirius XM requests renewal of this STA for a period of

!    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. However, no such permanent authorization can becomeeffective
until after the new rules have been approved by the Office of Management and Budget, which
has not yet occurred. See 75 Fed. Reg. 45058, 45058 (Aug. 2, 2010).


Ms. Marlene H. Dortch
September7, 2010
Page 2


180 days or until the Commission issues a blanket license for repeaters used in connection with
satellite radio. Absent renewal, this STA is scheduled to expire on September 8, 2010. 2

Sirius XM currently operates these repeaters and boosters in connection with both the Sirius
frequency band (2320—2332.5 MHz) and the former XM Radio Inc. ("XM") frequency band
(2332.5—2345 MHz), pursuant to the STA granted by the International Bureau on May 6, 2010,
File No. SAT—STA—20100303—00039. Sirius XM has not changed technical parameters for the
repeaters and boosters 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 to provide a quality signal at temporary events in various
locations across the United States.

Sirius XM has been using the repeaters and boosters authorized in the above—referenced STA for
over 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 and boosters operate at a power
level of not more than ten 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.




2      Because this request is timely, pursuantto 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.
©       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 deferfrom
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 ofthe STA (i) is conditioned on
operation on a non—interference basis; and (ii) is subjectto 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, Counselto the WCS Coalition, to Ms. Helen Domenici,
FCC, File No. SAT—STA—20061207—00145 (March 19, 2007). Sirius XM agreesto 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
September 7, 2010
Page 3


Sirius XM will continue to comply with the conditions the Commission imposed in granting the
above—referenced STA to operate the repeaters and boosters. These conditions and the technical
parameters ofthe repeaters and boosters 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 at various trade show events across the country.

Please direct any questions regarding this matter to the undersigned.




                                                       ice President, Regulatory Counsel


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



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Document Modified: 2019-04-20 01:08:24

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