Attachment Extension Request

This document pretains to SAT-STA-20100923-00201 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010092300201_839982

SIRIUS XM RADIO INC. 1500 Eckington Place, N.E. Washington, D.C. 20002 Tel: 202—380—4000 Fax: 202—380—4500 www.situs.com www.xmradio.com September 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 Extension of 180—Day Special Temporary Authority to Operate Two New Low Power Terrestrial Repeaters in New York City File No. SAT—STA—20100211—00025 Dear Ms. Dortch: Pursuantto 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 two low power terrestrial repeaters with an Effective Isotropically Radiated Power ("EIRP") of up to 2000 watts.‘ Specifically, the I 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; Establishmentof 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 September 15, 2010 Page 2 application sought authority to operate one repeater in the former Sirius Satellite Radio Inc. ("Sirius") frequency band (2320—2332.5 MHz) and one 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 180 days or until the Commission issues a blanketlicense for repeaters used in connecliole with satellite radio. Absent renewal, this STA is scheduled to expire on September 27, 2010. Sirius XM currently operates these repeaters pursuant to the STA granted by the International Bureau on March 31, 2010, File No. SAT—STA—20100211—00025. Sirius XM has not changed technical parameters for the repeaters since the original grant of the STA and is not herein requesting modification of any ofthose parameters. Renewing this STA will serve the public interest by enabling Sirius XM to continue to provide a quality signal to its subscribers in New York City. Sirius XM has been using the repeaters 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 operate at a powerlevel 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. * * 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 respectto this request. See 47 C.F.R. § 1.62. * See XM Radio, Inc., Applicationfor Special Temporary Authority to Operate Satellite Digital Audio Radio Service Complimentary Terrestrial Repeaters, Order and Authorization, 16 FCC Red. 16781 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 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 subjectto 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 September 15, 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. These conditions and the technical parameters of the repeaters 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 New York City. Please direct any questions regarding this matter to the undersigned. y Very truly yours, ice President, Regulatory Counsel ¢6: Stephen Duall, FCC International Bureau Jay Whaley, FCC International Bureau Sankar Persaud, FCC International Bureau


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Document Modified: 2019-04-12 23:06:14
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