Attachment STA Request SAT-STA-20101012-00213

Attachment STA Request

This document pretains to SAT-STA-20101012-00213 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010101200213_844806

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

October 12, 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 Two New Repeaters in Falls Church, Virginia

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 two terrestrial
repeaters in Falls Church, Virginia.1 Specifically, this application seeks 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). Neither
repeater will exceed 12 kw average EIRP, which is the maximum power level the Commission
permits in its new rules for satellite radio terrestrial repeaters.2 Sirius XM requires STA so that it

1
Section 25.120(b)(3) allows the International Bureau to grant an application for a 60-Day
STA without placing it on Public Notice. The Commission adopted formal rules for satellite radio
terrestrial repeaters in 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, FCC 10-82 (released
May 20, 2010) (the “May 20 Order”). The May 20 Order authorizes the 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
become effective 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).
2
47 C.F.R. § 25.214(d)(1). The Commission concluded in the May 20 Order “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.

Ms. Marlene H. Dortch
October 12, 2010
Page 2

can promptly return the Sirius network repeater to operation and minimize the disruption of service
to the public. The XM network repeater will need to be relocated by October 31, 2010, due to the
landlord’s unexpected termination of the current site lease.

The Commission has recognized that SDARS operators require terrestrial repeaters to provide high-
quality service nationwide.3 Consistent with this policy, in September 2001, the Bureau granted
STAs to Sirius XM to operate a nationwide network of terrestrial repeaters.4 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.5

Public Interest Considerations. Sirius XM has recently been informed by the landlord of the
current site at which the XM repeater is located that its equipment needs to be removed from the
location by October 31, 2010. Sirius XM plans to co-locate this repeater with a nearby Sirius
network repeater but recently had to discontinue operations on the Sirius repeater when it noted
minor discrepancies between the authorized site parameters and the site specifications. This STA
will correct those parameters and reauthorize the two sites to allow the prompt resumption of
service on the Sirius repeater and collocation of the XM repeater to the same site. Without these

3
See Establishment of Rules and Policies for the Digital Audio Radio Satellite Service in the
2310-2360 MHz Frequency Band, Report and Order, Memorandum Opinion and Order, and
Further Notice of Proposed Rulemaking, 12 FCC Rcd 5754, 5770 ¶ 37 (1997).
4
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”).
5
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 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). 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 File No.
SAT-STA-20031112-00371, effective Sept. 15, 2004); Public Notice, 2002 FCC Lexis 5670 (rel.
Oct. 30, 2002) (granting XM an STA, File No. SAT-STA-20020815-00153, effective Sept. 30,
2002); Public Notice, 2003 FCC Lexis 4803 (rel. Aug. 29, 2002) (granting File No. SAT-STA-
20030409-00076, effective June 26, 2003). The Commission has renewed all of these STA
authorizations. See Report No: SAT-00722, DA No. 10-1756 (rel. Sept. 17, 2010).

Ms. Marlene H. Dortch
October 12, 2010
Page 3

repeaters, Sirius XM cannot provide the signal quality that its Washington, D.C. area subscribers
have come to expect.

Technical Information for the New Repeaters. The following technical information pertaining to
the repeaters is provided in Exhibit A: (1) antenna type; (2) antenna orientation; (3) average
6
EIRP; (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 sheet for the antenna to be used by the repeater is attached as
Exhibit D.

Interference Considerations. As proposed in this STA, the XM repeater will operate with an
average EIRP of 2000 watts and the Sirius repeater will operate with an average EIRP of 6000
watts. Because Sirius XM has exclusive use of its licensed band, it is highly unlikely that these
repeaters will create interference to other licensees.7 The WCS licensees have confirmed that
operating terrestrial repeaters at an EIRP of 2 kW or less is not an interference concern8 and the
Commission found in the May 20 Order that “repeaters operating at average 12-kW EIRP and a
maximum PAPR of 13 dB will not cause substantially more interference to actual WCS operations
than repeaters operating at 2-kw EIRP.”9 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 (“Horizon”) in satisfaction of this coordination requirement.10 However, if prohibited

6
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.
7
Pursuant to a prior STA, the Sirius network repeater that will operate at this location
transmitted at 6000 watts EIRP from the time it began operating in 2002 until it was recently turned
off. The instant application makes only very minor changes to site parameters which would not
impact the repeater’s interference potential.
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. 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.
9
See May 20 Order, Para. 241 and 47 C.F.R. § 25.214(d)(1).
10
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

Ms. Marlene H. Dortch
October 12, 2010
Page 4

interference does occur, Sirius XM will cease operation of the repeaters until such interference can
be eliminated.11

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 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;

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.
11
The design of these repeaters 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

NETWORK
SITE SITE ANTENNA ANTENNA ANTENNA TOTAL
AND ANTENNA
CITY LATITUDE LONGITUDE ORIENTATION HEIGHT DOWNTILT AVERAGE
ANTENNA TYPE
(N) (W) (AZIMUTH) (FT. AGL) (DEGREES) EIRP(W)
NUMBER
Falls Church, VA Sirius 46-23 38-50-33 77-06-58 EMS FR90-17-00NVL 240 203 0 6000

XM
Falls Church, VA 38-50-33 77-06-58 TA-2350-DAB-T2 0 210 0 2000
WDC231S

Exhibit D

Antenna Specification Sheet for Repeater

Document Created: 2010-10-12 11:58:04
Document Modified: 2010-10-12 11:58:04

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