Attachment STA Request SAT-STA-20101026-00225

Attachment STA Request

This document pretains to SAT-STA-20101026-00225 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010102600225_847231

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 26, 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 180-Day Special Temporary Authority
For Six New Repeaters at Various Locations

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 180-Day Special Temporary Authority (“STA”) to operate six
terrestrial repeaters at various locations throughout the United States. Sirius XM seeks authority to
operate these repeaters for a period of 180 days or until the Commission issues a blanket license for
these repeaters pursuant to 47 C.F.R. § 25.144(e), whichever occurs first.1 Specifically, this
application seeks authority to operate three repeaters in the former Sirius Satellite Radio Inc.
(“Sirius”) frequency band (2320-2332.5 MHz) and three repeaters in the former XM Radio Inc.
(“XM”) frequency band (2332.5-2345 MHz). None of the repeaters will exceed 12 kw average

1
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, 25 FCC Rcd 45058 (2010) (the “Order”).
The 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).

Ms. Marlene H. Dortch
October 26, 2010
Page 2

EIRP, which is the maximum power level the Commission permits in its new rules for satellite
radio terrestrial repeaters.2

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. Grant of the STA will serve the public interest by enabling Sirius
XM to provide quality service to subscribers throughout the United States. Without these low
power terrestrial repeaters, Sirius XM cannot provide the signal quality that its subscribers expect.

2
47 C.F.R. § 25.214(d)(1). The Commission concluded in the 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.
3
See 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, 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 26, 2010
Page 3

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 EIRP;
(4) height above ground level (“AGL”); and (5) antenna downtilt.6 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 repeaters are
attached as Exhibit D.

Interference Considerations. As proposed in this STA, the repeaters will operate with an average
EIRP of well below 12 kw. Because Sirius XM has exclusive use of its licensed band, it is highly
unlikely that these repeaters will create interference to other licensees. The WCS licensees have
confirmed that operating terrestrial repeaters at an EIRP of 2 kW or less is not an interference
concern7 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.”8 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 Comcast
WCS ME19, Inc. (“Comcast”) in satisfaction of this coordination requirement.9 However, if

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
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.
8
See Order, Para. 241 and 47 C.F.R. § 25.214(d)(1).
9
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 show that Comcast has certified that it operates three WCS
stations serving the Kokomo, IN area, Call Signs KNLB281, KNLB280, and WPQL633. It is not
clear from Comcast’s certification whether its base stations are receiving transmissions from CPE
or whether they are engaged in transmit-only operations. If only the latter, potential interference to
the Comcast base station is not an issue. In any event, Sirius XM has reviewed the interference
environment and determined that these repeaters will not create interference to Comcast’s operating
WCS sites.

Ms. Marlene H. Dortch
October 26, 2010
Page 4

prohibited interference does occur, Sirius XM will cease operation of the repeaters until such
interference can be eliminated.10

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 the repeaters 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 facilities will be limited to 75+10log (EIRP) dB less
than the transmitter EIRP;
(8) Sirius XM will operate the repeaters according to the technical parameters provided in
this application;
(9) Sirius XM will maintain full ownership and operational control of the repeaters; and

10
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
XM
Atlanta, GA 33-42-09 84-19-47 TA2304-2-DAB (120) 120 240 0 2000
ATL056A
Sirius IND
Kokomo, IN 40-27-17 86-06-08 TA-2350-DAB 0 95 0 2000
17-03

Kokomo, IN XM IND201A 40-27-17 86-06-08 TA-2350-DAB 0 95 0 2000

Sirius
Las Vegas, NV 36-06-58 115-11-12 TA2304-2-DAB (45) 140 438 10 1000
LVX004B
Sirius 48-01
Las Vegas, NV 36-08-09 115-09-06 EMS-FR90-17-00NVL 180 350 2 3200
(Sector 1)
Sirius 48-01
Las Vegas, NV 36-08-09 115-09-06 EMS-FR65-18-00NVL 240 355 2 4000
(Sector 2)
XM
Las Vegas, NV LVX010A 36-08-09 115-09-06 EMS-FR90-17-00NVL 180 350 2 3200
(Sector 1)
XM
Las Vegas, NV LVX010A 36-08-09 115-09-06 EMS-FR65-18-00NVL 240 355 2 4000
(Sector 2)

Exhibit D

Antenna Specification Sheets for Repeaters

Document Created: 2010-10-26 11:41:18
Document Modified: 2010-10-26 11:41:18

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