Attachment STA Request SAT-STA-20101118-00240

Attachment STA Request

This document pretains to SAT-STA-20101118-00240 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010111800240_853272

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

November 18, 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 Co-Located Sirius and XM Network Terrestrial Repeaters At Six 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 co-located
terrestrial repeaters at six different locations in the former Sirius Satellite Radio Inc. (“Sirius”)
frequency band (2320-2332.5 MHz) and the former XM Radio Inc. (“XM”) frequency band
(2332.5-2345 MHz).1 None of these repeaters will exceed 12 kw average EIRP with a maximum
peak-to-average power ratio of 13 dB, which is the maximum power level the Commission permits
in its new rules for satellite radio terrestrial repeaters.2

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
“WCS/SDARS Order”). The WCS/SDARS 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).

Ms. Marlene H. Dortch
November 18, 2010
Page 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. Sirius XM seeks to operate terrestrial repeaters at the locations
identified on Exhibit A hereto, all of which are sites at which Sirius XM will co-locate repeaters for
use on the legacy Sirius network and the legacy XM network. Co-locating Sirius XM terrestrial
repeaters offers efficiencies in constructing and operating the Sirius XM repeater network while
providing the level of service that the Commission has recognized is necessary in connection with
the provision of quality satellite radio service.

Technical Information for the New Low Power Repeaters. The following technical information
pertaining to the repeaters is provided in Exhibit A: (1) antenna type; (2) antenna orientation;

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
November 18, 2010
Page 3

(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 sheet for the antenna to be used by the repeater is
attached as Exhibit D.

Interference Considerations. The repeaters proposed in this application will all operate below
12 kw EIRP. The Commission recognized in the WCS/SDARS 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.”7 Moreover, 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
even 2 kW or less is not an interference concern8 and the Commission said in the WCS/SDARS
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 Comcast and Horizon Wi-Com in satisfaction of this
coordination requirement.10 However, if prohibited interference does occur, Sirius XM will cease
operation of the repeaters until such interference can be eliminated.11

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
WCS/SDARS Order at Para. 243.
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 the WCS Coalition has said it will defer from objecting to Sirius
XM’s 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). Sirius XM agrees to these conditions.
9
See WCS/SDARS 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 Comcast has certified that it operates WCS
stations serving the Detroit area (Call Signs WPQL632 and KNLB278) and Horizon Wi-Com has
certified that it operates WCS stations serving the Providence area (Call Sign KNLB210), the
Bethesda area (Call Sign KNLB315), and the Norfolk area (Call Sign KNLB316). It is not clear
from these certifications whether the base stations are receiving transmissions from CPE or are
engaged in transmit-only operations. If only the latter, potential interference to the base station is

Ms. Marlene H. Dortch
November 18, 2010
Page 4

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;
(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;

not an issue. In any event, Sirius XM has determined the repeaters proposed in this application are
highly unlikely to not create any interference concern for Horizon’s and Comcast’s operating WCS
sites 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
Sirius CLE
Cleveland, OH 09-05 41-30-00 81-41-29 EMS FR90-16-00NVL 70 656 0 3500
(Sector 1)
Sirius CLE
Cleveland, OH 09-05 41-30-00 81-41-29 EMS FR90-16-00NVL 260 656 0 3500
(Sector 2)
XM CLE002S
Cleveland, OH 41-30-00 81-41-29 TA-2335-DAB-H 90 613 0 3000
(Sector 1)
XM CLE002S
Cleveland, OH 41-30-00 81-41-29 TA-2335-DAB-H 225 613 0 3000
(Sector 2)
Sirius PRO
Providence, RI 33-03 41-49-31 71-24-36 HMD8V360-R05-H 0 428 0 3000
(Sector 1)
Sirius PRO
Providence, RI 33-03 41-49-31 71-24-36 HMD8V360-R05-H 0 428 0 3000
(Sector 2)
XM PRO001S
Providence, RI 41-49-31 71-24-36 HMD8V360-R05-H 0 428 0 2500
(Sector 1)
Sirius WDC
Bethesda, MD 46-26 38-59-04 77-05-45 EMS FR90-17-00NVL 90 192 7 3000
(Sector 1)
Sirius WDC
Bethesda, MD 46-26 38-59-04 77-05-45 EMS FR65-18-00NVL 210 192 7 3500
(Sector 2)
Sirius WDC
Bethesda, MD 46-26 38-59-04 77-05-45 EMS FR90-17-00NVL 330 192 0 3000
(Sector 3)

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
Bethesda, MD WDC312S 38-59-04 77-05-45 TA-2350-DAB 0 206 0 2000
(Sector 1)
Sirius NOX
New Orleans, LA 26-01 29-57-00 90-04-16 HMD8V360-R05-H 0 709 0 3000
(Sector 1)
Sirius NOX
New Orleans, LA 26-01 29-57-00 90-04-16 HMD8V360-R05-H 0 709 0 3000
(Sector 2)
XM
New Orleans, LA NOX011S 29-57-00 90-04-16 HMD8V360-R05-H 0 709 0 2500
(Sector 1)
Sirius DET
Detroit, MI 14-34 42-22-19 83-22-34 TA-2335-DAB-H 270 127 6 3500
(Sector 1)
Sirius NOR
Norfolk, VA 47-02 36-50-44 76-17-26 HMD8V360-R05-H 0 270 0 3000
(Sector 1)
Sirius NOR
Norfolk, VA 47-02 36-50-44 76-17-26 HMD8V360-R05-H 0 270 0 3000
(Sector 2)
XM
Norfolk, VA NOR002S 36-50-44 76-17-26 HMD8V360-R05-H 0 270 0 2500
(Sector 1)

Exhibit D

Antenna Specification Sheet for Repeater

Document Created: 2010-11-18 16:17:32
Document Modified: 2010-11-18 16:17:32

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