Attachment STA Request

This document pretains to SAT-STA-20110907-00173 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011090700173_915448

Sirius XM Radio Inc. 1500 Eckington Place NE Washington, DC 20002 T: 202-380-4000 F: 202-380-4500 siriusxm.com September 7, 2011 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 Bulk Extension of Special Temporary Authority to Operate Terrestrial Repeaters at Various Locations for 180 Days, FCC File No. SAT-STA-20110303-00047 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 Special Temporary Authority (“STA”) to operate terrestrial repeaters. Sirius XM requests extension of the STA grant listed above to operate these repeaters in the Sirius frequency band (2320- 2332.5MHz) at various locations across the United States, 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. Absent renewal, these STAs will expire on September 11, 2011.1 The Commission’s May 20, 2010 decision adopting formal rules for satellite radio terrestrial repeaters established mechanisms to facilitate the continued operation of repeaters under STA until the new rules were fully in effect, including directing the staff to provide a uniform expiration date for all such STAs: In order to effect an orderly transition from operations under grants of STA to permanent authority to operate terrestrial repeaters, we instruct the International Bureau to extend all existing grants of STA for SDARS repeaters for a period of 1 Because this request is timely, pursuant to Section 1.62 of the Rules, the listed STAs 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.

Ms. Marlene H. Dortch September 7, 2011 Page 2 180 days from the release date of this Second Report and Order.2 The instant application asks that the Bureau grant the bulk STA extension contemplated in the 2010 Order. 3 Incorporating multiple extension applications into a single filing facilitates the STA process going forward by establishing a consistent expiration date for many of Sirius XM’s repeater STA grants. Sirius XM currently operates these repeaters pursuant to an STA granted by the International Bureau on May 11, 2011 and covering a 180-day period beginning on March 15, 2011. Sirius XM has not changed technical parameters for the repeaters since the original grants of the STAs and is not herein requesting modification of any of those parameters. Renewing this STA will serve the public interest by assisting the Bureau to implement the Commission’s directive in the 2010 Order concerning STA extensions and will enable Sirius XM to continue to provide a quality signal to its subscribers at various locations across the United States. During the time the referenced STAs have been operating, Sirius XM has not been made aware of any incidents where the equipment has caused any interference to other radio services. None of these repeaters will exceed 12 kw average EIRP, which is the maximum power level the Commission permits in its new rules for satellite radio terrestrial repeaters.4 2 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, at Para. 264 (released May 20, 2010) (the “2010 Order”). The 2010 Order also allows Sirius XM to request further 180 day extensions of this initial 180 day automatic extension “[i]n the event blanket licenses are not issued within 180 days of the effective date of this Order.” Id., note 615. The Commission cannot grant these blanket licenses 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 (Aug. 2, 2010); 76 Fed. Reg. 30706 (May 26, 2011). 3 A similar Request for Bulk STA Extension is being filed for the terrestrial repeater STA grants issued to XM Radio LLC. 4 47 C.F.R. § 25.214(d)(1). The Commission concluded in the 2010 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 September 7, 2011 Page 3 Sirius XM will continue to comply with the conditions the Commission imposed in granting the referenced STAs to operate these repeaters. These conditions and the technical parameters of the repeaters have provided sufficient protection to other radio services. Sirius XM is submitting payment to the Federal Communications Commission in the amount of Two Thousand Eight Hundred Sixty Dollars ($2860.00) -- the filing fee applicable to requests for STAs for non-geostationary (“NGSO”) satellites.5 Please direct any questions regarding this matter to the undersigned. Very truly yours, James S. Blitz Vice President, Regulatory Counsel cc: Stephen Duall, FCC International Bureau Jay Whaley, FCC International Bureau Sankar Persaud, FCC International Bureau 5 See International and Satellite Services Fee Filing Guide (February 2009).


Document Created: 2011-09-07 16:02:15
Document Modified: 2011-09-07 16:02:15
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