Attachment XM Radio - Grant Nov

XM Radio - Grant Nov

DECISION submitted by IB,FCC

Grant

2014-11-26

This document pretains to SAT-STA-20141017-00110 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014101700110_1070441

s2118          SAT—STA—20141                                                         File # S¢t siBb—201 1017— COno
XM Radio LLC                   se              1B2014002063
XM—1
                                                                                     Call Sign S2148           Grant Date 11/2 6 /4
                                                                                     (or other identifier)                          1
                                                                                                               Term Dates perie d of       Approved by OMB
                                                                                                                        To:   ISC O"Qflé_         3060—0678
                                                                                    | From 11 /Z7(l‘i

       Date & Time Filed: Oct 17 2014 12:12:19:693PM
                                                                              '   1_| Approved:
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       File Number: SAT—STA—20141017—00110                                                                   Sféfile‘)_ s Dg*[‘ Garh
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       Callsign:
                                                  FEDERAL COMMUNICATIONS COMMISSION
                                        APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                                FOR OFFICIAL USE ONLY


         APPLICANT INFORMATION
    Enter a description of this application to identify it on the main menu:
       XM—1 (S2118) Retirement STA Extension and Modification Oct 2014
       1. Applicant


                    Name:         XM Radio LLC                     Phone Number:                               202—380—1 383
                    DBA Name:                                      Fax Number:                                 202—380—4981

                    Street:       1221 Avenue of the Americas      E—Mail:                                     james.blitz@siriusxm.com
                                  36th Floor
                    City:         New York                         State:                                      NY

                    Country:      USA                              Zipcode:                                    10020          =—

                   . Attention:   James S. Blitz


                                              XM Radio LLC
                                  IBFS File No. SAT—STA—20141017—00110
                                              Call Sign $2118

The application of XM Radio LLC (XM Radio) for special temporary authority, IBFS File No.
SAT—STA—20141017—00110, is granted. Specifically, XM Radio is authorized, for a period of
180 days, commencing on November 27, 2014, to conduct Telemetry, Tracking, and Command
(TT&C) operations necessary to drift its Satellite Digital Audio Radio Service (SDARS) space
station, XM—1 (Call Sign $2118), from its current orbital location of 115.25° W.L. to the 39.0°
W.L. orbital location and to maintain it at that location with an east—west stationkeeping
tolerance of +/— 0.1 degrees. XM Radio is authorized to conduct such TT&C operations using
the following center frequencies: 2339.2 MHz, 2339.7 MHz, 2344.0 MHz, and 2344.5 MHz
(space—to—Earth); 7049.0 MHz and 7074.0 MHz (Earth—to—space). Additionally, we grant XM
Radio‘s request to operate beyond the current license term for the XM—1 space station during this
180—day period to allow XM Radio sufficient time to complete its planned maneuvers for XM—1
in preparation for the space station‘s removal to a disposal orbit.‘ All operations of the XM—1
space station must be in accordance with the technical specifications set forth in its application,
XM—1‘s current authorization, the Commission‘s rules, and the conditions set forth below.
        1. All operations under this grant of special temporary authority must be on an
unprotected and non—harmful interference basis, i.e., XM Radio shall not cause harmful
interference to, and must not claim protection from interference caused to it by, any other
lawfully operating radiocommunication system.
        2. In the event of any harmful interference as a result of the operations under this grant
of special temporary authority, XM Radio must cease operations immediately upon notification
of such interference and shall immediately inform the Commission, in writing, of such an event.
        3. XM Radio must coordinate the operations of XM—1 with existing geostationary space
stations to ensure that no unacceptable interference results from its operations during drift to the
39.0° W.L. orbital location.
        4. XM Radio must operate only the TT&C frequencies on XM—1 during the space
station‘s drift to and operations at the 39.0° W.L. orbital location.
        5. We grant XM Radio‘s request for a waiver of Section 25.210(j) of the Commission‘s
rules, 47 C.FR. § 25.210, to allow operation of XM—1 at 39.0° W.L. with an east—west
stationkeeping tolerance of +/— 0.1 degrees instead of the +/— 0.05 degree tolerance required by
the rule. XM Radio was previously granted a waiver of Section 25.210(j) to permit XM—1 to
operate with an east—west stationkeeping tolerance of +/— 0.1 degrees at 115.25° W.L. See IBFS
File No. SAT—MOD—20101216—00262 (Call Sign $2118), grant—stamped Mar. 8, 2011. We grant this
waiver for the same reasons as provided for the previous waiver at 115.25 W.L.
         6. Any action taken or expense incurred as a result of operations pursuant to this grant

‘ XM—1‘s authorization expired on May 31, 2014.XM Radio was previously granted special temporary authority for
180 days to perform these same maneuvers by drifting XM—1 to the 27.0° W.L. orbital position. See IBFS File No.
SAT—STA—20140321—00033, granted Apr. 30, 2014. However, in light of the experience XM Radio gained while
performing similar maneuvers for XM—1‘s companion space station, XM—2 (IBFS File No. SAT—STA—20140204—
00018, granted Mar. 28, 2014), XM Radio now proposes to drift XM—1 to 39° W.L, rather than 27° W.L., prior to
commencing of orbit raising maneuvers. Narrative at 1—3. XM Radio states that in order to deorbit XM—1
successfully, it must first drift the space station east to the 39.0° W.L. orbital location so that the westward drift of
the space station that will occur during the planned orbit—raising maneuver will not take XM—1 out of the range of
XM Radio‘s TT&C earth stations and thus lose control over the space station. Id.


                                                             1


                                      XM Radio LLC
                          IBFS File No. SAT—STA—20141017—00110
                                      Call Sign $2118

of special temporary authority is at XM Radio‘s own risk.
        7. This action is taken on delegated authority pursuant to 47 C.E.R. § 0.261 and is
effective upon release. Petitions for reconsideration under 47 C.F.R. § 1.106 or applications for
review under 47 C.F.R. § 1.115 may be filed within 30 days of the date of the Public Notice
announcing this action.



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                                         (or other identifier)
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2. Contact


             Name:          Karis A. Hastings                   Phone Number:                     _    202—599—0975
             Company:       SatCom Law LLC                      Fax Number:

             Street:        1317 F Street, N.W.                 E—Mail:                               karis@satcomlaw.com
                            Suite 400
             City:          Washington                          State:                                 DC
             Country:           USA                             Zipcode:                              20004      —
             Attention:                                         Relationship:                         Legal Counsel


   (If your application is related to an application filed with the Commission, enter either the file numberor the IB Submission ID of the related
application. Please enter only one.)
  3. Reference File Number SATSTA2014032100033 or Submission ID

  4a. Is a fee submitted with this application?
& IfYes, complete and attach FCC Form 159.          If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
C Governmental Entity           «3 Noncommercial educational licensee
C) Other(please explain):

4b. Fee Classification    CRY — Space Station (Geostationary)

5. Type Request             |           %

4 Change Station Location                          & Extend Expiration Date                           {4 Other


6. Temporary Orbit Location                                                7. Requested Extended Expiration Date
                                                                                2015—05—26 00:00:00.0


8. Description   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     XM Radio LLC re(juests extension and modification of the special temporary authority it was
     granted in File No.            SAT—STA—20140321—00033              to further extend the license term for the XM—1
      (§2118)    space station and permit relocation of the satellite to 39 deg. W.L.                                         +/— 0.1 deg.
     in preparation for its removal to a disposal orbit.




9. By checking Yeé, the undex;signed certifies that neither applicant nor any other party to the application is subject @ Yes              <4 No
to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988,
21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR
1.2002(b) for the meaning of &quot;party to the application&quot; for these purposes.


10. Name of Person Signing                                                  11. Title of Person Signing
James S. Blitz                                                              Vice President, Regulatory Counsel
12. Please supply any need attachments.
 Attachment 1: STA Narrative                       Attachment 2:                                      Attachment 3:


          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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                                                                           XM—1, Call Sign $2118
                                                                                          Page 1 of 4

              REQUEST FOR EXTENSION AND MODIFICATION OF STA

               XM Radio LLC ("XM Radio") respectfully requests extension and modification

of the special temporary authority ("STA") it was granted in File No. SAT—STA—20140321—

00033,‘ which extended the satellite‘s license term and authorized relocation of XM—1 to

27° W.L. in preparation for its removal to a disposal orbit. Specifically, XM Radio seeks a

further 180—day extension of the XM—1 license and authority to drift the satellite eastward, but to

a different location than currently authorized. Based on knowledge gained with a similar drift of

the XM—2 satellite, XM Radio now proposes to position XM—1 at 39° W.L, rather than 27° W.L.,

before beginning orbit raising maneuvers. Grant of the requested authority will serve the public

interest by facilitating the orderly retirement of XM—1.

                                           Background

               XM—1 is currently positioned at 115.25° W.L. with a +/— 0.1 degree east—west

stationkeeping tolerance, where it had been serving as an in—orbit spare." XM Radio began the

process of retiring both XM—1 and XM—2 last year, working closely with Boeing Satellite

Systems ("BSS"), the satellites‘ manufacturer. As XM Radio has explained, the planning

process has been especially complex because thqse are the first satellites in the XM Radio fleet

and the first spacecraft in the BSS 702 productline to be removed to a disposal orbit."

Furthermore, ground resources that are equipped to communicaté with the satellites in the XM




    See XM Radio LLC, Call Sign $2118, File No. SAT—STA—20140321—00033 (the "XM—1
Retirement STA"), grant—stamped Apr. 30, 2014.
    See XM Radio LLC, Call Sign S2118, File No. SAT-MOD-20101216-OO262 (the "XM—1
Modification"), grant—stamped Mar. 8, 2011 (the "XM—1 Modification Grant").

°   XM—1 Retirement STA, Narrative at 2.


  Radio fleet and have the tracking capabilities needed to support the satellite orbit raising and

  decommissioning process are extremely limited."

                     XM Radio propdsed to drift both XM—1 and XM—2 significantly eastward before

  beginning orbit—raising maneuvers in order to keep the satellites withfi range of its earth station

  network for a longer period during the decommissioning process. XM Radio advised the

  Commission that it would perform the necessary maneuvers for XM—2 first, and would start the

  drift of XM—1 eastward only afterit had completed the orbit raising process for XM—2.° XM

  Radio explained that this sequencing would allow XM Radio to make any appropriate

  adjustments to the XM—1 plan based on the results of the XM—2 satellite decommissioning and

  would permit use of the same ground facilities to suppofi the maneuvers of both satellites.°

                     Pursuant to Commission authority," XM—2 was relocated to 27° W.L. and held

  there during venting of onboard propellant, and the satellite is now being raised to a disposal

  orbit. XM Radio had originally planned to drift XM—1 to 27° W.L. as well, and it specified that

  location in the XM—1 Retirement STA. However, lessons learned from the XM—2 drift have led

  XM Radio to revise its plans for XM—1. In particular, communicating with XM—2 at the

  27° W.L. location required operating ground stations at a low elevation angle which created

  tec‘:hnical difficulties given the co—frequency operation of XM Radio‘s terrestrial repeater

  network. Although these issues were successfully managed in the case of XM—2, XM Radio can




  *    1Id. at 23.
205
       Id. at 3.

  °‘   1d.
  ‘   See XM Radio LLC, Call Sign $2119, File Nos. SAT—STA—20140204—00018, grant—stamped
  Mar. 28, 2014 & SAT—STA—20140922—00103, grant—stamped Sept. 26, 2014.


avoid them with XM—1‘s drift by using 39° W.L., rather than 27° W.L., as the location at which

XM—1 will be prepared for orbit raising.

                          Request for Continued Operating Authority

               XM Radio requests STA to extend the XM—1 license authority for a further 180—

day period. Grant of the requested extension will allow XM Radio to complete the

decommissioning of XM—2, finalize its plans for XM—1‘s retirement, and implement the eastward

drift of XM—1 necessary in preparation for raising the satellite to a disposal orbit.

                                   Revised Relocation Request

               XM Radio also seeks authority to relocate XM—1 to 39° W.L. instead of 27° W.L.

in preparation for retirement. The current schedule is to begin in mid—April 20158 to drift XM—1

from 115.25° W.L. to 39° W.L., maintain the satellite there with an east—west stationkeeping of

+/— 0.1 degrees® while venting excess propellant, and begin orbit—raising maneuvers in November

2015 following the autumn eclipse season.

               The same public interest factors underlying the Commission‘s decision to allow

relocation to 27° W.L. in the XM—1 Retirement STA support the revised request for relocation to

39° W.L. Specifically, grant of authority to move XM—1 to 39° W.L. will allow XM Radio to

maintain ground contact with XM—1 during orbit—raising maneuvers, and fio other operations will

be adversely affected. XM Radio will conduct the eastward drift of the spacecraft conséétent

with industry practice, providing advance notification of the relocation to operators of satellites



$   XM Radio had previously anticipated beginning XM—1‘s eastward drift of XM—1 in
November 2014 (see XM—1 Retirement STA, Narrative at 5), but the timing of the XM—2
decommissioning and constraints on availability of the necessary ground station resources have
pushed back the XM—1 retirement schedule.
°   XM Radio does not plan to perform north—south stationkeeping maneuvers while XM—1 is
positioned at 39° W.L.


that XM—1 will pass during its relocation and ensuring adequate separation between XM—1 and

other spacecraft.‘" Because the 39° W.L. location is unoccupied, XM—1 will not be collocated

with any other spacecraft while it remains at this position prior to commencing orbit raising

maneuvers. XM Radio has not changed its plan to raise XM—1 to a disposal orbit at least 313 km

above the geostationary arc, which is the altitude derived by application of the IADC standard."‘

               XM Radio seeks any waiver of Section 25.210(j) of the Commission‘s rules

necessary to permit XM—1 to be maintained at 39° W.L. with a +/—0.1 degree east—west

stationkeeping tolerance. Grant of this waiver is consistent with Commission precedent.‘" The

requested stationkeeping volume for XM—1 will not overlap with that of any other satellite.

               For the foregoing reasons, XM Radio respectfully requests special temporary

authority for a period of 180 days commencing on November 27, 2014, to extend the XM—1

license term and permit relocation of the satellite to 39° W.L. in preparation for retirement.

Grant of the requested authority will serve the public interest by facilitating the orderly removal

of XM—1 to a disposal orbit.




" See XM—1 Modification, Technical A’ppendix at 5 (describing measures to ensure safe
operation during satellite relocation).
_ See File No. SAT—AMD—20080129—00031 (Call Sign $2118), Attachment 1 at 3, grant—
stamped Feb. 14, 2008. Although no change to the disposal orbit altitude is proposed at this
time, XM Radio anticipates seeking Commussion authority for changes to the XM—1 orbital
debris mitigation plan. In particular, as with XM—2, the residual xenon projected to remain in
XM—1‘s xenon ion propulsion system at end of life will need to be revised. XM Radio will seek
authority for such changes in a subsequent request once decisions regarding the XM—1 retirement
plan have been finalized.
12
     See XM—1 Modification Grant at 1—2, [ 5 (granting waiver of Section 25.210(j) to permit
XM—1 to be operated with an east—west stationkeeping tolerance of +/— 0.1 degrees at the
115.25° W.L. orbital location).



Document Created: 2014-12-03 14:48:20
Document Modified: 2014-12-03 14:48:20

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