Attachment Satellite CD Radio -

Satellite CD Radio -

DECISION submitted by IB,FCC

GRANT

2015-07-30

This document pretains to SAT-STA-20150722-00050 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2015072200050_1098115

                                                                              File #3fl'"
                                                                                       —sm 20\50’722—00050
                                          1B2015001354   |                               $    4
$2105       SAT—STA—20150722—00050
Satellite CD Radio LLC                                                        Cansm BNAOS Grant Date 07 A30/15
                                                         |                    (otdflflt;nflflet)
                                                         |                    ¥HXRE!         Term Dates Pem: of              Approved by OMB
                                                                              From 06/01/i§            To: days                    3060—0678
                                                                           | Approved:
    Date & Time Filed: Jul 22 2015 11:38:41:510AM                                                         Duall
   File Number: SAT—STA—20150722—00050                                                        Ch ,Sa%“(k Polmj Branch
   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:
    Satellite CD Radio LLC, Request for Special Temporary Authority for 30 Days, Call Sign $2105
    1. Applicant

               Name:         Satellite CD Radio LLC             Phone Number:                     202—380—1383

               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


2. Contact


             Name:           Jennifer Hindin                    Phone Number:                        202—719—4975
             Company:        Wiley Rein LLP                     Fax Number:                          202—719—7049
             Street:         1776 K Street, NW                  E—Mail:                              jhindin@wileyrein.com


             City:           Washington                         State:

             Country:        USA                                Zipcode:                             20006      —
             Attention:                                         Relationship:                        Legal Counsel


  (If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
  3. Reference File Number       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          g*3 Noncommercial educational licensee
£74 Other(please explain):

4b. Fee Classification    CXW — Space Station (Non—Geostationary)

5. Type Request


{£4 Change Station Location                         4 Extend Expiration Date                        «) Other


6. Temporary Orbit Location                                                7. Requested Extended Expiration Date


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.)

     Satellite CD Radio LLC,                a wholly—owned subsidiary of Sirius XM Radio Inc.,                               requests a
     grant of Special Temporary Authority for 30—days, beginning August 1,                                           2015,    to operate the
     FM—1,       FM—2,   and FM—3 non—geostationary satellite orbit spacecraft                                 (call sign §$2105)            with
     relaxed orbital parameters as a result of suspension of certain station—keeping maneuvers.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject @ Yes                  <y 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                                                                V.P., Regulatory Counsel
12. Please supply any need attachments.
 Attachment 1: STA Request                           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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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


                                      Sirius XM Radio Inc.
                           Request for Special Temporary Authority

Satellite CD Radio LLC, a wholly—owned subsidiary of Sirius XM Radio Inc. ("Sirius XM"),
herein requests a grant of Special Temporary Authority ("STA") for 30—days, beginning August
1, 2015, to operate the FM—1, FM—2, and FM—3 non—geostationary satellite orbit ("NGSO")
spacecraft (call sign $2105, collectively the "Sirius NGSO Satellites") with relaxed orbital
parameters as a result of suspension of certain station—keeping maneuvers.‘

Grant of this STA is in the public interest because it will allow Sirius XM to extend the life of
the Sirius NGSO Satellites while conserving the propellant necessary to comply with end—of—life
maneuvers previously approved by the Commission." The suspension of certain station—keeping
maneuvers for the Sirius NGSO Satellites is similar to inclined orbit operations for geostationary
satellites: there will be a gradual growth of some of the orbital parameters but the orbit variations
will not increase physical or radio interference with other satellite operators. Because the
Commission has no inclined orbit rule for NGSO satellites," Sirius XM files the instant STA
request out of an abundance of caution.

The following table details the revised orbital parameters for the Sirius NGSO Satellites:




       Perigee Altitude              24,469 km               1    20           24,469 + 1200 km
      Apogee Altitude               47,102 km                     —            47,102 + 1200 km
    Ascending Equatorial            65.6 W +2°                    —              60.0 W +7.6°


1      As a result of the requested suspension of certain station—keeping maneuvers, Sirius XM
anticipates that the first satellite would exceed currently licensed parameters on August 16, 2015.
Sirius XM also is filing a 180—day STA request. Sirius XM anticipates operating pursuant to
these relaxed operating parameters until de—orbit of each of the NGSO satellites, which is
currently anticipated to occurin the second half of 2016. Sirius XM will seek renewal of its
STA authority as necessary.
2       See Satellite CD Radio, Inc., Application for Modification to Extend License Term and to
De—Orbit the FM—1, FM—2 and FM—3 Satellites, File No. SAT—MOD—20091119—00123 (stamp
grant Feb. 4, 2010).
>      Compare 47 C.F.R. § 25.280 (inclined orbit operations rule for geostationary satellites).
4       Satellite CD Radio, Inc., Application to Launch and Operate a Digital Audio Radio
Satellite Service in the 2320.0—2332.5 MHz Frequency Band, File No. SAT—MOD—19981211—
00099 (filed Dec. 11, 1998).
5      Satellite CD Radio, Inc., Application for Modification to Extend License Term and to
De—Orbit the FM—1, FM—2 and FM—3 Satellites, File No. SAT—MOD—20091119—00123 (filed Nov.
19, 2009).


          Crossing
    Descending Equatorxal             1264 W 42°                 _                 122.4 W £6°
           Crossing
       Perigee Radius                     —              30,847 +211 km        30,847 + 1200 km
       Apogee Radius                      —              53,841 +211 km        53,841 + 1200 km
         Eccentricity                   0.2684            0.2684 +0.005           0.2684 +0.03
          Inclination                 63.4 +/—7°             63.4 + 2°              63.4 +/—7°
    Argument of Perigee                   —                  270 + 2°                267 + 5°
     Right Ascension of               X, X+120°,            120 + 0.5°             X, X+120°,
  Ascending Node (RAAN)                X+240°                        *               X+240°
      Nominal Apogee                      o                                             o
          Longitude                     26° W                    _                    20° W


The revised orbital parameters will not increase the risk of collision with geostationary satellite
orbit ("GSO") satellites. Although eccentricity will drift beyond its nominal station—keeping
range resulting in variation of the nominal apogee and perigee altitudes, the apogee and perigee
altitude changes do not coincide with the equatorial crossings and thus will not impact safe
physical separation distances with GSO satellite operators. The relaxation of the eccentricity and
argument of perigee control will result in the equatorial crossings drifting from the nominal
65.6°%and 126.4°W longitude, but the altitudes of the equatorial crossings will not change
significantly and will remain a safe distance below the GSO altitude. GSO satellite operators are
typically concerned at proximities of less than 10 km and the Sirius NGSO Satellites will remain
at least 1300 km below the GSO altitude at the equatorial crossings. There is no increase in risk
of collision with a geostationary satellite because the Sirius NGSO Satellites altitude at the
equatorial crossings will be more than two orders of magnitude higher than a typical "close
approach" threshold defined by a geostationary satellite operator. Moreover, the inclination,
Right Ascension of the Ascending Node (RAAN), and nominal apogee longitude will not change
from the currently licensed limits.

In addition, there is no increase in risk of radio frequency interference with a GSO satellite
because the Sirius NGSO Satellites will continue to turn off the 4 GHz telemetry transmitter and
prohibit commanding in the 6 GHz band within 2° of the equatorial crossing. Furthermore, the
Sirius NGSO Satellites do not transmit S—band payload service near the equatorial crossings.
Sirius XM will continue to coordinate and communicate with other satellite operators and will
increase the frequency of its fleet coordination letter from bi—annually to quarterly. These
notifications will cover U.S. operators within +5° and non—U.S. operators within +10° of a Sirius
NGSO Satellite‘s equatorial crossing. Sirius XM will continue to monitor close approach limits
and should a Sirius NGSO Satellite get inside those limits, Sirius XM will notify any affected
operator and take necessary corrective actions.

In light of the above, Sirius XM respectfully requests Commission approval of this STA request.



Document Created: 2015-07-31 14:14:33
Document Modified: 2015-07-31 14:14:33

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