Letter re Power Leve

LETTER submitted by Sirius XM Radio Inc.

Letter Regarding Power Levels

2012-05-11

This document pretains to SES-MOD-20111123-01394 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2011112301394_951744

                                                                                SatCom Law LLC
                                                                         1317 F St. NW, Suite 400
                                                                         Washington, D.C. 20004
                                                                                 T 202.599.0975
                                                                             www.satcomlaw.com

May 11, 2012

By Electronic Filing

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

Re:       Power Level Correction for Sirius XM Radio Inc. Earth Station Modification
          File No. SES-MOD-20111123-01394, Call Sign E040363

Dear Ms. Dortch:

Sirius XM Radio Inc. (“Sirius XM”), by its attorney, hereby clarifies the above-referenced
application for modification of the E040363 earth station (the “E040363 Modification”) to correct
the power levels specified for one of the carriers and withdraw the associated waiver request.

In the E040363 Modification, Sirius XM sought authority to change the earth station antenna
and make related revisions to the technical parameters of the license. Sirius XM explained that
this earth station is used to transmit programming to the company’s network of terrestrial
                                                         1
repeaters, requiring a high level of signal availability. Sirius XM proposed to use uplink power
control (“UPC”) in order to ensure that the signal from the new antenna is strong enough to
                                      2
overcome atmospheric attenuation. Sirius XM explained that at the highest UPC power
settings, the maximum input spectral power density for one of the transmit carriers, emission
designator 11M0G7W, would exceed the limit of -14 dBW/4 kHz specified in Section 25.212 of
                          3
the Commission’s rules. Sirius XM requested any necessary waiver of Section 25.212 in
connection with its proposed use of UPC for this carrier on an ALSAT basis.4 Sirius XM noted,
however, that use of UPC to overcome rain fade for this carrier appeared to be expressly
authorized by Section 25.204(e) of the Commission’s rules.5


1
    See File No. SES-MOD-20111123-01394, Exhibit A at 1.
2
    Id.
3
    Id.
4
    Id. at 2-3.
5
    Id. at 2.


Ms. Marlene H. Dortch                          -2-                                   May 11, 2012


Based on subsequent conversations with Commission staff, Sirius XM now seeks to change the
maximum input power spectral density requested for the 11M0G7W transmit carrier to comply
with the Section 25.212 limit of -14 dBW/4 kHz. Specifically, Sirius XM advises the Commission
that in the Schedule B for the E040363 Modification, the answers to items E48 and E49 for the
emission designator 11M0G7W in transmit mode operating in the 14-14.5 GHz band should be
changed as follows:

       E48. Maximum EIRP per Carrier (dBW): 79.78 instead of 84.0
       E49. Maximum EIRP Density per Carrier (dBW/4kHz): 45.39 instead of 49.61

Because it no longer seeks authority for a maximum input power spectral density in excess of
that specified in Section 25.212, Sirius XM withdraws its request for waiver of that rule. Sirius
XM understands that it will be allowed to use UPC to exceed the power levels specified in the
E040363 license consistent with the terms of Section 25.204(e) of the Commission’s rules.

Accordingly, Sirius XM respectfully requests that the Commission update its records relating to
the E040363 Modification to reflect the change in power specifications for emission designator
11M0G7W as described herein and the withdrawal of the associated waiver request. Sirius XM
respectfully requests expedited action on the E040363 Modification as updated.

Please let me know if you have any questions regarding this matter.

Respectfully submitted,

/s/ Karis A. Hastings

Karis A. Hastings
Counsel for Sirius XM Radio Inc.
karis@satcomlaw.com

cc:    Paul Blais



Document Created: 2012-05-11 09:29:44
Document Modified: 2012-05-11 09:29:44

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