Attachment Exhibit A

This document pretains to SES-MOD-20150127-00042 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2015012700042_1074262

                                                                          FCC Form 312, Exhibit A
                                                                               Call Sign E080168
                                                                                       Page 1 of 7

                     EXHIBIT A: DESCRIPTION OF MODIFICATION

               Sirius XM Radio Inc. (“SiriusXM”), a satellite digital audio radio service

(“SDARS”) licensee, applies for a modification of the license for its Ellenwood, GA, earth

station, Call Sign E080168. 1 The purpose of the modification is to: (1) simplify and update the

license by reducing the number of separate carriers authorized; (2) specify a broader range of the

geostationary arc for communications, consistent with prior coordination for the earth station;

and (3) seek flexibility to allow communications with SDARS satellites operated by SiriusXM

affiliates during and after authorized relocations of the satellites without the need for additional

authority. 2 Grant of these modifications will serve the public interest by enhancing SiriusXM’s

ability to use the E080168 facilities to support the provision of SDARS to over 26 million

customers.

               The specific requested modifications are described in this exhibit and set forth in

the accompanying Form 312, Schedule B. Apart from these changes, SiriusXM certifies that the

information previously provided to the Commission regarding this facility remains complete and

accurate.

               License Simplification and Update. First, SiriusXM proposes changes to

Section B of its current license, Particulars of Operations, which currently lists characteristics for


1
 See Call Sign E080168, File No. SES-MOD-20130315-00265, granted May 9, 2013 (“E080168
License”).
2
 SiriusXM also advises the Commission that one of the space stations with which E080168 is
currently authorized to communicate, the XM-2 spacecraft (Call Sign S2119), has been retired
and therefore can be removed from the points of communication identified in Section D of the
E080168 License. See Letter of Karis A. Hastings, Counsel for XM Radio LLC, to Marlene H.
Dortch, Secretary, Federal Communications Commission submitted Oct. 30, 2014 in File
No. SAT-STA-20141017-00109 (advising the Commission that XM-2 has been placed in a
disposal orbit and requesting termination of the license account in the IBFS database).


                                                                           FCC Form 312, Exhibit A
                                                                                Call Sign E080168
                                                                                        Page 2 of 7

a total of 44 carriers for the three feeder link antennas at this site. 3 SiriusXM proposes to

consolidate and streamline the information provided in this section by combining carriers with

similar characteristics, deleting redundant or unnecessary carriers, and updating the license by

specifying additional emission designators.

                 The attached Form 312, Schedule B, provides the information regarding the

carriers that SiriusXM wishes to retain as modified or add. SiriusXM requests that the

Commission remove the remaining carriers from the E080168 license. Details for the changes

associated with each of the feeder link antennas are provided below.

                                                  Feeder 1

                 The carriers numbered 1-10 on the current E080168 License are associated with

the Feeder 1 antenna. SiriusXM requests that the Commission modify the parameters for carriers

1, 3, 5, and 7, as set forth below and in the Schedule B. SiriusXM asks that current carriers 2, 4,

6, 8, 9, and 10 be deleted from the license.

    Modified                                         Max.      Max.
    or New                                          EIRP/      EIRP      Assoc.       Modulation/
     Carrier     Freq.    Pol.   Emission   T/R     Carrier   Density   Antenna         Services
    Modified    7060-      R     4M50G7E     T       75.0      44.5     Feeder 1    TDM QPSK 8PSK
    carrier 1   7072.5                                                               16QUAM DARS
                                                                                       PROGRAM
                                                                                        UPLINK
    Modified    7051.5-    L     1M00F1D    T        75.0      51.0     Feeder 1      PCM/PSK/FM
    carrier 3   7056.5                                                                 COMMAND
    Modified     2320-     R     300KG1D    R         0         0       Feeder 1     BIPHASE PCM
    carrier 5   2332.5                                                                TELEMETRY
    Modified     2320-     L     4M50G7E    R         0         0       Feeder 1    TDM QPSK 8PSK
    carrier 7   2332.5                                                               16QUAM DARS
                                                                                       PROGRAM
                                                                                       DOWNLINK




3
    See E080168 License, Section B, Particulars of Operations.


                                                                         FCC Form 312, Exhibit A
                                                                              Call Sign E080168
                                                                                      Page 3 of 7

                                             Feeder 2

               The carriers numbered 11-27 on the current E080168 License are associated with

the Feeder 2 antenna. SiriusXM requests that the Commission modify the parameters for current

carriers 11, 13, 15, 17, 19, and 22, and add four carriers reflecting updated operational

parameters, as set forth below and in the Schedule B. SiriusXM asks that current carriers 12, 14,

16, 18, 20, 21, 23, 24, 25, 26, and 27 be deleted from the license.

 Modified                                           Max.       Max.
  or New                                           EIRP/       EIRP       Assoc.      Modulation/
  Carrier       Freq.     Pol.   Emission    T/R   Carrier    Density    Antenna        Services
 Modified      7060-       R     4M50G7E      T     75.0       44.5      Feeder 2      TDM QPSK
 carrier 11    7072.5                                                                8PSK 16QUAM
                                                                                         DARS
                                                                                       PROGRAM
                                                                                        UPLINK
 Modified      7051.5-     L     1M00F1D      T      75.0      51.0      Feeder 2     PCM/PSK/FM
 carrier 13     7056.5                                                                 COMMAND
 Modified     6422-6425    L     1M00F1D      T      75.0      51.0      Feeder 2     PCM/PSK/FM
 carrier 15                                                                            COMMAND
 Modified      4196.3-     R     300KG1D      R       0          0       Feeder 2    BIPHASE PCM
 carrier 17    4197.2                                                                 TELEMETRY
 Modified       2320-      R     300KG1D      R       0          0       Feeder 2    BIPHASE PCM
 carrier 19    2332.5                                                                 TELEMETRY
 Modified       2320-      L     4M50G7E      R       0          0       Feeder 2      TDM QPSK
 carrier 22    2332.5                                                                8PSK 16QUAM
                                                                                         DARS
                                                                                       PROGRAM
                                                                                       DOWNLINK
   New        7056.845-   L,R    1M84G1W      T      75.0      48.4      Feeder 2      TDM QPSK
 emission     7074.869                                                               8PSK 16QUAM
designator                                                                               DARS
                                                                                       PROGRAM
                                                                                        UPLINK
   New         7042.6-     L     800KF2D      T      75.0      52.0      Feeder 2     PCM/PSK/FM
 emission      7074.4                                                                  COMMAND
designator
   New         2332.5-     R     100KG2D      R       0          0       Feeder 2    BIPHASE PCM
 emission       2345                                                                  TELEMETRY
designator
   New         2332.5-     L     1M84G1W      R       0          0       Feeder 2     TDM QPSK
 emission       2345                                                                 8PSK 16QUAM
designator                                                                              DARS
                                                                                      PROGRAM
                                                                                      DOWNLINK


                                                                         FCC Form 312, Exhibit A
                                                                              Call Sign E080168
                                                                                      Page 4 of 7

                                             Feeder 3

               The carriers numbered 28-44 on the current E080168 License are associated with

the Feeder 3 antenna. SiriusXM requests that the Commission modify the parameters for carriers

28, 30, 32, 34, 36, and 39, and add four carriers reflecting updated operational parameters, as set

forth below and in the Schedule B. SiriusXM asks that current carriers 29, 31, 33, 35, 37, 38, 40,

41, 42, 43, and 44 be deleted from the license.

 Modified                                           Max.      Max.
  or New                                           EIRP/      EIRP       Assoc.      Modulation/
  Carrier       Freq.     Pol.   Emission    T/R   Carrier   Density    Antenna        Services
 Modified      7060-       R     4M50G7E      T     75.0      44.5      Feeder 3      TDM QPSK
 carrier 28    7072.5                                                               8PSK 16QUAM
                                                                                        DARS
                                                                                      PROGRAM
                                                                                       UPLINK
 Modified      7051.5-      L    1M00F1D      T     75.0       51.0     Feeder 3     PCM/PSK/FM
carrier 30      7056.5                                                                COMMAND
 Modified     6422-6425     L    1M00F1D      T     75.0       51.0     Feeder 3     PCM/PSK/FM
carrier 32r                                                                           COMMAND
 Modified      4196.3-     R     300KG1D      R       0         0       Feeder 3    BIPHASE PCM
carrier 34r    4197.2                                                                TELEMETRY
 Modified       2320-      R     300KG1D      R       0         0       Feeder 3    BIPHASE PCM
carrier 36     2332.5                                                                TELEMETRY
 Modified       2320-       L    4M50G7E      R       0         0       Feeder 3      TDM QPSK
carrier 39     2332.5                                                               8PSK 16QUAM
                                                                                        DARS
                                                                                      PROGRAM
                                                                                      DOWNLINK
   New        7056.845-    L,R   1M84G1W      T     75.0       48.4     Feeder 3      TDM QPSK
 emission     7074.869                                                              8PSK 16QUAM
designator                                                                              DARS
                                                                                      PROGRAM
                                                                                       UPLINK
   New         7042.6-      L    800KF2D      T     75.0       52.0     Feeder 3     PCM/PSK/FM
 emission      7074.4                                                                 COMMAND
designator
   New         2332.5-     R     100KG2D      R       0         0       Feeder 3    BIPHASE PCM
 emission       2345                                                                 TELEMETRY
designator
   New         2332.5-      L    1M84G1W      R       0         0       Feeder 3     TDM QPSK
 emission       2345                                                                8PSK 16QUAM
designator                                                                             DARS
                                                                                     PROGRAM
                                                                                     DOWNLINK


                                                                            FCC Form 312, Exhibit A
                                                                                 Call Sign E080168
                                                                                         Page 5 of 7

                Extended Satellite Arc: Second, SiriusXM proposes to modify and update

Section C of the E080168 License, Frequency Coordination Limits, to conform to the ranges of

frequencies and satellite arcs for which the earth station’s antennas have been coordinated.

Section C of the current E0801688 License includes five entries for frequency ranges and

associated operational data. SiriusXM proposes to modify the data listed in items 1, 3, and 4,

retain the data in items 2 and 5 with no changes, and add two new entries, as set forth in the table

below and in the Schedule B.

                   Satellite Arc       Elevation         Azimuth          Max EIRP
                   (Deg. Long.)        (Degrees)        (Degrees)          Density
    Frequency                                                              toward
      Limits       East West         East West         East West           Horizon        Associated
#     (MHz)        Limit Limit       Limit Limit       Limit Limit       (dBW/4kHz)        Antennas
1   7040-7075       80W-120W          50.6 - 35.4      172.3 - 232.4         -9.6          Feeder 1
2   6422-6425          NGSO                                                   2.5           Feeder 3
3   7040-7075       25W-140W           16.8-19.8       108.2-249.3            2.5           Feeder 3
4   7040-7075       25W-140W           16.8-19.8       108.2-249.3            2.5           Feeder 2
5   6422-6425          NGSO                                                   2.5           Feeder 2
6   7040-7075          NGSO                                                   2.5           Feeder 2
7   7040-7075          NGSO                                                   2.5           Feeder 3


                SiriusXM has coordinated the proposed changes to the technical parameters of the

E080168 License with terrestrial networks, as reflected in the Comsearch report attached as

Exhibit B to the application.

                Requested Flexibility: Finally, SiriusXM requests added flexibility so that its

authority to use the E080168 antennas to communicate with SDARS satellites licensed to

SiriusXM’s affiliates is not limited to the specific orbital locations identified in the license.

Instead, SiriusXM seeks authority to communicate with SDARS satellites during and after any

authorized relocations of those satellites, provided that the operations otherwise conform to the


                                                                          FCC Form 312, Exhibit A
                                                                               Call Sign E080168
                                                                                       Page 6 of 7

terms of the E080168 License. Granting this flexibility will avoid the need to request a license

modification or special temporary authority for E080168 each time the Commission may

authorize a change in the location of an SDARS satellite.

                For example, in preparation for the retirement of the XM-1 satellite, SiriusXM’s

affiliate XM Radio LLC plans to relocate the satellite eastward from its current position at

115.25° W.L. to 39° W.L., maintain the satellite at the latter location for an interim period, and

then commence orbit-raising maneuvers during which the satellite will be drifting westward. 4

These moves will all be within the orbital arc for which E080168 has been coordinated, but the

current terms of the E080168 License permit the earth station to communicate with XM-1 only at

115.25° W.L. 5 Thus, absent grant of the requested flexibility, SiriusXM would need to request

and the Commission would need to grant special temporary authority to allow SiriusXM to use

the E080168 antennas to support XM-1’s retirement.

                Although SiriusXM and its affiliates do not contemplate further changes in

satellite locations at this time (other than those of which the Commission is already aware),

should any such changes become necessary, allowing SiriusXM the requested flexibility would

avoid the need to expend Commission resources on such requests and will not result in harmful

interference to other authorized communications systems. SiriusXM’s affiliates hold exclusive

rights to the S-band frequencies used for SDARS downlink operations, so no other satellite

operators will be affected by the use of those frequencies. Similarly, grant of this request will

not cause harmful interference to terrestrial facilities operating in the X-band frequencies, as the

proposed operations have been fully coordinated with terrestrial networks.

4
    See XM Radio LLC, Call Sign S2118, File No. SAT-STA-20141017-00110.
5
    See E080168 License, Section D, Points of Communications.


                                                                         FCC Form 312, Exhibit A
                                                                              Call Sign E080168
                                                                                      Page 7 of 7

              To implement the requested flexibility, SiriusXM proposes that the Commission

add a condition to the E080168 License. SiriusXM suggests the following language for the

Commission’s consideration:

              SiriusXM’s authority to communicate with the satellites listed in Section D of this
              license is not limited to the specific orbital locations identified in that section.
              SiriusXM may communicate with the listed satellites at any location authorized
              by the Commission, provided such operations are consistent with Sections B and
              C of this license.

              The changes proposed herein will serve the public interest by enhancing

SiriusXM’s ability to employ the antennas licensed under E080168 to support the delivery of

reliable, diverse programming to satellite radio customers nationwide.



Document Created: 2015-01-27 09:34:11
Document Modified: 2015-01-27 09:34:11

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