Attachment Narrative

This document pretains to SES-STA-20110425-00501 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011042500501_885454

                                     Before the
                      FEDERAL COMMUNICATIONS COMMISSION
                               Washington, D.C. 20554


In the Matter of Application by                )
                                               )
XM RADIO INC.                                  ) Call Signs S2786, E000158, & E040204
                                               )
For Special Temporary Authority to             )
Activate XM-5 for Performance Testing          )

                  REQUEST FOR SPECIAL TEMPORARY AUTHORITY
                                                                   1
               By this application, XM Radio Inc. (“XM Radio”), respectfully requests special

temporary authority (“STA”) for a period of up to 30 days, commencing May 9, 2011, to permit
                                                                         2
XM Radio to activate the communications payload of its XM-5 satellite and transmit to the

satellite using XM Radio’s Washington, D.C. and Ellenwood, GA feeder link earth stations.

XM-5 is an in-orbit spare spacecraft that was launched in October 2010. XM Radio proposes to

activate XM-5 for a limited period to conduct additional performance tests on the XM-5 payload.

Grant of the requested authority will permit XM Radio to make more detailed assessment of the

performance characteristics of XM-5 and evaluate its ability to provide replacement capacity in

the event XM-5 is needed for primary service in response to an anomaly with an operating

satellite. The call signs of the space station and earth stations for which STA is requested are

listed in the caption above.

               XM-5 is authorized to serve as an in-orbit spare for XM Radio’s fleet of satellite

digital audio radio service (“SDARS”) spacecraft that provide a high-quality, continuous, multi-

1
    XM Radio is a wholly-owned subsidiary of Sirius XM Radio Inc. (“Sirius XM”).
2
    The Commission recently authorized XM Radio to relocate XM-5 to 85.15º W.L. and
operate it there with +/- 0.1 degree east-west stationkeeping. See File No. SAT-MOD-
20101216-00264 (Call Sign S2786), grant-stamped Mar. 8, 2011.


                                                     3
channel audio service throughout the United States. XM-5 is also equipped with frequencies

allowing it to serve as back-up capacity for the SDARS services of XM Radio’s affiliate,
                    4
Satellite CD Radio. The XM-5 license authorizes activation of the satellite’s communications

payloads only “in the event of a service outage of the XM-3 (Call Sign: S2617), XM-4 (Call

Sign: S2616), FM-1, FM-2, FM-3 (Call Sign: S2105), or FM-5 (Call Sign: S2710) space
         5
stations.”

               Immediately following launch, XM Radio performed a series of in-orbit payload

tests of XM-5 while the satellite was temporarily located at 80º W.L. to assess the spacecraft’s
                               6
performance characteristics. XM Radio requests authority to conduct additional tests of XM-5’s

performance now at its operating orbital position in order to be better prepared if a future

anomaly in an operating satellite requires activation of the XM-5 satellite.

               During the testing period, XM Radio’s existing feeder link earth stations in

Washington, D.C. (Call Sign: E000158) and Ellenwood, GA (Call Sign: E040204) will transmit
         7
to XM-5. Testing will use the frequencies for which the earth stations and XM-5 are authorized,

with uplinks in the X-band, 7056.8450-7074.8690 MHz, and downlinks in the S-band, 2332.5-


3
    See File No. SAT-LOA-20090217-00025 (Call Sign S2786), grant-stamped Aug. 31, 2009.
4
    See id.
5
     Id., Attachment at ¶ 2.
6
     See File No. SAT-STA-20100917-00194, grant-stamped Oct. 22, 2010 (authorizing
positioning of XM-5 at 80º W.L., testing at that location, and drift to 85.2º W.L. following
completion of testing).
7
    These earth stations are authorized to communicate with XM-5. See File Nos. SES-MOD-
20101022-01323 (E000158) & SES-MOD-20101022-01324 (E040204), both granted Jan. 4,
2011.


                                                 2


             8
2345.0 MHz. The testing transmissions from the feeder link earth stations will include the

authorized modulated carrier or an unmodulated carrier operating at or below the earth stations’

maximum authorized EIRP of 78 dBW. In all other respects, the transmissions for purposes of

testing will conform to the technical specifications of the earth stations’ licenses.

                 The temporary testing is expected to have no impact on listeners of XM Radio’s

satellite radio network. Furthermore, the proposed testing will not cause harmful interference to

the operations of any other spacecraft. There are no satellites using either S-band or X-band

frequencies within two degrees of 85.2° W.L. other than satellites licensed to XM Radio. XM

Radio does not share S-band spectrum with other satellite systems (except its affiliate, Satellite

CD Radio), and the SDARS downlink frequencies are not subject to two degree spacing rules.

                 The proposed testing will also not result in harmful interference to regularly

authorized terrestrial operations. The feeder link earth stations that will be communicating with

XM-5 have been coordinated with terrestrial licensees for the frequencies and EIRP levels
                                                                                        9
proposed for use here, and the coordination arc includes the XM-5 orbital location. XM Radio

will not exceed the previously-coordinated parameters during the proposed testing.

                 For the foregoing reasons, XM Radio respectfully requests special temporary

authority for a period of up to 30 days commencing May 9, 2011 to activate the XM-5

communications payload and transmit to the satellite using XM Radio’s feeder link earth

stations. Grant of the requested authority will serve the public interest by facilitating XM

8
     As noted above, XM-5 is also capable of operating in the S-band frequencies authorized to
Satellite CD Radio, 2320-2332.5 MHz, but no testing of this portion of the XM-5 payload is
planned during the period of the requested STA.
9
    See Exhibit B to File Nos. SES-MOD-20101022-01323 (E000158) (eastern limit of the
coordination arc is 85.0º W.L.) & SES-MOD-20101022-01324 (E040204) (eastern limit of the
coordination arc is 80.0º W.L.).


                                                  3


Radio’s ability to better evaluate the performance of the XM-5 space station and will not result in

harmful interference to any other regularly authorized operations.

                                             Respectfully submitted,

                                             XM Radio Inc.

                                             /s/ James S. Blitz
                                             James S. Blitz
                                             Vice President, Regulatory Counsel
                                             XM Radio Inc.
                                             1500 Eckington Place, N.E.
                                             Washington, D.C. 20002
                                             (202) 380-4000
Karis A. Hastings
Hogan Lovells US LLP
555 Thirteenth Street, N.W.
Washington, D.C. 20004
(202) 637-6400
Counsel for XM Radio Inc.

April 25, 2011




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Document Created: 2011-04-25 15:04:39
Document Modified: 2011-04-25 15:04:39

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