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FEDERAL COMMUNICATIONS COMMISSION Washington, D.C Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of: ) ) ) Commission Staff Requests That Interested ) WT Docket No. 07-293 Parties Supplement the Record on Draft ) IB Docket No. 95-91 Interference Rules For Wireless ) GEN Docket No. 90-357 Communications Service and Satellite Digital ) RM No. 8610 Audio Radio Service. ) ) SUPPLEMENTAL COMMENTS OF SIRIUS XM RADIO INC. Sirius XM Radio Inc. (“Sirius XM”) hereby submits these supplemental comments for the record in the above-captioned proceeding in order to provide additional technical information regarding the effect that the Commission’s proposed Part 27 Wireless Communications Service (“WCS”) rules1 would have on satellite radio receivers. Sirius XM has commissioned Dr. Theodore S. Rappaport, P.E., of the Telisite Corporation, who is the William and Bettye Nowlin Chair in Engineering at the University of Texas at Austin and the founding director of the Wireless Networking and Communications Group (WNCG) at the University’s Austin campus, to assess the probabilities of interference to satellite radio service caused by WCS devices operating under the proposed rules that are contained in the Staff Public Notice. This analysis is contained in the attached report entitled “Technical Analysis of the Impact of Adjacent Service Interference to the Sirius XM Satellite Digital Audio Radio Services (SDARS)” and provides some of the clearest evidence yet that the 1 Commission Staff Requests that Interested Parties Supplement the Record on Draft Interference Rules for Wireless Communications Service and Satellite Digital Audio Radio Service, Public Notice, WT Docket No. 07-293, IB Docket No. 95-91, GEN Docket No. 90-357, RM No. 8610 (rel. Apr. 2, 2010) (“Staff Public Notice”). staff’s proposed Part 27 rules would result in crippling interference to satellite radio operations in an unacceptable number of cases. Although retained by Sirius XM to conduct this study, Dr. Rappaport has undertaken this project under the express written conditions that the opinions provided in this study are his own. In his study, Dr. Rappaport engages in a scientifically rigorous and transparent engineering analysis of the potential for mobile-to-mobile interference from WCS devices to satellite radio receivers. In addition to explaining how the proposed rules are inconsistent with the specific technical and operational needs of satellite broadcast systems, Dr. Rappaport also presents the results of a detailed and realistic “Monte Carlo” simulation of the interaction between these services. Dr. Rappaport’s study demonstrates that the proposed Part 27 rules will unacceptably reduce the availability of satellite radio services, causing disruptive muting to a significant portion of satellite radio users. Dr. Rappaport’s conclusions are consistent with the results of various studies Sirius XM has submitted in this proceeding. Before revising the Part 27 service rules, the Commission should carefully consider Dr. Rappaport’s well-reasoned analysis of the potential harm to over 35 million satellite radio listeners. Dr. Rappaport’s analysis is founded upon reasonable, conservative assumptions and sound engineering. His findings confirm that there is a possible technical solution that will allow robust deployment of mobile broadband services in the WCS spectrum while also protecting satellite radio. Regrettably, Dr. Rappaport’s findings also conclusively demonstrate that the proposed rules in the Staff Public Notice are not consistent with that optimum solution. -2- Respectfully submitted, /s/ James S. Blitz James S. Blitz Vice President, Regulatory Counsel Sirius XM Radio Inc. 1500 Eckington Place, N.E. Washington, DC 20002 /s/ Terrence R. Smith Terrence R. Smith Corporate Vice President and Chief Engineering Officer Sirius XM Radio Inc. 1221 Avenue of the Americas New York, NY 10020 /s/ Robert L. Pettit Robert L. Pettit Jennifer Hindin Wiley Rein LLP 1776 K Street, NW Washington, DC 20006 April 29, 2010 -3- Technical Analysis of the Impact of Adjacent Service Interference to the Sirius XM Satellite Digital Audio Radio Services (SDARS) Dr. Theodore S. Rappaport, P.E. TELISITE Corporation April 29, 2010 Technical Analysis of the Impact of Adjacent Service Interference to the Sirius XM Satellite Digital Audio Radio Services (SDARS) STATEMENT OF DR. THEODORE S. RAPPAPORT TELISITE Corporation I, Dr. Theodore S. Rappaport, hereby state the following: 1. I received B.S., M.S., and Ph.D. degrees in electrical engineering from Purdue University in 1982, 1984, and 1987, respectively. 2. I am the William and Bettye Nowlin Chair in Engineering at the University of Texas at Austin (UT Austin) and am the founding director of the Wireless Networking and Communications Group (WNCG) at the university’s Austin campus. 3. Prior to joining UT Austin, I was on the electrical and computer engineering faculty of Virginia Tech from 1988 to 2002, where I founded the Mobile and Portable Radio Research Group (MPRG), one of the world’s first university research and teaching centers dedicated to the wireless communications field. 4. I have served on the Technological Advisory Council of the Federal Communications Commission, assisted the Governor and Secretary of Technology of Virginia in formulating rural broadband initiatives for internet access, and conducted research for the National Science Foundation, the Department of Defense (DOD), and dozens of global telecommunications companies. 5. I have provided objective technical analysis for the FCC and the listening public in the past. During the FCC proposed rulemaking for Low Power FM (LPFM), my work provided a thorough analysis of the technology and the regulations of existing and proposed FM broadcasting equipment. In the LPFM report, my company undertook a careful study of the state of FM receivers, the existing and proposed FCC regulations for LPFM, and used a database of actual FM broadcasting stations to conduct a computer simulation for coverage and interference levels. The results provided a meticulous, credible analysis which aided the FCC in making informed decisions regarding the LPFM interference regulations and protection to incumbent FM broadcasting stations. 6. I have testified before the United States Congress, served as a consultant for the International Telecommunication Union, consulted for over 30 major telecommunications firms, and have worked on many national committees pertaining to communications research and technology policy. 2 Technical Analysis of the Impact of Adjacent Service Interference to the Sirius XM Satellite Digital Audio Radio Services (SDARS) 7 I am a technically qualified penon and am familiu with the rulcmaking proceeding felated 10 intedClence l!,lles for wileless communications sel'vice and satellite digital audio ladio service 8 The contents ofthis report were pIepared by me or under my dilect supervision and 8fe complete and acewate to the best ofmy knowledge and belief 01. Theodofe S. Rappapon 3 Table of Contents STATEMENT OF DR. THEODORE S. RAPPAPORT ................................................................................................................... 2 Executive Summary ......................................................................................................................................................... - 6 - 1 Introduction ........................................................................................................................................................... - 8 - 2 Fundamental Differences between Broadcast and Cellular Services ..................................................................... - 10 - 2.2 Fundamental Technical differences between Satellite and Cellular networks ........................................................- 11 - 3 The Sirius XM Satellite System and the WCS mobile radio service ........................................................................ - 15 - 3.1 The Sirius XM Satellite System .................................................................................................................................- 15 - 3.2 The WCS broadband mobile service ........................................................................................................................- 16 - 4 Comparison of Existing FCC Interference Protection Rules for Broadcasters and adjacent services ...................... - 19 - 4.1 Overview of existing SDARS out of band interference protections: .........................................................................- 19 - 4.2 Overview of FCC Protection Rules for Different existing Broadcast Services ...........................................................- 24 - 5 Creation of a Simulator to understand WCS out-of-band interference to SDARS and impact on listening quality - 27 - 5.1 WCS Power Control Analysis ....................................................................................................................................- 30 - 5.2 Vehicle – to – Vehicle Path Loss Modeling ...............................................................................................................- 33 - 5.3 Usage and Activity Considerations ..........................................................................................................................- 34 - 5.4 WCS Block Allocations and OOBE Spectral Mask Considerations ............................................................................- 35 - 5.5 Path Loss and WCS Interference Power Received at Satellite Receivers ..................................................................-
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