Communications General Corp Complains to FCC About Sirius

Monday, May 01, 2006

Communications General Corp. said it has filed a formal complaint with the FCC against Sirius Satellite. CGC says the complaint is "for incorporating 87.7 and 87.9 MHz into the intentional radiator mini-transmitters built into many of Sirius' satellite receivers."

"CGC reasoned that if the FCC ultimately fined Sirius for the use of prohibited frequencies, that action would send a powerful message to other manufacturers of mini-transmitters that they, too, should abandon the use of the prohibited 'below 88 MHz' frequencies," the company wrote in its newsletter.

I have to say in the Washington/Baltimore area many SIRUIS Subs are using 87.7FM and 87.9FM to get a clean sound. Many car radios do not go under 88.1FM, but some do.

To: Mr. Jim Collins
Corporate Communications
Sirius Satellite Radio

cc: Rebecca Schnall
Media Relations
Sirius Satellite Radio

cc: FCC (Per E-Mail Header Above)

From: Robert Gonsett, E.E.
Editor, The CGC Communicator
Communications General Corp.
r.gonsett(at) or

Date: March 29, 2006

Re: Impermissible Use of 87.7 and 87.9 MHz in Sirius Satellite Consumer Products

Confirming and expanding on my voice mail message of March 27, 2006, my company, Communications General Corporation, provides consultant radio engineering services for a number of radio and television stations on the west coast and we also publish the CGC Communicator newsletter for broadcast engineers. The CGC Communicator has been in continuous publication for over 30 years.

As editor of that newsletter, I have been following a number of radio and television interference complaints where the FM modulators inside various Sirius Satellite receivers are suspected of causing interference to authorized over-the-air FM and TV Channel 6 signals. Usually the interference is transient in nature, and usually audio from Howard Stern is reported.

Our current focus is on one particular question: Does Sirius (or its satellite receiver manufacturers) have an FCC waiver letter permitting the sale to consumers of "intentional radiator" FM modulators that are capable of transmitting on 87.7 and/or 87.9 MHz? These two frequencies are close to TV Channel 6's aural carrier, and are barred for use in intentional radiator FM modulators by FCC Rule 15.209(a).

On March 26, 2006 at Circuit City in Escondido, CA, I found five models of Sirius receivers on display with built-in intentional radiator FM modulators, and four of those had modulators capable of being tuned to 87.7 and 87.9 MHz. Those receivers are as follows: Sirius Sportster Replay (model DEI SPTK2), Sirius Starmate, Sirius DEI SCFM1 and Sirius Plug N Play Receiver Kit (XAT XTR3CK). The only Sirius satellite receiver on display at Circuit City that appeared to be frequency-compliant with Rule 15.209(a) was the JVC Sirius Satellite Tuner.

FYI, all seven XM Satellite receivers on display at Circuit City appeared to be frequency-compliant with Rule 15.209(a). None of the mini-transmitters built into XM receivers could be programmed to transmit on either 87.7 or 87.9 MHz.

For your convenience, I have copied below a response that I received from [# an FCC source] stating unequivocally with respect to intentional radiators that primary transmissions at 87.9 MHz would violate FCC rules. Rules 15.209(a) and 15.239 also ban the use of 87.7 MHz in the same context.

Our next newsletter is scheduled for publication on Tuesday of this coming week.* If Sirius (or its satellite receiver manufacturers) has an FCC waiver letter allowing the use of 87.7 and/or 87.9 MHz, I would appreciate receiving a pdf copy of that document by Monday of next week at the latest.

Thank you in advance for your prompt attention to this inquiry.


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