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GeoBroadcast, NAB File Reply Comments to FCC NPRM


Federal Communications Commission
Federal Communications Commission

In a reply to comments filing on Friday, GeoBroadcast Solutions sought to address industry concerns and speculations to its FCC request for a rule change that would allow the upgrade of decades-old FM booster rules by permitting, but not requiring, radio broadcasters to provide geo-targeted content for a small portion of a broadcast hour. In the Commission's notice of proposed rulemaking late last year, the FCC proposes to amend its rules to enable FM broadcasters to use FM booster stations to air geo-targeted content independent of the signals of its primary station.

"Our efforts to improve radio technology and provide an economic lifeline to broadcasters competing on a daily basis against less regulated mediums, met surprising opposition from those we had hoped would embrace the opportunity to work with us and build new economic models that would help the industry remain competitive," said GeoBroadcast Solutions spokesperson Robert Udowitz. "As the rule change progresses we are going to continue working together with broadcasting groups, stations, advertisers, and industry organizations."

The GeoBroadcast reply focuses on four elements that it says "will improve any radio station using geotargeting technology."

  • The technology will be seamless to the listener as transition zones will comprise typically less than one tenth of one percent of a broadcaster's service area. Transition zones will be engineered by the broadcaster to avoid self-interference.

  • The Emergency Alert System will not be impacted by the technology as ZoneCasting will have no impact on the EAS alerts.

  • The technology represents a meaningful revenue impact, as proven by example in the cable TV industry. A radio station that chooses to launch geo-targeted content would only be able to do so for a maximum of three minutes per broadcast hour, with the remainder of the advertising time during that hour going DMA-wide.

  • Three upcoming live demonstrations of ZoneCasting will illustrate how it will improve the station's signal strength and reach, and demonstrate each station's ability to add localized weather and traffic, news, advertising, and EAS tests to its listeners. This will be the fifth test of the technology and the third using the same booster configuration.

GeoBroadcast says its ZoneCasting technology can help stations provide content to better serve their communities by offering hyper-localized news, weather, emergency alerts, advertising and alternative languages during a small part of the broadcast hour. It could be implemented by stations across the country through a revenue-share model that essentially allows stations to deploy the technology without upfront capital expenses, with GeoBroadcast Solutions providing the infrastructure and each local station using it to sell localized advertising.

In reply comments filed by the NAB, the trade group said broadcasters generally favor technical and policy innovations intended to bolster their ability to serve listeners. For this reason, the National Association of Broadcasters supported further consideration of the proposal by GeoBroadcast Solutions to amend the Commission's rules to allow booster stations to originate programming, independent of a broadcaster's primary signal.

However, NAB wrote, after a thorough review of the Notice, an overwhelming majority of NAB members agree that GBS's proposal would pose significant risks to radio stations that far outweigh the speculative benefits offered by GBS. Although comments from approximately 57 mostly smaller broadcasters support amending the booster rule, NAB wrote none of the parties fully addresses the financial, competitive or technical risks of allowing geo-targeting set forth in the record.

On the other hand, NAB, which represents many thousands of FM broadcasters, is joined by separate coalitions of large, mid-sized, small and minority- and women-owned radio companies covering hundreds more stations that detail their own concerns or outright opposition to revising the booster rule. In fact, NAB says, several stakeholders, including the leading minority-owned radio group in the nation and the former Administrator of the Federal Emergency Management Agency (FEMA) tapered or even reversed their earlier support for GBS's proposal after further review.

NAB also noted the concerns of FEMA's IPAWS Program Management Office about the effect of amending the booster rule on the Emergency Alert System(EAS). "This alone should be enough to table the matter," wrote the trade group.

NAB also wrote the record highlights three major flaws in GBS's proposal:

  • First, allowing boosters to originate content will undermine the business model of FM radio by depressing advertising rates and reducing revenues as advertisers replace market-wide ads with less expensive, zoned ads on boosters.

  • Second, revising the booster rule will, if anything, advantage larger, well-funded broadcasters because the substantial investment needed to effectively implement ZoneCasting would be out of reach for most stations. Also, larger stations located in the urban center of a market will be better able to absorb lower ad revenues and capture local advertising business that is critical to smaller stations near the edges of a market.

  • Third, allowing radio stations to geo-target content may harm listeners by facilitating the advertising "redlining" of certain segments of a market, and disrupting radio service where the boundaries of a station's primary signal meet a booster airing different content.

NAB further wrote the record lacks sufficient real-world study of such interference on signal quality, EAS and HD Radio, any of which would reflect poorly on FM service and potentially spur listeners to change to a competing source for audio.

The rule GeoBroadcast seeks to change relates to FM boosters and their ability to originate geotargeted content. It says there would be no changes to the FCC's rules regarding interference or translators. GeoBroadcast also noted that radio is the only medium that lacks the ability to geo-target content and this rule change would put radio on par with television which now has that ability due to the 2017 FCC decision that allowed television broadcasters to use the Next Generation TV standard (also known as ATSC 3.0) and the many features of that standard include geo-targeted programming.

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