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GBS Counters NAB Issue Paper, State Broadcasters Letter


GEO Broadcast Solutions.png
GEO Broadcast Solutions.png

NAB has created an "issue paper," currently being circulated as well as a newly-submitted letter to the FCC signed by state broadcasters' associations that are designed to disseminate information about the rule change proposal currently in front of the FCC for "zonecasting" using FM boosters. In March, 2020, GeoBroadcast Solutions, who says the paper "specifically misinforms and is misleading" asked the FCC to revise its rules so the broadcast radio industry could choose, on a voluntary basis, to deploy geo-targeted programming, including emergency alerts, news and advertising.

GBS says the proposed rule change -- RM-11854 -- relates solely to FM boosters and requested no changes to the FCC's rules regarding translators or interference. In a release, GBS claims that NAB decided, after first being for the rule change that is was now against it, and in so doing has reached for various flawed reasons.

For example, GBS says NAB has never explained why geo-targeting capability is good for the TV industry, thanks to a rule change NAB persuaded the FCC to adopt in 2017, but is not good for the radio industry. "It remains a mystery why NAB cannot encourage this change in radio, where it's needed the most."

"The radio industry's rapid decline and concentration of shrinking revenue in a tiny number of station groups is obvious to anyone paying attention. But the NAB and its affiliated state associations insist that what the radio industry needs is more of the same: more regulation and less innovation. They seem to think that not innovating, adapting to the likes of Facebook, Google and their ability to geo-target content, is the way to success. The good news is that most small and mid-sized station owners know the opposite is true. We are confident the FCC will, too," said a spokesman for GeoBroadcast Solutions.

The following are some of the statements from NAB and GBS responses:

NAB claim: It could limit emergency information
GBS response: Extensive testing establishes that the EAS works just as it should. The Emergency Alert System (EAS) will function as well or better for radio stations opting to use geo-targeting technology. In response to FEMA's filing asking about EAS performance from Feb. 2021, the EAS system was tested robustly in two different markets deploying geo-targeting technology over past nine months and it seamlessly passes through alerts just as designed. In GBS response, because of the way the geo-target technology works, station signal coverage is improved during all on-air hours to increase the dissemination of EAS messages to more listeners.

NAB claim: It will divert information from less affluent neighborhoods
GBS response: It will not. The FCC specifically prohibits local radio stations from conducting advertising that is discriminatory and all licensees must affirmatively state they do not discriminate in their advertising in their license renewals. No radio station owners want to risk their license and especially not about something as important as not discriminating in any form. Local radio operators seek to serve their audiences and advertisers with a competitive service. In addition to the FCC prohibition against discriminatory advertising practices on local radio stations, it makes no sense to think any radio station would not offer their advertising services to willing buyers.

NAB claim: It will upend the advertising market
GBS response: On the contrary, it will make local radio more relevant and competitive in the advertising market. The ability to geo-target content for a part of each broadcast hour offers local radio operators the option to be more relevant in a market where every other local ad-supported media offers geotargeted ads and content. Geo-targeted ad inventory has been available for years and years in local media with the exception of local radio. While the FCC prohibits local radio stations from over-the-air geo-targeting, it supports this same capability for local TV stations. Local radio stands alone in not being able to geo-target content. As for causing rates to plummet, again all market evidence points to the contrary. Local radio stations can look to their own digital ad sales where they nearly certainly offer geo-targeted ad inventory. Geo-targeted ad inventory with widely used yield management and revenue optimization systems increase overall revenues.

NAB claim: It particularly hurts small and minority-owned stations
GBS response: That message is being delivered by iHeart, Audacy, Cummulus. Does anyone really think they are focused on the best interest of small and minority-owned stations? As opposed to protecting their own self-interest. Think about who does support this innovative technology. Small and minority-owned stations and their supporters including NABOB, MMTC and leading members of Congress see a path to greater economic opportunities for these stations to compete more effectively with bigger radio companies and digital media. Leading voices representing and advocating for diverse communities including NABOB, MMTC, leading members of Congress firmly committed to minority ownership and advancement have spoken clearly and powerfully in the FCC record to ask for this rule change to allow geotargeted content to increase the competitiveness and relevance of this important segment of the local radio market.

NAB claim: It will cause interference for radio listeners
GBS response: Extensive testing has shown that is not true, and common sense reinforces it. It will not cause interference for radio listeners. Robust, transparent, and publicly documented field demonstrations of the current geo-targeting technology are in the FCC record. The bottom line from one of the most respected engineering firms in operation is, "there is no technical reason to not adopt this rule change." Moreover, a broadcaster has every incentive and ability to design a system so that it does not cause any problems for its audience.

"Over the course of two years the NAB has switched sides and its arguments on this issue to a dizzying effect; and we just don't understand why," said GBS. "Unlike NAB, which seems to want the FCC to stifle and limit innovation, we think the market should decide if geo-targeting is good for radio. But for some reason the NAB doesn't even want it to get that far. Instead, it wants the FCC to stymie innovation."

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