BIA Submits Comments to FCC Over GBS Zonecasting

RADIO ONLINE | Thursday, July 28, 2022

BIA Advisory Services

In two detailed follow-up letters to the FCC's request for comments on recent filings concerning the use of FM boosters for geo-targeted content, BIA Advisory Services CEO and Founder Thomas Buono and BIA Managing Director Richard V. Ducey outline the company's strong support for a rule change to allow limited origination of programming as a means of benefitting the local radio business, advertisers, and audiences through the use of GeoBroadcast Solutions' ZoneCasting technology.

"Having examined the circumstances surrounding the use of FM Boosters for geotargeting, it makes good sense to support this innovative technology as one that will be a positive for broadcasters," said Buono in his letter to FCC Chairwoman Jessica Rosenworcel. "By giving broadcasters this capability, they can increase their inventory of advertising opportunities, with some commercial slots available to more than one advertiser."

"We believe that deployment of this technology will allow the radio industry to grow its over-the-air revenue, something it desperately needs," Buono concluded. "One important other consideration is that providing geotargeting is optional. If a broadcaster does not want to offer geotargeting, it does not have to offer geotargeting. We believe, however, that many broadcasters, both large and small, would want to have this capability or at least the opportunity to choose for themselves whether to deploy this technology."

In his letter, Ducey stated, "BIA submits these comments to inform the record and provide insights into the technical, economic, and business model of local radio relative to NAB's concerns. It is BIA's position that the ability to originate content on FM boosters will help local radio stations become more competitive in the local advertising market, provide content that is better attuned to the local public interest, convenience and necessity and reattain a path to revenue growth in its over-the-air broadcast advertising."

BIA has ongoing consulting relationships with the NAB, as well as GeoBroadcast Solutions, and many of the radio industry's broadcast companies.

Ducey's letter takes issue and goes into research-backed detail on four areas of concern raised by the National Association of Broadcasters.

Ducey asserts:

1. Revising the booster rule will not undermine the business model of radio, it will enhance it.

2. Amending the booster rule will advantage smaller radio stations, including minority- and women-owned stations.

3. ZoneCasting will not lead to advertising "Redlining" of certain parts of a radio market.

4. The current technical record supports approval of the proposed rule.

Ducey concludes his letter with an assertion that the future of local radio's over-the-air advertising is challenged due to other digital media where geo-targeting is common.

"Local radio is at a severe competitive disadvantage to other local media, both traditional (e.g., newspapers, magazines, cable, telco, satellite, etc.) and digital (search, display, OTT, podcasting, streaming, etc.) that do offer advertisers the ability to geo-target their ads to cost effectively and more impactfully reach the consumers with their messaging."

"BIA sees only favorable tailwinds for local radio if the FCC were to adopt the proposed change in FM booster rules to allow local radio stations the option to become more competitive with a geotargeting service for advertising and targeted content including zoned traffic reports, zoned weather reports, zoned PSAs, zoned school closing, zone public health announcements, etc."