The technology developer behind ZoneCasting is asking the Federal Communications Commission to move forward and finalize rules that allow radio broadcasters to originate a limited amount of programming on their FM boosters.
The FCC gave unanimous approval to the technology in April; its order limits local origination to three minutes per hour and requires boosters to handle emergency alerts in the same manner as the primary station.
The commission still needs to create final rules for processing, licensing and service. We reported earlier that some early adopters had filed applications to begin FM geotargeting using the ZoneCasting technology from GBS; and on June 21 GBS said that Bustos Media Holdings LLC had filed to deploy it for KTZM and KDDS in the greater Seattle metro, which it said was significant because of that market’s size.
GeoBroadcast Solutions now has filed comments about technical matters in response to the FCC’s further notice of proposed rulemaking.
The company says the FCC now has a complete record to resolve issues raised in its further notice. It says it agrees with commenters who believe that “not all FM booster situations are created equal” and acknowledges that synchronization of program-originating boosters is essential, but sees a better solution than having the FCC specify how broadcasters achieve it.
“For one, an attempt to establish synchronization parameters will inevitably not account for every potential scenario, leading the commission down an engineering rabbit hole cluttered with unique waiver requests,” GBS wrote.
The FCC proposed a limit of 25 program-originating boosters per primary station, which GBS says it agrees is a suitable number for now. “To the extent that the commission remains uncertain about whether to make permanent this cap, GBS suggests that the commission delegate to the Media Bureau the authority to adjust the cap or to handle any variances by waiver,” it wrote.
However, GBS reiterated that the commission should be open to expanding the three-minute per hour limitation, at least a bit, and not look upon it as a one-way ratchet.
Among the items discussed is emergency alerting. Program-originating FM boosters are already subject to FCC disclosure requirements for EAS participants, GBS says, and thus new notification rules – whether upstream monitoring sources or downstream monitoring recipients – are unnecessary. In fact, the company says the geotargeting aspect of ZoneCasting will broadcasters to better serve their communities. “The value of a program-originating booster’s ability to deliver hyper-local news and emergency information benefits from effective and broad awareness of the booster’s capability.”
The commission also asked in its further notice how radio stations should handle political advertisements aired solely on program-originating boosters. GBS says ZoneCasting creates opportunities for FM stations to increase engagement in the democratic process. The company also believes that program-originating boosters should be treated as “separate facilities for the limited purposes of applying the equal opportunities, reasonable access and lowest unit charge rules to booster originating sales.”
The National Association of Broadcasters recently tried again to convince the commission that geotargeting is a bad concept that will hurt small broadcasters, especially Class A FM stations in fringe areas of large markets.
NAB told the FCC it fears that large broadcasters in those markets will use this technology to capture local advertising business from smaller stations, which could lead to a reduction in ad rates and pave the way for the redlining of advertising away from less affluent areas.
GBS pushed back, writing: “As demonstrated throughout this proceeding, program-originating boosters will increase competition by unlocking new markets to new advertisers and reinvigorating FM broadcasting for broadcasters, advertisers and listeners alike. Program-originating boosters will be uniquely beneficial to small businesses and minority communities, and concerns about discriminatory practices are baseless and unwarranted.”
In closing, the company told the FCC that some issues raised by commenters attempted to reopen technical issues already resolved by the Report and Order. “The commission has before it all the information necessary to resolve the issues on which it sought comment in the Further Notice,” it wrote.
The company reported in the filing that a total of five broadcasters have now filed for 21 new boosters. GBS says it believes more will file soon.
GBS says the boosters will serve geographically diverse markets from Seattle and Las Vegas to Fort Duchesne, Utah, outside Salt Lake City. Broadcasters in Nevada and Mississippi have also filed applications with the FCC.
Reply comments on the FCC’s Further Notice of Proposed Rulemaking were due June 17. Comments can be read online; refer to MB Docket 20-401.
