REC Networks: “FCC’s Missing Key Point in Developing ZoneCasting Rules”

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REC Networks believes the FCC is ignoring the Local Community Radio Act (LCRA) when reviewing GeoBroadcast Solutions’ (GBS) geo-targeted FM amplification system.

LPFM’s attorney, in a new filing with the commission, cites the statutory implications of licensing new FM amplifiers in well-served areas where no “community need” has been expressed.

ZoneCasting uses a series of FM boosters to cut out segments from a broadcaster’s coverage area to geographically target programming and advertisements for short periods of time. The technology has been heavily reviewed by NAB. GBS believes ZoneCasting is viable and allows broadcasters to super-serve very specific parts of their coverage areas with particularly relevant advertisements and information.

REC Networks argues that although the FCC considered the LCRA in a recent rulemaking proceeding for LPFM, the LCRA was suddenly overlooked by the commission when assessing the “needs of the community” when it came to allowing new FM translator stations in the 99 and 100 auctions.

“And so far, on the record of this proceeding (GBS ZoneCasting), the LCRA has not been mentioned by stakeholders or by the commission, even though it should be,” REC Networks said in its statement. recent file. “The booster ramp proposed by GBS must be assessed under the LCRA.”

Michelle Bradley, founder of REC Networks, made the claim after reviewing data from two recent experimental tests of the GBS geo-targeted FM amplification system. Earlier this year, the FCC requested comments on experimental field tests at KSJO (FM) in San Jose, Calif., and WRBJ (FM) in Brandon, Mississippi.

To briefly summarize, President Obama signed the LCRA and signed it into law in 2011. The LCRA was compromise legislation between the interests of LPFM, the National Association of Broadcasters and other interests representing LPFM and broadcast owners full-service, according to REC Networks.

A section of the LCRA commits the FCC, when licensing new FM translator stations, booster stations, and low-power FM stations, to ensure the following:

  1. Licenses are available for FM Translator Stations, FM Booster Stations, and Low Power FM Stations;
  2. These decisions are made based on the needs of the local community; and
  3. FM translator stations, FM booster stations, and low-power FM stations must retain the same status and be secondary to existing and modified full-service FM stations.

REC Networks has previously proposed to the FCC to adopt a Community Needs Criteria (see additional information below) which establishes whether a proposed FM amplifier is used for the intended purpose of the technology, which is to provide filler coverage with the 1 mV/m contour of a station when the service of the main station is otherwise obstructed by intermediate terrain or other reasons.

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REC, which opposes the concept of ZoneCasting, argues that criteria that constitute a “community need” justified the placement of experimental boosters for geo-targeting testing at the KSJO, but not at the WRBJ.

“The two reports submitted by GBS do an excellent job of demonstrating both the right reason to add an FM amplifier (KSJO) and the wrong reason to add an amplifier (WRBJ). coverage within the main station service contour due to intervening terrain,” REC commented.

A screenshot of the REC folder showing the field strength of the primary WRBJ (FM) at the booster sites.

When the commission first licensed FM amplifiers, the service’s intent was to provide low-power installations to fill coverage gaps due to terrain and other factors, particularly in mountainous areas such as the western United States, according to REC. “In these cases, the public would benefit from the addition of a radio service in their area that otherwise would not be received. Therefore, there was a “community need,” REC commented.

REC in its filing asks several things of the FCC: “Above all, the Commission must recognize that the LCRA does not only apply to LPFM stations, but also applies to FM translators and FM amplifiers. Prior to the adoption of any regulations, the Commission is required by law to ensure that new licenses for LPFM stations, FM translators and FM amplifiers are issued according to the needs of the community and not solely the wishes of the station.

[Related: “HD Radio Developer Takes Close Look at ZoneCasting“]

Second, REC is proposing that the commission’s rules be amended to also apply to FM amplification applications. “Currently an FM translator, LPFM or even a full service station has no documented recourse against an interfering or potentially interfering FM amplifier until the FM amplifier is built and causes interference. Over time that it takes the Commission to deal with these interference packets, it could cause significant damage to the incumbent station with which the proposed FM amplifier could interfere.

Regarding the GBS ZoneCasting technology, REC had previously concluded that geo-targeting did nothing to increase diversity in broadcast ownership.

“Instead, it only makes a select and diverse owners even stronger while ruling out future opportunities for other groups seeking to be heard,” REC told the FCC. “The ability for broadcast stations to exclude certain programs and services from an area, particularly within the licensing community in favor of wealthier areas of the Gold Coast, creates a new form of discrimination and discrimination socio-economic…there is no public outcry for FM boosters.which will cover well-received FM stations in order to place advertisements.Stations should focus first on their licensing community and not on the so-called “gold coast” parts of their service outline.”

REC concludes, “We need to set the rules for FM amplifiers, but we need to do it in a way that’s consistent with the original intent of FM amplifiers and do it in a way that’s consistent with federal law. Geo-targeted content does not meet this criteria.


Additional information

Michelle Bradley, CBT, explains the steps of the Community Needs Criteria developed by REC Networks and proposed to the FCC as a method to demonstrate community need when licensing a new FM amplifier under the LCRA:

  • Draw a 60 dBu contour of the proposed FM amplifier.
  • Determine the population inside this 60 dBu contour.
  • Perform a Longley/Rice propagation study of the proposed booster primary station.
  • Measure the population within the 60 dBu of the proposed booster which is notRated to receive a field strength of 54 dB or more from the primary station.
  • If this population represents more than 40% of the overall 60 dBu (as measured in step 2), then the community need is met.

Bradley tells Radio World that she has not received any indication from the commission as to what it thinks of its proposal or the FCC’s position on the application of the LCRA.

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