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FCC gives green light for geo-targeted ad-insertion on FM boosters

Michi

Administrator
Staff member
From REC Networks
posted by author.

In a Report and Order released today, the FCC has given the green light for broadcast stations, including noncommercial educational (NCE) and low power FM (LPFM) stations to operate FM boosters that can originate its own programming up to three minutes per hour.

FM boosters, not to be confused with FM translators are separate transmitters operating on the same frequency as the main broadcast station that rebroadcast the signal of the main station. Boosters are normally used in areas where reception of the main station is impeded by terrain or other factors. The service areas of FM boosters are limited to the area within the 60 dBu service contour of the main station. In other words, the service contour of the booster must remain entirely within the main station’s service contour and cannot be used to extend the reach of the station outside of its authorized service contour. FM translators are limited to 20% of the effective radiated power (ERP) of the main station’s service class (for example, boosters operated by LPFM stations are limited to 20 watts ERP).

This ability was requested by a company called Geo Broadcast Solutions (GBS), which markets a technology called zone-casting (or geo-targeting). The primary use of zone-casting is to allow the service area received by a booster to receive different advertising/underwriting as well as other information such as localized weather, school closures and other similar announcements intended for just that area and not the overall coverage area of the main station.

While boosters are normally used in areas with very weak or no reception by the main station, GBS plans to take advantage of “capture effect” in order to broadcast the geo-targeted messages. “Capture effect” is where the signal of a stronger signal on the same frequency is able to “capture” the FM receiver and present the programming on the capturing transmitter (in this case, the booster). In many, but not all cases, the audio of the booster is synchronized with the audio from the main transmitter and in some cases, the average listener may not know that they are actually listening to a booster.

While REC Networks was intrigued by the technology, we did raise concerns due to both technical and economic concerns. Geo-targeting was sold to the FCC as a means of improving broadcasters, especially those owned by women and minorities. In our opposition to the technology, REC stated that it was concerned that this new application for using an FM booster would create a “booster boom” by placing boosters in areas where boosters would not normally be warranted, taking advantage of capture effect in order to broadcast different advertising and other messages to different ‘zones’. REC stated that the additional boosters will increase the “noise floor” which increases interference and could cause interference to other services, including existing LPFM and FM translator stations. REC stated that a “booster boom” would be inconsistent with the Local Community Radio Act of 2010 (LCRA), which states that the FCC must issue licenses for LPFM, FM translators and FM boosters based on community need and that all three service types must remain equal in status.

In the Report and Order, the FCC states that the implementation of zone-casting by a broadcast station with boosters is completely optional and that stations deploying zone-casting/geo-targeting are not limited to using the GBS-specific technology.

FM boosters that use zone-casting are limited to only three minutes (180 seconds) of local origination per hour. In hours where less than 180 seconds of locally originated programming on the booster takes place, the remaining time cannot be “carried over” into the next hour. There are no specific restrictions on the program content, however, all existing rules regarding content, such as the noncommercial nature of educational broadcast stations, etc. continue to apply.

FM boosters using zone-casting must be equipped with technology that, in the event of an activation of the Emergency Alert System (EAS), the booster will break away from locally originated programming and return to the main station’s programming to broadcast the alert.

To address some LCRA concerns, a main broadcast station will be limited to 25 FM boosters that originate programming. The use of 25 boosters is quite uncommon, both prior to zone-casting as well as during the testing that GBS conducted for the technology, even though GBS has included materials that suggest that broadcast stations could construct dozens of FM boosters in order to provide zone-casting. Despite the limit announced today in the Report and Order, LPFM stations are still limited to two boosters (or one translator and one booster or two translators).

As an interim process, the FCC will allow broadcast stations with boosters that wish to engage in zone-casting operation to file for an experimental authorization prior to deploying the technology. Those without a booster in the desired location will need to also file for a construction permit for a new booster (which can be done outside of a filing window).

The FCC denied REC’s request that FM booster applicants, as part of LCRA compliance to demonstrate “community need” through a technical showing that the area served by the proposed FM booster does not receive a strong signal from the main station. The FCC also misinterpreted our comments and failed to address co-channel interference between new FM boosters and existing secondary stations such as FM translators and LPFM stations. As noted below, the FCC will be proposing a new interference remediation policy for boosters while in the pre-construction phases. FCC Rules currently require FM translators to protect first-adjacent facilities, but not facilities on the same channel or on second or third-adjacent channels.

In addition to today’s Report and Order specific prompting rule changes, the FCC has also included a Further Notice of Proposed Rulemaking which proposes the following:

  • Reverting from the use of experimental authorizations to a more permanent method of authorization (experimental authorizations are only good for one year, but can be renewed), including a new form in LMS that will be used for such notifications.
  • An REC requested modification to §74.1204(f) of the Rules, which would extend the pre-construction FM translator interference remediation policy (the 45 dB rule) to also include the ability for impacted stations to file an interference package against proposed FM booster operations following the same guidelines as FM translator stations.
  • A requirement that FM boosters implement synchronization.
  • The question to whether booster operators that have EAS-related issues should report information to the FCC or FEMA.
  • To make permanent, the cap of 25 zone-casted boosters per main station (LPFM would remain at 2).
  • Whether broadcast stations (including LPFM) should maintain a separate political file for FM booster stations.
  • Whether any other technical or non-technical safeguards will be needed.
  • Modification of §73.801 of the LPFM rules to include references to rules outside of Part 73.
Comment and Reply Comment dates on the Further Notice of Proposed Rulemaking in MB Docket 20-401 will be announced at a later time after publication in the Federal Register.

REC advises LPFM stations to be watchful for increased FM booster activity by using tools such as the myLPFM portal, which is available free to all LPFM stations as well as monitoring the daily activity at FCC.today.
 
This is a terrible decision from a reception standpoint.

The FCC is relying far too heavily on the FM receiver “capture effect” to justify the booster scheme, without understanding how it actually works in the real world. The commission seems to think there is a completely clean switchover between signals, but that is not the case.

Of course boosters have been used for decades in areas affected by terrain blockage. In those situations there is not a clash of signals. But over flat land, or in areas where there is no signal blockage, the boosters will battle the primary station.

When there are two or more competing co-channel FM signals, one signal will dominate in the receiver, but the competing signals will cause hissing, swishing, bubbling, ano other audio distortion. And capture effect switching between signals can often be messy, rapidly repetitious, and loaded with signal degradation. FM signal contours are not perfect circles, but are jagged, spotty, and scattered.

Ever heard a situation where an FM station’s Main and AUX facilities are inadvertently running at the same time? That is a mess, and that is what you can expect if the 60 dBu primary contour of an FM station is cluttered with multiple co-channel outlets.

One FM rimshot station here in flat-as-a-pancake Houston tried an on-channel booster for a while, and the result was a complete mess—badly degraded reception of the main signal far beyond the supposed contour of the booster due to signal clash.

And one further thought: Won’t this scheme involve a lot of transmitter infrastructure that will add to operational costs?
 
Will this even matter or do anything? When I read the details in the rules I'm like "WTF is this?" So, for 3 min an hour, I can flip on a booster signal to target a certain area. Thats it?

I originally thought this would be for hours a day and that would present more programming options.

This isn't going to do anything. Its fake pointless solution to a much bigger problem. Most stations wont bother.
 
Will this even matter or do anything? When I read the details in the rules I'm like "WTF is this?" So, for 3 min an hour, I can flip on a booster signal to target a certain area. Thats it?
No, the booster will always be on, but only a few minutes an hour can it "break" from the mother station and insert local content.
I originally thought this would be for hours a day and that would present more programming options.
No, the idea is that they can run localized 30" and 60" commercial spots in each hour's stopsets.
This isn't going to do anything. Its fake pointless solution to a much bigger problem. Most stations wont bother.
If there is localized ad revenue... such as a single location store or service... they might buy, at a much lesser rate, the local area but not the full signal.
 
I just dont see the point of targeting local spots for a few minutes an hour for all the trouble.
If there are mutiple boosters covering many different areas of a market, there will be lots of potential clients that don't want full market coverage that might use a limited area option.
 
If there are mutiple boosters covering many different areas of a market, there will be lots of potential clients that don't want full market coverage that might use a limited area option.
Anybody who has ever been a DXer knows multiple boosters will be a disaster. Building out 25 boosters to sell some $7.00 ads to a barber in West Suburbia?
 
I could see this possibly working in a mountainous area where there is significan terrain shielding between communities. Place the transmitter where it would theorhetically cover all of the communities and stick a booster in each valley. The more shielding that exists, the less that would need to be done to synchronize the signals. Puerto Rico might work given the extensive use of FM bosters there.
 
Thank you Michi for opposing this. It's so unfortunate that it got approved.

How ironic that the FCC is going to allow countless co-channel signals on top of signals, when they won't even allow a station like New York's WXBK to move a couple miles east, because they're concerned about "interference" to a station 2 channels away out in the suburbs. Well, are they really concerned about interference or not?

The capture effect of FM receivers wasn't designed to handle this kind of willful strong signal interference abuse. Certainly not when someone jams 25 boosters into an FM signal contour. Anyone who has ever driven through the perimeter of an FM booster embedded within the footprint of a strong local signal knows how much hash and noise it creates where the two signals intersect because the receiver can't capture one or the other cleanly. That aggravation will only be compounded when transitioning between the booster and main signals during a local ad insertion, where the audio will become nothing but a jumble.

As usual, the companies foisting these conditions upon people won't care about the damage they cause to the listening experience. They'll only care about cashing the ten dollar checks from the micro-advertisers they con into buying time on their noisemakers.

I would compare this to the real estate developer who jams an ugly multifamily McMansion into the middle of a pretty neighborhood of single family homes, pockets the cash and leaves. He doesn't live there so he doesn't care, as long as he can profit at others' expense.

It's just another nail in FM radio's coffin.
 
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I could see this possibly working in a mountainous area where there is significan terrain shielding between communities. Place the transmitter where it would theorhetically cover all of the communities and stick a booster in each valley. The more shielding that exists, the less that would need to be done to synchronize the signals. Puerto Rico might work given the extensive use of FM bosters there.
But there are truly no local ad markets there. Nearly all advertising is Island-wide (we capitalize “Island”) and there is not enough good local business to sustain the cost of a booster.

In TV, all the significant stations are based in San Juan and used additional stations and repeaters to cover the island. No TV station, no AM and no FM covers the whole island.
 
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Anybody who has ever been a DXer knows multiple boosters will be a disaster. Building out 25 boosters to sell some $7.00 ads to a barber in West Suburbia?
We are talking about car dealers, local one location stores, tax accountants, restaurants,j and the like who have limited service areas.
 
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David, I figured you would pop in, since you had programmed there.
I was GM of WUNO in the early 70's, GM of WQII / WSRA in the mid-70's, GM of WZNT in the late 70's, consultant to a new WSRA 1973-1978, consultant to WDOY 1980-1981 and 1985-1988, and VP of ARSO Radio Corp (multiple PR stations and 4 stations in FL) 1985-1992 and then consultant to ARSO and all its stations through 2007 when I worked on WKAQ AM and FM as consultant from 2005 to 2021.

I got to pick the program directors. Fun.

I was the de facto PD of WPRM from 1985 to 2005, during the time it was always #1 with about twice the share of the #2 station. Owner's son did the music and concerts, I did formatics, talent and all the rest.

I'd still be there, but the congressional handling of Puerto Rico's tax incentives drove high unemployment and criminality and drug use exploded. After two stick-ups in my car and an attempted home invasion, I left in '82 but continued to consult. Many of my best friends ever are there or, now, in Florida.
 
To address some LCRA concerns, a main broadcast station will be limited to 25 FM boosters that originate programming. The use of 25 boosters is quite uncommon, both prior to zone-casting as well as during the testing that GBS conducted for the technology, even though GBS has included materials that suggest that broadcast stations could construct dozens of FM boosters in order to provide zone-casting.

Up to 25 boosters per station? That's crazy what a mess.
 
Here in San Diego, KWFN/97.3 has a few of these boosters. They run all-sports. I believe they have five boosters. I can't remember if it was the HD channel or the standard RDS information but I remember seeing one of the boosters identifying itself, something like KWFN Black Mountain for the one serving that area.
 
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