RM-11854: REC supports "hyperlocal" content on FM boosters but warns of a "booster boom"

In comments filed by REC Networks in response to a Petition for Rulemaking filed by GeoBroadcast Systems in RM-11854, REC expresses some interest in the concept of allowing FM broadcast licensees with boosters to be able to "split off" small portions of their programming for hyperlocal content over the booster.  Such hyperlocal content can include localized weather, traffic reports and local commercials.  Current rules require that FM boosters rebroadcast the programming of their primary FM station at all times.

In addition to the commercial applications for what is being called "ZoneCasting", the concept of separating content could be used by noncommercial stations with boosters to carry separate underwriting acknowledgement announcements in these areas for businesses local to the booster.  REC provides an example in Southern California where REC consulted station KWSV-LP could use their booster, which is directed to a distinct "market" to carry San Fernando Valley-based underwriting acknowledgements while the primary station would carry Simi Valley-based announcements.  REC has already worked with 4 LPFM stations in Southern California to obtain 5 booster authorizations with one, for KWSV-LP actively on the air.  

The rule changes proposed by GeoBroadcast Systems relate only to the content that can be carried over a booster and make no technical changes.  Boosters are normally only used in areas where terrain causes an FM station to not be heard in a particular location within their designated service contour.  Boosters are not permitted to extend the reach of a station past their designated service contour.  Unless the area to be served is separated by the primary station by "hard terrain", some very careful engineering and system design is involved in constructing a booster.  Not all stations would benefit from boosters but it would provide some opportunity for "rimshot" stations (stations licensed to communities outside of a metro area but have a service contour in a portion of the metro) to improve their service.

Despite this new application for existing boosters, REC warns of a "booster-boom", in other words, stations that are more likely to obtain boosters in order to take advantage of the ZoneCasting technology.  While boosters can only be inside of primary station service contours, REC does warn of the potential harm to LPFM and FM translator facilities if boosters are added in some cases including those where the full-service FM station's current facilities were authorized subsequent to the LPFM or translator, and in the case of LPFM, did not cause a 70 dBu overlap triggering a displacement opportunity under §73.809 of the rules.  LPFM and translators would be subject to harmful interference by new boosters in those cases.

REC reminded the Commission that Section 5(3) of the Local Community Radio Act states that LPFM stations, FM translators and FM boosters are all equal in status and all secondary.  This means that under statute, an FM booster is unable to displace an LPFM station or a FM booster.  Current FCC rules, §74.1203(a) and §74.1204(f), which are traditionally used for FM translators also apply to FM boosters.  LPFM stations would be able to seek relief under these rules in the event of encroachment by a new booster.