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                               December 13, 2022 

The Honorable Jessica Rosenworcel 
Chairwoman 
Federal Communications Commission 
45 L Street, NE 
Washington, D.C. 20554 

Dear Chairwoman Rosenworcel: 

I  write regarding the  significant  public  interest  in the  proposed  Federal  Communication 
Commission  (FCC)  rule  change to  permit the  use  of ZoneCasting technology by  FM  radio 
broadcasters. As  you  know, GeoBroadcast  Solutions  LLC  (GeoBroadcast)’s ZoneCasting 
technology enables booster geo-targeting capabilities by FM radio broadcasters. A diverse array 
of respondents—established industry stakeholders, broadcasters of all sizes, civil rights advocates, 
radio engineers, and members of the listening public—have raised concerns about ZoneCasting 
that deserve the Commission’s attention.   

As you know, the technology the Commission is considering would allow radio stations to geo-
target programming,  including  emergency  alerts,  news,  and advertising, to  different  areas  and 
communities. Because radio stations operate under licenses that require them to broadcast to a 
specific geographic area, ZoneCasting would create a new regime where advertisers and stations 
could pick and choose who hears different types of information and solicitations. And because 
most radio play occurs while listeners are traveling by car, with ZoneCasting, listeners could hear 
varying content as they drove around a single region, for example, through Maryland, Washington, 
D.C., and Virginia, as many do regularly during a single trip.

Comments submitted to the FCC warn that the hyper-targeted messaging ZoneCasting enables 
could reduce the effectiveness of emergency alert systems, exacerbate racial inequity by restricting 
content and advertising, and undermine the overall economic ecosystem of the broadcast industry, 
specifically disadvantaging small and minority-owned radio stations. The limited testing of the 
technology, which has led to uncertainty about the degree of disruption to listeners and stations 
from signal interference, is also noteworthy. Despite the voluntary nature of the proposed change, 
this new technology would be an added expense for radio stations to acquire and maintain. 

Therefore, I urge you to seriously consider the concerns raised by respondents and work to address 
and resolve them to the satisfaction of all parties before any modification of FCC’s rules.  

Thank you for your consideration. 

Sincerely,  

                                                       
_______________________ 
Chris Van Hollen   
United States Senator