FEDERAL COMMU NICATIONS C OMMISSIO N WASHI N GTON OFFICE OF September 1, 2020 T HE C H AIRMAN The Honorable Mark E. Green U.S. House of Representatives 533 Cannon House Office Building Washington, DC 20515 Dear Congressman Green: Thank you for your letter regarding Part 15 unlicensed devices and their use by houses of worship during the COVID-19 pandemic. These devices can be useful in providing a way for churches to continue to connect with congregations during this period of social distancing. However, one of the fundamental responsibilities that Congress placed on the Commission under the Communications Act of 1934 is the protection of licensed stations. To this end, the Commission long ago established carefully calibrated rules regarding the specifications under which licensed and unlicensed FM stations may operate. For example, when granting applications for new FM stations or for modifications of existing FM stations, our rules require that applicants demonstrate that their proposals would not cause harmful interference, and applications must be supported with detailed engineering information to make this showing. Additionally, our rules provide for public notice of these applications, and afford potentially impacted stations the opportunity to object to these applications if they believe that they will receive interference. Because of these requirements, Part 15 devices must stay within the strict confines of our rules in order to protect licensed stations from harmful interference. A waiver of these requirements would undermine the Commission's goal of ensuring the integrity of already­ crowded FM radio spectrum, and would deny existing licensees the opportunities to defend their costly investments. I am proud of the work that licensed broadcasters have done during the pandemic. They have been providing vital information to listeners, while facing an unprecedent challenge from loss of advertising revenue. Moreover, as the recent tropical storms in the Gulf of Mexico and the Atlantic have demonstrated, licensed broadcasters provide up-to-the-minute information on natural disasters and are required to participate in the Emergency Alert System. These services and many more could be adversely impacted by providing waivers to allow churches to operate Part 15 devices above the current power limits. I understand that this makes it more challenging for churches during this difficult time, but I want to emphasize that there are options available. Churches can contact local broadcast stations to see if any would be willing to air their weekly services. Indeed, many local stations partnered with house of worship to broadcast Easter services. Churches also could explore using multiple Part 15 devices to cover a larger area if they continue to provide "drive-in" style services. Or churches could look into "call-to-listen" services where congregants would only Page 2 The Honorable Mark E. Green need a phone to hear the service. Finally, if congregants have access to broadband at home, there are multiple, free streaming services that could be used (and have been used across the country). Please let me know if I can be of any further assistance.