Wednesday, July 6, 2022                                           453

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


Dear Chairwoman Rosenworcel: 

We write to express serious concerns about a proposal to amend the Commission’s rules on FM 
broadcast booster stations, which seeks to allow the use of geo-targeting technology in the 
environment of free, over-the-air broadcast radio, including especially for advertising.  We are 
deeply concerned about the potential harms of this technology on communities of color, which 
rely disproportionately on broadcast radio for news, emergency information and entertainment. 

We know you share our strong commitment to ensuring that all communities are treated 
equitably and have full access to the many benefits free over-the-air broadcast radio offers. 
Radio broadcasters are licensed by the FCC to operate in the public interest and the Commission 
must not allow geo-targeting technology to be used as a tool for advertising redlining that will 
enable its users to “cherry pick” only the most affluent listening audiences in a station’s market.  
The proposal before the Commission is cleverly marketed as a tool to serve Black and Brown 
communities, when in fact it can be used for just the opposite – to avoid serving those 
communities. Any potential benefit must be weighed against this significant risk for harm. 
As members of the Committee of jurisdiction in this matter, we also are concerned about any 
technology that could degrade free, over-the-air radio service by introducing harmful 
interference. As the Commission proceeds with this Rulemaking, it must take great care not to 
make any decision that somehow degrades broadcast radio. The record of this proceeding reveals 
significant concerns among broadcasters that the testing to date has not been sufficient, and that 
interference concerns have not been addressed sufficiently.  We want your assurance that the 
Commission will not allow geo-targeting technology or FM boosters to degrade or interfere with 
the public’s access to essential broadcast radio services, including news, traffic information, 
weather reports, and emergency alerts. 

With these concerns in mind, we ask that you please answer the following questions: 

   1. We are already seeing the negative impacts of online targeted advertising in the real
      world, as communities of color, low-income, and immigrant communities are often
      disproportionately isolated from key housing, education, and economic opportunities
      online. Considering the natural similarities between online targeted advertising and geo-

 
      targeting technology in broadcasting, how can we trust that this technology will not cause 
      the same harms associated with targeted online advertising? 
   2. What is the Commission’s plan to test the level of interference geo-targeting technology 
      would cause if fully operational, including in a variety of geographic and population 
      environments? Who is conducting the independent technical analysis and assessment to 
      address this concern? What have the tests for interference revealed to date? Has the 
      Commission received feedback on any potential technical concerns about geo-targeting 
      technology from a broad cross section of broadcast engineers? What have they said about 
      this issue? 
   3. To what extent have there been real-world listener impact studies of the admitted 
      interference and whether that interference would degrade their experience to the point of 
      turning to non-broadcast options? How will this impact lower income populations who 
      can’t afford satellite radio and other subscription services? 
   4. To what extent might geo-targeting technology interfere with the delivery of critical 
      public safety information, such as weather or emergency broadcasting services?  Has the 
      Commission sought or received specific feedback on this issue from federal, state and 
      local public safety entities?  Has the FCC conferred with FEMA? Has FEMA otherwise 
      weighed in on this issue and provided its opinion on any potential concerns or likelihood 
      of interference in its ability to reach radio broadcast audiences during times of 
      emergency? 
We urge the Commission to carefully assess these issues as it considers the changes to its rules 
for FM Booster Stations.  We look forward to your response. 
 

      Sincerely, 

       

                                        
            ________________                 ___________________ 
            Yvette D. Clarke                 Darren Soto 
            Member of Congress               Member of Congress