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2024 FCC AI Deepfakes Disclosure Sign-On Letter

2024 FCC AI Disclosure Sign On Letter

Kathy Berthot, 
Media Bureau, Policy Division
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

Dear Ms. Berthot,

We, the undersigned, write to express our strong support for the Federal Communications Commission’s (FCC) proposal to ensure transparency in the use of AI-generated content in political advertisements on TV and radio, especially when the AI-generated content falsely depicts a candidate or persons saying or doing something that they never did with the intent to cause harm or deceive voters (known as “deepfakes”). These rules are essential to safeguard the integrity of our democratic processes and ensure that voters are fully informed of the origins of political advertisements.

Evidence now abounds of the significant and deceptive impact that AI-generated content can have.  The proposed disclosure requirements are a natural and common-sense extension of the FCC’s existing mandates to ensure transparency in broadcasting in general and in political advertising on radio and TV in particular. The proposed rules are especially important because broadcasters interpret the FCC’s current rules as prohibiting them from requiring disclosure of AI-generated content. 

We support the following aspects of the proposed rules:

  1. On-Air and Written Disclosure Requirements: We favor requiring both on-air disclosures and written disclosures in broadcasters’ political files when AI-generated content is used, especially to create deceptive deepfakes. 
  2. Application to Both Candidate and Issue Advertisements: Extending the disclosure requirements to both candidate and issue advertisements recognizes the broad impact of AI-generated content and ensures that all political messaging is subject to the same transparency standards.
  3. Inclusive Application to Broadcasters and Other Entities: Applying the disclosure requirements to all pertinent content carriers ensures that all major content platforms under the FCC’s jurisdiction are covered at the local, state and federal levels, 

We urge the FCC to adopt these rules promptly. We commend your office’s leadership in addressing this critical issue and look forward to continued collaboration to provide transparency about the use of AI on broadcast the airwaves.

Sincerely,

Access Now 

Accountable Tech 

AFL-CIO 

AFT 

Asian Americans Advancing Justice 

Business for America 

Campaign Legal Center 

Center for Biological Diversity 

Citizens for Responsibility and Ethics in Washington 

Clean Elections Texas 

Common Sense Media 

Consumer Action 

Democracy 21 

End Citizens United//Let America Vote Action Fund 

Fix Democracy First 

Franciscan Action Network 

Friends of the Earth 

Grey Nuns of the Sacred Heart 

Indivisible Santa Fe 

Institute for Strategic Dialogue 

Issue One 

Maine Citizens for Clean Elections 

MOVI, Money Out Voters In 

National Disability Rights Network (NDRN) 

National Organization for Women 

NETWORK Lobby for Catholic Social Justice 

North Carolina for the People 

Oxfam America 

People Power United 

Public Citizen

Public Knowledge 

Restaurant Opportunities Centers United 

Secure Elections Network 

The Value Alliance 

The Workers Circle 

Transparency International U.S. 

United Church of Christ 

United We Dream 

Verified Voting 

Vote.org 

WALKING TO FIX OUR DEMOCRACY 

Wisconsin Democracy Campaign