Dear Ms. Dortch: The U.S. Chamber of Commerce (“Chamber”) respectfully submits these comments to the Federal Communications Commission (“Commission” or “FCC”) in response to the abovetitled Notice of Proposed Rulemaking (“NPRM”).1 The Chamber believes the NPRM is premature and will adversely impact consumers. If the Commission opts to proceed with the NPRM, it should pursue a narrow rulemaking that avoids imposing onerous new requirements on commercial callers.
The Chamber believes the responsible and ethical use of artificial intelligence (“AI”) is critical to unlock innovation and improve the lives of Americans. We are actively engaging with more than a dozen federal agencies’ efforts on AI, as well as various state and international governments. Last year, the Chamber’s Artificial Intelligence Commission on Competitiveness, Inclusion, and Innovation (“Chamber AI Commission”) released a comprehensive report on AI, which, among other policies, called for a gap filling risk-based regulatory framework.
The Chamber’s response to the Commission’s Notice of Inquiry (“NOI”) noted that “new regulations or legislation to address AI-enabled robocalls or robotexts would be premature” and “the Commission should leverage existing law, collaborate with industry and other governmental entities as well as other stakeholders to further its understanding on AI, and utilize its current enforcement tools to combat bad actors.” 3 Further, we agreed that the Commission’s Declaratory Order was a helpful step to clarify that AI-generated voices constitute an artificial or recorded voice under the TCPA. We maintain this position and believe that the Declaratory Order is sufficient to address any harmful impacts arising from the using of AI in robocalls and robotexts.
Read the full letter here.
