Proposed FCC $50 Application fee NPRM has been published
Many Central Division members have contacted me in the past month
about the FCC's proposal for a $50 "application fee" for license
applications in the Amateur Radio Service.
The fees Notice of Proposed Rule-making was published in yesterday's Federal Register.
https://tinyurl.com/yyk8f2yp
The deadline for comments is November 16, and the Reply comment deadline
is November 30.
Since the "official" comment period is now open now is the time to
file comments against this proposal !
Below are some details to consider when filing comments to the FCC
in response to the NPRM. Our thanks to Dave Siddall K3ZJ, ARRL Counsel,
for these guidelines included below.
Please be sure to carefully
review the paragraphs; "Some Suggestions" as the information
therein will assist with much of the applicable background.
This subject is critical, the timing is critical.
I urge you to contact the FCC.
Address and related information is contained in the article
referenced in the Federal Register. Please use your own words to
express your objections to the proposed fees.
(Good) Arguments Against FCC Fees for Radio Amateurs
Amateurs contribute to the public good. In many areas they provide an
emergency communications backbone capability at no taxpayer cost.
Consistently we have witnessed storms and natural disasters completely
wipe out internet, cellular, and other means of communication. Radio
amateurs often fill that void on an unmatched, flexible basis when
needed. One recent example is the California wildfires.
Unlike operators in other FCC licensed services, Amateur Radio
operators
by law domestic and international -- must eschew using their license
for any pecuniary interest. Amateurs are prohibited from earning or
charging any money for any communications activity. The expenses for
their equipment and activities come out of their own pockets, with no
opportunity for reimbursement or payment of any kind.
The United States is experiencing a severe lack of RF engineers and
expertise at the very time it is needed by the burgeoning wireless
industries. Amateur radio is helping to meet the deficit, but much
more is needed and youngsters (High School and College-aged) are least
able to afford licensing fees. RF knowledge and related digital
expertise is needed to maintain U.S. leadership in wireless industries.
At a minimum, young people (below the age of 26) should be exempt from
the proposed license fees.
Amateur radio is self-regulating;
(a) Amateur examinations are written and administered by radio
amateur volunteers.
(b) Examination results
and paperwork most often are submitted electronically to the FCC.
Electronic submission could be required if there would be a cost
savings
to the Commission.
(c) Amateur radio educational classes are conducted
by volunteers who by-and-large do not charge fees or tuition for
teaching.
(d) The amateur service, in cooperation with the FCC's
Enforcement Bureau, has a volunteer corps that monitors the amateur
airwaves and has programs that try to prevent their misuse before FCC
involvement might be needed. The amateurs also observe non-amateur
signals both within amateur spectrum and outside it, and report unusual
or suspicious signals.
Amateur radio continues to be a source of significant technological
innovation that should be encouraged, not discouraged.
Some Suggestions:
We do not recommend arguing that the $50. fee every 10 years, which
amounts to $5.00 a year, will harm or "kill" amateur radio, even though
as proposed this is for each covered application, which includes upgrade
applications. Tech-General-Extra could be $150. If exams taken at
different sessions this would be a substantial amount. But it is the
wrong way to say the whole service turns on $5/year for each licensee.
The Commission argues that the charges are required by the statute.
The word used in the Congressional Act which directs the FCC to collect
fees is "shall" , which is mandatory, not optional.
But the statute does not set the amount, nor does it prohibit reasonable
exceptions evidenced by the Commission's proposal to exempt from
fees administrative update applications based on policy grounds.
There is a long history and precedent on charging fees for the licensing
service involved, just as there is for passports, green cards, drivers'
licenses (issued by states), etc.
Better to make pertinent arguments on why the fees would impair the public benefits of the amateur radio service than argue that the whole service might die as a result of a fee that, in fact, is less than the fee many of us paid in the 1960's and 1970's.
For background: this proceeding is being handled by staff unfamiliar
with amateur radio. It is being handled in the FCC's Office of
Managing Director (OMD), not in the Wireless Telecommunications Bureau
where the amateur-specific Part 97 matters are handled. The focus of
OMD is accounting budgets and the like for the entire Commission.
The fee proposals cover every FCC license and service across the board
and the consideration was directed by Congress. It is recommended
that respondents keep "ham argon" out of comments, which would not be
understood by the intended recipients.
Comments to the Federal Communication Commission may be filed
online at;
https://www.fcc.gov/ecfs/filings
FCC’s Electronic Comment Filing System (ECFS)
reference - posting to MD Docket No. 20-270