SPECIAL BULLETIN: Comment Deadline Set For Proposed FCC Amateur License Fees NPRM

In my September 2020 Northwest Division Newsletter we discussed newly
proposed FCC mandated fees for amateur radio licenses and other
transactions.

A refresher: Under the proposed fee structure amateur radio licensees
would pay a $50 fee for each amateur radio license transaction.
Included in the FCC’s fee proposal are applications for new licenses,
renewal and upgrades to existing licenses, vanity call sign requests,
and even for official copies of amateur licenses. Excluded are
applications for administrative updates, such as changes of address. The
FCC proposal is contained in a Notice of Proposed Rulemaking (NPRM) in
MD Docket 20-270, which was adopted to implement portions of the
“Repack Airwaves Yielding Better Access for Users of Modern Services
Act” of 2018 — the so-called “Ray Baum’s Act.”

The Act requires that the FCC switch from a Congressionally-mandated fee
structure to a cost-based system of assessment. In its NPRM, the FCC
proposed application fees for a broad range of services that use the
FCC’s Universal Licensing System (ULS), including the Amateur Radio
Service that had been excluded by an earlier statute. The 2018 statute
excludes the Amateur Service from annual regulatory fees, but not from
application fees.

The ARRL has been notified that the NRPM was formally published in
yesterday morning’s Federal Register (https://tinyurl.com/yyk8f2yp).
The Register notes the deadline for comments on the NPRM is November 16,
and the Reply comment deadline is November 30.

I would highly recommend that all amateurs submit comments to the FCC
regarding this repressive NRPM. Not only our wallets, but the possible
long term viability of this wonderful hobby depends on it! If you would
like to submit a comment on this proceeding, the official FCC website
address is: https://www.fcc.gov/ecfs/filings. Where it asks for:
Proceeding(s), type in: 20-270.

ARRL FCC Counsel, David Siddall, K3ZJ has provided us all information
and suggestions that would be very helpful for those submitting
comments:

“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.”

More comments from David, K3ZJ:

“I do not recommend arguing that the $50.00 fee every 10 years, which
amounts to $5.00 a year, will “kill” amateur radio, even though as
proposed this is for each covered application, which includes upgrade
applications. Tech-General-Extra could be $150, if the exams are taken
at different sessions, a substantial amount. But it “rings” the
wrong way to say the whole service turns on $5.00/year for each
licensee.

The Commission argues that the charges are required by the statute. The
word used 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.

This is not “aimed at amateur radio to kill it.” There is a long
history and precedent on charging fees for the licensing service
involved, just as there is for passports, green cards, driver’s
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, including myself as a struggling high school and college
student (if adjusted for inflation).

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. I recommend keeping
“ham jargon” out of comments, it won’t be understood by the
intended recipients.”

I think that David is right on target here. I recommend, and also urge,
that arguments submitted for this petition are both thoughtful and
respectful. To do otherwise leaves a very poor light on the hobby we
all love. Take what you see here, re-word as necessary so it comes from
your heart, and let’s get this defeated, (or at the very least,
mitigated)!

73;

Mike Ritz, W7VO
ARRL NW Division Director

www.arrl.org
www.arrlnwdiv.org
w7vo@arrl.net


ARRL Northwestern Division
Director: Michael T Ritz, W7VO
w7vo@arrl.org

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