FCC Fee Opposition – now is the time!

From: ARRL Members Only Web site <memberlist@www.arrl.org>
Date: October 17, 2020 at 09:57:19 CDT
To: 
Subject: FCC Fee Opposition – now is the time! The amateur radio fee proposal has been published in the Federal
Register.

https://www.federalregister.gov/documents/2020/10/15/2020-21530/schedule-of-application-fees

Now that it is published, it is time to comment on the FCC website:

https://www.fcc.gov/ecfs/search/filings?proceedings_name=20-270

AND, if you wish, reference the Federal Register, and send your comments
to your elected representatives and the President.

THERE ARE FEWER THAN 30 DAYS TO COMMENT. PLEASE DO THIS NOW!

The Priority is getting comments filed with the FCC.


ARRL Washington Counsel David Siddall, K3ZJ, has suggested the following
arguments:

Arguments Against FCC Fees for Radio Amateurs

1. 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.  

2. 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.

3. 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.

4. 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 corp 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.

5. Amateur radio continues to be a source of significant technological
innovation that should be encouraged, not discouraged.

Some Suggestions

I do not recommend arguing that the $50. 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 exams taken at
different sessions, a substantial amount.  But it “rings” the wrong
way to say the whole service turns on $5./year for each licensee. If
that’s all it would take ….

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, 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,
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.”

73,

——————————————————————–
ARRL Southeastern Division
Director: Mickey V Baker, N4MB
n4mb@arrl.org

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