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Default [KB6NU] Time to comment on the proposed new fees

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Time to comment on the proposed new fees

Posted: 15 Oct 2020 08:59 PM PDT

From our division director, Dale, WA8EFK.

The fees Notice of Proposed Rulemaking was published in this morning’s
Federal Register. The deadline for comments is November 16, and the Reply
comment deadline is November 30.

With this in mind, I am extending the following suggestions you might
consider using in writing to the FCC in response to the NPRM. Our thanks to
Dave Siddall K3ZJ, ARRL Counsel, for these guidelines. 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

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 “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.

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

Thank you.

ARRL Great Lakes Division

Director: Dale R Williams, WA8EFK

The post Time to comment on the proposed new fees appeared first on KB6NUs
Ham Radio Blog.

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