Subject: FCC Notice of Proposed Rulemaking - Amateur License Fees


Dear ARRL Members of the Midwest Division,

The fees Notice of Proposed Rulemaking was published in this morning’s
Federal Register (https://tinyurl.com/yyk8f2yp).  The deadline for
Comments is November 16, and the deadline for Reply Comment is November
30.  I urge you to first read the Notice at this link and then submit
your comments opposing this proposed fee for amateur licensing actions.

You may submit comments, identified by MD Docket No. 20-270, by either
of the following methods:

Federal Communications Commission's Website: http://apps.fcc.gov/ecfs/.
Follow the instructions for submitting comments.

People With Disabilities: Contact the FCC to request reasonable
accommodations (accessible format documents, sign language interpreters,
CART, etc.) by email: FCC504@fcc.gov or phone: 202-418-0530 or TTY:
202-418-0432.

The following information, provided by ARRL General Counsel, David
Siddall, K3ZJ, is provided to facilitate your comments to the FCC:

Good 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 core that monitors the amateur
airwaves with 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 Additional 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 were taken at
different sessions, would be a substantial amount.  But it “rings”
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 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 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 FCC 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 your comments as it won’t
be understood by the intended recipients.

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ARRL Midwest Division
Director: Roderick K Blocksome, K0DAS
k0das@arrl.org