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 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 “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.
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ARRL Great Lakes Division
Director: Dale R Williams, WA8EFK
[email protected]
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Norm Davis WB4BKO says
You are probably wasting your time. I doubt the FCC will listen and will do what it wants. Those contemplating this fee regulation, are oblivious to the negative impact this may have on Amateur Radio.
W8SFC~Steve says
I realize that this is a lot to ask, however other than a non specific mandate to charge fees, to what purpose are these fees collected and what are they ultimately used for? Government governs and administrators administer, but is is too much for them to justify the need for these fees and to inform the payers of them what the FCC does with this money? I agree it isn’t a huge impact on my finances, BUT why are they all of a sudden concerned with this in the first place? I believe if you are going to make people pay for something you should at the very least demonstrate responsibility in explaining the changes from past procedure and policy.
K8MEJ says
I disagree with most of what Dale suggests and to be fair, it’s a lot of what I’ve heard from other hams. I think continuing to push the aspect of emergency communications as the leading argument is anachronistic. Whether this aspect is still useful or not doesn’t matter much because I frankly don’t think the FCC believes that hams provide much of that value. I know a lot of OMs have put a lot of time in EMCOM so I don’t mean to imply they are worthless.
The notion of not charging license fees for people under 26 is a novel idea and seems reasonable.
I don’t mind one bit paying a $50 fee every ten years. And, given that, I’ll throw out another thought. If we “pay” for licensing you could make the argument, then, that we’re paying something to access the bands we’ve been allocated. That equates to millions or billions of dollars of value and if we can show that we have put some skin in the game directly to the governing authority, perhaps then that gives the ARRL more ammunition to say “hey, we’re not mooching here. We pay a small fee to maintain access to the spectrum”. That’s probably a weak argument because it could also be argued it’s just an administration fee, not a right to use fee.
I also wouldn’t mind paying a fee if that fee went to hiring a couple of people at the FCC who actually gave a damn about the amateur service. Enforcing regulations would be a novel concept these days. Help us track down jammers, lids, squirrels, pirates, and the yahoos on 7.200 and I’d be happy to pay more for my license.
Dan KB6NU says
I agree with your comment that emergency communications/public service should not be the lead argument against this fee. As I noted in my post on the ARRL Annual Report, the total “volunteer value” provided by these activities was only $14.6 million. That’s not chump change, but in the grand scheme of things, it’s not very much. Pointing that out just emphasizes how little amateur radio contributes.
Mark Rose says
I’m good with it if it especially eliminates the lids that like to change call signs every time a “good one” shows up on the availability list.