AG41
QST de W1AW  
ARRL Bulletin 41  ARLB041
>From ARRL Headquarters  
Newington CT  December 31, 2020
To all radio amateurs 

SB QST ARL ARLB041
ARLB041 FCC Reduces Proposed Amateur Radio Application Fee to $35

The FCC has agreed with ARRL and other commenters that its proposed
$50 fee for certain amateur radio applications was 'too high to
account for the minimal staff involvement in these applications.'

In a Report and Order (R&O), released on December 29, the FCC scaled
back to $35 the fee for a new license application, a special
temporary authority (STA) request, a rule waiver request, a license
renewal application, and a vanity call sign application. All fees
are per application. There will be no fee for administrative
updates, such as a change of mailing or email address.

The R&O can be found online in PDF format at,
https://docs.fcc.gov/public/attachments/FCC-20-184A1.pdf .

This fall, ARRL filed comments in firm opposition to the FCC
proposal to impose a $50 fee on amateur radio license and
application fees and urged its members to follow suit.

As the FCC noted in its R&O, although some commenters supported the
proposed $50 fee as reasonable and fair, 'ARRL and many individual
commenters argued that there was no cost-based justification for
application fees in the Amateur Radio Service.' The fee proposal was
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.'

Information on Ray Baum's Act can be found online in PDF format at,
https://www.congress.gov/115/plaws/publ141/PLAW-115publ141.pdf .

'After reviewing the record, including the extensive comments filed
by amateur radio licensees and based on our revised analysis of the
cost of processing mostly automated processes discussed in our
methodology section, we adopt a $35 application fee, a lower
application fee than the Commission proposed in the NPRM for
personal licenses, in recognition of the fact that the application
process is mostly automated,' the FCC said in the R&O. 'We adopt the
proposal from the NPRM to assess no additional application fee for
minor modifications or administrative updates, which also are highly
automated.'

The FCC said it received more than 197,000 personal license
applications in 2019, which includes not only ham radio license
applications but commercial radio operator licenses and General
Mobile Radio Service (GMRS) licenses.

The FCC turned away the arguments of some commenters that the FCC
should exempt amateur radio licensees. The FCC stated that it has no
authority to create an exemption 'where none presently exists.'

The FCC also disagreed with those who argued that amateur radio
licensees should be exempt from fees because of their public service
contribution during emergencies and disasters.

'[W]e are very much aware of these laudable and important services
amateur radio licensees provide to the American public,' the FCC
said, but noted that specific exemptions provided under Section 8 of
the so-called 'Ray Baum's Act' requiring the FCC to assess the fees
do not apply to amateur radio personal licenses.  'Emergency
communications, for example, are voluntary and are not required by
our rules,' the FCC noted. 'As we have noted previously, '[w]hile
the value of the amateur service to the public as a voluntary
noncommercial communications service, particularly with respect to
providing emergency communications, is one of the underlying
principles of the amateur service, the amateur service is not an
emergency radio service.''

The Act requires that the FCC switch from a Congressionally-mandated
fee structure to a cost-based system of assessment. 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, which had been excluded previously. The 2018 statute
excludes the Amateur Service from annual regulatory fees, but not
from application fees.

'While the Ray Baum's Act amended Section 9 and retained the
regulatory fee exemption for amateur radio station licensees,
Congress did not include a comparable exemption among the amendments
it made to Section 8 of the Act,' the FCC R&O explained.

The effective date of the fee schedule has not been established, but
it will be announced at least 30 days in advance. The FCC has
directed the Office of Managing Director, in consultation with
relevant offices and bureaus, to draft a notice for publication in
the Federal Register announcing when rule change(s) will become
effective, 'once the relevant databases, guides, and internal
procedures have been updated.'