[GCARC] FW: This is a call to action for the ARRL Atlantic Division.

[djgrath1]

D. Jeffrey Garth
621 Greenbriar Drive
Williamstown, NJ 08094-1149
73, WB2ZBN
Club Publications
www.w2mmd.org

"Choose a job you love, and you will never have to work a day in your life" - Confucius

-----Original Message-----
From: ARRL Members Only Web site [mailto:memberlist at www.arrl.org] 
Sent: October 18, 2020 12:52
To: jeff.garth at comcast.net
Subject: This is a call to action for the ARRL Atlantic Division.

Greetings fellow ARRL Atlantic Division members,

It is time to protest the imposition of fees for Amateur Radio Licensing.

Many Atlantic Division members have contacted me in the past month about the FCC’s proposal for a $50 “application fee” for license applications in the Amateur Radio Service. The Notice of Proposed Rulemaking (NPRM) was published in the Federal Register (https://tinyurl.com/yyk8f2yp). 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 now. 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 harm or 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 is 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 in the Congressional Act which directs the FCC to collect fees 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 that respondents keep “ham jargon” out of the comments, which would not be understood by the intended recipients.

Thank you.

Tom Abernethy W3TOM

Comments to the Federal Communication Commission may be filed
online at;      https://www.fcc.gov/ecfs/filings
FCC’s Electronic Comment Filing System (ECFS) reference -  posting to MD Docket No. 20-270

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ARRL Atlantic Division
Director: Thomas J Abernethy, W3TOM
w3tom at arrl.org
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