[K3CAL] Fwd: This is a call to action for the ARRL Atlantic Division.

[Dave]

This is forwarded so those CARA members who are not ARRL members may see this action email.
DaveKB3RAN


-----Original Message-----
From: ARRL Members Only Web site <memberlist at www.arrl.org>
To: davehardy0101 at aol.com
Sent: Sun, Oct 18, 2020 12:51 pm
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

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

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