[OFARC] Subject: FCC proposal for license fees Response by November 16

[gammamann at aol.com]

Subject: FCC proposal for license fees Response by November 16

All, just a reminder that there is time to submit comments for the notice of proposed rulemaking NPRM 20-270 which proposes $50 fee for various ham related transactions.  The ARRL provides guidance for how to respond on their website.  Comments must be posted by Noember 16.  

 www.arrl.org/news/arrl-urges-members-to-join-in-strongly-opposing-fcc-s-application-fees-proposal

The information provided by FCC is insufficient to determine if the $50 fee is their actual cost.  
Since most of the work is done by ARRL for licenses and most of the other transactions are done electronically, it is unlikely that the $50 fee represents the real cost to FCC for amateur radio.  
The fee will likely be a barrier to new and younger hams and could limit renewals. 
The functional effect will be to drive down participation in amateur radio (which the FCC likely does not care about)

See notes for some details.  

Note 1. Each agency is tasked with setting fees according to their actual expenditure for the service they provide. Government cost allocation is complicated and it depends on how the direct (labor, materials, equpment) and indirect costs (general and administrative overhead, building cost, utilities, IT, etc) is allocated internally. Factoring these in, the cost for FCC could be in the range of $200/hr.  Given the usual minimum billable time is 15 minutes, even a small amount FCC staff time could add up to $50. The cost is probably in the $15 range or less if the transactions are electronic. If we start talking about paper checks, the processing of these, returns, accounting, etc the actual cost could exceed $50.  Transactions by credit card, paypal, etc., are obviously less.

Note 2.  Many hams have licenses but are inactive.  While the FCC probably does not care about these too much, this could be a back handed attempt to clean out dead wood and reduce the inactive ham population that could object to the loss of spectrum to commercial users. 

Note 3. Comparing this to say a night out with dinner, cost per month for cell phone or internet, or entertainment, fees of this level might be considered reasonable. The cost for GMRS license is relatively high but the number of transactions for hams is higher and would be likely barrier to entry and renewal.  The comparison to GMRS is a strong argument for reinstatement of the license fee. 

Note 4. The ARRL will file their response at the last minute which is customary for this kind of action.  Other than picking at the legal details of the regulations and the barriers to entry etc, the hams have very little leverage so they could get stuck with the fees while the bigger users negotiate their terms. Its important to file some objection. There is obviously behind the scenes negotiations going on at FCC with the users but at this time there is no official fall back position for a different fee structure according to John Stratton N5AUS, (ARRL W. Gulf Director)  with whom I spoke to today.  John is also willing to participate by Zoom for a club meeting to OFARC if invited.  

Note 5.  Its important to file your response. See the ARRL for guidance.  

Mark WB5ANN
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