11/19/2020

ARRL has urged the FCC to waive its proposed $50 amateur radio application fee. The Commission proposal was made last month in a Notice of Proposed Rulemaking (NPRM[1]) in MD 20-270. The proposal already has drawn more than 3,200 individual comments overwhelmingly opposed to the plan. The fees, directed by Congress and imposed on all FCC-regulated services, are to recover the FCC's costs of handling and processing applications.

"Amateur radio applications were not listed when the Congress adopted its 1985 fee schedule for applications, and therefore amateur license applications were excluded from the collection of fees," ARRL said on November 16 in its formal comments[2] on the proposal. "Similarly, a decade later when regulatory fees were authorized, the Amateur Service was excluded, except for the costs associated with issuing vanity call signs." The new statutory provisions are similar. Amateur radio license applications are not addressed in the application fees section and explicitly excluded from regulatory fees," ARRL said, and there is "no evidence of any intent by Congress to change the exempt status of amateur applications and instead subject them to new fees."

ARRL argued that the FCC has explicit authority to waive the fees if it would be in the public interest, and should do so for the Amateur Radio Service. Unlike other FCC services, the Amateur Radio Service is all volunteer and largely self-governing, with examination preparation, administration, and grading handled by volunteers, who submit licensing paperwork to the FCC, ARRL pointed out.

"Increasingly, the required information is uploaded to the Commission's database, further freeing personnel from licensing paperwork as well as [from] day-to-day examination processes," ARRL said. "The addition of an application fee will greatly increase the complexity and requirements for volunteer examiners."

The Communications Act, ARRL noted, also permits the FCC to accept the volunteer services of individual radio amateurs and organizations in monitoring for rules violations. In 2019, ARRL and the FCC signed a memorandum of understanding to renew and enhance the ARRL's Volunteer Monitor program, relieving the Commission of significant time-consuming aspects of enforcement.

These volunteer services lessen the regulatory burden - including the application burden - on the Commission's resources and budget in ways that licensees in other services do not, ARRL said.

Amateur radio's role in providing emergency and disaster communication, education, and other volunteer services also justifies exempting radio amateurs from FCC application fees. For example, ARRL noted, last year more than 31,000 participated as members of the ARRL Amateur Radio Emergency Service (ARES), and local ARES teams reported taking part in more than 37,000 events, donating nearly 573,000 volunteer hours, providing a total value of more than $14.5 million.

Amateur radio also has motivated many students to develop critical science, technology, engineering, and mathematics (STEM) skills. ARRL noted that the Amateur Radio Service contributes to the advancement of the radio art, advances skills in communication and technology, and expands the existing reservoir of trained operators, technicians, and electronics experts - all expressed bases and purposes of the Amateur Radio Service.

"Accomplishing these purposes entails working with young people, many of whom may have difficulty paying the proposed application fees of $50, $100, or $150," ARRL said. "The $150 fee would be the cost of passing the examinations for the three amateur license levels in three examination sessions," ARRL said. "Such multiple application fees to upgrade would dampen the incentive to study and demonstrate the greater proficiency needed to pass the examinations for the higher amateur classes."

ARRL concluded that the FCC should exercise its authority to exempt amateur radio from application fees generally. If the FCC cannot see its way clear to waive fees for all amateur radio license applications, the fees should be waived for applicants age 26 years and younger. Such individuals, ARRL contended, have the most to contribute to the future of radio technology and other STEM-related activities and are the most likely to find the proposed application fees burdensome.


[1] https://docs.fcc.gov/public/attachments/FCC-20-116A1.pdf
[2] https://www.fcc.gov/ecfs/filing/111762316365

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