Begin forwarded message:

> From: ARRL Members Only Web site <memberlist@...>
> Date: October 15, 2020 at 20:47:41 CDT
> To: larrystaples@...
> Subject: FCC Notice of Proposed Rulemaking - Amateur License Fees
>
> Dear ARRL Members of the Midwest Division,
>
> The fees Notice of Proposed Rulemaking was published in this morning’s
> Federal Register (https://tinyurl.com/yyk8f2yp).  The deadline for
> Comments is November 16, and the deadline for Reply Comment is November
> 30.  I urge you to first read the Notice at this link and then submit
> your comments opposing this proposed fee for amateur licensing actions.
>
> You may submit comments, identified by MD Docket No. 20-270, by either
> of the following methods:
>
> Federal Communications Commission's Website: http://apps.fcc.gov/ecfs/.
> Follow the instructions for submitting comments.
>
> People With Disabilities: Contact the FCC to request reasonable
> accommodations (accessible format documents, sign language interpreters,
> CART, etc.) by email: FCC504@... or phone: 202-418-0530 or TTY:
> 202-418-0432.
>
> The following information, provided by ARRL General Counsel, David
> Siddall, K3ZJ, is provided to facilitate your comments to the FCC:
>
> Good Arguments Against FCC Fees for Radio Amateurs
>
> 1.    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.
>
> 2.    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.
>
> 3.    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.
>
> 4.    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 core that monitors the amateur
> airwaves with 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.
>
> 5.    Amateur radio continues to be a source of significant technological
> innovation that should be encouraged, not discouraged.
>
> Some Additional Suggestions
>
> •    I do not recommend arguing that the $50 fee every 10 years, which
> amounts to $5.00 a year, will “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 were taken at
> different sessions, would be a substantial amount.  But it “rings”
> 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 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, driver 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,
> including myself as a struggling high school and college student (if
> adjusted for inflation).
>
> •    For background: this proceeding is being handled by FCC 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.
> I recommend keeping “ham jargon” out of your comments as it won’t
> be understood by the intended recipients.
>
> --------------------------------------------------------------------
> ARRL Midwest Division
> Director: Roderick K Blocksome, K0DAS
> k0das@...
> --------------------------------------------------------------------
>
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