My Comments On The Proposed FCC License Fees

You have probably heard about the FCC proposal to establish a $50 application fee for Amateur Radio licenses. This is part of an overall redesign of the FCC’s fee structure, affecting many radio services, not just amateur radio.

The Notice of Proposed Rule Making (NPRM) is found in Docket 20-270.  The public is invited to submit comments on the proposal via the Electronic Comment Filing System (ECFS). It is relatively easy to do. You can upload a document with your comments or use “express comment” to just type in your comments.  If you are short on time, you could simply submit a few sentences supporting or opposing the licensing fee along with your reasoning. The only tricky thing you need to know is the proceeding number: 20-270.

I thought this was important enough that I put together my thoughts and submitted them.  The short version of my comments are:

  • The $50 fee seems excessive, compared to the cost of relatively simple amateur radio license transactions. (If it really costs the FCC $50 to do this, they need to redesign their system.)
  • The $50 fee will be a barrier to getting an amateur radio license for many potential licensees. That’s my opinion based on interacting with a large number of new licensees coming through our club’s Technician license class.
  • I support charging a smaller fee, in the range of $15 to $25.

You can read my complete comments here:
Robert Witte K0NR Comments MD Docket No. 20-270

73 Bob K0NR

The post My Comments On The Proposed FCC License Fees appeared first on The KØNR Radio Site.

Bob Witte, KØNR, is a regular contributor to AmateurRadio.com and writes from Colorado, USA. Contact him at [email protected].

11 Responses to “My Comments On The Proposed FCC License Fees”

  • Ron N8WCR:

    I totally agree with you! When I first saw this I was shocked. This will drive away or even dry up existing hams, plus it will be an obstacle for hams to want to upgrade. A fee about $15-$20 is reasonable, this puts it in the realm of most hams, but $50 is way excessive. If it does cost the FCC around $50 to do this now, then they wouldn’t be doing it for free all this time as it is. We need to encourage new hams, not discourage it because of the excessive fees to get into the hobby. It is a hobby.

  • Trevor AG7GX:

    $15-$20 is still excessive when you add in the VEC fee on top of it (which is just barely reasonable for some examinees by itself).

    However, I could see $50 for vanity calls (one of the other things they are proposing doing) as being feasible. That would certainly cut down on the abuse that’s happened since it became free.

  • BOB AF2DX:

    Well FCC sees how much we spend on radios and gear.
    I feel the 50.00 fee for 10 years is very reasonable
    Just my 2 cents on the subject
    BOB AF2DX

  • Glenn W9IQ:

    The FCC has acknowledged, 5 years ago, that their cost to collect a fee was in excess of $25.00. Presumably this has increased by now so your proposed lower fee will be a non-starter as they are trying to achieve cost recovery through this proposal.

    – Glenn W9IQ

  • Steve NS9DX:

    I can’t see a justification for establishing a fee for processing an amateur radio call sign. $50.00 is unacceptable for any ham radio license. Aren’t Americans taxed enough by government? Keep it free: As it should be!

  • Richard KWØU:

    There certainly are a lot of opinions about this topic. QRZ has several dozen pages on it. But none of that matters if you don’t let the FCC know what you think. Commenting is easy. Here’s mine, but no one else’s need be as long.

    This is to respectfully oppose the institution of application fees for amateur radio, as briefly noted in 20-270, III.25. While I understand the mandate of PL 115-141 to cover such costs, there are serious issues with the proposal as it now is written. My concerns fall into the following areas:
    1. Institution of a fee set at $50. This appears to have been established by an unsupported “estimate” and perhaps is an arbitrary number that would be hard to justify. It certainly is not, as stated, a “nominal” amount for a young person, many retirees, and those otherwise on very limited budgets. As I am certain the Commission is aware, amateur radio is completely non-remunerative, handles its own license testing and, as much as possible all applicants’ paperwork. Surely a review of a test result and application form (both already checked by volunteer examiners) and entry of this information into a database cannot cost almost 7 times the federal hourly minimum wage. (In a similar manner, it seems that printing and mailing a paper license—something required of amateurs when they operate abroad— should not cost anywhere near this much.) Per Appendix B, paragraph 38, I therefore suggest recalculating the proposed fees based on the time required by a clerical worker to review, enter and file the paperwork, with a generous assumption of no more than 10 minutes per ordinary application. A similar time may be inferred for mailing a copy, which should be largely an automated process. As a final note, the entire issue may be moot, given that regulatory fees are specifically excluded from the amateur service. Under these circumstances is it even possible to clearly separate them from application fees?
    2. While much of the NPRM is written in the usual clear style that the FCC uses, in terms of amateur radio the meaning of “application” is uncertain. Since there are three classes of licenses in the amateur radio service, does this mean that upgrading will cost the licensee an additional $50? What happens if someone passes two or three tests at a single exam session? Would there be one, two or three fees?
    3. To continue the discussion of different operator classes, how does the discouragement of qualifying for an initial license, or of upgrading one, square with the specific public service purposes of amateur radio that are laid out in Part 97? As I am sure your staff is very aware, this mission is specified in Part 97.1, while 97.3(4) also notes the enhancement of operator skills. An increased skill level is rewarded with a higher license class, which in turn grants additional privileges. Given the service that amateur radio can provide this process is exactly in the public interest. Charging for new or higher licenses will not help the public as less people will be likely to study and test for them.
    4. Next, would a change of call sign be considered an “application”? Per the Commission’s practice that has been in effect since at least the 1950s, when radio amateurs receive a higher class license they frequently request a shorter call. And at any time operators may ask for a call sign that matches the radio district where they live. This could be different from where they were originally licensed. To pay for these changes appears completely unwarranted.
    5. Also regarding call signs, various short-term events are held that amateur radio operators publicize. Reflecting a procedure that is very common around the world, upon application the Commission has issued operators special prefixes for these events. “W19OG” for the Salt Lake Winter Olympics, “K96EWG” for the Atlanta Olympics, and “NN50CIA” for that agency’s anniversary are examples. More often a simple 1×1 call has been issued, such as W2W for the Pearl Harbor attack. Are application fees proposed for those who volunteer their time to conduct on-air celebrations of events that may be local, state, national or even international in scope? 6. Finally, it does not make sense to lump amateur operations in with the General Radio Mobile Service. The two have totally different uses of the spectrum. The GRMS is as a certainly a personal radio service that is limited to a few UHF bands for immediate communication. With the exception of the 60 meter band, amateur radio is not structured like this. Nor, as noted above, does it have a remotely similar mandate in how it is intended to serve the public good.
    Although Section 8 of the legislation may have inadvertently left out amateur radio, the service is definitely non-profit, non-pecuniary, and non-remunerative, and is thus deserving of exemption. Reclassifying it as such rather than as a personal service would avoid the application fee entirely. In any event, for the reasons noted above far more discussion and revision is needed. It is because of the issues raised here that I oppose the proposed rule change.

  • John KD0JPE:

    When I first read about this I was concerned but $50.00 doesn’t seem excessive when you consider that if you own a automobile, with a 20 gallon gas tank, you will spend that much to fill it up when empty. If you’re worried about the cost of renewal, put $5.00 in a bank account, once a year, and you’ll have the $50.00 when the 10 years is up. If you’re concerned that it will scare away those thinking about becoming a ham, look at what the average 20+ year old spends on their smart phone and Starbucks. One possible benefit from the implementation of fees is that it may stop those who abuse 1X2 and 2X1 call signs to keep them out of the hands of non-deserving hams. (Those who didn’t have to pass a 20 wpm code test and draw a Colpitts oscillator.)

  • Kenneth Lung//KD4HQQ:

    As usual, our government at work. They are most likely unaware of the public service amateur radio provides during local, state and national emergencies. What is a mere $50.00 to the US government?? Too bad they don’t have to justify their expenses to the public.

    I am totally against the advent of any money for amateur licensing.

    Kenneth Lung
    KD4HQQ

  • Brian AB9ZI:

    Comment 1:
    In my humble opinion, this is just another attempt by the FCC to change the concept FROM the airwaves belong to the public, TO the airwaves belong to the highest bidder.
    If higher license fees mean fewer licensed hams, then its easier to justify selling off portions of our bands to big business.

    Comment 2: Regarding John KD0JPE comment “Those who didn’t have to pass a 20 wpm code test and draw a Colpitts oscillator.”
    I gave a copy of a practice test for the current General license to an elderly ham friend who was first licensed in the early 1950s. He was appalled at how simple the test was compared to the test he took. Not only did he have to draw a circuit, he then had to explain to the examiner HOW the circuit functioned!

  • John KD0JPE:

    Comment 2, from Brian AB9ZI, supports my reason for believing the fee might be a good idea for vanity call signs. The so-called dumbing-down of today’s tests doesn’t justify the behavior of some who hoard call signs just to to keep newer hams from acquiring them. And no, I’m not interested in changing the call I got as a Technician for a 1X2 or 2X1. Like my uncle (WA9FBK) and my aunt (WA9EZP) I’ll keep my first call for life.

    I have my Extra and a GROL, with radar endorsement, and can draw an op amp-based band pass filter, calculate the necessary resistor and capacitor values for the band in question, and explain how it works. I would guess that many hams who were originally licensed in the 50’s can not do the same. Does that make me a better ham than them? I don’t think so.

  • John Demetrius, KC2OII:

    It is my opinion that the $50 fee forissuance of an amateur license is excessive, especially since many entrnace hams are teenagers and can’t afford to purchase a radio.

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