ARRL Encouraging Amateurs to File Comments Opposing FCC Fee Proposal

I am certain posting this will bring some controversy here, but I think it's an important development.

Per the title, the ARRL is encouraging amateurs to provide comments on the FCC proposal to re-institute fees for Amateur licensing. There are also instructions on how to file them.

http://www.arrl.org/FCC-Fees-Proposal

 

..and wouldn't it be helpful if we saw those objections to be submitted by the National Association of Amateur Radio--before the deadline?

Why is there not a link with the ARRL response to the NPRM--now?

For example, the ARRL might be able to point out certain aspects that the MANY respondents could AMPLIFY through their own expected experience, as responses.

SUGGESTING issues to address, specifically, is HELPFUL, rather than a call to arms without a proffered plan of attack.

It's not taking away people's right to think and respond if you help by articulating the issues and ways they may affect Part licensees..

That's called : 'leadership'.

 

Like I would count on the ARRL for anything. Well maybe cancelling anything far into the future. Gun owners have multiple groups supporting them so maybe its time we do the same. Tired old men with tired old ideas won't fix a thing.

 

It is disappointing again the ARRL response seems to be "a day late and a dollar short".

 

If anyone cares, and if it's helpful, maybe give some ideas, here's the ECFS Comment I filed on this proceeding a few weeks ago. There are other valid and important points that could be made, but I was trying to keep it brief, not write a book about it.

NN4RH ECFS Comment on Amateur Radio Fees.pdf

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COMMENTS CONCERNING MD DOCKET # 20-270, AMENDMENT OF THE SCHEDULE OF APPLICATION FEES ...

R.L. Holtz,
Amateur Extra Licensee NN4RH

These comments are directed toward the new $50 “application fee” for the Amateur Radio Service, as described in Sections 25 - 29.

1) The $50 fee applied to Amateur Radio Service is not “cost based”, but “nominal”, and clearly arbitrary.

The fees as applied to the Amateur Radio Service is described as a “cost-based fee” in Section 25, but in Section 27 the $50 is set as a “nominal application fee”. “Nominal” is not “cost based”, especially in the absence of a cost analysis. Thus, the $50 fee is arbitrary, not based on direct costs, especially since it applies to preexisting automated processes for which there currently are little or no direct costs.

2) The new fees applied to the ARS will have unintended consequences on youth participation. Fees should be waived for applicants under 17.

There is considerable concern in the Amateur Radio Service community that the imposition of a $50 per application fee will stifle growth and impede advancement of the service amongst the very important youth demographic. Creating this new hurdle to youth participation is likely to have negative consequences on the ability of the ARS to fulfill it’s Basis & Purpose and ability to provide public service in the future.

3) Enhancing Technician HF privileges will mitigate the expected loss of new amateur participation that can result from the fees.

A per-application fee will tend to discourage license upgrades, since each upgrade evokes another fee, unless new applicants can pass more than one test element in a single session. Having to study for two or three tests at one session will discourage many. Those who test for Technician only will result in even more new amateurs getting “stuck” at the Technician class level, for which spectrum allocations are very limited. If the new application fees are implemented, therefore, it becomes of utmost importance to add HF privileges to the Technician class license, as has been proposed by the ARRL.

4) A new fee for each instance of license class upgrade application is unfair economically.

If a fee is assessed for each upgrade application, then those who have the flexibility to study and pass two or three license elements in one session (and thus are filing only one application) have an economic advantage over those who may, for various reasons, for example job and family responsibilities, need to study for each element separately over a longer period of time. This is unfair and creates a “privileged class” of licensees. It should not cost two or three times more to reach Amateur Extra in two or three tests sessions, than it does in one test session.

5) Alternative is one-time fee for obtaining FRN and initial ULS entry, with subsequent license upgrades treated as administrative updates.

For an initial license application, the prospective licensee registers with the FCC and obtains an FRN. That action seems like it would entail more “direct labor” than subsequent license upgrades, which the NPRM admits in Section 27 are highly automated. License upgrades, once an FRN is issued and ULS entry created, are for all practical purposes “administrative updates”, given that the Amateur Service Volunteer Examiner (VEC) program does all the work of testing and processing the paperwork. This involves little or no additional “direct labor” at the FCC than, for example, an address change. Thus, if there must be any fee at all, it would make sense to assess a one-time fee for the creation of an FRN and the initial entry to the ULS. Then subsequent upgrades should not incur subsequent fees. This approach would avoid impeding the advancement of licensees to higher level licenses, and takes into account the fact that the Amateur Radio Service itself administers the licensing exams and prepares the applications through the Volunteer Examiner responsibilities.

6) The Amateur Radio Service, as a noncommercial service “without pecuniary interest”, should be exempt from the new fees.

Commercial entities have the ability to absorb application fees, by passing those costs on to customers. Non-commercial entities do not have that option. Indeed, the NRPM understandably carves out an exemption for “noncommercial radio stations”. The Amateur Radio Service is in an equally weak position to absorb application fees, because it also is defined as a noncommercial radio service. Additionally, the Amateur Radio Service is unique in that the regulations require our participation “without pecuniary interest”; i.e., it is explicitly against the regulations for us to recover our costs, including any fees.

 

The ARRL always seems to go about FCC proceedings in a secretive way and wait until the very last minute to submit their Comments. I don't know why that is. It comes across as they're dragging their feet because they aren't sure of their position, or maybe they're trying to "run out the clock" to leave as little time as possible for anyone to rebut what they say. Maybe they don't know what the amateur community thinks about it, so they wait to see what everyone else is saying first so they can word their Comments to do damage control. Whatever it is, I agree I'd rather they led rather than followed.

But as a practical matter, it doesn't matter. The FCC basically waits until some time after their deadlines before they even read any of this stuff. I don't think the order in which Comments are submitted carries any weight.

 

(As already mentioned), these are EXCELLENT points that Ron has submitted, and well worth re-enforcing.

 

People will religiously waste $50 a year on ARRL membership, which is basically nothing but a magazine subscription...spend thousands of dollars on radios, antennas, amplifiers, microphones, and all the other toys...but then gripe about and get bent all out of shape when asked to pay the equivalent of $5 a year for their license.

Would be tragic is it were not so damn funny...

 

The ARRL is trying to manage, like all of us, in troubled times. But the 'managers' just aren't making a lot of sense to, at least, some of us.

I support the ARRL. I think my Director is doing fine. But...in many cases, the directors don't seem to be getting nor sending the right message. They really should have given us helpful suggestions on this issue, on a board basis. Your opinion may differ.

 

whats even more funnier is that all this is smoke and mirror effect, no matter how much we complain or dislike what is proposed we are under cut right from the get go........ nothing is going to stop the fcc proposal......

 

$50,.... cheep at twice the price.

 

I received the email from ARRL and thought "what took so long." The FCC posted the info in the Federal Register on Oct.15 with a comment deadline of Nov.16 and the ARRL sends me the info at 1:30 this afternoon?
Guess they had more pressing business or maybe my expectations are a little high?

 

What I would like to know is the vote total on having Tech's in the HF Bands. Nothing has been released as to the numbers, there is no transparency other than the ARRL is on a money grab again keeping the manufacturers advertising in QRT...I mean QST. As for the $50.00 fee, that is cheap, it should be $500, that would keep the LID's and QRM'ers off the airwaves.

 

Yup $50 is cheap. ARRL remains incompetent. Nothing to see here folks...move along.

 

The ARRL does not want intelligent thinking members. It would be intelligent to give ALL Techs a two year Renewable licence to clean out the deadwood and give a more believable number of them instead of lying to us and advertisers.