Okay N3FAA, your argument is that "we" are "freeloaders," "cheap," "ought to feel embarrassed," and "everyone else is paying our way." These are non-arguments because they don't address the pros or cons of the appropriation act or the FCC response to it. Americans pay fees and/or taxes for a wide variety of things. Many of us believe we are already paying too much for the services we receive. We don't want to pay even more, to a government, drunk on over-reaching power grabs, unconstitutional regulations, and deficit spending, not to mention the incredible debt we're passing down to future generations. Many of us would like the spending to STOP, and we pray that our "elected representatives" will stop asking for more and more of our hard-earned money. We don't live in a communist oligarchy where petty bureaucrats are allowed to dictate to us how to be "good citizens" and "what we should pay" and how we should "feel." We all have a First Amendment right to speak, write, and petition the government for a redress of grievances. The latter has been a right since the Magna Carta, 800 years ago, and the former since the American Bill of Rights. When we take to the ECFS to comment, we're exercising our rights. You have a right to pay this fee/tax (whatever) freely, happily. If you choose to do so; good for you! You don't have a right to abuse, demean, and insult others who disagree with your opinion. Not here (according to our code of conduct) and perhaps more importantly, not as a member of the federal bureaucracy. You say, "I could care less" yet, you hold yourself out as a supervisory member of the FAA. In fact you changed your call to reflect your employment with the FAA when you upgraded to general in 2019 (according to your BIO). "(I) upgraded to General and then Extra 3 weeks later, in 2019. My current call sign (N3FAA) was selected to reflect my job as Operations Supervisor with the Federal Aviation Administration." https://n3faa.com/about.php There is NO benefit to hams to pay the fee/tax (whatever) to the General fund. It can't legally be used to fund the ULS or anything else at the FCC, because the FCC derives its funding from regulatory fees, not application fees. It may even be a complete mistake on the part of the legislators involved. That's one of a dozen valid arguments. The ARRL filing and hundreds of opposition filings cover the facts adequately. Now, in addition to the foregoing advice, you may want to add a disclaimer to your signature line here, as an ethical way to let people know you don't speak for the FAA, and that your comments are personal in nature and in no way intended to reflect FAA policy, and that any non-supervisory FAA employees are free to hold any opinion they wish, with regard to the fee, and any other FCC or governmental policies. Otherwise, non-supervisory FAA employees may believe their First Amendment rights are being unconstitionally chilled by an FAA supervisor, and their political speech, and right to petition the governemnt to redress their grievances are being chilled or coerced and unfairly infringed upon by a supervisor who believes they are "freeloaders," "cheap," "ought to feel embarrassed," and that "everyone else is paying their way." Based on your written words and attitude, I think it would not be unreasonable for similarly situated employees to believe retaliation might be forthcoming, if they disagree with you. It's okay if people disagree with the legislation. It's okay if people disagree with you. It's the American way. It's not a reflection on their character as Americans or upon their ability to pay their way. They're already paying more than any legitimate government would ever require under the tenets of our constitution. Many people don't enjoy the federal salary and benefits you enjoy, or anything close to it. It's okay if they don't want to pay more into the General Fund to increase those benefits and salary to other federal employees, like yourself. https://www.faa.gov/jobs/working_here/benefits/ And with regard to your comments here, I'm not going to complain to the FAA or the QRZ staff, because as a fairly new member of the Extra ranks, I'm trying to very gently Elmer you, regarding how to engage in a reasonable discussion with your peers via social media. You're free to reject my advice, and since you "could care less" you will probably reject my advice, and that's okay too. However, as a member of the public who helps pay your salary and benefits, I'd like to also gently remind you that you should probably review the following. https://www.faa.gov/jobs/new_employ...al/media/HRPM_ER-4.1_Standards_of_Conduct.pdf 7. General Conduct Expectations. All employees are responsible for conducting themselves in a manner which will ensure that their activities do not discredit the Federal Government and the FAA. d. Exercise courtesy and tact at all times in dealing with fellow workers, managers, contract personnel and the public. 10. [T]he right of employees, either individually or collectively, to petition Congress or any member thereof or to furnish information to any committee or member of Congress is provided by law. While the FAA desires that employees seek to resolve any problem or grievance within the agency, any employee exercising the right to correspond with a member of Congress shall be free from restraint, reprisal or coercion. Finally, you can easily reach out to discover how you can fully support and comply with all DOT and FAA regulations, policies and programs, regarding your social media participation. Deputy Ethics Official, Federal Aviation Administration Pat McNall Deputy Chief Counsel Pat.McNall@faa.gov 202-267-3773 https://www.transportation.gov/ethics I look forward to hearing many more of your well considered and thoughtful opinions, in the future. 73, and I do sincerely hope you consider this advice as I believe it will greatly benefit you and your fellow hams and supervisees, Tom
LMAO!!!! You really are crazy. Seriously....crazy. I'm not talking anything FAA or aviation, I'm not going to include any disclaimer. You can go pound sand. If you want to talk about the FCC license fee, then let's talk. If you want to try to overwhelm the forum with pages of useless nonsense, then we're finished here. The fact of the matter is that we account for almost half of all ULS entries. There are direct costs associated with that. If you don't feel like paying the license fee, then find a different hobby without such fees.
But the ULS fees are paid by regulatory fees, which hams are exempt from paying. Are you suggesting that hams should pay regulatory fees as well as these proposed application fees? If you are, then you need to make a new proposal to the FCC that removes the exemption from those regulatory fees. But once that can is opened, we might be libel for many more charges. Lots of entities are exempt from FCC regulatory fees and application fees. One example is non-commercial FM and TV stations that generate millions of dollars in revenue for their licensees. But they don't pay a single dime of application fees or regulatory fees. Nada. Would you not think that they should be paying something, or is it just the hams who have no legal ability to generate revenue from their activities?
They absolutely should pay as well. What revenue they make, makes absolutely no difference. That doesn't change the cost of processing applications, making ULS changes, etc. The cost is fixed no matter how much money you make with your license. The fact of the matter is that we still account for 40% of those actions. The only real arguments I have heard are: 1) Kids and elderly can't afford $50 2) We already pay taxes 3) 4% of us provide some form of public service, so we shouldn't pay None of them make sense.
But if we are exempt from regulatory fees, so we cannot be made to pay for the ULS. Until we are not exempt, we are not required to pay these regulatory fees. The current proposal holds our exemption in place, that doesn't change. The only thing that has changed is the FCC mandate to collect fees that cover their costs of processing the application. The ULS is not part of the application, and application fees are not used for that purpose (the ULS). So, drop the part about the ULS, at least until we are no longer exempt from paying for it. You can debate that if you want, but it is not a part of this proposal to collect application fees. You would first need to convince the FCC and others that we need to pay regulatory fees. That change doesn't seem to be on the horizon, as the RAY BAUM's act specifically exempts hams from paying regulatory fees.
You're trying to play some sort of semantics game here, as you have been all thread, and it isn't working. Call it whatever you want. When I refer to the ULS, that is to get an idea of just how much of the "application system" we use as hams. 40% of license actions and over 70% of personal license actions come from the amateur radio community. There is a cost of processing those applications and changes. We should absolutely pay for those costs. The arguments against it just don't make sense.
The argument against it is that application fees only pay for application processing. Regulatory fees pay for the ULS and a lot of other stuff. But hams don't pay regulatory fees, because we are exempt. Because we are exempt (now and even after this NPRM takes effect), we don't pay for the ULS, that cost burden is borne by others. Whether or not it should be borne by hams is not the issue of this NPRM, as clearly, hams are still exempt, and nothing has been proposed to change that. So, the only real question is how much should the FCC charge to process our applications? In the NPRM, there is a procedure given as to how the determination of fee is supposed to be done. Basically, a calculation of the labor required to process the application, that's all. But that is an extremely low figure, and the FCC knows this. So, they propose a "nominal fee" of $50. But RAY BAUM's act doesn't mandate a "nominal fee" to be collected, it mandates a collection of an amount equal to the costs of processing the application. IF the FCC actually proposed an amount equal to the labor costs involved, it would probably be on the order of $5 or so, which is a fraction of the $50 "nominal fee" that they are proposing. THAT is the problem that I see. A fair and equitable assessment of what it costs to process the application. Remember that this money in no way benefits the FCC, it is sent to the federal coffers, to be spent in any manner that they see fit. The FCC is not lacking for money, they submit a budget, and get every penny assigned to them. They collect FAR MORE in auction fees, regulatory fees, application fees, and enforcement fees than they use. The current FCC budget is around $339 million per year, but they take in billions of dollars each year.
Very true Joe. The Fee/Tax doesn't benefit hams or the FCC -- in any way. It will be wasted on things like salaries and benefits for our morass of arrogant and incompetent federal workers (See the OIG reports and the individual Inspector General reports). It will also be wasted on things like the $500,000 self-cleaning toilet at a D.C. area Metro station, or the $22 million effort to get Serbian cheese up to international standards, or something like the NIH study that looked into whether there was a link between drinking alcohol and going to the emergency room, or the mating habits of Blue-Tongued Skinks on cocaine. Dumb, wasteful, irrelevant spending. https://www.gao.gov/reports-testimonies/by-agency/All Agencies (A-Z) https://www.muckrock.com/foi/united...c-inspector-general-reports-16039/#file-37658 How many times can we point out the facts? The standard retort from those ignorant of the facts is "you're cheap!" and "you're crazy!" and other insulting, but ultimately uninformed opinions. It's also true that the current FCC budget is around $339 million per year, and they can allocate that for whatever they want to do, subject to congressional directives. Regulatory fees pay for the FCC. The uninformed argument is that the application tax/fee "will fund the ULS" but that's also an uninformed, non-starter. Regulatory fees pay for the FCC, where we're exempt, not application fees, which go to the general fund. The ULS is in the cloud, where the FCC will use$ 3 million (already in the budget) to pay for cloud services (there is no maintenance as it's a contractor line-item) and anyone can take 30 seconds to read page 19-21 in the 2020 budget, where that's explained. The FCC is fully funded. Period. Since FY 2014, the Commission has modernized several of its outdated legacy-based systems, including the following systems most recently: Electronic Document Management System (EDOCS), Reimbursable Funds Administrator System (RFAS), Universal Licensing System (ULS) Auctions Hotline, Fixed Satellite Services, and 3650 MHz Licensing. These modernization successes have resulted in a dramatic technology shift that has allowed the Commission to move away from on premises and custom developed systems to cloud-based platform solutions. These modernization efforts also have been successful in empowering the Commission by employing modern technology solutions to transform outdated legacy-based applications into more resilient, secure, and highly available cloud-based applications. https://docs.fcc.gov/public/attachments/DOC-356607A1.pdf https://aws.amazon.com/ Once again, what pays for FCC programs? Regulatory fees. Do we pay regulatory fees? No. Where does the application fee go? To the general fund. What does that pay for? All of the other wasteful garbage. https://www.paul.senate.gov/news/dr-rand-paul-releases-2019-‘festivus’-edition-‘-waste-report’
You have a pair Sir. Incredibly few would ever put forth a truth that could in all likelihood come back to bite them. Much better to remain silent and hope to all it passes without notice. You are offically a man amoung men. BECAUSE THAT'S THE WAY IT IS. God bless and keep the shiney side up.
You don't want to know what I think about this statement. I believe, everyone should pay there way, $5.00 a year is not unreasonable.
If the money goes toward Amateur Radio enforcement, it's not a bad thing, IMO. BUT, 50 bucks is way, way too much money. A TOKEN amount, say 5 or ten bucks every ten years, that is used EXCUSIVELY toward OUR interests as ham ops might help us. License modification, vanity calls and other 'services' could also be covered by the same token amount. Heck, we can't even get a paper license anymore, unless we ask for it. That's just nuts! If the moneys collected are squandered on other things, I'M OUT!!!! i
I have to post this. I have called amateur radio a hobby in the past. I have seen posts here say it's a Hobby. As a matter of law hobbies do not require a license from the federal government. So the argument that this is a hobby is dead. Thanks.
I don't think having a license requirement precludes any activity from being a hobby, it simply means that a license is required (for whatever reason). General aviation can be a hobby, and a license is required for that. Lots of hobbies are licensed at a state or local level, so requiring a license (or not) has no specific bearing on the classification as a hobby. A hobby is something you do apart from your normal job, something you do for enjoyment and personal reasons. It is not a job, so you don't expect to be paid for doing it. Most people would agree that ham radio fits that definition.
I DON'T KNOW WHAT THE FCC'S PROBLEMS ARE. FEE NO FEES OKAY FEE'S. THEN $50.00 WOW AND I THOUGHT 10. WAS ENOUGH. WE LICENSE IN VT AND NOT THE FCC INSISTS THAT THE ARRL VE GROUPS GET A LICENSE APPLICANT A FRN NUMBER BEFORE THEY EVEN TEST?? ARE YOU KIDDING? HAVEN'T THESE PEOPLE EVER HEARD THE EXPRESSION IF IT'S NOT BROKEN DON'T FIX IT... 73
