Yes and no. 1) FCC doesn't plan to charge for name and address changes, nor cancellations, so the cost of those has to be carried by the chargeable transactions. 2) It is not clear exactly how FCC does their accounting when it comes to the ARS. There's direct labor, additives (benefits and other costs), overhead (office space, expenses), and the cost of the computers, utilities, internet connections, etc. Also the added cost of collecting the fees, which they don't do now. Still, $50 for a renewal done and paid for online every 10 years seems kinda high.