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ARLB035 ARRL Seeks Waiver of Proposed FCC Amateur Application Fees

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ARRL Bulletin 35  ARLB035
From ARRL Headquarters  
Newington CT  November 19, 2020
To all radio amateurs 

SB QST ARL ARLB035
ARLB035 ARRL Seeks Waiver of Proposed FCC Amateur Application Fees

ARRL has urged the FCC to waive its proposed $50 amateur radio
application fee. The Commission proposal was made last month in a
Notice of Proposed Rulemaking (NPRM) in MD 20-270. The proposal
already has drawn more than 3,200 individual comments overwhelmingly
opposed to the plan. The fees, directed by Congress and imposed on
all FCC-regulated services, are to recover the FCC's costs of
handling and processing applications.

The NPRM can be found in PDF format at,
https://docs.fcc.gov/public/attachments/FCC-20-116A1.pdf .

"Amateur radio applications were not listed when the Congress
adopted its 1985 fee schedule for applications, and therefore
amateur license applications were excluded from the collection of
fees," ARRL said on November 16 in its formal comments on the
proposal. "Similarly, a decade later when regulatory fees were
authorized, the Amateur Service was excluded, except for the costs
associated with issuing vanity call signs." The new statutory
provisions are similar. Amateur radio license applications are not
addressed in the application fees section and explicitly excluded
from regulatory fees," ARRL said, and there is "no evidence of any
intent by Congress to change the exempt status of amateur
applications and instead subject them to new fees."

ARRL's formal comments can be found online at,
https://www.fcc.gov/ecfs/filing/111762316365 .

ARRL argued that the FCC has explicit authority to waive the fees if
it would be in the public interest, and should do so for the Amateur
Radio Service. Unlike other FCC services, the Amateur Radio Service
is all volunteer and largely self-governing, with examination
preparation, administration, and grading handled by volunteers, who
submit licensing paperwork to the FCC, ARRL pointed out.

"Increasingly, the required information is uploaded to the
Commission's database, further freeing personnel from licensing
paperwork as well as from day-to-day examination processes," ARRL
said. "The addition of an application fee will greatly increase the
complexity and requirements for volunteer examiners."

The Communications Act, ARRL noted, also permits the FCC to accept
the volunteer services of individual radio amateurs and
organizations in monitoring for rules violations. In 2019, ARRL and
the FCC signed a memorandum of understanding to renew and enhance
the ARRL's Volunteer Monitor program, relieving the Commission of
significant time-consuming aspects of enforcement.

These volunteer services lessen the regulatory burden - including
the application burden - on the Commission's resources and budget in
ways that licensees in other services do not, ARRL said.

Amateur radio's role in providing emergency and disaster
communication, education, and other volunteer services also
justifies exempting radio amateurs from FCC application fees. For
example, ARRL noted, last year more than 31,000 participated as
members of the ARRL Amateur Radio Emergency Service (ARES), and
local ARES teams reported taking part in more than 37,000 events,
donating nearly 573,000 volunteer hours, providing a total value of
more than $14.5 million.

Amateur radio also has motivated many students to develop critical
science, technology, engineering, and mathematics (STEM) skills.
ARRL noted that the Amateur Radio Service contributes to the
advancement of the radio art, advances skills in communication and
technology, and expands the existing reservoir of trained operators,
technicians, and electronics experts - all expressed bases and
purposes of the Amateur Radio Service.

"Accomplishing these purposes entails working with young people,
many of whom may have difficulty paying the proposed application
fees of $50, $100, or $150," ARRL said. "The $150 fee would be the
cost of passing the examinations for the three amateur license
levels in three examination sessions," ARRL said. "Such multiple
application fees to upgrade would dampen the incentive to study and
demonstrate the greater proficiency needed to pass the examinations
for the higher amateur classes."

ARRL concluded that the FCC should exercise its authority to exempt
amateur radio from application fees generally. If the FCC cannot see
its way clear to waive fees for all amateur radio license
applications, the fees should be waived for applicants age 26 years
and younger. Such individuals, ARRL contended, have the most to
contribute to the future of radio technology and other STEM-related
activities and are the most likely to find the proposed application
fees burdensome.
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