The following is from several ARRL Division Directors, and from
Courage Kenny Handi-Hams. There likely will be a similar message
on the ARRL website soon.

**

It is time to protest the imposition of fees for Amateur Radio Licensing.

The fees Notice of Proposed Rulemaking was published in this morning's
Federal Register (https://tinyurl.com/yyk8f2yp). The deadline for comments
is November 16, and the Reply comment deadline is November 30.

With this in mind, I am extending the following suggestions you might
consider using in writing to the FCC in response to the NPRM. Our thanks
to Dave Siddall K3ZJ, ARRL Counsel, for these guidelines. Be sure to
carefully review the paragraphs; "Some Suggestions" as the information
therein will assist with much of the applicable background.

This subject is critical, the timing is critical. I urge you to contact
the FCC. Address and related information is contained in the article
referenced in the Federal Register. Please use your own words to express
your objections to the proposed fees.

(Good) Arguments Against FCC Fees for Radio Amateurs

Amateurs contribute to the public good. In many areas, they provide an emergency communications backbone capability at no taxpayer cost.
Consistently, we have witnessed storms and natural disasters completely
wipe out internet, cellular, and other means of communication. Radio
amateurs often fill that void on an unmatched, flexible basis when needed.
One recent example is the California wildfires.

Unlike operators in other FCC licensed services, Amateur Radio operators
by law - domestic and international -- must eschew using their license
for any pecuniary interest. Amateurs are prohibited from earning or
charging any money for any communications activity. The expenses for
their equipment and activities come out of their own pockets, with no opportunity for reimbursement or payment of any kind.

The United States is experiencing a severe lack of RF engineers and
expertise at the very time it is needed by the burgeoning wireless
industries. Amateur radio is helping to meet the deficit, but much
more is needed, and youngsters (High School and College-aged) are
least able to afford licensing fees. RF knowledge and related digital
expertise is needed to maintain U.S. leadership in wireless industries.
At a minimum, young people (below the age of 26) should be exempt from
the proposed license fees.

Amateur radio is self-regulating. (a) Amateur examinations are written
and administered by radio amateur volunteers. (b) Examination results
and paperwork most often are submitted electronically to the FCC.
Electronic submission could be required if there would be a cost savings
to the Commission. (c) Amateur radio educational classes are conducted
by volunteers who by-and-large do not charge fees or tuition for teaching.
(d) The amateur service, in cooperation with the FCC's Enforcement Bureau,
has a volunteer corps that monitors the amateur airwaves, and has programs
that try to prevent their misuse before FCC involvement might be needed.
The amateurs also observe non-amateur signals both within amateur spectrum
and outside it, and report unusual or suspicious signals.

Amateur radio continues to be a source of significant technological
innovation that should be encouraged, not discouraged.

Some Suggestions

We do not recommend arguing that the $50 fee every 10 years, which amounts
to $5.00 a year, will "Kill" amateur radio, even though as proposed, this
is for each covered application, which includes upgrade applications. Tech-General-Extra could be $150. If exams taken at different sessions, a substantial amount. But it "rings the wrong way to say the whole service
turns on $5/year for each licensee. If that's all it would take".

The Commission argues that the charges are required by the statute. The
word used is "shall", which is mandatory, not optional. But the statute
does not set the amount, nor does it prohibit reasonable exceptions -
evidenced by the Commission's proposal to exempt from fees administrative update applications based on policy grounds.

This is not "aimed at amateur radio to kill it." There is a long history
and precedent on charging fees for the licensing service involved, just
as there is for passports, green cards, drivers' licenses (issued by
states), etc. Better to make pertinent arguments on why the fees would
impair the public benefits of the amateur radio service than argue that
the whole service might die as a result of a fee that, in fact, is less
than the fee many of us paid in the 1960's and 1970's.

For background: this proceeding is being handled by staff unfamiliar
with amateur radio. It is being handled in the FCC's Office of Managing Director (OMD), not in the Wireless Telecommunications Bureau, where the amateur-specific Part 97 matters are handled. The focus of OMD is
accounting - budgets and the like for the entire Commission. The fee
proposals cover every FCC license and service across the board, and the consideration was directed by Congress. It is recommended keeping "ham
jargon" out of comments, it won't be understood by the intended
recipients.

Thank you.

ARRL Great Lakes Division
Director: Dale R Williams, WA8EFK
wa8efk@arrl.org

ARRL Central Division
Director: Kermit A Carlson, W9XA

Comments to the Federal Communication Commission may be filed
online at:

https://www.fcc.gov/ecfs/filings

FCC's Electronic Comment Filing System (ECFS) reference - posting to
MD Docket No. 20-270
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