I understand your comments, and have read quite a few from members and nonmembers as well. With regard to formal FCC comments, like most major parties, we submit comments within a couple of days when they are due. This item has not yet been officially published. Consequently the deadline for comments has not yet been set,. It is at least 5 weeks into the future, perhaps longer. This appears to not be entirely satisfactory in this instance, so here are my suggestions. I hear a need for talking points and guidance on direction in opposing this. This is already in draft form and I will finish it and circulate. Since formal comments are several months away as a practical matter, I can recommend two actions to demonstrate opposition to the fees and ARRL movement. If the EC is amenable, an obvious one immediately available would be to announce that the EC has resolved to vigorously oppose the fees and outline leading arguments in a news item. Second would be to seek a meeting with the FCC staff and have a news item on that event. This fees proposal is from the finance part of the FCC, encompasses the entire agency, and those in the Wireless Bureau that govern amateur radio are not directly involved (although they could be consulted by the lead staff). The purpose of the meeting (virtual, of course) would be to brief the responsible staff on ARRL’s opposition and for us to gauge which arguments might have more traction than others. It is mandatory to make a filing after the meeting describing the discussion, and this would be the opportunity for a news article describing the points and demonstrate action. The third item would be the actual comments being filed, which looks like an end of October – early November timeframe. The reason we do not file formal comments early is that doing so allows the comments to account for issues and intelligence gathered beforehand; and eliminates opponents having multiple opportunities to state their arguments in opposition. (Although in this case I would expect that to be minimal, and for each service to limit their comments to their own service. But this isn’t always the case.) Of course, other suggestions are always welcome. 73, Dave K3ZJ David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300 Washington, DC 20006 direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you. From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of "david@davidsiddall-law.com" <david@davidsiddall-law.com> Date: Thursday, August 27, 2020 at 3:52 PM To: ODV <arrl-odv@arrl.org> Subject: [arrl-odv:30824] Proposed Amateur Radio Application Fees All, Yesterday the FCC did release a Notice of Proposed Rulemaking in which it proposes to overhaul its application fee structure. Since so many services use the same ULS system, the effect on amateurs if adopted as proposed would be to charge amateurs the same amounts as those in other radio services for similar actions. Specifically, for the amateur service, the FCC proposes a $50. fee for (1) new or renewal applications; (2) vanity call applications; (3) license upgrade applications. Administrative changes to a license – such as change of address – would continue to be free. There will be the standard opportunity to comment and lobby the Commission, as in most proceedings. Deadlines for doing so have not yet been established. Obviously we will be discussing this, including the Executive Committee when it comes time to comment. The FCC proposal in its entirety can be viewed here: https://docs.fcc.gov/public/attachments/FCC-20-116A1.pdf. Paragraphs 24-30 address applications in the amateur service (with GMRS and other similar licenses). 73, Dave David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300 Washington, DC 20006 direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.
