NAB To FCC: Change Fee Collection Now


The FCC is planning to increase application fees and add new fee categories for broadcasters.

And, the NAB says, that’s not cool.

That’s why it has filed comments with the Commission arguing that broadcasters already fork over to Washington a disproportionately large share of the agency’s costs, relative to the benefits received.

In a nine-page filing referencing the Amendment of the Schedule of Application Fees Set Forth in Sections 1.1102 through 1.1109 of the Commission’s Rules — MD Docket No. 20-270 — the NAB legal team led by Rick Kaplan (pictured) makes it point short and succinct.

“Despite the fact that broadcasters already pay more than their fair share of the
Commission’s costs through ever-increasing regulatory fees, the NPRM proposes to have
broadcasters pay again for much of the labor costs the Commission recovers from
broadcasters through regulatory fees, while others in the telecommunications ecosystem that are inexplicably exempt from regulatory fees receive a substantial discount,” the NAB states.

It continues, “This outcome is contrary to federal fee policy, unjustified, and unsustainable. The Commission must take steps now to overhaul its fee collection methodologies to ensure that broadcasters are not paying twice for the same services and that the costs of the Commission are recovered fairly from all beneficiaries of the Commission’s work.”

The NAB legal team also believes the NPRM “does not provide enough detail to allow for meaningful comment on the Commission’s cost calculations,” and that “broadcasters face substantial competition for advertising revenue from unlicensed spectrum users that significantly utilize the Commission’s resources to provide for new opportunities for their products but contribute nothing to the Commission’s costs.”

A suggestion from Kaplan and Co.: “The Commission should begin to reform its fee processes by responding to previous requests to ensure that broadcasters are not paying twice for the Commission to process their applications, by either removing the full-time employees (FTEs) involved in the application review process from the number of FTEs attributed to broadcasters for purposes of calculating regulatory fees or crediting application fee payments made in any given year by a broadcaster against their regulatory fees.”

And, “absent meaningful reform, the Commission’s costs are likely to continue to rise and the share of these costs imposed on broadcasters will continue to increase, ultimately to the detriment of the public.”

Read the 9-page filing from the NAB HERE.

This story was first reported by Streamline Publishing’s Radio Ink. Be sure to start your day with Radio Ink and end your business with!