WIA

The Wireless Infrastructure Association

  • NEWS
  • Membership
  • Frequency Coordination
Navigation
  • Home
  • About WIA
    • About WIA
    • Mission
    • Board of Directors
    • Staff
  • Advocacy
    • Advocacy Overview
    • Advocacy Issues
    • WIA Federal Filings
    • Advocacy Resources
    • Advocacy Contacts
  • Frequency Coordination
    • Frequency Coordination Services Overview
    • Fee Calculator
    • Welcome to WIA’s License*Link Online™
    • Frequency Coordination FAQ
    • Process Overview
    • FCC Forms
    • Fee Schedule
  • Events
  • Industry Initiatives
    • Industry Initiatives Overview
    • Innovation & Technology Council
    • Education and Training
    • HetNet Forum
    • TIRAP
    • Women’s Wireless Leadership Forum
    • Infrastructure Developers Forum (IDF)
    • State Wireless Association Program (SWAP)
    • City Networks Task Force
  • Membership
    • Join the Wireless Infrastructure Association
    • Member Benefits
    • Current Members
    • WIA Members Only Access
  • Search WIA.org
  • Resource Library
  • WIA Blog

Notice of Proposed Rulemaking on Application Fees – MD Docket No. 20-270

In the MD Docket No. 20-270 Notice of Proposed Rulemaking (NPRM) released on August 26, 2020, the Federal Communications Commission (FCC) seeks comment on a new application fee schedule with substantial changes to the application fee categories and processes covered by the fees and in the amounts of fees proposed.

The NPRM can be viewed at https://docs.fcc.gov/public/attachments/FCC-20-116A1.pdf. The deadline for reply comment to this NPRM is November 16th and the reply comments deadline is December 16th. You may submit comments for MD Docket No. 20-270 at the FCC’s website: http://apps.fcc.gov/ecfs/. Follow the instructions for submitting comments.

The FCC indicates that part of the purpose of the NPRM is to simplify and harmonize the fee structure to more reasonably reflect the current costs of processing applications. The FCC proposes to streamline the application fee schedule by reducing eight separate fee categories to five and reducing the number of application fees within those categories while still including new fees for services that were not listed previously. Charging fees for all services is appropriate and is now required by law.

According to the Commission, the proposed approach is easier to implement and reduces  administrative burdens on applicants and the Commission by being less complicated to administer, more equitable and easier for the public to understand.

WIA appreciates the FCC’s goals of simplifying and harmonizing the fee structure by making the assessment of fees more equitable and clearer to understand. The remaining rationale and the changes proposed to achieve those goals may create some concerns for applicants and licensees in the Part 90 Land Mobile Radio Services.

There are instances where the fee changes would significantly increase the cost to most of the Part 90 applicants and licensees.  

The Commission notes that its licensing software, the Universal Licensing System (ULS), provides for the filing, review, and disposition of all types of license applications in the Wireless Radio Services, including auctioned geographic licenses and site-based licenses. The FCC charges the same fees for similar types of application processing work: site-based, personal, geographic-based, and experimental applications. 

The proposed application fees are said to be based on “estimates of the direct labor costs to process a typical application”. The Commission seeks comment on the changes to application fees and whether they reasonably reflect current costs of application processing.

The new fees do not appear to reflect the fact that there are fewer applications for Part 90 Land Mobile systems filed compared to previous years.  In addition, there are fewer Commission staff assigned to process these applications and the software currently deployed appears to make the review task more efficient. The effect of a cost increase on the marketplace may be to drive down the volume of applications from those with legitimate need for licensed Part 90 Land Mobile two-way spectrum and could lead to an increase in unauthorized operators.

The NPRM also seeks comment on charging fees for certain types of amendments to pending applications and how to structure that fee when the amendment application expands or narrows the scope of the initial request where the Commission staff may need to completely re-review the application because of new licenses, spectrum, geography, or technical issues that were not in the original application. Currently, rules charge a fee for certain types of major amendments (e.g., Part 22 Services), and specific changes for certain site-based services (e.g., adding call signs, requesting waivers). 

The table in paragraph 18 (page 8) of the NPRM lists the current fee for Part 101 Common Carrier Microwave as the basis for comparison to the proposed cost-based fees. The NPRM proposes consolidating these two separate categories into one. The current fees for Part 90 PMRS applicants are generally much lower than for Part 101 Microwave applicants. The applications for Part 90 PMRS applicants are largely less detailed and far less complex for the applicant to produce and for the Commission’s processor to evaluate. 

The proposal lists the following fees that, if instituted for Part 90 PMRS applicants, will amount to significant increases in some cases.

ServiceFCC Form No.Proposed Fee AmountCurrent Fee
1.  Site-Based Wireless Licenses   a. New; Major Modification  601 & 159    $190.00  $70.00
  b. Minor Modification    601 & 159    $50.00  $70.00
c. Special Temporary Authority  601 & 159    $135.00  $70.00
  d.  Assignment/Transfer of Control  603 & 159  $50.00  $70.00
  e.  Renewal  601 & 159    $50.00  $70.00
  e.  Rule Waiver  601, 603, 608 or 609-T & 159  $380.00  $210.00

.

Latest News

WIA Provides Bipartisan Forum for Broadband, 5G

Topics Discussed with Capitol … Read More

Broadband Policy, FCC Transition, 5G Workforce Issues to be Featured at Digital Policy Summit

WIA Launches Connect (X): All Access … Read More

Latest Blog Posts

WWLF’s New President Amanda Cahill Looks Forward to Expanding Mentorship and Engagement

Mentorships and engagement will be key focuses for the Women’s Wireless … Read More

WIA CEO Adelstein Testifies Before House Committee about Broadband Access, Workforce Development

WIA President and CEO Jonathan Adelstein was an expert witness at a February 17 … Read More

Notable contributions to telecom, technology honored during Black History Month

  Recognizing that American history is Black history, WIA is … Read More

Sign Up For Updates

Sign Up

    Powered by Juicer

Wireless Infrastructure Association

  • 2111 Wilson Blvd., Suite 210, Arlington, VA 22201
  • 703.739.0300 703.836.1608

    • Follow us on Twitter
    • Like us on Facebook
    • Join our LinkedIn group

    Quick Links

    • Search WIA.org
    • Recent Federal Filings
    • Sign Up For Updates
    • WIA Resource Library
    • Employment Opportunities
    • SWAP Events

    Newsroom

    • WIA Press Releases
    • WIA Member News
    • Media and Press Contact
    • WIA Blog

    For Members Only

    • WIA Member Portal
    • WIA PAC Prior Approval Form
    WIA Websites:
    • Het Net Forum
    • TIRAP
    • Connect (X)
    • WWLF

    Copyright © WIA - All Rights Reserved.