07/16/2024

NJBA files joint comments in FCC’s latest regulatory fee proceeding

The New Jersey Broadcasters Association, in combination with the state broadcasters associations of all 50 states, the District of Columbia, and Puerto Rico, filed Joint Comments in the matter of review of the Commission’s assessment and collection of regulatory fees for fiscal year 2024, MD Docket No. 24-86.

The joint comments:

• Supported the FCC’s efforts to more precisely delineate which agency employees work on non-broadcast matters and to ensure that the cost of those employees, as well as associated overhead costs of the FCC, are covered by the regulatory fees paid by the non-broadcast entities benefiting from those employees’ work rather than by broadcasters;
• Urged the FCC to annually review the fee categorization of its employees agency-wide prior to issuing proposed regulatory fees to ensure that broadcasters’ regulatory fees are not paying for non-broadcaster FCC services;
• Urged the Commission, as required by the RAY BAUM’S Act of 2018, to expand its base of regulatory fee payors so that the costs of operating the FCC are spread across all entities that benefit from the Commission’s activities, and not just those that hold an FCC license and which are regulated by one the bureaus the FCC deems “core”;
• Urged the Commission to reexamine its practice of utilizing a single regulatory fee category for all transmit earth stations, causing a significant fee increase this year without any change in the benefit received by broadcasters utilizing such authorizations;
• Urged the FCC not to terminate its regulatory fee relief policy for silent and bankrupt stations; and
• Urged the FCC to make permanent temporary fee relief measures adopted during the pandemic, such as waiving the FCC’s downpayment requirement for installment plans, partially waiving the FCC’s ban on delinquent payors seeking fee relief, using its discretion to reduce the interest rate charged on installment plans, and allowing payors seeking relief to supplement their initial requests with additional documentation where needed.

 State Associations 2024 Regulatory Fee Comments Final