NYSBA in combination with the other state broadcasters’ associations recently filed Joint Reply Comments to push for lower regulatory fees. One key component to lower fees is to determine which FCC employees work on our issues. We 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.
We urged the FCC to conduct such reviews annually prior to issuing proposed regulatory fees and to ensure that, as required by the RAY BAUM’S Act of 2018, the costs of operating the FCC are spread across all entities that benefit from the Commission’s activities, licensees like broadcasters.
NYSBA supported the FCC’s proposal to create a lower-cost regulatory fee tier for smaller radio stations and to make permanent the elimination of various administrative obstacles to those seeking relief from regulatory fee obligations. Stations should be able to file multiple requests for relief in a single pleading. In addition, the filing process to request an installment payment plan should be simplified along with allowing electronic submission of those requests for relief via email. Many of these policies were adopted during the COVID pandemic and should continue.
Finally, the FCC should make permanent other temporary relief measures adopted during the pandemic, such as waiving its downpayment requirement for installment plans, partially waiving its bar on delinquent payors seeking fee relief, using its discretion to reduce the interest rate charged on installment plans, and allowing payors to supplement their requests with additional documentation to support their submissions after they are initially filed.
You can access our FCC filing here.