EWA Asks FCC for Clarification on Proposed Filing Fee Changes
Thursday, November 19, 2020 | Comments

The Enterprise Wireless Alliance (EWA) filed comments in response to the FCC’s notice of proposed rulemaking (NPRM) that proposed revising the agency’s application fee schedule.

The EWA said that the current schedule is incomplete, overly complex and does not reflect the enormous gains in efficiency that have been made in the application review and processing functions over the last 30 years. The alliance said it supports proposals to modify the fee schedule but also asked for clarification on certain matters so that applicants can ensure the revised fees are fair and appropriate.

The EWA asked about cost averaging and fee consolidation. With cost averaging, there will be an element of subsidization when large numbers of not entirely identical filings are involved. The EWA asked if in its effort to streamline the schedule, the FCC took into consideration the wide differences of wireless applications, and if not, did the FCC amplify the subsidization rider issue?

For example, the EWA said, the proposed fee increase for Part 90 mobile-only systems would rise to $190 where virtually no review is performed. Applicants will ask why filing fees have increased, yet the processing times for Part 90 applications now averages 45 to 60 days, EWA’s filing said.

On auction forms, the EWA recommended that the FCC consolidate the proposed fees for the pre-auction short-form and post-auction long form and impose a fee only on successful bidders that file long-form applications.

The NPRM proposed an increase to the per-waiver fee for both site-based and geographic-based applications. The EWA told the FCC it should accelerate the finalization of rulemaking and other proceedings and lift freezes where the failure to do so leaves applicants no alternative but to request rule waivers.

On construction notifications, the EWA noted that the FCC proposed filing fees on the notifications to defray routine Universal Licensing System (ULS) maintenance and for system monitoring. In that regard, EWA told the FCC that funds devoted to modernizing the ULS would be a prudent investment.

EWA said it is opposed to the FCC’s proposal to charge a fee for amendments to applications, arguing that amendments may be required for a variety of reasons, and in some instances, the FCC returns applications for reasons that subsequently are determined to be incorrect. Correcting even an incorrectly rejected application requires the applicant to file an amendment, thus adding a cost element that will prompt applicants to challenge certain FCC returns, the filing said.

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