The US Forest Service is proposing to implement a statutorily required annual fee for new and existing communications use authorizations to cover the costs of administering its authorization program. ARRL plans to vigorously oppose the imposition of the proposed fees on Amateur Radio.
The Forest Service proposal results from requirements set forth in the Agriculture Improvement Act of 2018 (aka “the Farm Bill”). Specifically, section 8705(c)(3)(b) of the Farm Bill directs the Forest Service to issue regulations that require fees for issuing communications use authorizations based on the cost to the Agency for maintenance or other activities to be performed by the Agency “as a result of the location or modification of a communications facility.”
The Forest Service is responsible for managing Federal lands and authorizes the use and occupancy of National Forest System (NFS) lands for communications facilities that provide communications services for adjacent rural and urban communities. The Agency said in its proposal that it administers more than 3,700 special use authorizations on NFS lands for infrastructure that supports more than 10,000 wireless communications uses at 1,367 communications sites.
According to the Forest Service Notice published in the December 22, 2021 issue of the Federal Register, revenues from the proposed fee, “would provide the funds necessary to support a more modernized, efficient, and enhanced communications use program,” and will “cover the costs of administering the Agency’s communications use program.” Costs, as laid out in section 8705(f)(4) of the Farm Bill, may include expenditures for such things as “on-site reviews of communications sites, developing communications site management plans, hiring and training personnel for the communications use program, conducting internal and external outreach for and national oversight of the communications use program, and obtaining or improving access to communications sites on NFS lands.”
ARRL encourages Amateur Radio licensees to file comments opposing the imposition of the proposed administrative fee on Amateur Radio users. Comments must be received in writing by no later than February 22, 2022. Comments may be submitted online at the Federal Rulemaking Portal or via USPS mail to Director, Lands & Realty Management Staff, 201 14th Street SW, Washington, DC 20250-1124, and must include the identifier “RIN 0596-AD44.”
Being short sighted could become the Achilles heel that will cause unforeseen and unintended consequences for the public.
Simply put, requiring these fees from a volunteer group such as Amateur Radio, that relies on using repeaters for the good of the public will create a huge void in emergency communications if these repeater sites are taken down. The majority of amateur radio clubs do NOT charge any dues from volunteers that may be called upon at times of Emergency, therefore these clubs do not have the means to support this proposal.
If the proposal goes through and consequently a yearly fee of $1400 is imposed, most amateur radio clubs will cease to use the repeaters, thereby creating great voids in the areas these repeaters cover. We, the amateur radio operators, have, at our own expense, provided communications for emergencies, special events, public events, races, marathons, and dozens more activities without any thought of compensation. This is what we do and is part of a lot of Amateur operators reason to attend classes and pass FCC exams to acquire an Amateur License just to volunteer their time and
equipment to help in an emergency. This is who we are.
This proposal will take this away from many areas, especially area’s in Mountainous Regions where most is governed by the USDA Forest Service and the Bureau of Land Management.
The consequences could be devastating and as a result may cause loss of life and property due to the lack of communications.
We ask that you re-think this proposal and do the right thing, and NOT be the end of Amateur Radio Repeaters when they are needed the most and be a very useful tool for us to support the General public and Public Safety agencies.