NAB and SIA Call for Changes on Reg Fees; ACA Connects Advises Caution
The FCC should reexamine its proportional allocation of indirect full-time equivalents in the assessment of regulatory fees, said NAB comments responding to the agency’s notice of inquiry in docket 22-301. “Rather than assuming the work performed by all the noncore…
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bureaus and offices of the Commission is so cross-cutting that it cannot be meaningfully disaggregated,” the FCC should examine whether those functions correspond to the way indirect costs are allocated, NAB said. The FCC's current division between indirect and direct FTEs is “too general to be a reasonably accurate proxy for the assignment of Commission work,” the Satellite Industry Association said. “Splitting all FTEs into direct and indirect FTEs based on whether they are assigned to a ‘core’ or ‘non-core’ bureau is an oversimplification.” The agency could assign indirect FTEs for noncore offices to the bureaus they largely support, or create a hybrid, “intersectional FTE,” the SIA said. NAB also called for the FCC to reexamine the Media Bureau FTEs working on broadband matters. “Regulatees in the other core bureaus also benefit from the Commission’s broadband work,” said NAB. “It would be inconsistent with the Commission’s methodology to not require such regulatees to share in the cost.” ACA Connects said the FCC should be cautious about altering the regulatory fee system. The system isn’t perfect, but it works, said the MVPD group. “As part of such an evaluation, the Commission should be guided by a bureaucratic Hippocratic Oath: first, do no harm.”