Federal Communications Commission	FCC 20-64

Before the
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, DC 20554


In the Matter of 

Assessment and Collection of Regulatory Fees for Fiscal Year 2020

Assessment and Collection of Regulatory Fees for Fiscal Year 2019
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MD Docket No. 20-105	


MD Docket No. 19-105

REPORT AND ORDER AND NOTICE OF PROPOSED RULEMAKING

Adopted:  May 12, 2020	Released:  May 13, 2020

By the Commission: Commissioner O’Rielly issuing a statement.

Comment Date:  June 12, 2020	
Reply Comment Date:  June 29, 2020
TABLE OF CONTENTS
I.	INTRODUCTION	1
II.	BACKGROUND	2
III.	REPORT AND ORDER	6
A.	Assessing Regulatory Fees on Non-U.S. Licensed Space Stations with U.S. Market Access	7
B.	Apportionment of Fees among International Bureau Regulatees	35
C.	Regulatory Fees Paid by VHF Broadcasters	49
IV.	NOTICE OF PROPOSED RULEMAKING	53
A.	Allocating FTEs for FY 2020	56
B.	International Bearer Circuits	59
C.	Television Broadcaster Issues	66
D.	Direct Broadcast Satellite Regulatory Fees	71
E.	Economic Effects of COVID-19 Pandemic	73
F.	Additional Regulatory Fee Reform	76
V.	PROCEDURAL MATTERS	77
VI.	ORDERING CLAUSES	90
APPENDIX A—List of Commenters and Reply Commenters
APPENDIX B—Calculation of FY 2020 Revenue Requirements and Pro-Rata Fees
APPENDIX C—FY 2020 Schedule of Regulatory Fees
APPENDIX D—Sources of Payment Unit Estimates for FY 2020
APPENDIX E—Factors, Measurements, and Calculations that Determine Signal Contours and 			        Associated Population Coverages
APPENDIX F—Space Station Satellite Charges for FY 2020 Regulatory Fees
APPENDIX G—FY 2020 Full-Service Broadcast Television Stations, by Call Sign
APPENDIX H—FY 2019 Regulatory Fees
APPENDIX I—Final Regulatory Flexibility Analysis
APPENDIX J—Initial Regulatory Flexibility Analysis

I. INTRODUCTION
1. In this Report and Order and Notice of Proposed Rulemaking, we follow through on our proposal in the FY 2019 Report and Order and Further Notice of Proposed Rulemaking Assessment and Collection of Regulatory Fees for Fiscal Year 2019, Report and Order and Further Notice of Proposed Rulemaking, 34 FCC Rcd 8199 (2019) (FY 2019 Report and Order).
 to level the playing field between domestic and foreign licensed space stations by assessing a regulatory fee on commercial space stations licensed by other administrations (non-U.S. licensed space stations) with United States market access, among other things.  We also seek comment on the Commission’s proposed regulatory fees for fiscal year (FY) 2020.  Specifically, we propose to collect $339,000,000 in regulatory fees for FY 2020, Fiscal year 2020 started on October 1, 2019.
 pursuant to sections 9 and 9A of the Communications Act of 1934, as amended (Act or Communications Act), and the Commission’s FY 2020 Appropriation. 47 U.S.C. § 159.  Consolidated Appropriations Act, 2020, Public Law 116-93 (appropriating $339,000,000.00 to the FCC for salaries and expenses and directing the FCC to assess and collect the same amount in offsetting collections) (FY 2020 Appropriation). Congress supplemented the FY 2020 salaries and expenses appropriation in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Public Law 116-136 (March 27, 2020), Division B, entitled “Emergency Appropriations for Coronavirus Health Response and Agency Operations,” Title V.  Congress, however, did not direct the Commission to include the CARES supplemental funding in the offsetting collection of regulatory fees.
  
II. BACKGROUND
2. The Commission is required by Congress to assess regulatory fees each year in an amount that can reasonably be expected to equal the amount of its appropriation. 47 U.S.C. §§ 159(a) (“shall assess and collect regulatory fees”), 159(b) (“Commission shall assess and collect regulatory fees at such rates as the Commission shall establish in a schedule of regulatory fees that will result in the collection, in each fiscal year, of an amount that can reasonably be expected to equal the amounts described in subsection (a) with respect to such fiscal year.”); see also 47 U.S.C. § 156(b). 
  Regulatory fees recover direct costs, such as salary and expenses; indirect costs, such as overhead functions; and support costs, such as rent, utilities, and equipment. Assessment and Collection of Regulatory Fees for Fiscal Year 2004, Report and Order, 19 FCC Rcd 11662, 11666, para. 11 (2004) (FY 2004 Report and Order).  
  Regulatory fees also cover the costs incurred in regulating entities that are statutorily exempt from paying regulatory fees (e.g., governmental and nonprofit entities, amateur radio operators, and noncommercial radio and television stations) 47 U.S.C. § 159(e).
 and entities whose regulatory fees are waived. 47 CFR § 1.1166.
  
3. The Commission’s methodology for assessing regulatory fees must “reflect the full-time equivalent number of employees within the bureaus and offices of the Commission, adjusted to take into account factors that are reasonably related to the benefits provided to the payor of the fee by the Commission’s activities.” 47 U.S.C. § 159(d).
  Since 2012, the Commission has assessed the allocation of full-time equivalents (FTE) One FTE, a “Full Time Equivalent” or “Full Time Employee,” is a unit of measure equal to the work performed annually by a full time person (working a 40-hour workweek for a full year) assigned to the particular job, and subject to agency personnel staffing limitations established by the U.S. Office of Management and Budget.
 by first determining the number of FTEs in each “core” bureau that carries out licensing activities (i.e., the Wireless Telecommunications Bureau, Media Bureau, Wireline Competition Bureau, and International Bureau) and then attributing all other FTEs to payor categories based on these core FTE allocations. Procedures for Assessment and Collection of Regulatory Fees, Notice of Proposed Rulemaking, 27 FCC Rcd 8458, 8460, para. 5 & n.5 (2012) (FY 2012 NPRM).

4. As part of its annual regulatory fee rulemaking process, the Commission seeks comment to improve the regulatory fee methodology and has adopted significant regulatory fee reforms.  Since 2013, the Commission has made numerous reforms to the regulatory fee schedule. For a summary of some of the Commission’s regulatory fee reforms, see FY 2019 Report and Order, 34 FCC Rcd at 8191, para. 4 (2019).
  Last year we adopted several amendments to our rules Id.at 8209-12, paras. 56-60.
 to conform them to the RAY BAUM’S Act of 2018. The Repack Airwaves Yielding Better Access for Users of Modern Services Act of 2018, or the RAY BAUM’S Act of 2018, amended sections 8 and 9 and added section 9A to the Communications Act, effective October 1, 2018.  See Consolidated Appropriations Act, 2018, Pub. L. No. 115-141, 132 Stat. 1084, Division P – RAY BAUM’S Act of 2018, Title I, § 103 (2018); 47 U.S.C. §§ 159, 159A.  
  We also concluded that because the new section 9 closely aligns to how the Commission assessed and collected regulatory fees under the prior section 9, we would hew closely to our prior methodology in assessing regulatory fees under the RAY BAUM’S Act. FY 2019 Report and Order, 34 FCC Rcd at 8193, para. 7.
  
5. In the Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order, we sought comment on proposals to amend our schedule of regulatory fees by adopting regulatory fees for non-U.S. licensed space stations with United States market access; Id. at 8212-14, paras. 63-66.
 revising the intra-bureau allocations in the International Bureau; Id. at 8214, para. 67.
 and adjusting regulatory fees paid by certain broadcasters. Id. at 8214-15, para. 68.  In addition, the Commission sought comment on exempting licensees in the incubator program from regulatory fees for the term of the license.  However, after the FY 2019 Report and Order was released, the Commission’s order adopting the incubator program was vacated and remanded by the United States Court of Appeals for the Third Circuit.  Prometheus Radio Project v. FCC, 939 F.3d 567 (3d Cir. 2019), petition for rehearing en banc denied, 3d Cir. Nov. 20, 2019, petition for cert. filed Apr. 17, 2020.  For that reason, we do not consider the issue of whether incubator program licensees should be exempt from regulatory fees at this time.

III. REPORT AND ORDER
6. In this Report and Order, we level the playing field among space stations by assessing a regulatory fee on non-U.S. licensed space stations with United States market access and including those non-U.S. licensed space stations in the current regulatory fee categories for geostationary (GSO) and non-geostationary (NGSO) space stations.  We impose this fee regardless of whether the non-U.S. licensed space station operator obtains the market access through a declaratory ruling or through an earth station applicant as a point of communication.  We also take the related action of adding four FTEs into the satellite regulatory fee category to account for the work that benefits these new fee payors.  We further adjust the FTE allocation for the international bearer circuit (IBC) category from 6.9 FTEs to eight FTEs to reflect direct FTE work in the International Bureau that benefits the fee payors in the IBC regulatory fee category.  Finally, we decline to categorically lower regulatory fees for VHF stations to account for signal limitations.
A. Assessing Regulatory Fees on Non-U.S. Licensed Space Stations with U.S. Market Access
7. The Commission currently assesses regulatory fees on GSO and NGSO space stations licensed by the Commission but does not assess regulatory fees on non-U.S. licensed space stations that have been granted market access to the United States. Under the Commission’s rules, a satellite licensed by an administration other than the United States may seek to communicate with satellite earth stations in the United States through a process called market access.  47 CFR § 25.137.  Market access is either requested by the space station operator through a petition for declaratory ruling from the Commission that market access by the non-U.S. licensed space station is in the public interest, or through an application by a U.S. licensed earth station to communicate with the non-U.S. licensed space station. 47 CFR § 25.137(a).  In either case, the Commission does not license the space station, but the request for U.S. market access requires the submission and review of the same legal and technical information for the non-U.S. licensed space station as would be required in a license application for that space station. 47 CFR § 25.137(b).
  The issue of assessing regulatory fees on non-U.S. licensed space stations with U.S. market access has been raised several times previously.  In the FY 1999 Report and Order, the Commission declined to adopt such a fee. Assessment and Collection of Regulatory Fees for Fiscal Year 1999, Report and Order, 14 FCC Rcd 9868, 9883, para. 39 (1999) (FY 1999 Report and Order).  
  In 2013 and again in 2014, the Commission sought comment on assessing regulatory fees on non-U.S. licensed space stations with U.S. market access, Assessment and Collection of Regulatory Fees for Fiscal Year 2014, Notice of Proposed Rulemaking, Second Further Notice of Proposed Rulemaking, and Order, 29 FCC Rcd 6417, 6433-34, paras. 47-50 (2014) (FY 2014 NPRM); Assessment and Collection of Regulatory Fees for Fiscal Year 2013, Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking, 28 FCC Rcd 7790, 7809-810, paras. 47-49 (2013) (FY 2013 NPRM).
 but the Commission declined to adopt such a fee at the time because it might “raise[] significant issues regarding our authority to assess such a fee as well as the policy implications if other countries decided to follow our example.” Assessment and Collection for Regulatory Fees for Fiscal Year 2014, Report and Order and Further Notice of Proposed Rulemaking , 29 FCC Rcd at 10781, para. 34 (FY 2014 Report and Order).
  The following year, the Commission observed that excluding non-U.S. licensed satellite operators from fees amounted to a subsidy of such operators by U.S. licensed satellite operators. Assessment and Collection of Regulatory Fees for Fiscal Year 2015, Report and Order and Further Notice of Proposed Rulemaking, 30 FCC Rcd at 10278, para. 24 (2015) (FY 2015 Report and Order).
  The Commission thus concluded that the four FTEs working on market access petitions or other matters involving non-U.S. licensed space stations should be removed from the regulatory fee assessments for U.S. licensed space stations and considered indirect for regulatory fee purposes. FY 2015 Report and Order, 30 FCC Rcd at 10278, para. 24.
  
8. The issue of assessing regulatory fees on non-U.S. licensed space stations with U.S. market access has been raised several times since Congress originally adopted the statutory schedule of regulatory fees originally in 1993. Section 6002(a) of the Omnibus Budget Reconciliation Act of 1993 (hereinafter, “1993 Budget Act”).  See Pub.L. No. 103–66, Title VI, § 6002(a), 107 Stat. 397 (approved August 10, 1993).  Congress made subsequent minor amendments to the schedule.
  In exercising our Congressional mandate to collect regulatory fees each fiscal year, we proceed with careful consideration and make changes in our process only after fully developing the record.  This may mean, as it did here, that the Commission considers the adoption of a new fee category or a change in categories multiple times and only proceeds with making a change when it develops sufficient basis for making the change.  This meticulous approach to making changes moreover serves the goal of ensuring that our actions in assessing regulatory fees are fair, administrable, and sustainable. See FY 2012 NPRM at 8464-65, paras. 14-16.  The concept of administrability includes the difficulty in collecting regulatory fees under a system that could have unpredictable dramatic shifts in assessed fees in certain categories from year to year.

9. In the Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order, the Commission again sought comment on assessing regulatory fees on non-U.S. licensed space stations with U.S. market access, noting that the International Bureau’s policy, regulatory, international, user information, and enforcement activities all benefit non-U.S. licensed space stations that access the U.S. market. FY 2019 Report and Order, 34 FCC Rcd at 8212, para. 63.
  Non-U.S. licensed space stations are monitored to ensure that their operators satisfy all conditions placed on their grant of U.S. market access, including space station implementation milestones and operational requirements, and are subject to enforcement action if the conditions are not met. Id.
  The Commission specifically sought comment on whether “we should or must assess regulatory fees on non-U.S. licensed space stations serving the United States under section 9, given that non-U.S. licensed space stations appear to benefit from the Commission’s regulatory activities in much the same manner as U.S. licensed space stations.” Id. at 8213, para. 64.
  The Commission noted that its initial decision in 1999 was premised on the Commission’s understanding at the time that its authority reached only space station “licensees,” i.e., those licensed under Title III.  We observed that section 9 of Communications Act, as amended by the RAY BAUM’S Act, does not mention “licensees” but only the “number of units” in each payor category—and that the “unit” used for assessing satellite space station regulatory fees is “per operational station in geostationary orbit” or “per operational system in non-geostationary orbit,” units that do not distinguish between the government issuing the license. Id. 
  The Commission also sought comment on reallocating four International Bureau indirect FTEs as direct, if regulatory fees are adopted for non-U.S. licensed space stations. Id. at 8214, para. 66.

10. We conclude that we can and should adopt regulatory fees for non-U.S. licensed space stations with U.S. market access.  On the question of whether we may assess regulatory fees on non-U.S. licensed space stations with U.S. market access, we start with the statutory text.  The Act contemplates that we impose fees on regulatees that reflect the “benefits provided to the payor of the fee by the Commission’s activities.” 47 U.S.C. § 159(d).
  The Act specifically contemplates the subset of regulatees that must be exempted from regulatory fees in a section entitled “Parties to which fees are not applicable.”  The statute exempts governmental and nonprofit entities, amateur radio operators, and noncommercial radio and television stations are exempt from regulatory fees under section 9(e)(1).  47 U.S.C. § 159(e)(1); 47 CFR § 1.1162.  Moreover, we note that the exemption for noncommercial radio ad television stations, which Congress added to the statute in the RAY BAUM’s Act, was a codification of an exemption that the Commission had previously established in its rules.    See 47 CFR § 1.1162(e) (1994); also compare current section 9(e) with the now-deleted section 9(h).  The Commission adopted the exemption based on its interpretation of the legislative history and Congressional direction.  See Implementation of Section 9 of the Communications Act, Notice of Proposed Rulemaking, 9 FCC Rcd 6957 at paras. 18-22 (explaining noncommercial broadcast exemption based on legislative history and wording of the statute) (1994); Implementation of Section 9 of the Communications Act, Report and Order, 9 FCC Rcd. 533 at paras 13, 20-21 (1994). In addition, Congress also codified in the RAY BAUM’s Act the Commission’s de minimis rule through the adoption of new section 9(e)(2).  See FY 2019 Report and Order, 34 FCC Rcd at 8206-07, paras. 46-47. 
  Notably, Congress did not include operators of non-U.S. licensed space stations with U.S. market access in that list, and thus did not require the Commission to exempt them from an assessment of regulatory fees.  Moreover, the Commission’s authority to waive regulatory fees is limited to specific instances and the Commission has consistently rejected consideration of waiving the regulatory fee for classes of regulatees. 47 CFR § 1.1166.
  Given the framework where the Commission has a mandate to collect fees from its regulatees, coupled with a limited list of exempt entities and narrow waiver authority, nothing in the text of the statute supports maintaining a blanket exception from regulatory fees for non-U.S. licensed space stations granted market access.  
11. U.S. licensed operators agree, arguing that we have the authority to impose regulatory fees on non-U.S. licensed space station operators with market access because section 9 provides that the purpose of regulatory fees is to recover the costs of the Commission’s activities taking “into account factors that are reasonably related to the benefits provided to the payor of the fee by the Commission’s activities.” U.S. Satellite Licensees Comments at 8 (quoting 47 U.S.C. § 159(d)).  These joint commenters are EchoStar Satellite Services, LLC (EchoStar), Hughes Network Systems, LLC (Hughes), Intelsat License LLC (Intelsat), and Space Exploration Technologies Corp. (SpaceX).
  Commenters contend that the use of the term “number of units” in the amended section 9(c)(1)(A), instead of “licensee,” broadens the language of the statute so that it appears to be applicable to both U.S. licensed and non-U.S. licensed space stations. U.S. Satellite Licensees Comments at 8-9; SpaceX Comments at 4-7; SpaceX Reply Comments at 6.  
  SpaceX contends that the Commission “must consider increases and decreases only in the ‘number of units’ of operational GSO satellites and NGSO systems regardless of licensing administration.” SpaceX Comments at 5.
  Based on the plain language of statute—and the absence of any express limitation that we impose regulatory fees only on “licensees” or that we exempt non-U.S. licensed space stations with U.S. market access, we conclude that there is no statutory bar to adopting a new regulatory fee for non-U.S. licensed space stations with U.S. market access.  
12. We dismiss the arguments of some commenters that focus on whether Congress intended to expand our authority by removing the word “licensees” in the amended section 9. OneWeb Comments at 4-7; Telesat Canada (Telesat) Comments at 3-4 & Reply Comments at 9-10; Myriota Comments at 5-6; Eutelsat Comments at 5; Kepler Communications (Kepler) Reply Comments at 2-3; Inmarsat Reply Comments at 2-3.
  Telesat argues that “[t]he number of ‘units’ says nothing about which entities are subject to the Commission’s regulatory fee authority in the first instance.” Telesat Comments at 10.
  Inmarsat contends that “the plain language of RAY BAUM’S Act is not directed to the entities from which the Commission may collect fees, but the manner in which the Commission may adjust fees.” Inmarsat Reply Comments at 3.
  Such arguments, however, are a double-edged sword because the word “licensees” in that sentence was the only textual hook (under prior law) that such advocates had for arguing that the Commission’s authority was limited to assessing fees on licensees.  And so, although we tend to agree that this change does not imply a change in who could be assessed, we also find that the use of the word “licensee” did not imply that only licensees could be assessed.  In other words, whether Congress intended to expand the reach of regulatory fees with this language is irrelevant.  The question instead remains whether Congress precluded us from imposing regulatory fees on non-U.S. licensed space stations that clearly benefit from market access to the United States and the activities of the Commission—and nothing in the language of the Act suggests Congress intended to preclude such regulatees from the ambit of regulatory fees.
13. Absent any textual hook, commenters turn to the legislative history of section 9 Telesat Comments at 2; Eutelsat Comments at 4-5; Inmarsat Reply Comments at 2-3.
 and argue that the Commission has taken this position previously. FY 1999 Report and Order, 14 FCC Rcd at 9883, para. 39; Assessment and Collection of Regulatory Fees for Fiscal Year 1995, Report and Order, 10 FCC Rcd 13512, 13550, para. 110 (1995) (FY 1995 Report and Order).
  Indeed, in the FY 1999 Report and Order, the Commission based its conclusion on legislative history from 1991. FY 1999 Report and Order, 14 FCC Rcd at 9883, para. 39; FY 1995 Report and Order, 10 FCC Rcd at 13550, para. 110.
  We find that it is appropriate to re-evaluate this conclusion at this time.  
14. The legislative history referred to in the FY 1999 Report and Order and the FY 1995 Report and Order is found in the House and Senate Reports, Committee on Energy and Commerce, 102 H. Rpt. 207, September 17, 1991, in which the Committee stated: “The Committee intends that fees in this category be assessed on operators of U.S. facilities, consistent with FCC jurisdiction.  Therefore, these fees will apply only to space stations directly licensed by the Commission under Title III of the Communications Act.  Fees will not be applied to space stations operated by international organizations subject to the International Organizations Immunities Act, 22 U.S.C. Section 288 et seq.” House and Senate Reports, Committee on Energy and Commerce, 102 H. Rpt. 207, at 33 (Sept. 17, 1991).  The language of the 1991 House and Senate Report was incorporated by reference in the Conference Report accompanying the 1993 Budget Reconciliation Act, which included the regulatory fee program. See Conference Report H. Rept. No. 213, 103d Cong., 1st Sess. 499 (1993); see also FY 1995 Report and Order at 13550.  The 1991 language related to a comparable bill that passed the House in 1991 but was not passed into law.  See PanAmSat Corp. v. FCC, 198 F.3d 890, 895 (D.C. Cir. 1999).  The Conference Report accompanying the 1993 Budget Reconciliation Act did not provide any statement on space station regulatory fees beyond incorporating by reference the language from 1991.
  
15. To understand these committee reports, it is helpful to recognize that in 1991 there was a very different marketplace and regulatory environment than now exists in 2020.  In 1991, U.S. licensed space stations operated as either domestic satellites (domsats) Domestic Communications Satellite Facilities, 22 FCC 2d 86 (1970).  The Commission’s Transborder Policy did permit the use of domsats for certain international services based on criteria set forth in a letter dated July 23, 1981 from then Under Secretary of State James L. Buckley to then FCC Chairman Mark Fowler (Buckley Letter).  The Buckley Letter stated that domsats could be used for public international telecommunications with nearby countries where: (1) INTELSAT could not provide the service; or (2) it would be clearly uneconomical or impractical to provide the planned service over the INTELSAT system.  See Transborder Satellite Video Services, 88 FCC2d 258 (1981); Satellite Business Systems, 88 FCC2d 195 (1981).
 or international systems (separate satellite systems). Establishment of Satellite Systems Providing International Communications, 101 FCC2d 1046 (1985), recon. grtd, 61 R.R. 2d 649 (1986), further recon. grtd 1 FCC Rcd 439 (1986).  The term “separate satellite system” refers to U.S. licensed international systems that are owned and operated separately from the INTELSAT global satellite system.
  Satellite services in the United States, however, were mainly provided by INTELSAT and INMARSAT, which were treaty-based international governmental organizations.  Both were the product of a unique set of initiatives undertaken by the United States and other countries to develop the global communications satellite systems.  As a result, they both benefited from a framework of protections based in statute, The Communications Satellite Act of 1962 declared it U.S. policy to join with other countries to create a commercial, global communications satellite system.  Pub. L. No. 87-624, 87th Cong., 2d Sess. (Aug. 31, 1962), 76 Stat. 419.  Similarly, the International Maritime Satellite Telecommunications Act of 1978 declared it U.S. policy to provide for U.S. participation in INMARSAT in order to develop a global maritime satellite system that will meet the maritime commercial and safety needs of the United States and foreign countries.  Pub. L. No. 95-564, 92 Stat. 2392 (1978).  The statutes provided that COMSAT would be the U.S. signatory to both INTELSAT and INMARSAT.  COMSAT, itself, had its own unique status under treaties.  All three entities were privatized by 2000/2001 in accordance with the requirements of the ORBIT Act.  For a review of the privatization process for these entities, refer to the FCC’s multiple ORBIT Act reports.  See, e.g., FCC Report to Congress as Required by the ORBIT Act, 15 FCC Rcd 11288 (2000); FCC Report to Congress as Required by the ORBIT Act, 16 FCC Rcd 12810 (2001).
 treaty, and Commission policy that protected and preserved the status of each international governmental organization.  
16. In this context, the phrase “space stations operated by international organizations subject to the International Organizations Immunities Act, 22 U.S.C. Section 288 et seq.” used in the 1991 legislative history referred to INTELSAT and INMARSAT, which at that time were international governmental organizations formed as a result of international treaties and with explicit support by the United States through statutory and regulatory mechanisms. Communications Satellite Corp. v. FCC, 836 F.2d 623 (1988) (providing a helpful description of the statutory and treaty-based genesis of INTELSAT, and the complicated regulatory framework whereby it provided international services to the U.S. domestic market); Satellites that Form a Global Communications System in Geostationary Orbit, Memorandum Opinion, Order and Authorization, 15 FCC Rcd 15460, recon. denied, 15 FCC Rcd 25234 (2000), further proceedings, 16 FCC Rcd 12280 (2001).  As such, they had the unique circumstance that their global satellite systems were not licensed by any national licensing authority.
  This conclusion is borne out by the focus in the same legislative history on licenses issued directly by the FCC (as opposed to indirect regulation of provision of INTELSAT and INMARSAT services through licenses issued to COMSAT) and on the International Organization Immunities Act, which provides certain exemptions, immunities, and privileges to international organizations and their employees, such as exemption from custom duties and internal-revenue taxes, 22 U.S.C. § 288a (Privileges, exemptions, and immunities of international organizations).
 and which applied to both INTELSAT and INMARSAT as international governmental organizations.  Further, it was not until 1997 that the Commission adopted a formal process for granting market access to non-U.S. licensed space stations. The adoption by the United States in 1997 of the WTO Agreement on Basic Telecommunications Services obligated the United States to open its satellite markets to foreign systems licensed by other WTO member countries.  Fourth Protocol to the General Agreement on Trade in Services (GATS) (April 30, 1996), 36 I.L.M. 336 (1997) (entered into force Jan. 1, 1998).  The Commission therefore adopted procedures to give satellite systems licensed by other countries access to the U.S. market.  Amendment of the Commission's Regulatory Policies to Allow Non–U.S. Licensed Space Stations to Provide Domestic and International Satellite Service in the United States, Report and Order, 12 FCC Rcd 24094 (1997) (DISCO II).  Prior to the adoption of DISCO II, the Commission allowed very limited provision of service in the U.S. through non-U.S. licensed space stations only upon a showing that existing U.S. domestic satellite capacity was inadequate to satisfy specific service requirements.  Letter from Bertram Rein, Deputy Assistant Secretary of Bureau of Economic and Business Affairs, U.S. Department of State, to Kenneth Williamson, Minister of Embassy of Canada (Nov. 7, 1972).  See also Letter from Thomas Tycz, Chief, Satellite and Radiocommunication Division, F.C.C. International Bureau, to Teresa Baer, Attorney, Latham & Watkins (Feb. 13, 1996) (confirming verbal grant of special temporary authority for Hughes Communications Galaxy, Inc. to lease capacity from a Brazilian satellite to provide domestic U.S. service).

17. Today, there are many commercial non-U.S. licensed satellite companies offering service in the United States.  The two International Government Organizations operating satellites at that time—INTELSAT and INMARSAT—are no longer International Governmental Organizations but instead are commercial enterprises.  INTELSAT became a private company in 2001, Intelsat, Ltd., after 37 years as an International Governmental Organization. See http://www.intelsat.com/about-us/history/.
  Intelsat’s corporate headquarters are in Luxembourg and the United States, and it currently has a fleet of more than 50 satellites. See http://www.intelsat.com/global-network/satellites/overview/.
  INMARSAT, now Inmarsat, Inc., is headquartered in London, England, has offices in over 40 countries, and owns and operates 13 satellites. See https://www.inmarsat.com/about-us/our-technology/our-satellites/.
  Other commercial non-U.S. licensed satellite companies include Eutelsat Communications SA, a public corporation, which has 38 satellites, is headquartered in France, See https://www.eutelsat.com/en/group/our-history.html.
 and has satellites licensed by France and other countries, including the United States; Eutelsat Comments at 1.
 and Telesat, a private Canadian satellite company, with 16 satellites. See https://www.telesat.com/services.
  These companies, and others, have U.S. market access and compete with the U.S. licensed satellite companies such as commenters EchoStar Satellite Services (EchoStar) and Space Exploration Technologies (SpaceX).  We find that the 1991 legislative history SpaceX observes that this legislative history is nearly 30 years old and “extremely dated.”  SpaceX Reply Comments at 6-7.
 purportedly limiting regulatory fees to U.S. licensed satellites is no longer relevant because in stating that “[f]ees will not be applied to space stations operated by international organizations” it was not exempting from regulatory fees commercial non-U.S. licensed satellites with general U.S. market access, which did not exist at that time, but two International Governmental Organizations that no longer exist.  In other words, we find that the legislative history of the Act poses no bar to assessing regulatory fees on non-U.S. licensed space stations with U.S. market access.  Operators of non-U.S. licensed space stations contend that Congress did in fact contemplate certain circumstances in which non-US licensed space stations could be used to provide service in the United States. Letter from Joseph A. Godles, Attorney for Telesat Canada, et al., to Marlene H. Dortch, Secretary, FCC (filed Apr. 22, 2020) (Godles April 22 Ex Parte).
  But at that time, Congress could not have been contemplating non-U.S. licensed space stations that provide commercial service in the United States on an ongoing, unrestricted basis under the same regulatory framework as their U.S. licensed counterparts. See DISCO II, 12 FCC Rcd at 24098, para. 7 (stating that “[a]s required by Title III of the Communications Act of 1934, as amended (Communications Act), we will examine all requests to determine whether grant of authority is consistent with the public interest, convenience and necessity.” See also DISCO II, 12 FCC Rcd at 24098, para. 7, n.7 (citing 47 U.S.C. § 301, et. seq.).
  The circumstances that the operators cite consisted of very limited provision of service in the U.S. through non-U.S. licensed space stations upon a showing that existing U.S. domestic satellite capacity was inadequate to satisfy specific service requirements. See footnote [49], supra.
  Such case-by-case approval of use of a non-U.S. licensed satellite on a bilateral, government-to-government basis to provide limited services was much more rare, and of a very different nature, than the regulations that the Commission adopted years later to permit U.S. market access by non-U.S. licensed space stations. In 1993, the Commission considered and rejected the adoption of the type of market access provisions that the Commission would adopt several years later.  Amendment of the Commission's Rules to Establish Rules & Policies Pertaining to A Non-Voice, Non-Geostationary Mobile-Satellite Serv., Report and Order, 8 FCC Rcd. 8450, 8454 para. 13 (1993) (adopting rules clarifying “the basic tenets that [non-voice, non-geostationary orbit satellite service] transceivers operating in the United States must communicate with or through U.S. authorized space stations only, and that such communications must be authorized as well by the space station licensee or an authorized vendor” and explicitly rejecting a proposal that the FCC “devise a rule that will allow domestically authorized user transceivers to access foreign-licensed [non-voice, non-geostationary orbit satellite service] space station systems” stating that “[w]e do not believe that this type of arrangement should be dealt with by regulation.”)(emphasis added).

18. Non-U.S. licensed space station operators contend that Congressional silence subsequent to the Commission’s statements regarding the legislative history of section 9 presumes Congress’s approval of the Commission’s prior interpretation and argue that the “acquiescence doctrine” supports their position. See Godles April. 22 Ex Parte at 3.
 While this doctrine recognizes that Congressional silence may have some bearing on the interpretation of a statute, it neither requires that an agency’s interpretation be cemented in stone if not overtaken by subsequent legislative action, nor forecloses an agency from changing its interpretation of a statute and how the legislative history should inform such interpretation, Courts do not uniformly embrace the proposition that Congressional silence denotes acquiescence.  See Chisholm v. FCC, 538 F.2d 349, 361 (D.C. Cir. 1976) (“We begin by noting that attributing legal significance to Congressional inaction is a dangerous business”), citing Power Reactor Development Co. v. International Union of Electrical, Radio and Machine Workers, AFL-CIO, 367 U.S. 396, 408-10 (1961). The Supreme Court has said that Congressional failure to repudiate particular decisions “frequently betokens unawareness, preoccupation, or paralysis” rather than conscious choice, Zuber v. Allen, 396 U.S. 168, 185-86 n.21 (1969) and “affords the most dubious foundation for drawing positive inferences,” United States v. Price, 361 U.S. 304, 310-11 (1960) (Harlan, J.).  See also Jones v. Liberty Glass Co., 332 U.S. 524, 533 (1947) (“The doctrine of legislative acquiescence is at best only an auxiliary tool for use in interpreting ambiguous statutory provisions”). 
 no matter how longstanding, particularly when the prior interpretation is based on error. Chisholm v. FCC, 538 F.2d 349, 364 (D.C. Cir. 1976) (“We note initially that an administrative agency is permitted to change its interpretation of a statute, especially where the prior interpretation is based on error, no matter how longstanding.”) (internal citations omitted).  Similarly, an agency may change its policies and standards, so long as it provides a reasoned explanation for change.  See, e.g., FCC vs. Fox Television Stations, Inc., 556 U.S. 502, 514-15 (2009); National Labor Relations Board v. CNN America, Inc., 865 F.3d 740, 751 (D.C. Cir. 2017).
  Here we acknowledge a change in our interpretation of the legislative history underlying section 9 based on a fuller and more accurate analysis of the context of the legislative history at the time it was adopted. We also note that when Congress recently re-visited section 9 as part of the RAY BAUM’S Act, it did not elect to amend the list of entities exempted from assessment of regulatory fees to include non-U.S. licensed space stations.  Although non-U.S. licensed space station operators state that “[n]othing in Ray Baum’s Act, or in the associated legislative history, evidences any intent to alter the FCC’s understanding that its authority to impose regulatory fees on space stations is limited to those licensed pursuant to Title III,” Godles April 22 Ex Parte at 4, it could equally be said that Congress demonstrated no intent to endorse our prior interpretation or reiterate some intent to exempt non-U.S. licensed space stations in the legislative history of the RAY BAUM’S Act. 

19. On the policy question of whether we should assess regulatory fees on non-U.S. licensed space stations with U.S. market access, we start with the fact that these non-U.S. licensed space stations benefit from the Commission’s regulatory activities in much the same manner as U.S. licensees. FY 2019 Report and Order, 34 FCC Rcd at 8213, para. 64.
  Operators of U.S. licensed space stations argue that non-U.S. licensed operators consume, and benefit from, Commission resources just as do U.S. licensees. See, e.g., U.S. Satellite Licensees Comments at 1-2.
  They estimate that nearly half of all satellite space station authorizations granted between 2014 and 2018 (30 of 62) were filed by non-U.S. operators In addition, they note that there are more market access requests than new satellite applications; in 2019 there were nine new market access requests, but only six new U.S. satellite license applications.  U.S. Satellite Licensees Reply Comments at 2-3.
 and that non-U.S. operators participate actively in Commission rulemaking proceedings and benefit from Commission monitoring and enforcement activities. U.S. Satellite Licensees Reply Comments at 2.  Furthermore, SpaceX highlights that Eutelsat and Telesat are also involved in a proceeding to repurpose C-band satellite spectrum in which these non-U.S. operators and others have argued that they may not be denied access to portions of the 3700-4200 GHz band in the United States without significant compensation.  SpaceX Reply Comments at 2-3.
  
20. Certain non-U.S. licensed space stations argue that they should not contribute regulatory fees because the Commission incurs no costs regulating them and that non-U.S. licensed space stations do not benefit from the FCC’s regulatory activities, including international coordination and enforcement activities. Eutelsat Comments at 2-3 (“Foreign-licensed satellite operators do not receive a Commission license or the benefits that come with it.”); Myriota Comments at 3 (“Foreign-licensed satellite system operators do not receive an FCC space station license or the significant benefits associated with it. . . .”); Eutelsat Comments at 3 (“While [compliance] oversight is ongoing, the administrative burden is both minimal and conducted for the benefit of United States space and earth station licensees.”); Myriota Comments at 3 (“Although [compliance] oversight is ongoing, however, the actual administrative cost of such monitoring is minimal and imposing a recurring regulatory fee to recover these de minimis costs would not be appropriate.”); Inmarsat Reply Comments at 4 (“[Non-U.S. licensed space stations] do not receive the benefit of United States-led coordination negotiations, relying instead on the country of licensure.”). 
  Inmarsat contends that non-U.S. licensed satellites do not benefit from FCC regulatory activities because oversight of their operations is accomplished by the country that licenses the satellite, not by the FCC. Inmarsat Reply Comments at 4 (“Spacecraft maintenance, end-of-life, and orbital debris mitigation are supervised not by the United States, but by the administration issuing the license.”)
  
21. We find that the Commission devotes significant resources to processing the growing number of market access petitions of non-U.S. licensed satellites and that they benefit from much of the same oversight and regulation by the Commission as the U.S. licensed satellites.  For example, processing a petition for market access requires evaluation of the same legal and technical information as required of U.S. licensed applicants.  The operators of non-U.S. licensed space stations also benefit from the Commission’s oversight efforts regarding all space and earth station operations in the U.S. market, since enforcement of Commission rules and policies in connection with all operators—whether licensed by the United States or otherwise—provides a fair and safe environment for all participants in the U.S. marketplace.  Likewise, the Commission’s adjudication, rulemaking, and international coordination efforts benefit all U.S. marketplace participants by evaluating and minimizing the risks of radiofrequency interference, increasing the number of participants in the U.S. satellite market, opening up additional frequency bands for use by satellite services, providing a level and uniform regime for mitigating the danger of orbital debris, and streamlining Commission rules that apply to all providers of satellite services in the United States, whether through U.S. licensed or non-U.S. licensed space stations. FY 2019 Report and Order, 34 FCC Rcd at 8212-13, para. 63 (citing Mitigation of Orbital Debris in the New Space Age, IB Docket No. 18-313, Notice of Proposed Rulemaking and Order on Reconsideration, 33 FCC Rcd 11352 (2018) (Orbital Debris NPRM); Amendment of Parts 2 and 25 of the Commission’s Rules to Facilitate the Use of Earth Stations in Motion Communicating with Non-Geostationary Orbit Space Stations in Frequency Bands Allocated to the Fixed-Satellite Service, IB Docket No. 18-315, Notice of Proposed Rulemaking, 33 FCC Rcd 11416 (2018) (ESIM NPRM); Amendment of the Commission’s Policies and Rules for Processing Applications in the Direct Broadcast Satellite Service, IB Docket No. 06-160, Second Notice of Proposed Rulemaking, 33 FCC Rcd 11303 (2018); Amendment of Parts 2 and 25 of the Commission’s Rules to Facilitate the Use of Earth Stations in Motion Communicating with Geostationary Orbit Space Stations in Frequency Bands Allocated to the Fixed Satellite Service, IB Docket No 17-95, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 9327 (2018); Further Streamlining Part 25 Rules Governing Satellite Services, IB Docket No. 18-314, Notice of Proposed Rulemaking, 33 FCC Rcd 11502 (2018) (Part 25 Further Streamlining NPRM); Streamlining Licensing Procedures for Small Satellites, IB Docket No. 18-86, Notice of Proposed Rulemaking 33 FCC Rcd 4152 (2018); Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related Matters, IB Docket No. 16-408, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 7809 (2017); Amendment of Parts 2 and 25 of the Commission’s Rules to Facilitate the Use of Earth Stations in Motion Communicating with Geostationary Orbit Space Stations in Frequency Bands Allocated to the Fixed-Satellite Service, IB Docket No. 17-95, Notice of Proposed Rulemaking, 32 FCC Rcd 4239 (2017).
  The active participation of operators of non-U.S. licensed space stations in these adjudications and rulemakings—either individually or through involvement in industry trade organizations—demonstrates that they recognize benefits from Commission action to their operations within the U.S. market, since they would not participate in such proceedings if they held no possibility of benefit to them. Market access recipients filed comments in nearly all of the Commission’s recent satellite rulemaking proceedings.  See, e.g., Comments of WorldVu Satellites Limited d/b/a OneWeb, SES Americom and Eutelsat in Orbital Debris NPRM, (filings made Apr. 5, 2019); ESIM NPRM (filings made Feb. 11, 2019) and Part 25 Further Streamlining NPRM (filings made Mar. 18, 2019).
  Thus, the significant benefits to non-U.S. licensed satellites with market access support including them in regulatory fees.
22. In the Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order, we also sought comment on whether assessing non-U.S. licensed space stations would promote regulatory parity among space station operators. FY 2019 Report and Order, 34 FCC Rcd at 8212-13, para. 63
  U.S. licensees argue that the current fee system is inequitable and encourages companies to simply move overseas to evade fees and oversight. U.S. Satellite Licensees Comments at 2.
  Non-U.S. licensed satellite operators respond by contending that imposing regulatory fees on non-U.S. licensed satellites would place those entities at a competitive disadvantage. WorldVu Satellites Limited d/b/a OneWeb (OneWeb) Comments at 1-4; Kepler Reply Comments at 4.
  Non-U.S. licensed satellite operators are already paying regulatory fees in their own jurisdictions and, they assert, our regulatory fees would be a duplicative fee. Eutelsat Comments at 2, 7; Telesat Reply Comments at 3-4.
  Operators of non-U.S. licensed space stations also contend that imposing regulatory fees will negatively impact U.S. consumers because smaller foreign operators will bypass the U.S. market and the increased costs will be passed on to U.S. consumers. OneWeb Comments at 7-8 & Reply Comments at 6; Myriota Comments at 3-4; Kepler Reply Comments at 4-5; Telesat Reply Comments at 4; 
  Imposing such a fee, they argue, would jeopardize the United States’ position in the global satellite market and other jurisdictions could also now impose similar charges on U.S. licensed satellites. OneWeb Comments at 7-8 & Reply Comments at 4-5; Myriota Comments at 3-4; Eutelsat Comments at 6-8; Telesat Reply Comments at 5; Inmarsat Reply Comments at 4; Kepler Reply Comments at 4.
  
23. We agree with the comments of U.S. licensed space station operators—who express more concern about fee inequity in the United States than the prospect of new or increased fees in other markets—that entities receiving U.S. market access, through either a space station or earth station authorization, should be subject to the same satellite regulatory fees as those assessed on U.S. licensed space station systems. U.S. Satellite Licensees Comments at 6-7.  SpaceX proposes that earth station operators that received U.S. market access prior to August 27, 2019, the release date of the FY 2019 Report and Order , would be exempt from such regulatory fees under this proposal. SpaceX Comments at 2-3.    
  Indeed, we are not convinced by the parade of horribles cited by non-U.S. licensed satellite operators as they offer insufficient evidence to support their claims.  
24. Non-U.S. licensed satellite operators also argue that an assessment of fees conflicts with international trade agreements under the WTO Agreement on Basic Telecommunications Services. Telesat Comments at 12 & Reply Comments at 5; Kepler Reply Comments at 3; Inmarsat Reply Comments at 4-5.  AT&T disagrees that this assessment of fees would be precluded by international agreements.  AT&T Reply Comments at 5-6; OneWeb Reply Comments at 7-8.
  Eutelsat and Telesat contend that under the Commission’s DISCO II decision, the Commission rejected the idea of issuing a separate license for non-U.S. licensed space stations. Eutelsat Comments at 2, 7, citing DISCO II at 24174, para. 188; Telesat Reply Comments at 6.  OneWeb also argues that our proposal would violate DISCO II because it would put non-U.S. licensed satellite operators at a disadvantage.  OneWeb Comments at 2.  We disagree, as discussed above, because the U.S. licensed satellite operators competing against non-U.S. licensed operators, are disadvantaged due to the imposition of regulatory fees on the U.S. licensed operators.
  In response, SpaceX asserts that spreading the regulatory costs evenly across U.S. and non-U.S. licensed space station operators instead of imposing the entire cost on U.S. space station licensees is fully consistent with the DISCO II decision. SpaceX Reply Comments at 8-9.
  We find that our actions are consistent with the DISCO II decision because we are treating non-U.S. licensed space station operators the same as U.S. licensed space station operators in assessing regulatory fees.
25. Non-U.S. licensed space station operators argue that it would be unfair now to assess regulatory fees on non-U.S. licensed space stations accessing the U.S. market because they have relied on a prior finding that regulatory fees for space stations were to be assessed on only those stations licensed by the United States and that they have made business plans based on this long-standing prior finding. Godles April 22 Ex Parte at 3.
  Licensees have no vested right to an unchanged regulatory framework. Improving Public Safety Communications in the 800 Mhz Band, 21 FCC Rcd 678, 682 (2006); Motient Communications Inc., 19 FCC Rcd 13086, 13093 (2004), citing Amendment of Part 1 of Commission's Rules - Competitive Bidding Procedures, Order on Reconsideration of the Third Report and Order, Fifth Report and Order, and Fourth Further Notice of Proposed Rule Making, 15 FCC Rcd 15293, 15306 para. 22 (2000).
  This is as true for market access grantees as it is for licensees, since both are subject to the Commission’s regulatory framework while providing service in the United States.  Moreover, each year the Commission engages in a proceeding seeking comment on its proposed fees for the year and frequently makes adjustments to the regulatory scheme to reflect changes in fact and law.  For the reasons stated herein, we have concluded that non-U.S. licensed space stations accessing the U.S. market should be subject to assessment of regulatory fees under section 9. Congress mandates that the Commission recover as an offsetting collection its fiscal year appropriation and prescribes the mechanism to do so. Congress has prescribed that regulatees bear the FTE burden associated with the Commission’s work in respect to a given set of regulatees.

26. Including non-U.S. licensed space stations in the Commission’s assessment of regulatory fees is important to fulfilling Congress’s mandate that the Commission recover the costs associated with its activities, since market access by non-U.S. licensed space stations has become a significant portion of the satellite services regulated by the Commission and exemption of non-U.S. licensed space stations places the burden of regulatory fees—which are designed to defray the costs of Commission regulatory activities (which we undertake to serve the overall interests of the public, including all parties engaged in the communications marketplace)—solely on the shoulders of U.S. licensees, either directly or indirectly. The Commission’s prior solution in 2015 of recategorizing four International Bureau FTEs as indirect to avoid assessing U.S. licensed space stations for work that directly benefited non-U.S. licensed space stations that did not pay regulatory fees still required U.S. licensees to bear the costs of the non-U.S. licensed space station operators participation in the regulatory environment; it simply broadened the base of U.S. licensees bearing those costs, since the costs were labeled as indirect, and therefore borne by all FCC entities that were assessed regulatory fees.  See FY 2015 Report and Order, 30 FCC Rcd at 10278, para.24.
 We find that this is not sustainable, since the ability to gain the same benefits of Commission activities without being assessed regulatory fees presents an incentive for space station operators, even U.S.-based companies, to elect to be licensed by a foreign administration in order to still have access to the U.S. market, but without being assessed regulatory fees.  In summary, we conclude that assessing the same regulatory fees on non-U.S. licensed space stations with market access as we assess on U.S. licensed space stations will better reflect the benefits received by these operators through the Commission’s adjudicatory, enforcement, regulatory, and international coordination activities.  Moreover, it will promote regulatory parity and fairness among space station operators by evenly distributing the regulatory cost recovery.
27. In the interest of equity and to eliminate regulatory arbitrage, we further conclude that regulatory fees for non-U.S. licensed space stations should be contributed regardless of the method by which the space station obtains U.S. market access.  In addition to receiving U.S. market access directly through a petition for declaratory ruling, a non-U.S. licensed space station operator may also receive market access by being added as a point of communication in an earth station license application.  In either case, the Commission’s review of the space station market access request is the same.  The earth station application may be filed by the non-U.S. licensed operator, one of its subsidiaries, or an independent third party.  Currently, neither the earth station licensee nor the non-U.S. satellite operator with market access through that earth station pays a regulatory fee despite the benefits it receives and the additional Commission resources consumed by such market access.  We find that it serves the public interest to assess regulatory fees in the same manner against all non-U.S. licensed satellite operators with U.S. market access, regardless of how that access is obtained.  
28. We next address the mechanisms of assessment when non-U.S. satellite operators gain market access through earth stations.  As of October 1, 2019, there are approximately 25 non-U.S. licensed space stations serving the U.S. market through earth station licensees.  SpaceX proposes creating a new regulatory fee category for earth station authorizations that include a first-time market access grant for a satellite system to “apply the same regulatory fee applicable to non-U.S. licensed systems granted market access at the space station level.” SpaceX Comments at 8.  Kepler argues that it would be inequitable to assess the same regulatory fee on a foreign satellite operator with a single earth station.  Kepler Reply Comments at 5.  We note the same argument can be made regardless of whether the foreign operator communicating with only one earth station does so through a petition for declaratory ruling and an earth station license or solely through an earth station license.
  SpaceX asserts that doing so “would eliminate an opportunity for regulatory arbitrage while ensuring that the Commission’s regulatory fee structure equitably covers satellite systems granted access to the U.S. market regardless of the mechanism used to achieve that end.” SpaceX Comments at 8.
  We agree with SpaceX that assessing a regulatory fee to cover non-U.S. licensed space stations that gain market access through an earth station serves the public interest, although we assess the space station benefiting from the market access rather than the earth station operator(s).  Doing so will place the responsibility with the space station operator directly benefiting from market access rather than one or multiple earth stations that may be communicating with many other satellites as well.  
29. We will therefore require non-U.S. licensed space stations that enter into the U.S. market through earth station authorizations to be subject to regulatory fees similar to those space stations receiving U.S. market access directly through a petition for declaratory ruling. As a general matter, a single NGSO constellation that includes both U.S. and foreign-licensed satellites will be treated the same as any wholly U.S. or foreign-licensed constellation for regulatory fee purposes.

  Failure to pay a regulatory fee will subject the operator of the non-U.S. licensed space station to statutory penalties and the Commission’s rules governing nonpayment.  Under sections 9A(c)(1) & (2) of the Act, the Commission is required to impose a late payment penalty of 25 percent of the unpaid regulatory fee debt and to assess interest on the unpaid regulatory fee (including the 25 percent penalty) until the debt is paid in full.  The Commission is also required to pursue collection of all past due regulatory fees (including penalty and interest) using all collection remedies available to it under the Debt Collection Improvement Act of 1996.  These remedies include offsetting regulatory fee debt against monies owed to the debtor by the Commission, and referral of the debt to the United States Treasury for further collection efforts, including centralized offset against monies other federal agencies may owe the debtor. 31 U.S.C. §§ 3701 et seq.; 31 CFR §§ 901 et seq.; 47 CFR §§ 1.1901 et seq.  The failure to timely pay regulatory fees also subjects regulatees to the Commission’s “red light” rule and revocation of authorizations. 47 CFR §§ 1.1910 and 1.1164(f). 
  In addition to other penalties, non-payment may result in removal of the delinquent non-U.S. space station as a point of communication for any associated earth station authorizations.  Non-payment may also prevent such space station to obtain future U.S. market access or other regulatory benefits until such matters are resolved. See 47 U.S.C. § 159A(c)(3) (dismissal of applications or filings); id. at § 159A(c)(4) (revocations); 47 CFR § 1.1164(f) (same).
  This action eliminates any regulatory arbitrage or gaming opportunity by eliminating any regulatory fee differences between receiving U.S. market access directly through a petition for declaratory ruling or indirectly, through an earth station license application. 
30. In some cases, non-U.S. licensed space stations that do not access earth stations aboard aircraft (ESAA) terminals in the United States or its territorial waters have been identified as a point of communication for U.S. licensed ESAA terminals. See Letter from Karis Hastings, Counsel to SES, to Marlene H. Dortch, Secretary, Federal Communications Commission, at 2 (May 5, 2020).
  To the extent such license clearly limits U.S. licensed ESAA terminals’ access to these non-U.S. licensed space stations to situations in which these terminals are in foreign territories and/or over international waters and the license does not otherwise allow the non-U.S. licensed space station access to the U.S. market, the non-U.S. licensed space station does not fall within the category of a non-U.S. licensed space station with access to the U.S. market for regulatory fee purposes.  In addition, a non-U.S. licensed space station that communicates with a U.S. licensed earth station solely for tracking, telemetry and command (TT&C) purposes will not fall within the category of a non-U.S. licensed space station with access to the U.S. market for regulatory fee purposes. See Letter from Pamela L. Meredith, Counsel to Kongsberg Satellite Services AS, to Marlene H. Dortch, Secretary, Federal Communications Commission, at 1-2 (May 5, 2020).
  The relevant earth station license, however, must clearly limit the non-U.S. licensed space station's access to TT&C communications only.  If it does not include such a limitation, the relevant non-U.S. licensed space station will be subject to regulatory fees.  Accordingly, non-U.S. licensed space station operators may notify the Commission by July 15, 2020, as discussed below, to certify that their access is solely for TT&C and identify the relevant earth station licenses for any needed express condition that the relevant non-U.S. licensed space station is identified a point of communication for TT&C purposes only. We note that an earth station authorization allowing any other kind of data acquisition by a non- U.S. licensed space station will be considered to have access to the U.S. market and will be subject to the regulatory fees.
  Otherwise, they will be assessed regulatory fees.
31. We understand that non-U.S. licensed satellite operators have not always been conscientious in the past about advising the Commission when they have ceased to provide service to the U.S. from a particular satellite.  To provide a clear deadline for operators to correct the record and afford the International Bureau and the Office of Managing Director an opportunity to create a definitive list of market access grants from which to develop the final fee amounts,  non-U.S. licensed space station operators with U.S. market access may notify the Commission by July 15, 2020 whether they want to relinquish that market access. Such a voluntary surrender of market access can be made through existing procedures for surrender of grants of market access or removal of a non-U.S. licensed space station as a point of communications in an earth station license.
  Operators that relinquish their U.S. market access will not be assessed regulatory fees this year.  Accordingly, for FY 2020 we will require regulatory fees to be paid by those non-U.S. licensed space stations that have U.S. market access after July 15, 2020. We note that after FY 2020 it is the responsibility of a non-U.S. licensed space station with U.S. market access to inform the Commission (International Bureau) by September 30th before the new fiscal year begins that it is relinquishing its U.S. market access; failing timely notification, the non-U.S. licensed station will be assessed regulatory fees for the ensuing fiscal year.  For example, in FY 2021, a non-U.S. licensed space station with U.S. market access must inform the Commission (International Bureau) by September 30, 2020 that it wishes to relinquish its market access or it will be charged the FY 2021 regulatory fee in September 2021.   
  We instruct the International Bureau, when it receives a notice of surrender of market access by the operator of a non-U.S. licensed space station, to remove the space station as a point of communication in all earth station licenses, regardless of whether the earth station licensee itself requests removal of the non-U.S. licensed space station as a point of communication. The International Bureau will include notice of such surrenders in its routine weekly Public Notices of Actions Taken for satellite space and earth stations.
  We do this so that a non-U.S. licensed space station operator would not be prejudiced by non-action of a third-party earth station licensee.
32. Accordingly, we will issue an invoice for the annual space station regulatory fee to the non-U.S. licensed space station operator of record listed on the Schedule S filed in connection with a grant of a petition for declaratory ruling to access the U.S. market, or with an earth station application to add the non-U.S. licensed space station as a point of communication, as of July 16, 2020. In some cases, a single GSO satellite with access to the U.S. market may be operated by more than one entity, as reflected in the terms of the license or market access grant.  In such cases, the satellite operators should notify OMD which operator/FRN is the contact for the space station regulatory fee purposes and that operator/FRN will be billed.  If no notification is received, OMD will assign one party as the FRN contact for billing purposes.  
  To facilitate administration of regulatory fees, we require that all non-U.S. licensed space station operators with such market access to obtain an FCC Registration Number by August 1, 2020. https://apps.fcc.gov/coresWeb/publicHome.do.
  Further, we remind non-U.S. licensed space station operators who do not pay the regulatory fees in a timely fashion that they will be in violation of our regulatory fee rules and, while being subject to other regulatory fee enforcement consequences, may be unable to obtain future U.S. market access until such matters are resolved. See 47 U.S.C. § 159(a).
  To reiterate, this fee will be assessed on any non-U.S. licensed space station that has been granted market access through existing earth stations licensees as of July 16, 2020. For FY 2021 and subsequent years, the date of assessment will be October 1, which is the standard date of assessment for space and earth stations.
  
33. We also conclude that we should reallocate four International Bureau indirect FTEs as direct to account for our decision to assess regulatory fees on non-U.S. licensed space stations.  The Commission previously recategorized four International Bureau FTEs as indirect to avoid assessing U.S. licensed space stations for work that directly involved non-U.S. licensed space stations that did not pay regulatory fees. FY 2015 Report and Order, 30 FCC Rcd at 10278, para.24.  At the time, the Commission stated that the number of market access requests by these entities can vary; however, four FTEs was appropriate to be reallocated as indirect in calculating benefit to International Bureau fee payors at the time.  See id. para. 24, and n. 94.
  We find that it is appropriate to make this adjustment to account for our decision to assess regulatory fees on non-U.S. licensed space stations and the section 9 requirement that the Commission set regulatory fees to “reflect the full-time equivalent number of employees within the bureaus and offices of the Commission adjusted to take into account factors that are reasonably related to the benefits provided to the payor of the fee by the Commission’s activities.” 47 U.S.C. § 159(d).
  We accordingly add four FTEs to the satellite regulatory fee category as direct FTEs to account for the work that was allocated as indirect previously.  We note, however, that we add back these four FTEs only to correct the total number of direct FTEs in the International Bureau for regulatory fee purposes.  The apportionment of fees among International Bureau regulatees is calculated based on the factors reasonably related to the benefits provided to the payors of the fee, as discussed below..  
34. Finally, we find that subjecting non-U.S. licensed space stations with U.S. market access to the space station regulatory fees is an amendment as defined in section 9(d) of the Act. Id.
  Such an amendment must be submitted to Congress at least 90 days before it becomes effective pursuant to section 9A(b)(2). 47 U.S.C. § 159A(b)(2).

B. Apportionment of Fees among International Bureau Regulatees
35. The Commission has previously determined over the course of several orders that a significant number of FTEs in the International Bureau do work that should be considered indirect for regulatory fee purposes and set the number of direct FTEs at 24. In FY 2013, the Commission proposed that all Satellite Division FTEs working on issues involving regulatees, 25 FTEs, be considered direct FTEs for determining the regulatory fees for space stations and earth stations.  FY 2013 NPRM, 28 FCC Rcd at 7800, paras. 22-23.  The Commission further proposed that two FTEs from the Telecommunications and Analysis Division be allocated as direct FTEs for regulatory fee purposes.  Id. at 7802, para. 27.  The Commission also proposed that the Global Strategy and Negotiation Division would be considered indirect because their activities benefit the Commission as a whole and are not specifically focused on International Bureau regulatees.  Id. at 7802-803, para. 28.  The Commission adopted the proposal, but revised the number of direct International Bureau FTEs to 28.  Assessment and Collection of FY 2013 Regulatory Fees, Report and Order, 28 FCC Rcd 12351, 12355-56, para. 14 (FY 2013 Report and Order,).  Then, in 2015, the Commission further reduced the number of direct FTEs in the International Bureau to 24 due to the number of International Bureau FTEs in the Satellite Division working on non-U.S. licensed space station market access requests.  FY 2015 Report and Order, 30 FCC Rcd at 10278, para. 24.
  The International Bureau fees are divided into a satellite category (with subcategories of GSO space stations, NGSO space stations, and earth stations) and an international bearer circuits category (consisting of submarine cable systems in one subcategory and terrestrial and satellite international facilities in another).  In the FY 2019 Report and Order, the Commission explained that we currently allocate 17.1 of the 24 International Bureau FTEs to the satellite category and 6.9 to the international bearer circuits category. FY 2019 Report and Order, 34 FCC Rcd at 8197, para. 20.
  Including the 4 FTEs that were previously considered indirect because of their work with non-U.S. licensed space stations as discussed above brings those totals to 21.1 FTEs assigned to the satellite category and 6.9 to the international bearer circuit category. 
36. In the Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order, we sought comment on whether we should adjust the apportionment among fee categories within the International Bureau. Id. at 8214, para. 67.
  In response, the International Bureau undertook a review of its work, staffing, and distribution of responsibilities benefiting its fee payers, division by division and between the Telecommunications and Analysis Division and the Satellite Division.  Based on this review, we find that adjusting the FTE allocation for the international bearer circuit category to 8 FTEs rather than 6.9 FTEs would better reflect the direct FTE work in the International Bureau that benefits the fee payors in the international bearer circuit category.  This action brings the FTEs for the satellite category to 20 and the total number of direct FTEs for the International Bureau to 28.
37. We are not persuaded by the Submarine Cable Coalition’s assertion that two FTEs from the Telecommunications and Analysis Division are sufficient for international bearer circuit regulation. Submarine Cable Coalition Comments at 3-4.  The Commission initially indicated the number of FTEs was two in 2013.  FY 2013 NPRM, 28 FCC Rcd at 7802, para. 27.
  As we explained in the FY 2015 Report and Order, two FTEs do not take into account all the work provided for this industry by the International Bureau. FY 2015 Report and Order, 30 FCC Rcd 10273, para. 12.
  Currently, almost all of the work of the Telecommunications and Analysis Division, as well as some of the work by the Office of the Bureau Chief, benefits international telecommunications service providers including submarine cable operators. One exception is the work in the Telecommunications and Analysis Division on foreign ownership issues under section 310 of the Communications Act, 47 U.S.C. § 310, which benefits domestic common carrier wireless providers by facilitating foreign investment in wireless carriers. 
  
38. The Submarine Cable Coalition also argues that the number of FTEs in the International Bureau was not appropriately reduced when the Office of Economics and Analytics was created and the reassignment of staff led to decreases in the direct FTEs in the Media, Wireline Competition, and Wireless Telecommunication Bureaus. Submarine Cable Coalition Comments at 4-5.
  None of the 24 FTEs from the International Bureau identified as direct for regulatory fee purposes, however, were moved to the Office of Economics and Analytics.  Therefore, the number of direct FTEs in the International Bureau was not reduced due to the creation of the Office of Economics and Analytics.  Accordingly, we reject these arguments.  In the FY 2019 Report and Order we recognized that the increase to fees for International Bureau regulatees was not trivial when we rejected similar arguments and explained that such an increase was consistent with previous FTE shifts we have made as well as the statute. FY 2019 Report and Order, 34 FCC Rcd at 8195, paras. 15-18.
  
39. GSO and NGSO Space Stations Apportionment.—In the Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order, we sought comment on adjustments to the allocation of FTEs among GSO and NGSO space and earth station operators. Id. at 8214, para. 67 (citing Letter from Jennifer A. Manner, Senior Vice President, EchoStar Satellite Operating Corporation and Hughes Network Systems, LLC, to Marlene H. Dortch, Secretary, FCC, MD Docket No. 19-105, Attachment at 1 (filed Aug. 8, 2019) (EchoStar August 8 Ex Parte Letter)).
  The FY 2019 annual regulatory fee per unit for Space Stations (Geostationary Orbit) is $159,625, and the comparable fee per unit for Space Stations (Non-Geostationary Orbit) is $154,875. 47 CFR § 1.1156(a).
  
40. In response, SES Americom, Intelsat, EchoStar, and Hughes (collectively, the GSO Satellite Operators), request that the Commission rebalance the cost allocations between GSO and NGSO space stations to address perceived unfairness in the current balance and because the current balance purportedly does not align with underlying costs. GSO Satellite Operators Comments at 1-2.  
  The GSO Satellite Operators observe that, for FY 2019, the expected regulatory fee revenue from GSO satellite operators was $15,643,250, which is more than 14 times the expected $1,084,125 regulatory fee revenue for NGSO satellite operators. Id. at 2 (citing FY 2019 Report and Order, 34 FCC Rcd at 8223-24, Appendix B).
  This imbalance in regulatory fee revenue results from the large disparity in number of units between GSO space stations (98) and NGSO space stations (7), It may also arise from the fact that the Commission does not assess regulatory fees on licenses that do not have operational satellites associated with them.  Thus, even though there may be an increase in NGSO licensing in recent years, there would not be an increase in regulatory fees if those licensed systems had not yet launched and operated satellites.
 even though under a single NGSO license hundreds, or thousands, of satellites can be operated while counting as a single unit for regulatory fee purposes, whereas only one satellite can be operated per GSO space station regulatory fee unit. See, e.g., Space Exploration Holdings, LLC, Application for Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System, IBFS File Nos. SAT-LOA-20161115-00118, SAT−LOA−20170726−00110, 33 FCC Rcd 3391 (2018).
  
41. We agree with the GSO Satellite Operators that the significantly larger amount of regulatory fee payments by GSO operators cannot be attributed to them benefiting more from the Commission’s regulatory activities.  We instead allocate 80% of space station fees to Space Stations (Geostationary Orbit) and 20% to Space Stations (Non-Geostationary Orbit).  We consider three factors that reflect the benefits of Commission oversight to GSO and NGSO operators: the number of applications processed (that is, the benefits of adjudication), the number of changes made to the Commission’s rules (that is, the benefit of rulemaking), and the number of FTEs working on oversight for each category of operators.  
42. First, using the data compiled from the International Bureau Filing System, we looked at the applications received and processed by the International Bureau for each of the most recent three years (that is, 2017-2019). The application counts include applications from U.S. and non-U.S. space station operators for new systems, requests for modification or amendment, and requests for special temporary authority.  By reporting the data as part of this proceeding, we address the request of the Satellite Industry Association to provide additional factual detail on fee decisions.  Satellite Industry Association Comments at 17.  
  The breakdown shows that GSO applications accounted for 79% (108/136) of applications disposed in 2019 and 79% (124/157) of applications received in 2019.  For 2018, the GSO share is 75% (88/117) disposed and 84% (77/92) received.  For 2017, the GSO share is 84% (122/146) disposed and 77% (128/167) received.  Thus, the total number of applications received and disposed of in this three-year period continues to support a significantly greater allocation of adjudication benefits to GSO than NGSO systems in the range of 75% to 84%.
43. Second, using compiled data for the last three years on the number of Commission-level items originating from the Satellite Division of the International Bureau, we considered each items’ relative precedential value to GSO and NGSO operators. We limited our review to Commission-level items because of their greater precedential value and because they include rulemaking proceedings that affect the industry as a whole, rather than a particular entity.   
  The list consists of 6 items during 2017-2019, Notices of Proposed Rulemakings that resulted in the adoption of an Order within the same three-year period were not included since inclusion could result in double-counting of an eventual benefit.
 of which 3 held more benefit for GSOs and 3 held more benefit for NGSOs. The following proceedings primarily benefit GSO systems:  (1) Amendment of the Commission’s Policies and
Rules for Processing Applications in the Direct Broadcast Satellite Service, Second Report & Order, IB Docket No. 06-160  (rel. Sep. 27, 2019); (2) Further Streamlining Part 25 Rules Governing Satellite Services, Notice of Proposed Rulemaking, 33 FCC Rcd 11502 (2018); and (3) Facilitating the Communications of Earth Stations in Motion with Non-Geostationary Orbit Space Stations, Report and Order and Further Notice of Proposed Rulemaking, 33 FCC Rcd 9327 (2018).  The following rulemaking proceedings primarily benefit NGSO systems: (1) Mitigation of Orbital Debris in the New Space Age, Notice of Proposed Rulemaking, 33 FCC Rcd 11352 (2019); (2) Streamlining Licensing Procedures for Small Satellites, Report and Order, 34 FCC Rcd 13077 (2019); (3) Facilitating the Communications of Earth Stations in Motion with Non-Geostationary Orbit Space Stations, Notice of Proposed Rulemaking, 33 FCC Rcd 11416 (2018).  One of the six items, Mitigation of Orbital Debris in the New Space Age, could be seen as benefitting both GSOs and NGSOs, but since the item largely addresses mitigation of debris resulting from new space operations in NGSOs, it was counted as benefitting NGSO more.

  Accordingly, the data presented suggests that there was approximately the same rulemaking benefit to GSO operators as to NGSO operators.  We note, however, that, quantifying only the most recent rulemaking activities does not take into account any continued benefits derived from older rulemakings.  Some of those continued benefits are received through the efforts of adjudication and administration of the rules adopted in those rulemakings.  Accordingly, we find that attributing a value to rulemaking activities directly is a somewhat subjective exercise and lacks precision.
44. Third, we considered whether we could examine FTE activities directly, but there has been no change in the number of FTEs attributable to satellite regulatory activities in the International Bureau from previous years and the International Bureau does not separate FTEs by work done on GSO versus NGSO matters. Similarly. the International Bureau also does not separate FTEs by work done on U.S licensed versus non-U.S. licensed space stations.  Most regulatory activities benefit all space stations, whether U.S licensed or not.  
  Indeed, a single FTE may work on authorizations and rulemakings that benefit both categories of satellite operations.  Because we are unable to assess benefits based on a clearly identifiable division of work by assigned FTEs, we must estimate the relative percentage of FTEs that are attributable to benefitting either GSO or NGSO systems based on the factors above.
45. We recognize the considerable challenge of assigning a precise number to the apportionment of regulatory fees between GSO and NGSO space stations.  Taking all of the foregoing factors and data into consideration we conclude, however, that the GSO/NGSO ratio should be adjusted to reflect that GSO space stations derived roughly 75-84% of the benefit from the Commission’s adjudicatory efforts.  Given that our consideration of FTE activities did not yield a clearly identifiable division between GSO and NGSO, and because it is difficult to be precise in quantifying benefits of rulemaking activities, we believe a number in the middle of the 75-84% range is appropriate.  We are also mindful that the number of NGSO units for which regulatory fees are assessed is small, so selection of a number at the bottom end of the 75-84% range would result in a much greater change in the regulatory fee assessed.  We find that selecting a number in the middle of the 75-84% range best reflects the other factors considered in our re-balancing and imposes a balanced burden in that range on all space station operators, including the smaller number of NGSO system operators.  Accordingly, for FY 2020, GSO and NGSO space stations will be allocated 80% and 20% of the space station fees, respectively.
46. Earth Station and Space Station Apportionment.—Although the Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order did not propose adjusting the allocation within the satellite category for earth station regulatory fees, certain satellite operators asked that we review such apportionment GSO Satellite Operators Comments, at 4; SIA Comments at 9.  
 and suggested that we implement different earth station subcategories for regulatory fee purposes. GSO Satellite Operators Comments at 4.
  
47. We decline to adopt any changes at this time.  We find that there is insufficient evidence in the record to increase the apportionment of fees paid by earth station licensees.  GSO Satellite Operators state that earth station licensees collectively are responsible for $1,402,500 in total regulatory fees, which is less than one-eleventh of the regulatory fees paid by GSO space station licensees. Id.
  Although the GSO Satellite Operators claim that this proportion is out of synch with actual relative costs, Id.
 they do not provide any data to support this claim, or propose an appropriate apportionment of fees between earth and space stations.  In support of their claim, GSO Satellite Operators point solely to a pair of proceedings focused on Earth Stations in Motion (ESIMs). Id. (citing Amendment of Parts 2 and 25 of the Commission’s Rules to Facilitate the Use of Earth Stations in Motion Communicating with Geostationary Orbit Space Stations in Frequency Bands Allocated to the Fixed-Satellite Service, Notice of Proposed Rulemaking, 32 FCC Rcd 4239 (2017); Facilitating the Communications of Earth Stations in Motion with Non-Geostationary Orbit Space Stations, Notice of Proposed Rulemaking, 33 FCC Rcd 11416 (2018).
  Although earth station licensees do benefit from these proceedings, we also find that the proceedings are of equal, if not more, benefit to space station licensees, which would gain access to additional frequency bands in which to sell transponder capacity for mobility services and increased streamlining of their regulatory environment.  Accordingly, the record does not support an increase of the apportionment of fees paid by earth station licensees at this time.
48. We also find that the record does not support implementing different classes of earth stations for regulatory fee purposes or increasing earth station regulatory fees.  GSO Satellite Operators suggest that blanket-licensed earth station licensees involving multiple antennas under a single authorization should pay higher fees than other earth station licensees because blanket-licensed earth station licensees require more regulatory oversight. GSO Satellite Operators Comments at 4.
  The GSO Satellite Operators, however, provide no factual support for the proposition other than a conclusory statement.  GSO Satellite Operators instead observe that the fee schedule originally adopted by Congress differentiated between blanket-licensed earth stations and stand-alone antennas. Id. at 4-5.
  But the prior statutory differentiation pertained to application fees, not regulatory fees—i.e., it was not tied to the statutory factors that bind us in setting regulatory fees. The GSO Satellite Operators cite section 159(g) of Title 47 of the United States Code in support, which was repealed in 2018.  GSO Satellite Operators Comments at 5 n.12.  Section 159(g) was entitled “Application of Application Fees” and addressed the separate issue of FCC filing fees, not regulatory fees.
  Accordingly, we find no basis in the record to support an increase in regulatory fees for earth station licenses or to support the creation of a separate, higher regulatory fee for blanket-licensed earth stations.
C. Regulatory Fees Paid by VHF Broadcasters 
49. In the FY 2018 Report and Order, we adopted a new methodology for assessment of broadcast television regulatory fees, finding that the service contour-based population method more accurately reflects the actual market served by full-power television stations for purposes of assessing regulatory fees than the DMA-based methodology we previously employed. Assessment and Collection of Regulatory Fees for Fiscal Year 2018, Report and Order and Order, 33 FCC Rcd 8497, 8501-8502, paras. 13-15 (2018) (FY 2018 Report and Order).
  We also said that we would phase in implementation of the new methodology in two years, using a transitional fee structure for FY 2019 fees and the new methodology for assessment of FY 2020 fees. Id. 
  
50. In the Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order, we sought comment on whether we should adjust population counts for the new methodology to address a signal limitation issue raised by commenters to the FY 2019 NPRM. FY 2019 Report and Order, 34 FCC Rcd at 8214-15, para. 68.
  Specifically, those commenters argued that VHF channels should have lower regulatory fees because the predicted contour distance does not adequately account for all of the possible effects on the VHF station signal, such as environmental noise issues, the result of which may limit the signal and the population reached.  Thus, they argued, the population count is overstated for VHF stations and should be adjusted downward accordingly. Id.
 
51. Commenters reiterate and amplify the signal limitation concern.  NAB explains that following the digital transition, some VHF channels encountered environmental noise that affected the reliability of those broadcasters’ signals. NAB Comments at 2.
  As a compensatory measure, some VHF stations have increased their power levels, resulting in an increase in the theoretical, but not the actual, population served and higher regulatory fees under the new methodology. NAB Comments at 3-4; NAB suggests a station’s original DTV contour is a more accurate reflection of a VHF station’s actual coverage and population reach.  See also Maranatha Broadcasting Comments at 1-4.
  PMCM TV argues that we should assess VHF stations, and especially low band VHF stations, a significantly lower regulatory fee. PMCM Comments at 4.  PMCM TV and Maranatha Broadcasting observe that the advertising revenues for TV are based on the DMA where the station is located, because that is where most of the audience is, and not on the population outside the DMA that may also be able to reach the station.  PMCM TV Comments at 4; Maranatha Broadcasting Comments at 5.
  Maranatha Broadcasting proposes that we average the fee amounts assessed to the commercial full power UHF stations in a given market and apply the average UHF fee as the fee to be assessed VHF stations in the same market. Maranatha Broadcasting Comments at 6-7.  See also Letter from Barry Fisher, President, Maranatha Broadcasting Company, Inc., to Marlene H. Dortch, Secretary, FCC, MD Docket No. 19-105, (filed May 1,2020).
  Maranatha Broadcasting argues that the population methodology does not properly account for “the inherent technical inferiority of the VHF signal in the digital broadcast world,” and that VHF stations should not be charged more than UHF stations in the same market. Maranatha Broadcasting Comments at 7.
 
52. We decline to categorically lower regulatory fees for VHF stations to account for signal limitations. Inconsistencies in the reports of low-VHF reception issues have led the Media Bureau to conclude that there is nothing inherent in VHF transmission that creates signal deficiencies but that environmental noise issues can affect reception in certain areas and situations.  And although we agree that environmental noise blockages affecting signal strength and reception exist, they do not exist across the board.  The impact of signal disruptions, to the extent they exist, varies widely from service area to service area and does not lend itself to an across-the-board rule.  However, we do agree with NAB and propose to take into account the licensed power increases that go beyond the maximum allowed for VHF stations. Therefore, we will assess the fees for those VHF stations that are licensed with a power level that exceeds the maximum based on the maximum power level specified for channels 2-6 in 73.622(f)(6) and for channels 7-13 in 73.622(f)(7).
IV. NOTICE OF PROPOSED RULEMAKING 
53. Congress has required us to collect $339,000,000 in regulatory fees for FY 2020.  Section 9 of the Act directs the Commission to set regulatory fees to “reflect the full-time equivalent number of employees within the bureaus and offices of the Commission adjusted to take into account factors that are reasonably related to the benefits provided to the payor of the fee by the Commission’s activities.” 47 U.S.C. § 159(d).
  We implement this directive by looking first to identify the bureaus that conduct work that directly benefits fee payors and their FTEs, in order to establish “direct” FTEs.  The remaining FTEs and other Commission costs we categorize as indirect.  In doing this calculation, we separate out the FTEs and other expenses associated with our auctions program, which are separately funded. Regulatory fees under section 9 of the Act recover the total amount provided for in the Commission’s appropriation.  47 U.S.C. § 159(a), (b).  Auctions expenses are not included in the appropriation.
  Once we have identified the direct FTEs by operating bureau, we look within each bureau to allocate fees to specific fee categories.  We use these proportional calculations to allocate all Commission non-auction costs, direct and indirect, across all fee categories.  To establish specific fees, we identify “units” that corollate to the benefit provided; for example, broadcast licensee fees will vary by population served See Appendix G.
 and wireless licensees will pay fees based on their number of subscribers. See Appendix D.

54. We implement this framework by first proposing to allocate direct FTEs within the Commission.  We then consider the very specific proposals by industry segment of how to allocate within each regulatory fee category.  We seek comment on these proposals.  
55. For the majority of the Commission’s regulatory fees, the allocation within fee category by unit is well established. Such proposed fees are based on the established methodology being applied to the result of the FTE allocation being applied to the Commission’s appropriation amount.  For those fees, we propose and seek comment on the schedule of FY 2020 regulatory fees as set forth in Appendices B and C and seek comment on those fees. See Appendix C.
  
A. Allocating FTEs for FY 2020  
56. The first step in our annual regulatory fee rulemaking is to identify the FTEs doing work directly benefitting our regulatees.  The Commission identifies the number of FTEs within each of the four core bureaus (i.e., Wireline Competition Bureau, Wireless Telecommunications Bureau, International Bureau, and Media Bureau) and then further subdivides within each core bureau to account for its regulatory fee categories.  The phrase core bureaus was first adopted in the FY 2012 NPRM where the Commission explained that under (prior) section 9(b)(1)(A), the Commission was instructed to calculate the regulatory fees by determining the FTEs performing the activities enumerated in section 9(a)(1) within the Private Radio Bureau, Mass Media Bureau, and Common Carrier Bureau, and other offices of the Commission, and those bureaus had subsequently been renamed as the Wireless Telecommunications Bureau, Media Bureau, and Wireline Competition Bureau, and a new International Bureau had been formed.  FY 2012 NPRM, 27 FCC Rcd at 8460, para. 5 & n.5.  The Commission explained that “[f]or simplicity and ease of reference, in this Notice we will refer to these four bureaus as the ‘core’ bureaus or the ‘core licensing’ bureaus.”  Id.    
  As a general matter, we expect that the work of the FTEs in the four core bureaus will remain focused on the industry segment regulated by each of those bureaus.  Consistent with past practices, we propose that for FY 2020 the allocation of fees to fee categories will be based on the Commission’s calculation of FTEs in each regulatory fee category.  The work of the FTEs in the indirect bureaus and offices benefits the Commission and the telecommunications industry generally and is not specifically focused on the regulatees and licensees of one core bureau. The indirect FTEs are the non-auctions-funded employees from the following bureaus and offices:  Enforcement Bureau, Consumer and Governmental Affairs Bureau, Public Safety and Homeland Security Bureau, part of the International Bureau, part of the Wireline Competition Bureau, Chairman and Commissioners’ offices, Office of the Managing Director, Office of General Counsel, Office of the Inspector General, Office of Communications Business Opportunities, Office of Engineering and Technology, Office of Legislative Affairs, Office of Workplace Diversity, Office of Media Relations, Office of Economics and Analytics, and Office of Administrative Law Judges.  
  We thus propose that, consistent with past practices, the total FTEs for each fee category include the direct FTEs associated with that category plus a proportional allocation of indirect FTEs. The Commission observed in the FY 2013 Report and Order that “the high percentage of the indirect FTEs is indicative of the fact that many Commission activities and costs are not limited to a particular fee category and instead benefit the Commission as a whole.”  See FY 2013 Report and Order, 28 FCC Rcd at 12357, para. 17.  The new Office of Economics and Analytics consists of indirect FTEs.
  
57. Applying the section 9 requirements to calculate regulatory fees, we propose to allocate the total collection target across all regulatory fee categories.  Each regulatee within a fee category then pays its proportionate share based on an objective measure of size (e.g., revenues or number of subscribers). See FY 2012 NPRM, 27 FCC Rcd at 8461-62, paras. 8-11.  
  These calculations are illustrated in Appendix B.  The sources for the unit estimates that are used in these calculations are listed in Appendix D.  
58. We project approximately $30.52 million (9.00% of the total FTE allocation, 28 direct FTEs) in fees from International Bureau regulatees; $79.57 million (23.47% of the total FTE allocation, 73 direct FTEs) in fees from Wireless Telecommunications Bureau regulatees; $102.46 million (30.23% of the total FTE allocation, 94 direct FTEs) from Wireline Competition Bureau regulatees; and $126.45 million (37.30% of the total FTE allocation, 116 direct FTEs) from Media Bureau regulatees.  We seek comment on our calculation for the FY 2020 FTEs (311 direct FTEs). 
B. International Bearer Circuits
59. The regulatory fees associated with IBCs reflect the work performed by the International Bureau, primarily the Telecommunications and Analysis Division and the Office of the Bureau Chief, for the benefit of all U.S. international telecommunications service providers.  International telecommunications service is provided over terrestrial, satellite, and submarine cable facilities. 
60. IBC fees are currently broken into two components: (1) terrestrial and satellite circuits, Regulatory fees for terrestrial and satellite IBCs are paid based on active (used or leased) international bearer circuits as of December 31 of the previous year in any terrestrial or satellite transmission facility for the provision of service to an end user or resale carrier.  Active circuits include backup and redundant circuits as of December 31.  Whether circuits are used specifically for voice or data is not relevant for purposes of determining that they are active circuits.
 and (2) submarine cable systems.  Prior to 2009, IBC fees were collected based on 64 kbps circuits for each of the three types of facilities used to provide international service.  In 2009, at the request of a large number of submarine cable operators, the Commission changed the methodology for assessing IBC fees and began to assess fees on a per cable landing license basis, with higher fees for larger submarine cable systems and lower fees for smaller submarine cable systems. Assessment and Collection of Regulatory Fees for Fiscal Year 2008, Second Report and Order, 24 FCC Rcd 4208, 4214-17, paras. 13-22 (2009) (Submarine Cable Order).  The Commission did not change the methodology of assessing regulatory fees for terrestrial and satellite facilities on a per bearer circuit basis.  Id. at 4223, para. 20.
  The Commission concluded that this methodology served the public interest and was competitively neutral because it included both common carriers and non-common carriers. Id. at 4212-13, paras. 8-9.
  Through FY 2019, the Commission continued to assess fees for international service provided over terrestrial and satellite facilities based on a per 64 kbps basis.  Under this bifurcated approach, based on the 2009 Consensus Proposal from the submarine cable operators, 87.6% of IBC fees are assessed to submarine cable systems and 12.4% to terrestrial and satellite facilities based on relative active or lit capacity at the time. Initially, this fee category was for common carrier IBCs.  The Commission added non-common carrier satellite IBCs to this regulatory fee category in 1997.  See FY 1997 Report and Order, 12 FCC Rcd at 17189, para. 71.  More recently, the Commission added non-common carrier terrestrial IBCs to this regulatory fee category in 2017.  See Assessment and Collection of Regulatory Fees for Fiscal Year 2017, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 7057, 7071-72, paras. 34-35 (2017) (FY 2017 Report and Order).
  The Commission adopted a five-tier structure for assessing fees on submarine cables systems, with larger systems paying more based on active capacity, and a per gigabits per second (Gbps) assessment for terrestrial and satellite facilities that similarly maintained an active capacity basis. See FY 2019 Report and Order, 34 FCC Rcd at 8203-04, paras. 37, 40.
 
61. The Further Notice of Proposed Rulemaking attached to the FY 2019 Report and Order sought comment on appropriate allocation within the IBC fee category in response to assertions regarding the relative benefits received by the different IBC components.  Id. at 8214, para. 67.
  Based on our review of the record, we find the International Bureau provides many services that benefit international telecommunications service providers no matter whether they use terrestrial facilities, satellites, or submarine cables to transport their international services.  These services include maintaining the licensing database, The International Bureau reviews, processes, analyzes, and grants applications for international section 214 authorizations and submarine cable landing licenses, as well as applications for modifications, transfers, and assignments.  The International Bureau also coordinates processing of the applications with the relevant Executive Branch agencies.
 enforcing benchmarks, See, e.g., International Settlement Rates, IB Docket No. 96-261, Report and Order, 12 FCC Rcd 19806 (1997) (Benchmarks Order); Report and Order on Reconsideration and Order Lifting Stay, 14 FCC Rcd 9256 (1999) (Benchmarks Reconsideration Order); aff’d sub nom. Cable & Wireless, 166 F.3d 1224.  
 coordination with other U.S. government agencies, For example, the International Bureau coordinates with the Executive Branch agencies regarding national security, law enforcement, foreign policy and trade policy issues related to international services.  See Rules and Policies on Foreign Participation in the U.S. Telecommunications Market; Market Entry and Regulation of Foreign-Affiliated Entities, IB Docket Nos. 97-142 and 95-22, Report and Order and Order on Reconsideration, 12 FCC Rcd 23891 (1997) (Foreign Participation Order), recon. denied, 15 FCC Rcd 18158 (2000).   
 protecting U.S. customers and consumers from anticompetitive actions by foreign carriers, licensing international section 214 authorizations and submarine cables including review of transactions, and representing U.S. interests at bilateral and multilateral negotiations and at international organizations. FY 2017 Report and Order, 32 FCC Rcd at 7070-71, para. 31.
  A fundamental premise of how the Commission assesses regulatory fees is that licensees with larger facilities benefit more from the Commission’s work and thus should pay a larger proportion of the Commission’s costs. See FY 2019 Report and Order, 34 FCC Rcd at 8205, para. 43.

62.  We find it appropriate to consider adjusting the allocation of IBC fees given the significant changes in submarine cable system active or lit capacity and usage since 2009.  Commenters representing the terrestrial and satellite facility owners argue that the 87.6%-12.4% split is out of date and that submarine cable operators should pay a larger proportion of the IBC fees.  For example, SIA argues that the 87.6%-12.4% split between submarine cable and satellite and terrestrial IBCs should be revised to reflect current relative capacity, to 98.3%-1.7%. SIA Comments at 4.
  CenturyLink contends that, based on current capacity, the split should be 1.2% for satellite and terrestrial IBCs and 98.8% for submarine cable. CenturyLink Comments at 6-8 & Reply Comments at 3-4.
  If we use the minimum capacity for the 2019 rate tiers for regulatory fees paid for submarine cables in FY 2019 (meaning a licensee that paid the rate for a capacity of 4000 Gbps or higher on the submarine cable is presumed to have a capacity of 4000 Gbps), we calculate that the ratio is at least 90.8% submarine cable and 9.8% terrestrial and satellite circuits.  However, we believe that this approach of assuming lit capacity at the minimum capacity in the tier substantially undercounts actual lit capacity and that an upward adjustment of 5% more closely approximates actual lit capacity numbers.  We therefore propose a ratio attributing 95% to submarine cables and 5% to terrestrial and satellite circuits.  We seek comment on this allocation. 
63. Because the benefits from the work of the International Bureau accrue to international service providers regardless of which facilities are used, we propose to simplify the assessment by combining the two categories and assess IBC fees based on a unified fee structure.  Under this approach, terrestrial and satellite facility owners will pay regulatory fees based on the number of active international circuits using the rates set out in the tiers.  Submarine cable operators would continue to pay regulatory fees for each international submarine cable system based on the active (or lit) capacity of the cable system using the same tiers. 
FY 2020 International Bearer Circuits

Submarine Cable Systems
(capacity as of December 31, 2019)
FY 2020 Regulatory Fees
Less than 30 Gbps
$1,000
30 Gbps or greater, but less than 250 Gbps
$18,450
250 Gbps or greater, but less than 1,000 Gbps
$36,875
1,000 Gbps or greater, but less than 2,000 Gbps
$73,750
2,000 Gbps or greater, but less than 3,500 Gbps
$147,500
3,500 Gbps or greater, but less than 6,500 Gbps
$295,000
6,500 Gbps or greater
$590,000

We seek comment on the use of a unified tiered structure for IBCs and these proposed fees, which are based on a ratio attributing 95% to submarine cables and 5% to terrestrial and satellite international bearer circuits.  As an alternative, we seek comment on maintaining the current fee structure for international bearer circuits and having the fees for submarine cables based on the proposed tier structure and assessing fees for terrestrial and satellite capacity at $41 per Gbps circuits.
64. We are not persuaded that we should artificially reduce rates paid by submarine cable operators compared to terrestrial and satellite IBC operators because of “limited oversight” of submarine cables beyond the licensing process. NASCA argues that almost all of the Commission’s activities involving submarine cables arise from “sporadic and comparatively infrequent licensing and transaction reviews.”  NASCA Comments at 6-8.  Further, the Submarine Cable Coalition argues that the allocation of two FTEs to submarine cables “is consistent with the general lack of oversight required for submarine cables as a whole, beyond the initial licensing process.”  Submarine Cable Coalition Comments at 4.
  In addition to the work that the International Bureau provides that benefits all international telecommunications service providers, it provides services that specifically benefit submarine cable operators and the international services that are carried on the submarine cables.  For example, the International Bureau is in close coordination with other government agencies to facilitate the deployment of submarine cables and protect them once they are laid and in service. See Improving Outage Reporting for Submarine Cables and Enhanced Submarine Cable Outage Data, GN Docket No. 15-206, Report and Order, 31 FCC Rcd 7947, 7976 (2016) (“[T]he International Bureau, in coordination with the Public Safety and Homeland Security Bureau, will continue to lead interagency coordination efforts to help increase transparency and information sharing among the government agencies, cable licensees, and other stakeholders and promote improved interagency coordination processes to mitigate threats to undersea cables and facilitate new projects to improve geographic diversity.”)  
  Further, as SIA clearly states, we find that the “Commission’s efforts in these areas lay the groundwork for robust competition necessary to support the operations of international telecommunications providers that use submarine cable capacity.  Thus, submarine cable operators that provide capacity to these carriers unquestionably reap the rewards of International Bureau activities that foster competition.” SIA Reply Comments at 6; see also AT&T Reply Comments at 6-7. We disagree however with SIA’s contention that satellite operators should not be assessed IBC fees or that IBC fees should be substantially reduced to reflect current data on capacity used for international telecommunications. SIA Comments at 2-3 & Reply Comments at 2-5.  We also disagree with SIA’s contention that the industry already pays regulatory fees for space stations and earth stations and that satellite IBCs are a very small portion of the IBCs.  SIA Comments at 3-4.  
  
65. We disagree with satellite operators’ assertions that they should bear a smaller portion of IBC fees because they also pay satellite regulatory fees.  Space station and earth station regulatory fees are based on the work done by the Satellite Division for those facilities.  The international bearer circuit fees paid by satellite operators are for the work done by the International Bureau for the international services carried on the satellites.  To the extent that satellites carry a smaller amount of international traffic than terrestrial facilities or submarine cables, they will then pay a smaller amount in fees.  As we noted in the FY 2019 Report and Order, regulatees with larger capacities reap more benefits from the Commission’s work and thus pay a larger fee. FY 2019 Report and Order, 34 FCC Rcd at 88205, para. 43.
 
C. Television Broadcaster Issues
66. This year we propose to complete the transition to a population-based full-power broadcast television regulatory fee.  Historically, regulatory fees for full-power television stations were based on the Nielsen Designated Market Area (DMA) groupings 1-10, 11-25, 26-50, 51-100, and remaining markets (DMAs 101-210).  In the FY 2018 NPRM, we sought comment on whether using the actual population covered by the station’s contours instead of DMAs would more accurately reflect the market served by a full-power broadcast television station for purposes of assessing regulatory fees. FY 2018 NPRM, 33 FCC Rcd at 5102, para. 28.
  In the FY 2018 Report and Order, we adopted the new methodology.  We determined that we would fully transition to the methodology by FY 2020, and in the interim, for FY 2019, we adopted a blended fee based partly on the historical DMA methodology and partly on the new population-based methodology. FY 2018 Report and Order, 33 FCC Rcd at para.14.
  
67. Accordingly, we now propose FY 2020 fees for full-power broadcast television stations based on the population covered by a full-power broadcast television station’s contour.  We also propose adopting a factor of .78 of one cent ($.007837) [per person served] for FY 2020 full-power broadcast television station fees. The factor of .78 of one cent ($.007837) was derived by taking the revenue amount required from all television fee categories and dividing it by the total population count of all “feeable” call signs.
  The population data for broadcasters’ service areas are extracted from the TVStudy database, based on a station’s projected noise-limited service contour. 47 CFR § 73.622(e).
  Appendix G lists this population data for each licensee and the population-based fee (population multiplied by $.007837) for each full-power broadcast television station, including each satellite station.  We seek comment on these proposed fees. See 47 U.S.C. § 159(d) (“the Commission shall by rule amend the schedule of regulatory fees established under this section if the Commission determines that the schedule requires amendment so that such fees reflect the full-time equivalent number of employees within the bureaus and offices of the Commission, adjusted to take into account factors that are reasonably related to the benefits provided to the payor of the fee by the Commission’s activities.”).  
  
68. Puerto Rico Broadcasters.—The Puerto Rico Broadcasters contend that the population-based methodology overstates the population served by Puerto Rico stations for two reasons.  These commenters contend that Puerto Rico’s mountainous terrain conditions drive engineering decisions that result in the TVStudy overstating the population served. Puerto Rico Broadcasters Comments at 5-10.
  They additionally argue that significant and measurable drops in Puerto Rico’s population resulting from an exodus caused in part by Hurricane Maria evidence that the population counts underlying the TVStudy overstate the population served by Puerto Rico television broadcasters.
69. We agree and propose to adjust the fees of such broadcasters in two discrete ways.  First, Puerto Rico Broadcasters state that an outdated base population for Puerto Rico does not factor in the dramatic decrease in residents due to severe economic recession, and devastation caused by Hurricanes Irma and Maria. Id. at 10.
  Specifically, Census Bureau data indicate that Puerto Rico’s population has decreased from 3.73 million in 2010 to 3.19 million in 2018, which is a 14% decline. See https://www.census.gov/quickfacts/PR.
  More recent data suggest the decline is higher, with an estimated 3.10 million Puerto Rico base population in 2020, a 16.9% decline. See Puerto Rico Broadcasters Ex Parte, Attachment, at 7.
  We propose to account for the objectively measurable reduction in population by reducing the population counts used in TVStudy by 16.9%, or the decline between the last census in 2010 and the current population estimate.
70. Second, Puerto Rico Broadcasters assert that actual signal coverage for broadcast stations is far less than predicted coverage because Puerto Rico is an island with rugged mountainous terrain conditions. Puerto Rico Broadcasters Comments at 3-13.
  In particular, the rugged mountain range that divides the island blocks signals in many locations. Id. at 4.
  For this reason, broadcasters employ a unique network that relies on multiple full power satellite facilities in addition to a primary station. Id.
  The Puerto Rico Broadcasters contend that under the regulatory fee methodology adopted for television broadcasters, millions of viewers in Puerto Rico are now counted multiple times, once for each predicted noise-limited service contour in which they live. Id. at 5-10.
  To address this issue, we further propose to limit the market served by a primary television stations and commonly owned satellite broadcast stations in Puerto Rico to no more than 3.10 million people, the latest population estimate. See https://www.census.gov/quickfacts/PR
  Under this scenario, the fee for television broadcasters and commonly owned satellites, using the proposed population fee of $.007837, would not exceed $24,300.  We seek comment on these proposals.
D. Direct Broadcast Satellite Regulatory Fees
71. Direct Broadcast Satellite (DBS) service is a nationally distributed subscription service that delivers video and audio programming via satellite to a small parabolic dish antenna at the subscriber’s location.  The two DBS providers, AT&T and DISH Network, are MVPDs. MVPD is defined in section 602(13) of the Act, 47 U.S.C. § 522(13).
  The Media Bureau oversees the regulation of MVPDs, i.e., regulated companies that make available for purchase, by subscribers or customers, multiple channels of video programming.  The Media Bureau relies on a common pool of FTEs to carry out its oversight of MVPDs and other video distribution providers. FY 2018  Report and Order, 33 FCC Rcd at 8944, para. 8.
  These responsibilities include market modifications, local-into-local, must-carry and retransmission consent disputes, program carriage and program access complaints, over-the-air reception device declaratory rulings and waivers, media rule modernization, media ownership, and proposed transactions. Id. at 8944-8500, para. 8.
  For Media Bureau activities in FY 2020, the Commission must collect $69.53 million in regulatory fees from MVPDs, i.e., cable TV systems (including CARS licenses), IPTV providers, and DBS operators.  
72. We propose to continue to assess cable TV systems and IPTV providers at the same rate for regulatory fee purposes. When adopting the regulatory fee for IPTV, the Commission determined that IPTV providers should be subject to the same regulatory fees as cable providers.  FY 2013 Report and Order, 28 FCC Rcd at 12362, para. 32.
  The Commission has historically taken a different approach for establishing DBS operator regulatory fees.  In FY 2015, the Commission decided to phase in the new Media Bureau-based regulatory fee for DBS, starting at 12 cents per subscriber per year, as a subcategory in the cable television and IPTV category. FY 2015 Report and Order at 10277, para. 20.
  At the same time, the Commission committed to updating the regulatory fee rate in future years. FY 2015 Report and Order, 30 FCC Rcd at 10277, para. 20.
  The Commission has increased the DBS regulatory fee by 12 cents per subscriber per year in each subsequent year. From 2016 to 2019, the Commission increased the regulatory fee for DBS operators to 24 cents (plus a three cent moving fee), 36 cents (plus a two cent moving fee), 48 cents, and then 60 cents, per subscriber per year, with the regulatory fees paid by DBS operators reducing those paid by other MVPDs.
  The DBS regulatory fee is based on the significant number of Media Bureau FTEs that work on MVPD issues that include DBS, “not a particular number of FTEs focused solely on DBS” or “specific recent proceedings.” FY 2018 Report and Order, 33 FCC Rcd at 8501, para. 11; FY 2017 Report and Order, 32 FCC Rcd at 7067-68,  paras. 22-23; see also FY 2015 NPRM, 30 FCC Rcd at 5369, para. 33 (“We also reject the argument raised by DIRECTV and DISH that section 9 of the Act requires us to ‘show that DBS and cable occupy a comparable number of FTEs.’”).
  We propose, for FY 2020, to continue to phase in the DBS regulatory fee by increasing it by 12 cents per subscriber, to 72 cents.  This will result in a $ 0.89 fee per subscriber per year for other MVPDs.  We seek comment on this proposal.
E. Economic Effects of COVID-19 Pandemic
73. We recognize that the ongoing COVID-19 pandemic is having an impact on some of our regulatees’ businesses.  While many states in this country have begun to permit or are developing plans to permit businesses to re-open, it is not possible to forecast how quickly or to what extent businesses affected by the pandemic will return to normal levels of operation.  Some of our regulatees may continue to be affected and may require assistance in meeting their regulatory fee obligations.  We seek comment on how to provide assistance to these regulatees in these circumstances.  
74. In this regard, we note that the Commission is constrained in three important aspects.  First, we are required by statute to collect our FY 2020 appropriation, $339,000,000, as an offsetting collection from our regulatees by September 30, 2020.  Second, the Act requires that we allocate our regulatory fees among regulatees in a proportional manner to fairly reflect the value of FTE work expended to benefit regulatees.  Finally, we cannot exempt regulatees that are not expressly exempted under the statute. 47 U.S.C. §159; FY 2020 Appropriations.  
 Thus, we cannot reduce the proposed FY 2020 fees across-the-board; we cannot re-apportion the fees among categories based on, for example, relative ability to pay, and we cannot exempt regulatees based on their financial circumstances.    
75. Within those constraints, we have some flexibility to assist.  For example, we have authority to offer extended payment terms at nominal interest rates for regulatory fee payors that demonstrate they face significant financial challenges, 47 CFR § 1.1914; 31 CFR § 901.8.
 as we did in 2017 and 2018 for regulatees whose businesses were devastated by Hurricanes Florence Harvey, Irma, Maria and Florence.  We seek comment on how to  facilitate similar or additional relief here where appropriate. 
F. Additional Regulatory Fee Reform   
76. We also seek comment on additional regulatory fee reform and ways to further improve our regulatory fee process to make it less burdensome for all entities.  In particular, we seek comment on whether our fee setting methodologies could be improved or updated to ensure that our regulatory fees are more equitable or otherwise streamlined to make the fee schedule simpler.  As part of this analysis, we seek comment on the costs and benefits of reforming our fee-setting process.  
V. PROCEDURAL MATTERS
77. Included below are procedural items as well as our current payment and collection methods.  We include these payments and collection procedures here as a useful way of reminding regulatory fee payers and the public about these aspects of the annual regulatory fee collection process.    
78. Credit Card Transaction Levels.  Since June 1, 2015, in accordance with Treasury Financial Manual, Volume I, Part 5, Chapter 7000, Section 7045—Limitations on Card Collection Transactions. the highest amount that can be charged on a credit card for transactions with federal agencies is $24,999.99. Customers who owe an amount on a bill, debt, or other obligation due to the federal government are prohibited from splitting the total amount due into multiple payments.  Splitting an amount owed into several payment transactions violates the credit card network and Fiscal Service rules.  An amount owed that exceeds the Fiscal Service maximum dollar amount, $24,999.99, may not be split into two or more payment transactions in the same day by using one or multiple cards.  Also, an amount owed that exceeds the Fiscal Service maximum dollar amount may not be split into two or more transactions over multiple days by using one or more cards.
  Transactions greater than $24,999.99 will be rejected.  This limit applies to single payments or bundled payments of more than one bill.  Multiple transactions to a single agency in one day may be aggregated and treated as a single transaction subject to the $24,999.99 limit.  Customers who wish to pay an amount greater than $24,999.99 should consider available electronic alternatives such as Visa or MasterCard debit cards, ACH debits from a bank account, and wire transfers.  Each of these payment options is available after filing regulatory fee information in Fee Filer.  Further details will be provided regarding payment methods and procedures at the time of FY 2019 regulatory fee collection in Fact Sheets, https://www.fcc.gov/regfees.
79. Payment Methods.  Pursuant to an Office of Management and Budget (OMB) directive, Office of Management and Budget (OMB) Memorandum M-10-06, Open Government Directive, Dec. 8, 2009; see also http://www.whitehouse.gov/the-press-office/2011/06/13/executive-order-13576-delivering-efficient-effective-and-accountable-gov.
 the Commission is moving towards a paperless environment, extending to disbursement and collection of select federal government payments and receipts. See U.S. Department of the Treasury, Open Government Plan 2.1, Sept. 2012.
  In 2015, the Commission stopped accepting checks (including cashier’s checks and money orders) and the accompanying hardcopy forms (e.g., Forms 159, 159-B, 159-E, 159-W) for the payment of regulatory fees. FY 2015 Report and Order, 30 FCC Rcd at 10282-83, para. 35.  See 47 CFR § 1.1158.
  During the fee season for collecting regulatory fees, regulatees can pay their fees by credit card through Pay.gov, In accordance with Treasury Financial Manual, Volume I, Part 5, Chapter 7000, Section 7045—Limitations on Card Collection Transactions., the amount that may be charged on a credit card for transactions with federal agencies has been reduced to $24,999.99.
 ACH, debit card, In accordance with U.S. Treasury Financial Manual Announcement No. A-2012-02, the maximum dollar-value limit for debit card transactions is eliminated. Only Visa and MasterCard branded debit cards are accepted by Pay.gov.  For a list of acceptable credit cards, debit cards, and digital wallets, see  https://www.pay.gov/WebHelp/HTML/payments_what.html.
 or by wire transfer.  Additional payment instructions are posted on the Commission’s website at http://transition.fcc.gov/fees/regfees.html.  The receiving bank for all wire payments is the U.S. Treasury, New York, NY (TREAS NYC).  Any other form of payment (e.g., checks, cashier’s checks, or money orders) will be rejected.  For payments by wire, a Form 159-E should still be transmitted via fax so that the Commission can associate the wire payment with the correct regulatory fee information.  The fax should be sent to the Federal Communications Commission at (202) 418-2843 at least one hour before initiating the wire transfer (but on the same business day) so as not to delay crediting their account.  Regulatees should discuss arrangements (including bank closing schedules) with their bankers several days before they plan to make the wire transfer to allow sufficient time for the transfer to be initiated and completed before the deadline.  Complete instructions for making wire payments are posted at http://transition.fcc.gov/fees/wiretran.html.
80. Standard Fee Calculations and Payment Dates.—The Commission will accept fee payments made in advance of the window for the payment of regulatory fees.  The responsibility for payment of fees by service category is as follows:
· Media Services:  Regulatory fees must be paid for initial construction permits that were granted on or before October 1, 2019 for AM/FM radio stations, VHF/UHF broadcast television stations, and satellite television stations.  Regulatory fees must be paid for all broadcast facility licenses granted on or before October 1, 2019.  
· Wireline (Common Carrier) Services:  Regulatory fees must be paid for authorizations that were granted on or before October 1, 2019.  In instances where a permit or license is transferred or assigned after October 1, 2019, responsibility for payment rests with the holder of the permit or license as of the fee due date.  Audio bridging service providers are included in this category. Audio bridging services are toll teleconferencing services. 
  For Responsible Organizations (RespOrgs) that manage Toll Free Numbers (TFN), regulatory fees should be paid on all working, assigned, and reserved toll free numbers as well as toll free numbers in any other status as defined in section 52.103 of the Commission’s rules. 47 CFR § 52.103.
  The unit count should be based on toll free numbers managed by RespOrgs on or about December 31, 2019.
· Wireless Services:  CMRS cellular, mobile, and messaging services (fees based on number of subscribers or telephone number count):  Regulatory fees must be paid for authorizations that were granted on or before October 1, 2019.  The number of subscribers, units, or telephone numbers on December 31, 2019 will be used as the basis from which to calculate the fee payment.  In instances where a permit or license is transferred or assigned after October 1, 2019, responsibility for payment rests with the holder of the permit or license as of the fee due date.  
· Wireless Services, Multi-year fees:  The first eight regulatory fee categories in our Schedule of Regulatory Fees pay “small multi-year wireless regulatory fees.”  Entities pay these regulatory fees in advance for the entire amount period covered by the five-year or ten-year terms of their initial licenses, and pay regulatory fees again only when the license is renewed, or a new license is obtained.  We include these fee categories in our rulemaking to publicize our estimates of the number of “small multi-year wireless” licenses that will be renewed or newly obtained in FY 2020. 
· Multichannel Video Programming Distributor Services (cable television operators, CARS licensees, DBS, and IPTV):  Regulatory fees must be paid for the number of basic cable television subscribers as of December 31, 2019. Cable television system operators should compute their number of basic subscribers as follows: Number of single family dwellings + number of individual households in multiple dwelling unit (apartments, condominiums, mobile home parks, etc.) paying at the basic subscriber rate + bulk rate customers + courtesy and free service.  Note: Bulk-Rate Customers = Total annual bulk-rate charge divided by basic annual subscription rate for individual households.  Operators may base their count on “a typical day in the last full week” of December 2019, rather than on a count as of December 31, 2019. 
  Regulatory fees also must be paid for CARS licenses that were granted on or before October 1, 2019.  In instances where a permit or license is transferred or assigned after October 1, 2019, responsibility for payment rests with the holder of the permit or license as of the fee due date.  For providers of DBS service and IPTV-based MVPDs, regulatory fees should be paid based on a subscriber count on or about December 31, 2019.  In instances where a permit or license is transferred or assigned after October 1, 2019, responsibility for payment rests with the holder of the permit or license as of the fee due date.
· International Services (Earth Stations, Space Stations (GSO and NGSO):  Regulatory fees must be paid for (1) earth stations and (2) geostationary orbit space stations and non-geostationary orbit satellite systems that were U.S licensed, or non-U.S. licensed but granted U.S. market access, and operational on or before October 1, 2019.  In instances where a permit or license is transferred or assigned after October 1, 2019, responsibility for payment rests with the holder of the permit or license as of the fee due date.  For FY 2020 only, non-U.S. licensed GSO and NGSO satellites that have been granted market access to the U.S. through a Petition for Declaratory Ruling (PDR) or through an earth station have until July 15, 2020 to relinquish their market access status to avoid having to pay FY 2020 regulatory fees in September 2020.  If non-U.S. licensed GSO and NGSO satellites, either through a PDR or an earth station, still have market access after July 15, 2020, regulatory fees will be assessed and payment will be required by the due date of FY 2020 regulatory fees. 
· International Services (Submarine Cable Systems, Terrestrial and Satellite Services):  Regulatory fees for submarine cable systems are to be paid on a per cable landing license basis based on lit circuit capacity as of December 31, 2019.  Regulatory fees for terrestrial and satellite IBCs are to be paid based on active (used or leased) international bearer circuits as of December 31, 2019 in any terrestrial or satellite transmission facility for the provision of service to an end user or resale carrier.  When calculating the number of such active circuits, entities must include circuits used by themselves or their affiliates.  For these purposes, “active circuits” include backup and redundant circuits as of December 31, 2019.  Whether circuits are used specifically for voice or data is not relevant for purposes of determining that they are active circuits. We encourage terrestrial and satellite service providers to seek guidance from the International Bureau’s Telecommunications and Analysis Division to verify their particular IBC reporting processes to ensure that their calculation methods comply with our rules.
  In instances where a permit or license is transferred or assigned after October 1, 2019, responsibility for payment rests with the holder of the permit or license as of the fee due date.  
81. Commercial Mobile Radio Service (CMRS) and Mobile Services Assessments.  The Commission will compile data from the Numbering Resource Utilization Forecast (NRUF) report that is based on “assigned” telephone number (subscriber) counts that have been adjusted for porting to net Type 0 ports (“in” and “out”). See Assessment and Collection of Regulatory Fees for Fiscal Year 2005, Report and Order, 20 FCC Rcd 12259, 12264, paras. 38-44 (2005).
  This information of telephone numbers (subscriber count) will be posted on the Commission’s electronic filing and payment system (Fee Filer) along with the carrier’s Operating Company Numbers (OCNs).  
82. A carrier wishing to revise its telephone number (subscriber) count can do so by accessing Fee Filer and follow the prompts to revise their telephone number counts.  Any revisions to the telephone number counts should be accompanied by an explanation or supporting documentation. In the supporting documentation, the provider will need to state a reason for the change, such as a purchase or sale of a subsidiary, the date of the transaction, and any other pertinent information that will help to justify a reason for the change.
  The Commission will then review the revised count and supporting documentation and either approve or disapprove the submission in Fee Filer.  If the submission is disapproved, the Commission will contact the provider to afford the provider an opportunity to discuss its revised subscriber count and/or provide additional supporting documentation.  If we receive no response from the provider, or we do not reverse our initial disapproval of the provider’s revised count submission, the fee payment must be based on the number of subscribers listed initially in Fee Filer.  Once the timeframe for revision has passed, the telephone number counts are final and are the basis upon which CMRS regulatory fees are to be paid.  Providers can view their final telephone counts online in Fee Filer.  A final CMRS assessment letter will not be mailed out.
83. Because some carriers do not file the NRUF report, they may not see their telephone number counts in Fee Filer.  In these instances, the carriers should compute their fee payment using the standard methodology that is currently in place for CMRS Wireless services (i.e., compute their telephone number counts as of December 31, 2019), and submit their fee payment accordingly.  Whether a carrier reviews its telephone number counts in Fee Filer or not, the Commission reserves the right to audit the number of telephone numbers for which regulatory fees are paid.  In the event that the Commission determines that the number of telephone numbers that are paid is inaccurate, the Commission will bill the carrier for the difference between what was paid and what should have been paid.
84. Congressional Review Act.— The Commission will submit this draft Report and Order and Notice of Proposed Rulemaking to the Administrator of the Office of Information and Regulatory Affairs, Office of Management and Budget, for concurrence as to whether this rule is “major” or “non-major” under the Congressional Review Act, 5 U.S.C. § 804(2).  The Commission will send a copy of this Report and Order and Notice of Proposed Rulemaking to Congress and the Government Accountability Office pursuant to 5 U.S.C. § 801(a)(1)(A).
85. Initial Regulatory Flexibility Analysis.  An initial regulatory flexibility analysis (IRFA) is contained in Appendix J.  Comments to the IRFA must be identified as responses to the IRFA and filed by the deadlines for comments on the Notice of Proposed Rulemaking.  The Commission will send a copy of the Notice of Proposed Rulemaking, including the IRFA, to the Chief Counsel for Advocacy of the Small Business Administration.
86. Initial Paperwork Reductions Act of 1995 Analysis. This document does not contain new or modified information collection requirements subject to the Paperwork Reduction Act of 1995 (PRA), Public Law 104-13.  In addition, therefore, it does not contain any new or modified information collection burden for small business concerns with fewer than 25 employees, pursuant to the Small Business Paperwork Relief Act of 2002, Public Law 107-198, see 44 U.S.C. § 3506(c)(4).
87. Filing Instructions.  Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419, interested parties may file comments and reply comments on or before the dates indicated on the first page of this document.  Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS).  See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
· Electronic Filers:  Comments may be filed electronically using the Internet by accessing the ECFS:  http://apps.fcc.gov/ecfs/.
§ Paper Filers:  Parties who choose to file by paper must file an original and one copy of each filing.  

§ Filings can be sent by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail.  All filings must be addressed to the Commission’s Secretary, Office of the Secretary, Federal Communications Commission.

§ Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9050 Junction Drive, Annapolis Junction, MD 20701.

§ U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street, SW, Washington DC 20554.

§ Effective March 19, 2020, and until further notice, the Commission no longer accepts any hand or messenger delivered filings.  This is a temporary measure taken to help protect the health and safety of individuals, and to mitigate the transmission of COVID-19.  See FCC Announces Closure of FCC Headquarters Open Window and Change in Hand-Delivery Policy, Public Notice, DA 20-304 (March 19, 2020), https://www.fcc.gov/document/fcc-closes-headquarters-open-window-and-changes-hand-delivery-policy.

§ During the time the Commission’s building is closed to the general public and until further notice, if more than one docket or rulemaking number appears in the caption of a proceeding, paper filers need not submit two additional copies for each additional docket or rulemaking number; an original and one copy are sufficient. 
88. People with Disabilities:  To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
89. Ex Parte Information.  This proceeding shall be treated as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules. 47 CFR §§ 1.1200 et seq.
  Persons making ex parte presentations must file a copy of any written presentation or a memorandum summarizing any oral presentation within two business days after the presentation (unless a different deadline applicable to the Sunshine period applies).  Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all persons attending or otherwise participating in the meeting at which the ex parte presentation was made, and (2) summarize all data presented and arguments made during the presentation.  If the presentation consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s written comments, memoranda, or other filings in the proceeding, the presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them in the memorandum.  Documents shown or given to Commission staff during ex parte meetings are deemed to be written ex parte presentations and must be filed consistent with section 1.1206(b) of the Commission’s rules.  In proceedings governed by section 1.49(f) of the Commission’s rules or for which the Commission has made available a method of electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf).  Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules.
VI. ORDERING CLAUSES
90. Accordingly, IT IS ORDERED that, pursuant to the authority found in sections 4(i) and (j), 9, 9A, and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 154(j), 159, 159A, and 303(r), this Report and Order and Notice of Proposed Rulemaking IS HEREBY ADOPTED.
91. IT IS FURTHER ORDERED that the Report and Order SHALL BE EFFECTIVE 30 days after publication in the Federal Register.
92. IT IS FURTHER ORDERED that the amendment adopted in section III A shall be effective 90 days after notice to Congress, pursuant to section 159A(b) of the Communications Act of 1934, as amended, 47 U.S.C. § 159A(b),
93. IT IS FURTHER ORDERED that the Commission’s Consumer and Governmental Affairs Bureau, Reference Information Center, SHALL SEND a copy of this Report and Order, including the Final Regulatory Flexibility Analysis in Appendix I, to Congress and the Government Accountability Office pursuant to 5 U.S.C. § 801(a)(1)(A).

																			FEDERAL COMMUNICATIONS COMMISSION




						Marlene H. Dortch
						Secretary
44
APPENDIX A

List of Commenters

Commenter
Abbreviated name
North American Submarine Cable Association
NASCA
National Association of Broadcasters
NAB
Intelsat License LLC
Intelsat
WorldVu Satellites Ltd.
OneWeb
MMTC and NABOB
MMTC & NABOB
EchoStar Satellite Services, LLC; Hughes Network Systems, LLC, Intelsat License LLC, Space Exploration Technologies Corp.

U.S. Satellite Licensees
Eutelsat S.A.
Eutelsat
Satellite Industry Association
SIA
Telesat Canada
Telesat
Space Exploration Technologies Corp.
SpaceX
SES Americom, Inc.; Intelsat License LLC, EchoStar Satellite Services LLC, Hughes Network Systems LLC

Satellite Operators
America-CV Station Group, Inc., Spanish Broadcasting System Holding Company, Inc., Televicentro of Puerto Rico LLC

Puerto Rico Television Broadcasters
Myriota Pty. Ltd
Myriota
CenturyLink
CenturyLink
PMCM TV LLC
PMCM
Maranatha Broadcasting Company, Inc.
MBC


List of Reply Commenters


Reply Commenter
Abbreviated name
Kepler Communications
Kepler
Inmarset, Inc.
Inmarset
Maranatha Broadcasting Company
MBC
EchoStar Satellite Services, LLC; Hughes Network Systems, LLC, Intelsat License LLC, Space Exploration Technologies Corp.

U.S. Satellite Licensees
Century Link
CenturyLink
AT&T Services, Inc.
AT&T
Satellite Industry Association
SIA
Space Exploration Technologies Corp.
SpaceX
Telesat Canada
Telesat
WorldVu Satellites Ltd.
OneWeb
SES Americom, Inc.; Intelsat License, LLC; EchoStar Satellite Services, LLC; Hughes Network Systems, LLC

Satellite Operators


APPENDIX B

Calculation of FY 2020 Revenue Requirements and Pro-Rata Fees 

Regulatory fees for the categories shaded in gray are collected by the Commission in advance to cover the term of the license and are submitted at the time the application is filed.  
Fee Category
FY 2020 Payment Units

Yrs
FY 2019 Revenue Estimate
Pro-Rated FY 2020 Revenue Require-ment
Computed FY 2020 Regulatory Fee
 Rounded 
FY 2020 
Reg. Fee
Expected
FY 2020
Revenue
PLMRS (Exclusive Use) 
750
10 
112,500
187,500
25.00
25
187,500
PLMRS (Shared use)
11,700
10
1,240,000
1,170,000
10.00
10
1,170,000
Microwave
12,600
10 
2,500,000
3,150,000
25.00
25
3,150,000
Marine (Ship)
7,100 
10 
1,065,000
1,065,000
15.00
15
1,065,000
Aviation (Aircraft)
5,500 
10 
450,000
550,000
10.00
10
550,000
Marine (Coast)
90 
10 
24,000
36,000
40.00
40
36,000
Aviation (Ground)
1,100 
10 
220,000
220,000
20.00
20
220,000
AM Class A1
62
1
285,200
296,501
4,782
4,775
296,050
AM Class B1
1,458
1
3,541,950
3,678,692
2,523
2,525
3,681,450
AM Class C1
819
1
1,266,000
1,317,039
1,608
1,600
1,310,400
AM Class D1
1,372
1
4,200,800
4,351,447
3,172
3,175
4,356,100
FM Classes A, B1 & C31
2,973
1
8,823,375
9,156,345
3,080
3,075
9,141,975
FM Classes B, C, C0, C1 & C21
2,952
1
10,833,000
11,216,626
3,800
3,800
11,217,600
AM Construction Permits 2
6 
1 
1,785
3,720
620.1
620
3,720
FM Construction Permits2
60 
1 
67,000
64,500
1,075
1,075
64,500
Digital Television5
(including Satellite TV) 
3.25 billion population
1
24,294,675
25,473,855
.00783665
.007837
25,473,855
Digital TV Construction Permits2
3 
1 
13,350
14,850
4,950
4,950
14,850
LPTV/Translators/ Boosters/Class A TV
5,340 
1 
1,621,500
1,684,648
315.5
315
1,682,100
CARS Stations
160 
1 
202,125
208,683
1,304
1,300
208,000
Cable TV Systems, including IPTV 
55,500,000 
1 
49,020,000
49,207,472
.887
.89
49,395,000
Direct Broadcast Satellite (DBS)
27,800,000
1
18,000,000
20,117,050
.724
.72
20,116,000
Interstate Telecommunication Service Providers
$30,700,000,000
1 
102,708,000
98,504,384
0.003209
0.00321
98,547,000
Toll Free Numbers
33,000,000
1
3,960,000
3,975,316
0.1205
0.12
3,960,000
CMRS Mobile Services (Cellular/Public Mobile)
425,000,000 
1 
79,990,000
72,127,369
0.1697
0.17
72,250,000
CMRS Messaging Services
1,900,000 
1 
152,000
152,000
0.0800
0.080
152,000
BRS/3
LMDS 

1,280
340

1
1 

869,400
96,600
716,800
190,400
560
560
560
560

716,800
190,400
Per Gbps circuit Int’l Bearer Circuits 
Terrestrial (Common & Non-Common) & Satellite (Common & Non-Common) 
10,700 
1 
900,240
436,293
40.8
41
438,700
Submarine Cable Providers (See chart at bottom of Appendix C)4
31.063
1 
6,363,741
8,280,414
266,573
266,575
8,280,486
Earth Stations 
3,000 
1 
1,402,500
1,678,050
559
560
1,680,000
Space Stations (Geostationary) 
179
1 
15,643,250
16,092,194
89,901
89,900
16,092,100
Space Stations (Non-Geostationary) 

14
1

1,084,125
4,023,049
287,361
287,350
4,022,900
******  Total Estimated Revenue to be Collected


340,929,616
338,686,759



338,911,046
******  Total Revenue Requirement


339,000,000
339,000,000


339,000,000
                   Difference


1,929,616
(313,241)


(88,954)

Notes on Appendix B

1 The fee amounts listed in the column entitled “Rounded New FY 2020 Regulatory Fee” constitute a weighted average broadcast regulatory fee by class of service.  The actual FY 2020 regulatory fees for AM/FM radio station are listed on a grid located at the end of Appendix C.

2 The AM and FM Construction Permit revenues and the Digital (VHF/UHF) Construction Permit revenues were adjusted, respectively, to set the regulatory fee to an amount no higher than the lowest licensed fee for that class of service.  Reductions in the Digital (VHF/UHF) Construction Permit revenues, and in the AM and FM Construction Permit revenues, were offset by increases in the revenue totals for Digital television stations by market size, and in the AM and FM radio stations by class size and population served, respectively. 
3 The MDS/MMDS category was renamed Broadband Radio Service (BRS).  See Amendment of Parts 1, 21, 73, 74 and 101 of the Commission’s Rules to Facilitate the Provision of Fixed and Mobile Broadband Access, Educational and Other Advanced Services in the 2150-2162 and 2500-2690 MHz Bands, Report & Order and Further Notice of Proposed Rulemaking, 19 FCC Rcd 14165, 14169, para. 6 (2004).
4 The chart at the end of Appendix C lists the submarine cable bearer circuit regulatory fees (common and non-common carrier basis) that resulted from the adoption of the Assessment and Collection of Regulatory Fees for Fiscal Year 2008, Report and Order and Further Notice of Proposed Rulemaking, 24 FCC Rcd 6388 (2008) and Assessment and Collection of Regulatory Fees for Fiscal Year 2008, Second Report and Order, 24 FCC Rcd 4208 (2009).  The Submarine Cable fee in Appendix B is a weighted average of the various fee payers in the chart at the end of Appendix C. 
5 The actual digital television regulatory fees to be paid by call sign are identified in Appendix G.  
   

APPENDIX C

Regulatory Fees
FY 2020

Regulatory fees for the categories shaded in gray are collected by the Commission in advance to cover the term of the license and are submitted at the time the application is filed.
			

Fee Category

Annual Regulatory Fee
(U.S. $s)
PLMRS (per license) (Exclusive Use) (47 CFR part 90)
25
Microwave (per license) (47 CFR part 101)	
25
Marine (Ship) (per station) (47 CFR part 80)
15
Marine (Coast) (per license) (47 CFR part 80)
40
Rural Radio (47 CFR part 22) (previously listed under the Land Mobile category)
10
PLMRS (Shared Use) (per license) (47 CFR part 90)
10
Aviation (Aircraft) (per station) (47 CFR part 87)			
10
Aviation (Ground) (per license) (47 CFR part 87)	
20
CMRS Mobile/Cellular Services (per unit) (47 CFR parts 20, 22, 24, 27, 80 and 90)
.17
CMRS Messaging Services (per unit) (47 CFR parts 20, 22, 24 and 90)
.08
Broadband Radio Service (formerly MMDS/ MDS) (per license) (47 CFR part 27)
Local Multipoint Distribution Service (per call sign) (47 CFR, part 101)

560

560
AM Radio Construction Permits
620
FM Radio Construction Permits
1,075
AM and FM Broadcast Radio Station Fees
See Table Below
Digital TV (47 CFR part 73) VHF and UHF Commercial Fee Factor
$.007837
See Appendix. G for fee amounts due, also available at
https://www.fcc.gov/licensing-databases/fees/regulatory-fees
	Digital TV Construction Permits
4,950
Low Power TV, Class A TV, TV/FM Translators & Boosters (47 CFR
 part 74)
315
CARS (47 CFR part 78)	
1,300
Cable Television Systems (per subscriber) (47 CFR part 76), Including IPTV
.89
Direct Broadcast Service (DBS) (per subscriber) (as defined by section 602(13) of the Act)
.72
Interstate Telecommunication Service Providers (per revenue dollar)
.00321
Toll Free (per toll free subscriber) (47 CFR section 52.101 (f) of the rules)
.12
Earth Stations (47 CFR part 25)
560
Space Stations (per operational station in geostationary orbit) (47 CFR part 25) also includes DBS Service (per operational station) (47 CFR part 100)

89,900
Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25)
287,350
International Bearer Circuits - Terrestrial/Satellites (per Gbps circuit)
$41
Submarine Cable Landing Licenses Fee (per cable system) 
See Table Below

FY 2020 RADIO STATION REGULATORY FEES
Population 
Served
AM Class A
AM Class B
AM Class C
AM Class D
FM Classes
A, B1 & C3
FM Classes
B, C, C0, C1 & C2
<=25,000
$1,000
$715
$620
$680
$1,075
$1,250
25,001 – 75,000
$1,500
$1,000
$930
$1,000
$1,625
$1,875
75,001 – 150,000
$2,250
$1,600
$1,400
$1,525
$2,425
$2,825
150,001 – 500,000
$3,375
$2,425
$2,100
$2,300
$3,625
$4,225
500,001 – 1,200,000
$5,050
$3,625
$3,125
$3,450
$5,450
$6,325
1,200,001 – 3,000,000
$7,600
$5,425
$4,700
$5,175
$8,175
$9,500
3,000,001 – 6,000,000
$11,400
$8,150
$7,050
$7,750
$12,250
$14,250
>6,000,000
$17,100
$12,225
$10,600
$11,625
$18,375
$21,375


FY 2020 International Bearer Circuits - Submarine Cable Systems

Submarine Cable Systems
(capacity as of December 31, 2019)
FY 2020 Regulatory Fees
Less than 30 Gbps
$1,000
30 Gbps or greater, but less than 250 Gbps
$18,450
250 Gbps or greater, but less than 1,000 Gbps
$36,875
1,000 Gbps or greater, but less than 2,000 Gbps
$73,750
2,000 Gbps or greater, but less than 3,500 Gbps
$147,500
3,500 Gbps or greater, but less than 6,500 Gbps
$295,000
6,500 Gbps or greater
$590,000







APPENDIX D

Sources of Payment Unit Estimates for FY 2020

In order to calculate individual service fees for FY 2020, we adjusted FY 2020 payment units for each service to more accurately reflect expected FY 2020 payment liabilities.  We obtained our updated estimates through a variety of means and sources. For example, we used Commission licensee data bases, actual prior year payment records and industry and trade association projections, when available.  The databases we consulted include our Universal Licensing System (ULS), International Bureau Filing System (IBFS), Consolidated Database System (CDBS), Licensing and Management System (LMS) and Cable Operations and Licensing System (COALS), as well as reports generated within the Commission such as the Wireless Telecommunications Bureau’s Numbering Resource Utilization Forecast.  Regulatory fee payment units are not all the same for all fee categories.  For most fee categories, the term “units” reflect licenses or permits that have been issued, but for other fee categories, the term “units” reflect quantities such as subscribers, population counts, circuit counts, telephone numbers, and revenues.

We sought verification for these estimates from multiple sources and, in all cases, we compared FY 2020 estimates with actual FY 2019 payment units to ensure that our revised estimates were reasonable.  Where appropriate, we adjusted and/or rounded our final estimates to take into consideration the fact that certain variables that impact on the number of payment units cannot yet be estimated with sufficient accuracy.  These include an unknown number of waivers and/or exemptions that may occur in FY 2020 and the fact that, in many services, the number of actual licensees or station operators fluctuates from time to time due to economic, technical, or other reasons.  When we note, for example, that our estimated FY 2020 payment units are based on FY 2019 actual payment units, it does not necessarily mean that our FY 2020 projection is exactly the same number as in FY 2019.  We have either rounded the FY 2019 number or adjusted it slightly to account for these variables.
 
FEE CATEGORY
SOURCES OF PAYMENT UNIT ESTIMATES
Land Mobile (All), Microwave, Marine (Ship & Coast), Aviation (Aircraft & Ground), Domestic Public Fixed 
Based on Wireless Telecommunications Bureau (WTB) projections of new applications and renewals taking into consideration existing Commission licensee data bases. Aviation (Aircraft) and Marine (Ship) estimates have been adjusted to take into consideration the licensing of portions of these services on a voluntary basis.
CMRS Cellular/Mobile Services 
Based on WTB projection reports, and FY 2019 payment data. 
CMRS Messaging Services
Based on WTB reports, and FY 2019 payment data.  
AM/FM Radio Stations
Based on CDBS data, adjusted for exemptions, and actual FY 2019 payment units.
Digital TV Stations (Combined VHF/UHF units)
Based on LMS data, fee rate adjusted for exemptions, and population figures are calculated based on individual station parameters.
AM/FM/TV Construction Permits
Based on CDBS data, adjusted for exemptions, and actual FY 2019 payment units. 
LPTV, Translators and Boosters, Class A Television
Based on LMS data, adjusted for exemptions, and actual FY 2019 payment units.
BRS (formerly MDS/MMDS)LMDS
Based on WTB reports and actual FY 2019 payment units.  Based on WTB reports and actual FY 2019 payment units.
Cable Television Relay Service (CARS) Stations
Based on data from Media Bureau’s COALS database and actual FY 2019 payment units.
Cable Television System Subscribers, Including IPTV Subscribers
Based on publicly available data sources for estimated subscriber counts and actual FY 2019 payment units. 
Interstate Telecommunication Service Providers
Based on FCC Form 499-Q data for the four quarters of calendar year 2019, the Wireline Competition Bureau projected the amount of calendar year 2019 revenue that will be reported on the 2020 FCC Form 499-A worksheets due in April 2020.
Earth Stations
Based on International Bureau licensing data and actual FY 2019 payment units.
Space Stations (GSOs & NGSOs)
Based on International Bureau data reports and actual FY 2019 payment units.
International Bearer Circuits
Based on International Bureau reports and submissions by licensees, adjusted as necessary, and actual FY 2019 payment units.
Submarine Cable Licenses
Based on International Bureau license information, and actual FY 2019 payment units.

	Federal Communications Commission	FCC 20-64

APPENDIX E

Factors, Measurements, and Calculations that Determine Station Signal Contours and Associated Population Coverages

AM Stations

For stations with nondirectional daytime antennas, the theoretical radiation was used at all azimuths.  For stations with directional daytime antennas, specific information on each day tower, including field ratio, phase, spacing, and orientation was retrieved, as well as the theoretical pattern root-mean-square of the radiation in all directions in the horizontal plane (RMS) figure (milliVolt per meter (mV/m) @ 1 km) for the antenna system.  The standard, or augmented standard if pertinent, horizontal plane radiation pattern was calculated using techniques and methods specified in sections 73.150 and 73.152 of the Commission’s rules. Radiation values were calculated for each of 360 radials around the transmitter site.  Next, estimated soil conductivity data was retrieved from a database representing the information in FCC Figure R3. Using the calculated horizontal radiation values, and the retrieved soil conductivity data, the distance to the principal community (5 mV/m) contour was predicted for each of the 360 radials.  The resulting distance to principal community contours were used to form a geographical polygon.  Population counting was accomplished by determining which 2010 block centroids were contained in the polygon.  (A block centroid is the center point of a small area containing population as computed by the U.S. Census Bureau.)  The sum of the population figures for all enclosed blocks represents the total population for the predicted principal community coverage area.

	FM Stations

The greater of the horizontal or vertical effective radiated power (ERP) (kW) and respective height above average terrain (HAAT) (m) combination was used.  Where the antenna height above mean sea level (HAMSL) was available, it was used in lieu of the average HAAT figure to calculate specific HAAT figures for each of 360 radials under study.  Any available directional pattern information was applied as well, to produce a radial-specific ERP figure.  The HAAT and ERP figures were used in conjunction with the Field Strength (50-50) propagation curves specified in 47 CFR § 73.313 of the Commission’s rules to predict the distance to the principal community (70 dBu (decibel above 1 microVolt per meter) or 3.17 mV/m) contour for each of the 360 radials.  The resulting distance to principal community contours were used to form a geographical polygon.  Population counting was accomplished by determining which 2010 block centroids were contained in the polygon.  The sum of the population figures for all enclosed blocks represents the total population for the predicted principal community coverage area. 

APPENDIX F
Space Station Satellite Charts for FY 2020 Regulatory Fees

GSO vs. NGSO IBFS Applications (Received and Disposed)  2017-2019
RECEIVED
2019
2018
2017
GSO
124
77
128*
NGSO
33
15
39
GSO/NGSO split
79%/21%
84%/16%
77%/23%

DISPOSED
2019
2018
2017
GSO
108
88
122
NGSO
28
29
24
GSO/NGSO Split
79%/21%
75%/25%
84%/16%

* includes 12 withdrawals pending for 3 days or less


Non-U.S. Licensed Space Stations – Market Access Through Petition for Declaratory Ruling (PDR)
 
 
SATELLITE
SATELLITE
LICENSEE
CALL SIGN
COMMON NAME
TYPE
DBSD Services Ltd
S2651
ICO G1
GSO
Empresa Argentina De Soluciones Satelitales S.A.
S2956
ARSAT-2
GSO
ES 172 LLC
S3021
EUTELSAT 172B
GSO
European Telecommunications Satellite Organization
S2595
Atlantic Bird 1
GSO
European Telecommunications Satellite Organization
S2596
Atlantic Bird 2
GSO
European Telecommunications Satellite Organization
S2702
Eutelsat II-F2
GSO
Gamma Acquisition L.L.C.
S2633
TerreStar 1
GSO
Hispasati, S.A.
S2969
HISPASAT 30W-6
GSO
Hispasati, S.A.
S2476
HISPASAT-1D et al.
GSO
Horizons Satellite LLC
S2475
Galaxy 13
GSO
Horizons-1 Satellite LLC
S2970/S3049
HORIZONS-1 
GSO
Horizons-3 License LLC
S2947
Horizons 3e
GSO
Hughes Network Systems, LLC
S2753
SPACEWAY 4
GSO
Hughes Network Systems, LLC
S2834
Jupiter 2/EchoStar 1
GSO
Inmarsat PLC
S2780
I2F1
GSO
Inmarsat PLC
S2783
Inmarsat 3F4
GSO
Inmarsat PLC
S2932
Inmarsat-4 F3
GSO
Inmarsat PLC
S2949
Inmarsat-3 F5
GSO
Intelsat License LLC
S2592/S2868
Galaxy 23
GSO
Intelsat North America LLC
S2592
Intelsat Americas 13
GSO
Jansky-Barmet Telecommunications Inc.
S2793
AMAZONAS-2
GSO
New Skies Satellites B.V.
S2756
NSS-9
GSO
New Skies Satellites B.V.
S2870
SES-6
GSO
New Skies Satellites B.V.
S3048
NSS-6
GSO
New Skies Satellites B.V.
S2463
NSS-7
GSO
New Skies Satellites B.V.
S2828
SES-4
GSO
New Skies Satellites B.V.
S2950
SES-10
GSO
O3B Ltd.
S2935
O3B
NGSO
Satelites Mexicanos, S.A. DE C.V.
S2695
SATMEX 6
GSO
Satelites Mexicanos, S.A. DE C.V.
S2926
E117WB
GSO
Satelites Mexicanos, S.A. DE C.V.
S2938
EUTELSAT WEST 115 B
GSO
Satelites Mexicanos, S.A. DE C.V.
S2873
Satmex 8 et al.
GSO
SES Americom, INC.
S2676
AMC 21
GSO
SES Americom, INC.
S3037
NSS-11
GSO
SES Americom, INC.
S2964
SES-11
GSO
SES DTH do Brasil Ltda
S2974
SES-14
GSO
SES Satellites (GIBRALTAR) Ltd.
S2951
SES-15
GSO
Skynet Satellite Corp
S2462
Telstar 12
GSO
Space Communications Corp
S2685
Superbird-B2
GSO
Space Communications Corp
S2639
SUPERBIRD-C
GSO
Space Norway AS
S2978
ASBM
NGSO
Spectrum Five LLC
S2777
BSSNET119W
GSO
Star One S.A.
S2677
STAR ONE C1
GSO
Star One S.A.
S2678
STAR ONE C2
GSO
Star One S.A.
S2845
STAR ONE C3
GSO
Telesat Brasil Capacidade De Satelites Ltda.
S2821
ESTRELA DO SUL 2
GSO
Telesat Canada
S2597
Anik E2
GSO
Telesat Canada
S2674
ANIK F1R
GSO
Telesat Canada
S2745
ANIK F1
GSO
Telesat Canada
S2703
ANIK F3
GSO
Telesat Canada
S2646
ANIK F2
GSO
Telesat International Ltd.
S2955
TELSTAR 19 VANTAGE
GSO
Viasat, INC.
S2747
VIASAT-IOM
GSO
Viasat, INC.
S2902
VIASAT-2
GSO
Viasat, INC.
S2952
VIASAT-79W
GSO
Viasat, INC.
S2953
VIASAT-109W
GSO
WorldVu Satellites Ltd.
S2963
ONEWEB
NGSO


Non-U.S. Space Stations - Market Access Through Earth Stations
ITU Name
Common Name
Call Sign
GSO/NGSO
ANIK G1
ANIK G1
M090164
GSO
APSTAR 6C
APSTAR 6C(M161190)
M161190
GSO
APSTAR 6D
APSTAR 6D(M246190)
M246190
GSO
Apstar 7
Apstar 7
M090165
GSO
APSTAR VI
APSTAR 6(M292090)
M292090
GSO
AsiaSat 5
AsiaSat 5
M090163
GSO
AsiaSat 7
AsiaSat 7
M174161
GSO
AsiaSat-9
AsiaSat-9
M161191
GSO
AUSSAT B 152E
OPTUS D2
M221170
GSO
CAN-BSS3 and CAN-BSS
ECHOSTAR 23
SM1987
GSO
Chinasat 10
Chinasat 10(M246191)
M246191
GSO
Ciel Satellite Group
Ciel-2
E050029
GSO
ECHOSTAR 23
ECHOSTAR 23
SM2975
GSO
ECHOSTAR 8 (MEX)
ECHOSTAR 8
NUS1108
GSO
Eutelsat 10A
Eutelsat 10A (W2A)
M0311
GSO
Eutelsat 65 West A
Eutelsat 65 West A
E160081
GSO
Eutelsat 70B
Eutelsat 70B
M090167
GSO
exactEarth
exactEarth-7
E160028
NGSO
JCSAT- 5A
JCSAT 5A
M063130
GSO
JCSAT-2B
JCSAT-2B
M174163
GSO
QUETZSAT-1(MEX)
QUETZSAT-1
NUS1101
GSO
Superbird C2
Superbird C2
M334100
GSO
TELSTAR 18
TELSTAR 18
None
GSO
Yamal 300K
Yamal 300K
M174162
GSO
Yamal 401
Yamal 401
M001166
GSO



101
APPENDIX G

FY 2020 Full-Service Broadcast Television Stations by Call Sign


Facility Id. #
Call Sign
Service Area Population
Terrain-Ltd Population
FY 2020 Terrain-Ltd. Fee Amount
3246
KAAH-TV
             955,391 
               879,906 
$6,896
18285
KAAL
             589,502 
               568,169 
$4,453
11912
KAAS-TV
             220,262 
               219,922 
$1,724
56528
KABB
          2,474,296 
            2,456,689 
$19,253
282
KABC-TV*
        17,540,791 
          16,957,292 
$132,894
1236
KACV-TV
             372,627 
               372,330 
$2,918
33261
KADN-TV
             877,965 
               877,965 
$6,881
8263
KAEF-TV
             138,085 
               122,808 
$962
2728
KAET
          4,217,217 
            4,184,386 
$32,793
2767
KAFT
          1,204,376 
            1,122,928 
$8,800
62442
KAID
             711,035 
               702,721 
$5,507
4145
KAII-TV
             188,810 
               165,396 
$1,296
67494
KAIL
          1,967,744 
            1,948,341 
$15,269
13988
KAIT
             861,149 
               845,812 
$6,629
40517
KAJB
             383,886 
               383,195 
$3,003
65522
KAKE
             803,937 
               799,254 
$6,264
804
KAKM
             380,240 
               379,105 
$2,971
148
KAKW-DT
          2,615,956 
            2,531,813 
$19,842
51598
KALB-TV
             943,307 
               942,043 
$7,383
51241
KALO
             948,683 
               844,503 
$6,618
40820
KAMC
             391,526 
               391,502 
$3,068
8523
KAMR-TV
             366,476 
               366,335 
$2,871
65301
KAMU-TV
             346,892 
               342,455 
$2,684
2506
KAPP
             319,797 
               283,944 
$2,225
3658
KARD
             703,234 
               700,887 
$5,493
23079
KARE
          3,924,944 
            3,907,483 
$30,623
33440
KARK-TV
          1,212,038 
            1,196,196 
$9,375
37005
KARZ-TV
          1,066,386 
            1,050,270 
$8,231
32311
KASA-TV
          1,161,789 
            1,119,108 
$8,770
41212
KASN
          1,175,627 
            1,159,721 
$9,089
7143
KASW
          4,174,437 
            4,160,497 
$32,606
55049
KASY-TV
          1,144,839 
            1,099,825 
$8,619
33471
KATC
          1,348,897 
            1,348,897 
$10,571
13813
KATN
               97,466 
                 97,128 
$761
21649
KATU
          2,978,043 
            2,845,632 
$22,301
33543
KATV
          1,257,777 
            1,234,933 
$9,678
50182
KAUT-TV
          1,637,333 
            1,636,330 
$12,824
6864
KAUZ-TV
             381,671 
               379,435 
$2,974
73101
KAVU-TV
             320,484 
               320,363 
$2,511
49579
KAWB
             186,919 
               186,845 
$1,464
49578
KAWE
             136,033 
               133,937 
$1,050
58684
KAYU-TV
             809,464 
               750,766 
$5,884
29234
KAZA-TV
        14,973,535 
          13,810,130 
$108,230
17433
KAZD
          6,747,915 
            6,744,517 
$52,857
1151
KAZQ
          1,097,010 
            1,084,327 
$8,498
35811
KAZT-TV
             436,925 
               359,273 
$2,816
4148
KBAK-TV
          1,510,400 
            1,263,910 
$9,905
16940
KBCA
             479,260 
               479,219 
$3,756
53586
KBCB
          1,256,193 
            1,223,883 
$9,592
69619
KBCW
          8,020,424 
            6,962,363 
$54,564
22685
KBDI-TV*
          4,042,177 
            3,683,394 
$28,867
56384
KBEH*
        17,736,497 
          17,695,306 
$138,678
65395
KBFD-DT
             953,207 
               834,341 
$6,539
169030
KBGS-TV
             159,269 
               156,802 
$1,229
61068
KBHE-TV
             140,860 
               133,082 
$1,043
48556
KBIM-TV
             205,701 
               205,647 
$1,612
29108
KBIN-TV
             912,921 
               911,725 
$7,145
33658
KBJR-TV
             275,585 
               271,298 
$2,126
83306
KBLN-TV
             297,384 
               134,927 
$1,057
63768
KBLR
          1,964,979 
            1,915,859 
$15,015
53324
KBME-TV
             123,571 
               123,485 
$968
10150
KBMT
             743,009 
               742,369 
$5,818
22121
KBMY
             119,993 
               119,908 
$940
49760
KBOI-TV*
             715,191
               708,374 
$5,552
55370
KBRR
             149,869 
               149,868 
$1,175
66414
KBSD-DT
             155,012 
               154,891 
$1,214
66415
KBSH-DT
             102,781 
               100,433 
$787
19593
KBSI
             752,366 
               751,025 
$5,886
66416
KBSL-DT
               49,814 
                 48,483 
$380
4939
KBSV
          1,352,166 
            1,262,708 
$9,896
62469
KBTC-TV
          3,697,981 
            3,621,965 
$28,385
61214
KBTV-TV
             734,008 
               734,008 
$5,752
6669
KBTX-TV
          4,048,516 
            4,047,275 
$31,718
35909
KBVO
          1,498,015 
            1,312,360 
$10,285
58618
KBVU
             135,249 
               120,827 
$947
6823
KBYU-TV
          2,389,548 
            2,209,060 
$17,312
33756
KBZK
             116,485 
               106,020 
$831
21422
KCAL-TV*
        17,499,483 
          16,889,157 
$132,360
11265
KCAU-TV*
             714,315 
               706,224 
$5,535
14867
KCBA
          3,094,778 
            2,278,552 
$17,857
27507
KCBD
             414,804 
               414,091 
$3,245
9628
KCBS-TV
        17,853,152 
          16,656,778 
$130,539
49750
KCBY-TV
               89,156 
                 73,211 
$574
33710
KCCI
          1,102,130 
            1,095,326 
$8,584
9640
KCCW-TV
             284,280 
               276,935 
$2,170
63158
KCDO-TV
          2,798,103 
            2,650,225 
$20,770
62424
KCDT
             694,584 
               638,366 
$5,003
83913
KCEB
          1,163,228 
            1,159,665 
$9,088
57219
KCEC
          3,874,159 
            3,654,445 
$28,640
10245
KCEN-TV
          1,795,767 
            1,757,018 
$13,770
13058
KCET
        16,875,019 
          15,402,588 
$120,710
18079
KCFW-TV
             148,162 
               129,122 
$1,012
132606
KCGE-DT
             123,930 
               123,930 
$971
60793
KCHF
          1,118,671 
            1,085,205 
$8,505
33722
KCIT
             382,477 
               381,818 
$2,992
62468
KCKA
             953,680 
               804,362 
$6,304
41969
KCLO-TV
             138,413 
               132,157 
$1,036
47903
KCNC-TV
          3,794,400 
            3,541,089 
$27,752
71586
KCNS
          8,048,427 
            7,069,903 
$55,407
33742
KCOP-TV*
        17,386,133 
          16,647,708 
$130,468
19117
KCOS
          1,014,396 
            1,014,205 
$7,948
63165
KCOY-TV
             664,655 
               459,468 
$3,601
86208
KCPM
               90,266 
                 90,266 
$707
33894
KCPQ
          4,439,875 
            4,311,994 
$33,793
53843
KCPT
          2,507,879 
            2,506,224 
$19,641
33875
KCRA-TV
        10,612,483 
            6,500,774 
$50,947
9719
KCRG-TV*
          1,136.762 
            1,107,130 
$8,677
60728
KCSD-TV
             273,553 
               273,447 
$2,143
59494
KCSG
             174,814 
               164,765 
$1,291
33749
KCTS-TV
          4,177,824 
            4,115,603 
$32,254
41230
KCTV
          2,547,456 
            2,545,645 
$19,950
58605
KCVU
             630,068 
               616,068 
$4,828
10036
KCWC-DT
               44,216 
                 39,439 
$309
64444
KCWE
          2,460,172 
            2,458,913 
$19,271
51502
KCWI-TV
          1,043,811 
            1,042,642 
$8,171
42008
KCWO-TV
               50,707 
                 50,685 
$397
166511
KCWV
             207,398 
               207,370 
$1,625
24316
KCWX*
          3,961,268
            3,954,787 
$30,994
68713
KCWY-DT
               79,948 
                 79,414 
$622
22201
KDAF
          6,648,507 
            6,645,226 
$52,079
33764
KDBC-TV
          1,015,564 
            1,015,162 
$7,956
79258
KDCK
               43,088 
                 43,067 
$338
166332
KDCU-DT
             796,251 
               795,504 
$6,234
38375
KDEN-TV
          3,376,799 
            3,351,182 
$26,263
17037
KDFI
          6,684,439 
            6,682,487 
$52,371
33770
KDFW
          6,658,976 
            6,656,502 
$52,167
29102
KDIN-TV
          1,088,376 
            1,083,845 
$8,494
25454
KDKA-TV
          3,611,796 
            3,450,690 
$27,043
60740
KDKF
               71,413 
                 64,567 
$506
4691
KDLH
             263,422 
               260,394 
$2,041
41975
KDLO-TV
             208,354 
               208,118 
$1,631
55379
KDLT-TV
             639,284 
               628,281 
$4,924
55375
KDLV-TV
               96,873 
                 96,620 
$757
25221
KDMD
             374,951 
               372,727 
$2,921
78915
KDMI
          1,141,990 
            1,140,939 
$8,942
56524
KDNL-TV
          2,987,219 
            2,982,311 
$23,372
24518
KDOC-TV*
        17,503,793 
          16,701,233 
$130,888
1005
KDOR-TV
          1,112,060 
            1,108,556 
$8,688
60736
KDRV
             519,706 
               440,002 
$3,448
61064
KDSD-TV
               64,314 
                 59,635 
$467
53329
KDSE
               42,896 
                 41,432 
$325
56527
KDSM-TV
          1,096,220 
            1,095,478 
$8,585
49326
KDTN
          6,602,327 
            6,600,186 
$51,726
83491
KDTP
               26,564 
                 24,469 
$192
33778
KDTV-DT
          7,921,124 
            6,576,672 
$51,541
67910
KDTX-TV
          6,680,738 
            6,679,424 
$52,347
126
KDVR
          3,430,717 
            3,394,796 
$26,605
18084
KECI-TV*
             211,745
               193,803 
$1,519
51208
KECY-TV
             399,372 
               394,379 
$3,091
58408
KEDT
             513,683 
               513,683 
$4,026
55435
KEET
             177,313 
               159,960 
$1,254
41983
KELO-TV
             705,364 
               646,126 
$5,064
34440
KEMO-TV
          8,048,427 
            7,069,903 
$55,407
2777
KEMV
             619,889 
               559,135 
$4,382
26304
KENS
          2,544,094 
            2,529,382 
$19,823
63845
KENV-DT
               47,220 
                 40,677 
$319
18338
KENW
               87,017 
                 87,017 
$682
50591
KEPB-TV
             576,964 
               523,655 
$4,104
56029
KEPR-TV
             453,259 
               433,260 
$3,395
49324
KERA-TV
          6,681,083 
            6,677,852 
$52,334
40878
KERO-TV
          1,285,357 
            1,164,979 
$9,130
61067
KESD-TV
             166,018 
               159,195 
$1,248
25577
KESQ-TV
          1,334,172 
               572,057 
$4,483
50205
KETA-TV
          1,702,441 
            1,688,227 
$13,231
62182
KETC
          2,913,924 
            2,911,313 
$22,816
37101
KETD
          3,098,889 
            3,058,327 
$23,968
2768
KETG
             426,883 
               409,511 
$3,209
12895
KETH-TV
          6,088,821 
            6,088,677 
$47,717
55643
KETK-TV
          1,031,567 
            1,030,122 
$8,073
2770
KETS
          1,185,111 
            1,166,796 
$9,144
53903
KETV
          1,355,714 
            1,350,740 
$10,586
92872
KETZ
             526,890 
               523,877 
$4,106
68853
KEYC-TV
             544,900 
               531,079 
$4,162
33691
KEYE-TV
          2,732,257 
            2,652,529 
$20,788
60637
KEYT-TV
          1,419,564 
            1,239,577 
$9,715
83715
KEYU
             339,348 
               339,302 
$2,659
34406
KEZI
          1,113,171 
            1,065,880 
$8,353
34412
KFBB-TV
               93,519 
                 91,964 
$721
125
KFCT
             795,114 
               788,747 
$6,181
51466
KFDA-TV
             385,064 
               383,977 
$3,009
22589
KFDM
             732,665 
               732,588 
$5,741
65370
KFDX-TV
             381,703 
               381,318 
$2,988
49264
KFFV
          3,783,380 
            3,717,323 
$29,133
12729
KFFX-TV
             409,952 
               403,692 
$3,164
83992
KFJX
             515,708 
               505,647 
$3,963
42122
KFMB-TV
          3,947,735 
            3,699,981 
$28,997
53321
KFME
             393,045 
               392,472 
$3,076
74256
KFNB
               80,382 
                 79,842 
$626
21613
KFNE
               54,988 
                 54,420 
$426
21612
KFNR
               10,988 
                 10,965 
$86
66222
KFOR-TV
          1,616,459 
            1,615,614 
$12,662
33716
KFOX-TV
          1,023,999 
            1,018,549 
$7,982
41517
KFPH-DT
             347,579 
               282,838 
$2,217
81509
KFPX-TV
             963,969 
               963,846 
$7,554
31597
KFQX
             186,473 
               163,637 
$1,282
59013
KFRE-TV
          1,721,275 
            1,705,484 
$13,366
51429
KFSF-DT
          7,348,828 
            6,528,430 
$51,163
66469
KFSM-TV
             906,728 
               884,919 
$6,935
8620
KFSN-TV
          1,836,607 
            1,819,585 
$14,260
29560
KFTA-TV
             818,859 
               809,173 
$6,341
83714
KFTC
               61,990 
                 61,953 
$486
60537
KFTH-DT
          6,080,688 
            6,080,373 
$47,652
60549
KFTR-DT
        17,560,679 
          16,305,726 
$127,788
61335
KFTS
               74,936 
                 65,126 
$510
81441
KFTU-DT
             113,876 
               109,731 
$860
34439
KFTV-DT
          1,807,731 
            1,793,418 
$14,055
36917
KFVE
             953,895 
               851,585 
$6,674
592
KFVS-TV
             810,574 
               782,713 
$6,134
29015
KFWD
          6,610,836 
            6,598,496 
$51,712
35336
KFXA
             875,538 
               874,070 
$6,850
17625
KFXB-TV
             373,280 
               368,466 
$2,888
70917
KFXK-TV
             934,043 
               931,791 
$7,302
84453
KFXL-TV
             361,632 
               361,097 
$2,830
41427
KFYR-TV
             130,881 
               128,301 
$1,005
25685
KGAN
          1,083,213 
            1,057,597 
$8,288
34457
KGBT-TV
          1,230,798 
            1,230,791 
$9,646
52593
KGBY
             270,089 
               218,544 
$1,713
7841
KGCW
             888,054 
               886,499 
$6,947
24485
KGEB
          1,186,225 
            1,150,201 
$9,014
34459
KGET-TV
             917,927 
               874,332 
$6,852
53320
KGFE
             114,564 
               114,564 
$898
7894
KGIN
             230,535 
               228,338 
$1,789
83945
KGLA-DT
          1,645,641 
            1,645,641 
$12,897
34445
KGMB
             953,398 
               851,088 
$6,670
23302
KGMC
          1,824,786 
            1,803,796 
$14,136
36914
KGMD-TV
               94,323 
                 93,879 
$736
36920
KGMV
             193,564 
               162,230 
$1,271
10061
KGNS-TV
             267,236 
               259,548 
$2,034
34470
KGO-TV
          8,283,429 
            7,623,657 
$59,747
56034
KGPE
          1,699,131 
            1,682,082 
$13,182
81694
KGPX-TV
             685,626 
               624,955 
$4,898
25511
KGTF
             161,885 
               160,568 
$1,258
40876
KGTV
          3,960,667 
            3,682,219 
$28,858
36918
KGUN-TV*
          1,398,527
            1,212,484 
$9,502
34874
KGW
          3,058,216 
            2,881,387 
$22,581
63177
KGWC-TV
               80,475 
                 80,009 
$627
63162
KGWL-TV
               38,125 
                 38,028 
$298
63166
KGWN-TV
             469,467 
               440,388 
$3,451
63170
KGWR-TV
               51,315 
                 50,957 
$399
4146
KHAW-TV
               95,204 
                 94,851 
$743
34846
KHBC-TV
               74,884 
                 74,884 
$587
60353
KHBS
             631,770 
               608,052 
$4,765
27300
KHCE-TV
          2,353,883 
            2,348,391 
$18,404
26431
KHET
             959,060 
               944,568 
$7,403
21160
KHGI-TV
             233,973 
               229,173 
$1,796
29085
KHIN
          1,041,244 
            1,039,383 
$8,146
17688
KHME
             181,345 
               179,706 
$1,408
47670
KHMT
             175,601 
               170,957 
$1,340
47987
KHNE-TV
             203,931 
               202,944 
$1,590
34867
KHNL
             953,398 
               851,088 
$6,670
60354
KHOG-TV
             765,360 
               702,984 
$5,509
4144
KHON-TV
             953,207 
               886,431 
$6,947
34529
KHOU*
          6,083,336 
            6,081,785 
$47,663
4690
KHQA-TV
             318,469 
               316,134 
$2,478
34537
KHQ-TV
             822,371 
               774,821 
$6,072
30601
KHRR
          1,227,847 
            1,166,890 
$9,145
34348
KHSD-TV
             188,735 
               185,202 
$1,451
24508
KHSL-TV
             625,904 
               608,850 
$4,772
69677
KHSV*
          2,059,794 
            2,020,045 
$15,831
64544
KHVO
               94,226 
                 93,657 
$734
23394
KIAH
          6,099,694 
            6,099,297 
$47,800
34564
KICU-TV
          8,233,041 
            7,174,316 
$56,225
56028
KIDK
             305,509 
               302,535 
$2,371
58560
KIDY
             116,614 
               116,596 
$914
53382
KIEM-TV
             174,390 
               160,801 
$1,260
66258
KIFI-TV*
             324,422 
               320,118 
$2,509
10188
KIII
             569,864 
               566,796 
$4,442
29095
KIIN
          1,365,215 
            1,335,707 
$10,468
34527
KIKU
             953,896 
               850,963 
$6,669
63865
KILM
        17,256,205 
          15,804,489 
$123,860
56033
KIMA-TV
             308,604 
               260,593 
$2,042
66402
KIMT
             654,083 
               643,384 
$5,042
67089
KINC
          2,002,066 
            1,920,903 
$15,054
34847
KING-TV
          4,063,674 
            4,018,832 
$31,496
51708
KINT-TV
          1,015,582 
            1,015,274 
$7,957
26249
KION-TV
          2,400,317 
               855,808 
$6,707
62427
KIPT
             171,405 
               170,455 
$1,336
66781
KIRO-TV
          4,058,846 
            4,027,262 
$31,562
62430
KISU-TV
             311,827 
               307,651 
$2,411
12896
KITU-TV
             712,362 
               712,362 
$5,583
64548
KITV
             953,207 
               839,906 
$6,582
59255
KIVI-TV
             710,819 
               702,619 
$5,506
47285
KIXE-TV*
             467,518
               428,118 
$3,355
13792
KJJC-TV
               82,749 
                 81,865 
$642
14000
KJLA
        17,929,100 
          16,794,896 
$131,622
20015
KJNP-TV
               98,403 
                 98,097 
$769
53315
KJRE
               16,187 
                 16,170 
$127
59439
KJRH-TV
          1,416,108 
            1,397,311 
$10,951
55364
KJRR
               45,515 
                 44,098 
$346
42640
KJRW
             137,375 
               126,743 
$993
7675
KJTL
             379,594 
               379,263 
$2,972
55031
KJTV-TV
             406,283 
               406,260 
$3,184
13814
KJUD
               31,229 
                 30,106 
$236
36607
KJZZ-TV
          2,388,054 
            2,204,525 
$17,277
83180
KKAI
             955,203 
               941,214 
$7,376
58267
KKAP
             957,786 
               923,172 
$7,235
24766
KKCO
             206,018 
               172,628 
$1,353
35097
KKJB
             629,939 
               624,784 
$4,896
22644
KKPX-TV
          7,902,064 
            6,849,907 
$53,683
35037
KKTV
          2,795,275 
            2,293,502 
$17,974
35042
KLAS-TV
          2,094,297 
            1,940,030 
$15,204
52907
KLAX-TV
             367,212 
               366,839 
$2,875
3660
KLBK-TV
             387,783 
               387,743 
$3,039
65523
KLBY
               34,288 
                 34,279 
$269
38430
KLCS
        16,875,019 
          15,402,588 
$120,710
77719
KLCW-TV
             381,889 
               381,816 
$2,992
51479
KLDO-TV
             250,832 
               250,832 
$1,966
37105
KLEI
             175,045 
               138,087 
$1,082
56032
KLEW-TV
             164,908 
               148,256 
$1,162
35059
KLFY-TV
          1,355,890 
            1,355,409 
$10,622
54011
KLJB
             960,055 
               947,716 
$7,427
11264
KLKN
             932,757 
               895,101 
$7,015
47975
KLNE-TV
             120,338 
               120,277 
$943
38590
KLPA-TV
             414,699 
               414,447 
$3,248
38588
KLPB-TV
             749,053 
               749,053 
$5,870
749
KLRN
          2,374,472 
            2,353,440 
$18,444
11951
KLRT-TV
          1,171,678 
            1,152,541 
$9,032
8564
KLRU
          2,614,658 
            2,575,518 
$20,184
8322
KLSR-TV
             564,415 
               508,157 
$3,982
31114
KLST
             199,067 
               169,551 
$1,329
24436
KLTJ
          6,034,131 
            6,033,867 
$47,287
38587
KLTL-TV
             423,574 
               423,574 
$3,320
38589
KLTM-TV
             694,280 
               688,915 
$5,399
38591
KLTS-TV
             883,661 
               882,589 
$6,917
68540
KLTV
          1,069,690 
            1,051,361 
$8,240
12913
KLUJ-TV
          1,195,751 
            1,195,751 
$9,371
57220
KLUZ-TV
          1,079,718 
            1,019,302 
$7,988
11683
KLVX
          2,044,150 
            1,936,083 
$15,173
82476
KLWB
          1,065,748 
            1,065,748 
$8,352
40250
KLWY
             541,043 
               538,231 
$4,218
64551
KMAU
             213,060 
               188,953 
$1,481
51499
KMAX-TV
        10,644,556 
            6,974,200 
$54,657
65686
KMBC-TV
          2,507,895 
            2,506,661 
$19,645
56079
KMBH
          1,225,732 
            1,225,732 
$9,606
35183
KMCB
               69,357 
                 66,203 
$519
41237
KMCC
          2,064,592 
            2,010,262 
$15,754
42636
KMCI-TV
          2,429,392 
            2,428,626 
$19,033
38584
KMCT-TV
             267,004 
               266,880 
$2,092
22127
KMCY
               71,797 
                 71,793 
$563
162016
KMDE
               35,409 
                 35,401 
$277
26428
KMEB
             221,810 
               203,470 
$1,595
39665
KMEG
             708,748 
               704,130 
$5,518
35123
KMEX-DT
        17,628,354 
          16,318,720 
$127,890
40875
KMGH-TV
          3,815,253 
            3,574,365 
$28,012
35131
KMID
             383,449 
               383,439 
$3,005
16749
KMIR-TV
          2,760,914 
               730,764 
$5,727
63164
KMIZ
             550,860 
               548,402 
$4,298
53541
KMLM-DT
             293,290 
               293,290 
$2,299
52046
KMLU
             711,951 
               708,107 
$5,549
47981
KMNE-TV
               47,232 
                 44,189 
$346
24753
KMOH-TV
             199,885 
               184,283 
$1,444
4326
KMOS-TV
             804,745 
               803,129 
$6,294
41425
KMOT
               81,517 
                 79,504 
$623
70034
KMOV
          3,035,077 
            3,029,405 
$23,741
51488
KMPH-TV
          1,725,397 
            1,697,871 
$13,306
73701
KMPX
          6,678,829 
            6,674,706 
$52,310
44052
KMSB
          1,321,614 
            1,039,442 
$8,146
68883
KMSP-TV
          3,832,040 
            3,805,141 
$29,821
12525
KMSS-TV
          1,068,120 
            1,066,388 
$8,357
43095
KMTP-TV
          5,097,701 
            4,378,276 
$34,313
35189
KMTR
             589,948 
               520,666 
$4,080
35190
KMTV-TV
          1,346,549 
            1,344,796 
$10,539
77063
KMTW
             761,521 
               761,516 
$5,968
35200
KMVT
             184,647 
               176,351 
$1,382
32958
KMVU-DT
             308,150 
               231,506 
$1,814
86534
KMYA-DT
             200,764 
               200,719 
$1,573
51518
KMYS
          2,273,888 
            2,267,913 
$17,774
54420
KMYT-TV
          1,314,197 
            1,302,378 
$10,207
35822
KMYU
             133,563 
               130,198 
$1,020
993
KNAT-TV
          1,157,630 
            1,124,619 
$8,814
24749
KNAZ-TV
             332,321 
               227,658 
$1,784
47906
KNBC
        17,859,647 
          16,555,232 
$129,743
81464
KNBN
             145,493 
               136,995 
$1,074
9754
KNCT
          2,247,724 
            2,233,513 
$17,504
82611
KNDB
             118,154 
               118,122 
$926
82615
KNDM
               72,216 
                 72,209 
$566
12395
KNDO
             314,875 
               270,892 
$2,123
12427
KNDU
             475,612 
               462,556 
$3,625
17683
KNEP
             101,389 
                 95,890 
$751
48003
KNHL
             277,777 
               277,308 
$2,173
125710
KNIC-DT
          2,398,296 
            2,383,294 
$18,678
59363
KNIN-TV*
             708,289
               703,838 
$5,516
48525
KNLC
          2,944,530 
            2,939,956 
$23,040
48521
KNLJ
             655,000 
               642,705 
$5,037
84215
KNMD-TV
          1,120,286 
            1,100,869 
$8,628
55528
KNME-TV
          1,149,036 
            1,103,695 
$8,650
47707
KNMT
          2,887,142 
            2,794,995 
$21,904
48975
KNOE-TV
             733,097 
               729,703 
$5,719
49273
KNOP-TV
               87,904 
                 85,423 
$669
10228
KNPB
             604,614 
               462,732 
$3,626
55362
KNRR
               25,957 
                 25,931 
$203
35277
KNSD
          3,861,660 
            3,618,321 
$28,357
19191
KNSN-TV
             611,981 
               459,485 
$3,601
58608
KNSO*
          1,976,317 
            1,931,825 
$15,140
35280
KNTV
          8,022,662 
            7,168,995 
$56,183
144
KNVA
          2,550,225 
            2,529,184 
$19,821
33745
KNVN
             495,403 
               464,031 
$3,637
69692
KNVO
          1,241,165 
            1,241,165 
$9,727
29557
KNWA-TV
             815,678 
               796,488 
$6,242
16950
KNXT
          2,166,688 
            2,116,003 
$16,583
59440
KNXV-TV
          4,183,943 
            4,173,022 
$32,704
59014
KOAA-TV
          1,391,946 
            1,087,809 
$8,525
50588
KOAB-TV
             207,070 
               203,371 
$1,594
50590
KOAC-TV
          1,957,282 
            1,543,401 
$12,096
58552
KOAM-TV
             595,307 
               584,921 
$4,584
53928
KOAT-TV*
          1,132,372
            1,105,116 
$8,661
35313
KOB
          1,152,841 
            1,113,162 
$8,724
35321
KOBF
             201,911 
               166,177 
$1,302
8260
KOBI*
             562,463
               519,063 
$4,068
62272
KOBR
             211,709 
               211,551 
$1,658
50170
KOCB
          1,629,783 
            1,629,152 
$12,768
4328
KOCE-TV
        17,447,903 
          16,331,792 
$127,992
84225
KOCM
          1,434,325 
            1,433,605 
$11,235
12508
KOCO-TV
          1,716,569 
            1,708,085 
$13,386
83181
KOCW
               83,807 
                 83,789 
$657
18283
KODE-TV
             740,156 
               731,512 
$5,733
66195
KOED-TV*
          1,497,297
            1,459,833 
$11,441
50198
KOET
             658,606 
               637,640 
$4,997
51189
KOFY-TV
          5,097,701 
            4,378,276 
$34,313
34859
KOGG
             190,829 
               161,310 
$1,264
166534
KOHD
             201,310 
               197,662 
$1,549
35380
KOIN
          2,983,136 
            2,851,968 
$22,351
35388
KOKH-TV
          1,627,116 
            1,625,246 
$12,737
11910
KOKI-TV
          1,366,220 
            1,352,227 
$10,597
48663
KOLD-TV
          1,216,228 
               887,754 
$6,957
7890
KOLN
          1,225,400 
            1,190,178 
$9,327
63331
KOLO-TV
             959,178 
               826,985 
$6,481
28496
KOLR
          1,076,144 
            1,038,613 
$8,140
21656
KOMO-TV
          4,123,984 
            4,078,485 
$31,963
65583
KOMU-TV
             551,658 
               542,544 
$4,252
35396
KONG
          4,006,008 
            3,985,271 
$31,233
60675
KOOD
             113,416 
               113,285 
$888
50589
KOPB-TV
          3,059,231 
            2,875,815 
$22,538
2566
KOPX-TV
          1,501,110 
            1,500,883 
$11,762
64877
KORO
             560,983 
               560,983 
$4,396
6865
KOSA-TV
             340,978 
               338,070 
$2,649
34347
KOTA-TV
             174,876 
               152,861 
$1,198
8284
KOTI
             298,175 
                 97,132 
$761
35434
KOTV-DT
          1,417,675 
            1,403,021 
$10,995
56550
KOVR
        10,759,811 
            7,100,710 
$55,648
51101
KOZJ
             429,982 
               427,991 
$3,354
51102
KOZK
             836,532 
               825,077 
$6,466
3659
KOZL-TV
             992,495 
               963,281 
$7,549
35455
KPAX-TV
             206,895 
               193,201 
$1,514
67868
KPAZ-TV
          4,190,080 
            4,176,323 
$32,730
6124
KPBS
          3,584,237 
            3,463,189 
$27,141
50044
KPBT-TV
             340,080 
               340,080 
$2,665
77452
KPCB-DT
               30,861 
                 30,835 
$242
35460
KPDX
          2,970,703 
            2,848,423 
$22,323
12524
KPEJ-TV
             368,212 
               368,208 
$2,886
41223
KPHO-TV
          4,195,073 
            4,175,139 
$32,721
61551
KPIC
             156,687 
               105,807 
$829
86205
KPIF
             255,766 
               250,517 
$1,963
25452
KPIX-TV
          8,340,753 
            7,480,594 
$58,625
58912
KPJK
          7,672,473 
            6,652,674 
$52,137
166510
KPJR-TV
          3,402,088 
            3,372,831 
$26,433
13994
KPLC
          1,406,085 
            1,403,853 
$11,002
41964
KPLO-TV
               55,827 
                 52,765 
$414
35417
KPLR-TV
          2,968,619 
            2,965,673 
$23,242
12144
KPMR
          1,731,370 
            1,473,251 
$11,546
47973
KPNE-TV
               92,675 
                 89,021 
$698
35486
KPNX
          4,215,834 
            4,184,428 
$32,793
77512
KPNZ
          2,394,311 
            2,208,707 
$17,310
73998
KPOB-TV
             144,525 
               143,656 
$1,126
26655
KPPX-TV
          4,186,998 
            4,171,450 
$32,692
53117
KPRC-TV
          6,099,422 
            6,099,076 
$47,798
48660
KPRY-TV
               42,521 
                 42,426 
$332
61071
KPSD-TV
               19,886 
                 18,799 
$147
53544
KPTB-DT
             322,780 
               320,646 
$2,513
81445
KPTF-DT
               84,512 
                 84,512 
$662
77451
KPTH
             660,556 
               655,373 
$5,136
51491
KPTM
          1,414,998 
            1,414,014 
$11,082
33345
KPTS
             832,000 
               827,866 
$6,488
50633
KPTV
          2,998,460 
            2,847,263 
$22,314
82575
KPTW
               80,374 
                 80,012 
$627
1270
KPVI-DT
             271,379 
               264,204 
$2,071
58835
KPXB-TV
          6,062,472 
            6,062,271 
$47,510
68695
KPXC-TV
          3,362,518 
            3,341,951 
$26,191
68834
KPXD-TV
          6,555,157 
            6,553,373 
$51,359
33337
KPXE-TV
          2,437,178 
            2,436,024 
$19,091
5801
KPXG-TV
          3,026,219 
            2,882,598 
$22,591
81507
KPXJ
          1,138,632 
            1,135,626 
$8,900
61173
KPXL-TV
          2,257,007 
            2,243,520 
$17,582
35907
KPXM-TV
          3,507,312 
            3,506,503 
$27,480
58978
KPXN-TV
        17,256,205 
          15,804,489 
$123,860
77483
KPXO-TV
             953,329 
               913,341 
$7,158
21156
KPXR-TV
             828,915 
               821,250 
$6,436
10242
KQCA
          9,931,378 
            5,931,341 
$46,484
41430
KQCD-TV
               35,623 
                 33,415 
$262
18287
KQCK
          3,220,160 
            3,162,711 
$24,786
78322
KQCW-DT
          1,128,198 
            1,123,324 
$8,803
35525
KQDS-TV
             305,747 
               302,246 
$2,369
35500
KQED
          8,195,398 
            7,283,828 
$57,083
35663
KQEH
          8,195,398 
            7,283,828 
$57,083
8214
KQET
          2,981,040 
            2,076,157 
$16,271
5471
KQIN
             596,371 
               596,277 
$4,673
17686
KQME
             188,783 
               184,719 
$1,448
61063
KQSD-TV
               32,526 
                 31,328 
$246
8378
KQSL*
             196,316 
               133,564 
$1,047
20427
KQTV
          1,494,987 
            1,401,160 
$10,981
78921
KQUP
             697,016 
               551,824 
$4,325
306
KRBC-TV
             229,395 
               229,277 
$1,797
166319
KRBK
             983,888 
               966,187 
$7,572
22161
KRCA*
        17,540,791 
          16,957,292 
$132,894
57945
KRCB
          5,320,127 
            4,552,911 
$35,681
41110
KRCG
             684,989 
               662,418 
$5,191
8291
KRCR-TV*
             423,000
               402,594 
$3,155
10192
KRCW-TV
          2,966,577 
            2,842,523 
$22,277
49134
KRDK-TV
             349,941 
               349,915 
$2,742
52579
KRDO-TV
          2,622,603 
            2,272,383 
$17,809
70578
KREG-TV
             149,306 
                 95,141 
$746
34868
KREM
             817,619 
               752,113 
$5,894
51493
KREN-TV
             810,039 
               681,212 
$5,339
70596
KREX-TV
             145,700 
               145,606 
$1,141
70579
KREY-TV
               74,963 
                 65,700 
$515
48589
KREZ-TV
             148,079 
               105,121 
$824
43328
KRGV-TV
          1,247,057 
            1,247,029 
$9,773
82698
KRII
             133,840 
               132,912 
$1,042
29114
KRIN
             949,313 
               923,735 
$7,239
25559
KRIS-TV
             561,825 
               561,718 
$4,402
22204
KRIV
          6,078,936 
            6,078,846 
$47,640
14040
KRMA-TV
          3,722,512 
            3,564,949 
$27,939
14042
KRMJ
             174,094 
               159,511 
$1,250
20476
KRMT
          2,956,144 
            2,864,236 
$22,447
84224
KRMU
               85,274 
                 72,499 
$568
20373
KRMZ
               36,293 
                 33,620 
$263
47971
KRNE-TV
               47,473 
                 38,273 
$300
60307
KRNV-DT
             981,687 
               825,465 
$6,469
65526
KRON-TV
          8,050,508 
            7,087,419 
$55,544
53539
KRPV-DT
               65,943 
                 65,943 
$517
48575
KRQE*
          1,135,461
            1,105,093 
$8,661
57431
KRSU-TV
          1,000,289 
               998,310 
$7,824
82613
KRTN-TV
               96,062 
                 74,452 
$583
35567
KRTV
               92,687 
                 90,846 
$712
84157
KRWB-TV
             111,538 
               110,979 
$870
35585
KRWF
               85,596 
                 85,596 
$671
55516
KRWG-TV
             894,492 
               661,703 
$5,186
48360
KRXI-TV
             725,391 
               548,865 
$4,301
307
KSAN-TV
             135,063 
               135,051 
$1,058
11911
KSAS-TV
             752,513 
               752,504 
$5,897
53118
KSAT-TV
          2,530,706 
            2,495,317 
$19,556
35584
KSAX
             365,209 
               365,209 
$2,862
35587
KSAZ-TV*
          4,203,126 
            4,178,448 
$32,746
38214
KSBI
          1,577,231 
            1,575,865 
$12,350
19653
KSBW
          5,083,461 
            4,429,165 
$34,711
19654
KSBY
             535,029 
               495,562 
$3,884
82910
KSCC
             502,915 
               502,915 
$3,941
10202
KSCE
          1,015,148 
            1,010,581 
$7,920
35608
KSCI
        17,447,903 
          16,331,792 
$127,992
72348
KSCW-DT
             915,691 
               910,511 
$7,136
46981
KSDK
          2,986,764 
            2,979,035 
$23,347
35594
KSEE
          1,749,448 
            1,732,516 
$13,578
48658
KSFY-TV
             670,536 
               607,844 
$4,764
17680
KSGW-TV
               62,178 
                 57,629 
$452
59444
KSHB-TV
          2,432,205 
            2,431,273 
$19,054
73706
KSHV-TV
             943,947 
               942,978 
$7,390
29096
KSIN-TV
             340,143 
               338,811 
$2,655
664
KSIX-TV
               82,902 
                 73,553 
$576
35606
KSKN
             731,818 
               643,590 
$5,044
70482
KSLA
          1,009,108 
            1,008,281 
$7,902
6359
KSL-TV
          2,390,742 
            2,206,920 
$17,296
71558
KSMN
             320,813 
               320,808 
$2,514
33336
KSMO-TV
          2,401,201 
            2,398,686 
$18,799
28510
KSMQ-TV
             524,391 
               507,983 
$3,981
35611
KSMS-TV
          1,589,263 
               882,948 
$6,920
21161
KSNB-TV
             658,560 
               656,650 
$5,146
72359
KSNC
             174,135 
               173,744 
$1,362
67766
KSNF
             621,919 
               617,868 
$4,842
72361
KSNG
             145,058 
               144,822 
$1,135
72362
KSNK
               48,715 
                 45,414 
$356
67335
KSNT
             622,818 
               594,604 
$4,660
10179
KSNV
          1,967,781 
            1,919,296 
$15,042
72358
KSNW
             789,136 
               788,882 
$6,182
61956
KSPS-TV*
             819,101
               769,852 
$6,033
52953
KSPX-TV
          6,745,180 
            4,966,590 
$38,923
166546
KSQA
             382,328 
               374,290 
$2,933
53313
KSRE
               75,181 
                 75,181 
$589
35843
KSTC-TV
          3,843,788 
            3,835,674 
$30,060
63182
KSTF
               51,317 
                 51,122 
$401
28010
KSTP-TV
          3,788,898 
            3,782,053 
$29,640
60534
KSTR-DT
          6,617,736 
            6,615,573 
$51,846
64987
KSTS
          7,645,340 
            6,333,303 
$49,634
22215
KSTU
          2,384,996 
            2,201,716 
$17,255
23428
KSTW
          4,265,956 
            4,186,266 
$32,808
5243
KSVI
             175,390 
               173,667 
$1,361
58827
KSWB-TV
          3,677,190 
            3,488,655 
$27,341
60683
KSWK
               79,012 
                 78,784 
$617
35645
KSWO-TV
             483,132 
               458,057 
$3,590
74449
KSWT
             398,681 
               393,135 
$3,081
61350
KSYS
             519,209 
               443,204 
$3,473
59988
KTAB-TV
             270,967 
               268,579 
$2,105
999
KTAJ-TV
          2,343,843 
            2,343,227 
$18,364
35648
KTAL-TV
          1,094,332 
            1,092,958 
$8,566
12930
KTAS
             471,882 
               464,149 
$3,638
81458
KTAZ
          4,182,503 
            4,160,481 
$32,606
35649
KTBC
          3,242,215 
            2,956,614 
$23,171
67884
KTBN-TV
        17,795,677 
          16,510,302 
$129,391
67999
KTBO-TV
          1,585,283 
            1,583,664 
$12,411
35652
KTBS-TV
          1,163,228 
            1,159,665 
$9,088
28324
KTBU
          6,035,927 
            6,035,725 
$47,302
67950
KTBW-TV
          4,202,104 
            4,113,420 
$32,237
35655
KTBY
             348,080 
               346,562 
$2,716
68594
KTCA-TV
          3,693,877 
            3,684,081 
$28,872
68597
KTCI-TV
          3,606,606 
            3,597,183 
$28,191
35187
KTCW
             100,392 
                 83,777 
$657
36916
KTDO
          1,015,336 
            1,010,771 
$7,921
2769
KTEJ
             419,750 
               417,368 
$3,271
83707
KTEL-TV
               53,423 
                 53,414 
$419
35666
KTEN
             566,422 
               564,096 
$4,421
24514
KTFD-TV
          3,210,669 
            3,172,543 
$24,863
35512
KTFF-DT
          2,225,169 
            2,203,398 
$17,268
20871
KTFK-DT
          6,969,307 
            5,211,719 
$40,844
68753
KTFN
          1,017,335 
            1,013,157 
$7,940
35084
KTFQ-TV
          1,151,433 
            1,117,061 
$8,754
29232
KTGM
             159,358 
               159,091 
$1,247
2787
KTHV*
          1,275,062
            1,246,348 
$9,768
29100
KTIN
             281,096 
               279,385 
$2,190
66170
KTIV
             751,089 
               746,274 
$5,849
49397
KTKA-TV
             567,958 
               566,406 
$4,439
35670
KTLA
        18,156,910 
          16,870,262 
$132,212
62354
KTLM
          1,014,202 
            1,014,186 
$7,948
49153
KTLN-TV
          5,209,087 
            4,490,249 
$35,190
64984
KTMD
          6,095,741 
            6,095,606 
$47,771
14675
KTMF
             187,251 
               168,526 
$1,321
10177
KTMW
          2,261,671 
            2,144,791 
$16,809
21533
KTNC-TV
          8,048,427 
            7,069,903 
$55,407
47996
KTNE-TV
             100,341 
                 95,324 
$747
60519
KTNL-TV
                 8,642 
                   8,642 
$68
74100
KTNV-TV
          2,094,506 
            1,936,752 
$15,178
71023
KTNW
             450,926 
               432,398 
$3,389
8651
KTOO-TV
               31,269 
                 31,176 
$244
7078
KTPX-TV
          1,066,196 
            1,063,754 
$8,337
68541
KTRE
             441,879 
               421,406 
$3,303
35675
KTRK-TV
          6,114,259 
            6,112,870 
$47,907
28230
KTRV-TV
             714,833 
               707,557 
$5,545
69170
KTSC
          3,124,536 
            2,949,795 
$23,118
61066
KTSD-TV
               83,645 
                 82,828 
$649
37511
KTSF
          7,921,124 
            6,576,672 
$51,541
67760
KTSM-TV
          1,015,348 
            1,011,264 
$7,925
35678
KTTC
             815,213 
               731,919 
$5,736
28501
KTTM
               76,133 
                 73,664 
$577
11908
KTTU
          1,324,801 
            1,060,613 
$8,312
22208
KTTV*
        17,380,551 
          16,693,085 
$130,824
28521
KTTW
             329,557 
               326,309 
$2,557
65355
KTTZ-TV
             380,240 
               380,225 
$2,980
35685
KTUL
          1,416,959 
            1,388,183 
$10,879
10173
KTUU-TV
             380,240 
               379,047 
$2,971
77480
KTUZ-TV
          1,668,531 
            1,666,026 
$13,057
49632
KTVA
             342,517 
               342,300 
$2,683
34858
KTVB*
             714,865 
               707,882 
$5,548
31437
KTVC
             137,239 
               100,204 
$785
68581
KTVD
          3,800,970 
            3,547,607 
$27,803
35692
KTVE
             641,139 
               640,201 
$5,017
49621
KTVF
               98,068 
                 97,929 
$767
5290
KTVH-DT
             228,832 
               184,264 
$1,444
35693
KTVI
          2,979,889 
            2,976,494 
$23,327
40993
KTVK
          4,184,825 
            4,173,024 
$32,704
22570
KTVL
             415,327 
               358,979 
$2,813
18066
KTVM-TV*
             260,105
               217,694 
$1,706
59139
KTVN*
             955,490 
               800,420 
$6,273
21251
KTVO
             148,780 
               148,647 
$1,165
35694
KTVQ
             179,797 
               173,271 
$1,358
50592
KTVR
             147,808 
                 54,480 
$427
23422
KTVT
          6,912,366 
            6,908,715 
$54,144
35703
KTVU
          7,913,996 
            6,825,643 
$53,493
35705
KTVW-DT
          4,173,111 
            4,159,807 
$32,600
68889
KTVX
          2,389,392 
            2,200,520 
$17,245
55907
KTVZ
             201,828 
               198,558 
$1,556
18286
KTWO-TV
               80,426 
                 79,905 
$626
70938
KTWU
          1,703,798 
            1,562,305 
$12,244
51517
KTXA
          6,876,811 
            6,873,221 
$53,865
42359
KTXD-TV
          6,706,651 
            6,704,781 
$52,545
51569
KTXH
          6,092,710 
            6,092,525 
$47,747
10205
KTXL
          7,355,088 
            5,411,484 
$42,410
308
KTXS-TV
             247,603 
               246,760 
$1,934
69315
KUAC-TV
               98,717 
                 98,189 
$770
51233
KUAM-TV
             159,358 
               159,358 
$1,249
2722
KUAS-TV
             994,802 
               977,391 
$7,660
2731
KUAT-TV
          1,485,024 
            1,253,342 
$9,822
60520
KUBD
               14,817 
                 13,363 
$105
70492
KUBE-TV
          6,090,970 
            6,090,817 
$47,734
1136
KUCW
          2,388,889 
            2,199,787 
$17,240
69396
KUED
          2,388,995 
            2,203,093 
$17,266
69582
KUEN
          2,364,481 
            2,184,483 
$17,120
82576
KUES
               30,925 
                 25,978 
$204
82585
KUEW
             132,168 
               120,411 
$944
66611
KUFM-TV
             187,680 
               166,697 
$1,306
169028
KUGF-TV
               86,622 
                 85,986 
$674
68717
KUHM-TV
             154,836 
               145,241 
$1,138
69269
KUHT*
          6,090,213
            6,089,665 
$47,725
62382
KUID-TV
             432,855 
               284,023 
$2,226
169027
KUKL-TV
             124,505 
               115,844 
$908
35724
KULR-TV
             177,242 
               170,142 
$1,333
41429
KUMV-TV
               41,607 
                 41,224 
$323
81447
KUNP
             130,559 
                 43,472 
$341
4624
KUNS-TV
          4,023,436 
            4,002,433 
$31,367
86532
KUOK
               28,974 
                 28,945 
$227
66589
KUON-TV
          1,375,257 
            1,360,005 
$10,658
86263
KUPB
             318,914 
               318,914 
$2,499
65535
KUPK
             149,642 
               148,180 
$1,161
27431
KUPT
               87,602 
                 87,602 
$687
89714
KUPU
             956,178 
               948,005 
$7,430
57884
KUPX-TV
          2,374,672 
            2,191,229 
$17,173
23074
KUSA
          3,803,461 
            3,561,587 
$27,912
61072
KUSD-TV
             460,480 
               460,277 
$3,607
10238
KUSI-TV
          3,572,818 
            3,435,670 
$26,925
43567
KUSM-TV
             115,864 
               106,398 
$834
69694
KUTF
          1,210,774 
            1,031,870 
$8,087
81451
KUTH-DT
          2,219,788 
            2,027,174 
$15,887
68886
KUTP
          4,191,015 
            4,176,014 
$32,727
35823
KUTV
          2,388,211 
            2,192,182 
$17,180
63927
KUVE-DT
          1,294,971 
               964,396 
$7,558
7700
KUVI-DT
          1,204,490 
            1,009,943 
$7,915
35841
KUVN-DT
          6,680,126 
            6,678,157 
$52,337
58609
KUVS-DT
          4,043,413 
            4,005,657 
$31,392
49766
KVAL-TV
          1,016,673 
               866,173 
$6,788
32621
KVAW
               76,153 
                 76,153 
$597
58795
KVCR-DT*
        18,215,524 
          17,467,140 
$136,890
35846
KVCT
             288,221 
               287,446 
$2,253
10195
KVCW
          1,967,550 
            1,918,811 
$15,038
64969
KVDA
          2,400,582 
            2,391,810 
$18,745
19783
KVEA
        17,423,429 
          16,146,250 
$126,538
12523
KVEO-TV
          1,244,504 
            1,244,504 
$9,753
2495
KVEW
             476,720 
               464,347 
$3,639
35852
KVHP
             747,917 
               747,837 
$5,861
49832
KVIA-TV
          1,015,350 
            1,011,266 
$7,925
35855
KVIE*
        10,759,440
            7,467,369 
$58,522
40450
KVIH-TV
               91,912 
                 91,564 
$718
40446
KVII-TV
             379,042 
               378,218 
$2,964
61961
KVLY-TV
             350,732 
               350,449 
$2,746
16729
KVMD
          6,145,526 
            4,116,524 
$32,261
83825
KVME-TV
               26,711 
                 22,802 
$179
25735
KVOA
          1,317,956 
            1,030,404 
$8,075
35862
KVOS-TV
          2,019,168 
            1,954,667 
$15,319
69733
KVPT
          1,744,349 
            1,719,318 
$13,474
55372
KVRR
             356,645 
               356,645 
$2,795
166331
KVSN-DT
          2,706,244 
            2,283,409 
$17,895
608
KVTH-DT
             303,755 
               299,230 
$2,345
2784
KVTJ-DT
          1,466,426 
            1,465,802 
$11,487
607
KVTN-DT
             936,328 
               925,884 
$7,256
35867
KVUE
          2,661,290 
            2,611,314 
$20,465
78910
KVUI
             257,964 
               251,872 
$1,974
35870
KVVU-TV
          2,042,029 
            1,935,466 
$15,168
36170
KVYE
             396,495 
               392,498 
$3,076
35095
KWBA-TV
          1,129,524 
            1,073,029 
$8,409
78314
KWBM
             657,822 
               639,560 
$5,012
27425
KWBN
             953,207 
               840,455 
$6,587
76268
KWBQ
          1,148,810 
            1,105,600 
$8,665
66413
KWCH-DT
             883,647 
               881,674 
$6,910
71549
KWCM-TV
             252,284 
               244,033 
$1,912
35419
KWDK
          4,196,263 
            4,118,699 
$32,278
42007
KWES-TV
             424,862 
               423,544 
$3,319
50194
KWET
             127,976 
               112,750 
$884
35881
KWEX-DT
          2,376,463 
            2,370,469 
$18,577
35883
KWGN-TV
          3,706,495 
            3,513,577 
$27,536
37099
KWHB
             979,393 
               978,719 
$7,670
37103
KWHD
               97,959 
                 94,560 
$741
36846
KWHE
             952,966 
               834,341 
$6,539
26231
KWHY-TV*
        17,736,497 
          17,695,306 
$138,678
35096
KWKB
          1,121,676 
            1,111,629 
$8,712
162115
KWKS
               39,708 
                 39,323 
$308
12522
KWKT-TV
          1,010,550 
            1,010,236 
$7,917
21162
KWNB-TV
               91,093 
                 89,332 
$700
67347
KWOG
             512,412 
               505,049 
$3,958
56852
KWPX-TV
          4,220,008 
            4,148,577 
$32,512
6885
KWQC-TV
          1,080,156 
            1,067,249 
$8,364
29121
KWSD
             280,675 
               280,672 
$2,200
53318
KWSE
               54,471 
                 53,400 
$418
71024
KWSU-TV
             725,554 
               468,295 
$3,670
25382
KWTV-DT
          1,628,106 
            1,627,198 
$12,752
35903
KWTX-TV
          2,071,023 
            1,972,365 
$15,457
593
KWWL*
          1,089,498
            1,078,458 
$8,452
84410
KWWT
             293,291 
               293,291 
$2,299
14674
KWYB
               86,495 
                 69,598 
$545
10032
KWYP-DT
             128,874 
               126,992 
$995
35920
KXAN-TV
          2,678,666 
            2,624,648 
$20,569
49330
KXAS-TV
          6,774,295 
            6,771,827 
$53,071
24287
KXGN-TV
               14,217 
                 13,883 
$109
35954
KXII
          2,323,974 
            2,264,951 
$17,750
55083
KXLA
        17,929,100 
          16,794,896 
$131,622
35959
KXLF-TV
             258,100 
               217,808 
$1,707
53847
KXLN-DT
          6,085,891 
            6,085,712 
$47,694
35906
KXLT-TV
             348,025 
               347,296 
$2,722
61978
KXLY-TV*
             772,116 
               740,960 
$5,807
55684
KXMA-TV
               32,005 
                 31,909 
$250
55686
KXMB-TV
             142,755 
               138,506 
$1,085
55685
KXMC-TV
               97,569 
                 89,483 
$701
55683
KXMD-TV
               37,962 
                 37,917 
$297
47995
KXNE-TV
             300,021 
               298,839 
$2,342
81593
KXNW
             602,168 
               597,747 
$4,685
35991
KXRM-TV
          1,843,363 
            1,500,689 
$11,761
1255
KXTF
             121,558 
               121,383 
$951
25048
KXTV
        10,759,864 
            7,477,140 
$58,598
35994
KXTX-TV
          6,721,578 
            6,718,616 
$52,654
62293
KXVA
             185,478 
               185,276 
$1,452
23277
KXVO
          1,404,703 
            1,403,380 
$10,998
9781
KXXV
          1,771,620 
            1,748,287 
$13,701
31870
KYAZ
          6,038,257 
            6,038,071 
$47,320
21488
KYES-TV
             381,413 
               380,355 
$2,981
29086
KYIN
             581,748 
               574,691 
$4,504
60384
KYLE-TV
             324,032 
               324,025 
$2,539
33639
KYMA-DT
             396,278 
               391,619 
$3,069
47974
KYNE-TV
             929,406 
               929,242 
$7,282
53820
KYOU-TV
             651,334 
               640,935 
$5,023
36003
KYTV
          1,095,904 
            1,083,524 
$8,492
55644
KYTX
             927,327 
               925,550 
$7,254
13815
KYUR
             379,943 
               379,027 
$2,970
5237
KYUS-TV
               12,496 
                 12,356 
$97
33752
KYVE
             301,951 
               259,559 
$2,034
55762
KYVV-TV
               67,201 
                 67,201 
$527
25453
KYW-TV
        11,061,941 
          10,876,511 
$85,239
69531
KZJL
          6,037,458 
            6,037,272 
$47,314
69571
KZJO
          4,179,154 
            4,124,424 
$32,323
61062
KZSD-TV
               41,207 
                 35,825 
$281
33079
KZTV
             567,635 
               564,464 
$4,424
57292
WAAY-TV
          1,498,006 
            1,428,197 
$11,193
1328
WABC-TV*
        20,948,273
          20,560,001 
$161,129
43203
WABG-TV
             393,020 
               392,348 
$3,075
17005
WABI-TV
             530,773 
               510,729 
$4,003
16820
WABM
          1,703,202 
            1,675,700 
$13,132
23917
WABW-TV
          1,097,560 
            1,096,376 
$8,592
19199
WACH
          1,317,429 
            1,316,792 
$10,320
189358
WACP
          9,415,263 
            9,301,049 
$72,892
23930
WACS-TV
             621,686 
               616,443 
$4,831
60018
WACX
          3,967,118 
            3,966,535 
$31,086
361
WACY-TV
             946,580 
               946,071 
$7,414
455
WADL
          4,610,514 
            4,602,962 
$36,073
589
WAFB
          1,857,882 
            1,857,418 
$14,557
591
WAFF
          1,197,068 
            1,110,122 
$8,700
70689
WAGA-TV
          6,000,355 
            5,923,191 
$46,420
48305
WAGM-TV
               64,721 
                 63,331 
$496
37809
WAGV
          1,193,158 
            1,060,935 
$8,315
706
WAIQ
             611,733 
               609,794 
$4,779
701
WAKA
             799,637 
               793,645 
$6,220
4143
WALA-TV
          1,320,419 
            1,318,127 
$10,330
70713
WALB
             773,899 
               772,467 
$6,054
60536
WAMI-DT
          5,449,193 
            5,449,193 
$42,705
70852
WAND
          1,400,271 
            1,398,521 
$10,960
39270
WANE-TV
          1,108,844 
            1,108,844 
$8,690
52280
WAOE
             613,812 
               613,784 
$4,810
64546
WAOW
             636,957 
               629,068 
$4,930
52073
WAPA-TV
          3,764,742 
            3,363,102 
$21,902
49712
WAPT
             793,621 
               791,620 
$6,204
67792
WAQP
          1,992,340 
            1,983,143 
$15,542
13206
WATC-DT
          5,637,070 
            5,616,513 
$44,017
71082
WATE-TV
          1,874,433 
            1,638,059 
$12,837
22819
WATL
          5,882,837 
            5,819,099 
$45,604
20287
WATM-TV
             937,438 
               785,510 
$6,156
11907
WATN-TV
          1,787,595 
            1,784,560 
$13,986
13989
WAVE
          1,846,212 
            1,836,231 
$14,391
71127
WAVY-TV
          2,039,358 
            2,039,341 
$15,982
54938
WAWD
             553,676 
               553,591 
$4,338
65247
WAWV-TV
             705,549 
               699,377 
$5,481
12793
WAXN-TV
          2,677,951 
            2,669,224 
$20,919
65696
WBAL-TV
          9,596,587 
            9,190,139 
$72,023
74417
WBAY-TV
          1,225,928 
            1,225,335 
$9,603
71085
WBBH-TV
          2,046,391 
            2,046,391 
$16,038
65204
WBBJ-TV
             662,148 
               658,016 
$5,157
9617
WBBM-TV*
          9,914,233
            9,907,806 
$77,647
9088
WBBZ-TV
          1,269,256 
            1,260,686 
$9,880
70138
WBDT
          3,660,544 
            3,646,874 
$28,581
51349
WBEC-TV
          5,421,355 
            5,421,355 
$42,487
10758
WBFF
          8,509,757 
            8,339,882 
$65,360
12497
WBFS-TV
          5,349,613 
            5,349,613 
$41,925
6568
WBGU-TV
          1,343,816 
            1,343,816 
$10,531
81594
WBIF
             309,707 
               309,707 
$2,427
84802
WBIH
             736,501 
               724,345 
$5,677
717
WBIQ
          1,563,080 
            1,532,266 
$12,008
46984
WBIR-TV
          1,978,347 
            1,701,857 
$13,337
67048
WBKB-TV
             136,823 
               130,625 
$1,024
34167
WBKI
          1,983,992 
            1,968,048 
$15,424
4692
WBKO
             963,413 
               862,651 
$6,761
76001
WBKP
               55,655 
                 55,305 
$433
68427
WBMM
             562,284 
               562,123 
$4,405
73692
WBNA
          1,699,683 
            1,666,248 
$13,058
23337
WBNG-TV*
          1,442,745 
            1,060,329 
$8,310
71217
WBNS-TV
          2,847,721 
            2,784,795 
$21,824
72958
WBNX-TV
          3,642,304 
            3,629,347 
$28,443
71218
WBOC-TV
             813,888 
               813,888 
$6,378
71220
WBOY-TV
             711,302 
               621,367 
$4,870
60850
WBPH-TV*
        10,613,847
          9,474,797 
$74,254
7692
WBPX-TV
          6,833,712 
            6,761,949 
$52,993
5981
WBRA-TV
          1,726,408 
            1,677,204 
$13,144
71221
WBRC
          1,884,007 
            1,849,135 
$14,492
71225
WBRE-TV*
          2,879,196
            2,244,735 
$17,592
38616
WBRZ-TV
          2,223,336 
            2,222,309 
$17,416
82627
WBSF
          1,836,543 
            1,832,446 
$14,361
30826
WBTV
          4,433,020 
            4,295,962 
$33,667
66407
WBTW
          1,975,457 
            1,959,172 
$15,354
16363
WBUI
             981,884 
               981,868 
$7,695
59281
WBUP
             126,472 
               112,603 
$882
60830
WBUY-TV
          1,569,254 
            1,567,815 
$12,287
72971
WBXX-TV
          2,142,759 
            1,984,544 
$15,553
25456
WBZ-TV
          7,764,394 
            7,616,633 
$59,692
63153
WCAU
        11,269,831 
          11,098,540 
$86,979
363
WCAV
             949,729 
               727,455 
$5,701
46728
WCAX-TV
             784,748 
               661,547 
$5,185
39659
WCBB
             964,079 
               910,222 
$7,133
10587
WCBD-TV
          1,149,489 
            1,149,489 
$9,009
12477
WCBI-TV
             680,511 
               678,424 
$5,317
9610
WCBS-TV
        21,713,751 
          21,187,849 
$166,049
49157
WCCB
          3,542,464 
            3,489,260 
$27,345
9629
WCCO-TV
          3,837,442 
            3,829,714 
$30,013
14050
WCCT-TV
          5,818,471 
            5,307,612 
$41,596
69544
WCCU
             395,106 
               395,102 
$3,096
3001
WCCV-TV
          3,391,703 
            2,482,544 
$16,168
23937
WCES-TV
          1,098,868 
            1,097,706 
$8,603
65666
WCET
          3,122,924 
            3,108,328 
$24,360
46755
WCFE-TV
             445,131 
               411,198 
$3,223
71280
WCHS-TV
          1,352,824 
            1,274,766 
$9,990
42124
WCIA
             796,609 
               795,428 
$6,234
711
WCIQ*
          3,181,068
            3,033,573 
$23,774
71428
WCIU-TV
          9,891,328 
            9,888,390 
$77,495
9015
WCIV
          1,152,800 
            1,152,800 
$9,034
42116
WCIX
             554,002 
               549,682 
$4,308
16993
WCJB-TV
             977,492 
               977,492 
$7,661
11125
WCLF
          4,097,389 
            4,096,624 
$32,105
68007
WCLJ-TV
          2,258,426 
            2,256,937 
$17,688
50781
WCMH-TV
          2,756,260 
            2,712,989 
$21,262
9917
WCML
             233,439 
               224,255 
$1,757
9908
WCMU-TV
             707,702 
               699,551 
$5,482
9922
WCMV
             418,707 
               407,222 
$3,191
9913
WCMW
             106,975 
               104,859 
$822
32326
WCNC-TV
          3,822,849 
            3,747,880 
$29,372
53734
WCNY-TV
          1,358,685 
            1,290,632 
$10,115
73642
WCOV-TV
             862,899 
               859,333 
$6,735
40618
WCPB
             560,426 
               560,426 
$4,392
59438
WCPO-TV
          3,328,920 
            3,311,833 
$25,955
10981
WCPX-TV
          9,674,477 
            9,673,859 
$75,814
71297
WCSC-TV
          1,028,018 
            1,028,018 
$8,057
39664
WCSH
          1,682,955 
            1,457,618 
$11,423
69479
WCTE
             612,760 
               541,314 
$4,242
18334
WCTI-TV
          1,680,664 
            1,678,237 
$13,152
31590
WCTV
          1,049,825 
            1,049,779 
$8,227
33081
WCTX
          7,844,936 
            7,332,431 
$57,464
65684
WCVB-TV
          7,741,540 
            7,606,326 
$59,611
9987
WCVE-TV
          1,582,094 
            1,581,725 
$12,396
83304
WCVI-TV
               50,601 
                 50,495 
$396
34204
WCVN-TV
          2,108,475 
            2,100,226 
$16,459
9989
WCVW
          1,461,748 
            1,461,643 
$11,455
73042
WCWF
          1,040,984 
            1,040,525 
$8,155
35385
WCWG
          3,630,551 
            3,299,114 
$25,855
29712
WCWJ
          1,582,959 
            1,582,959 
$12,406
73264
WCWN
          1,698,469 
            1,512,848 
$11,856
2455
WCYB-TV*
          2,363,002
            2,057,404 
$16,124
11291
WDAF-TV
          2,539,581 
            2,537,411 
$19,886
21250
WDAM-TV
             512,594 
               500,343 
$3,921
22129
WDAY-TV
             339,239 
               338,856 
$2,656
22124
WDAZ-TV
             151,720 
               151,659 
$1,189
71325
WDBB
          1,669,214 
            1,646,336 
$12,902
71326
WDBD
             940,665 
               939,489 
$7,363
71329
WDBJ
          1,606,844 
            1,439,716 
$11,283
51567
WDCA
          8,070,491 
            8,015,328 
$62,816
16530
WDCQ-TV
          1,269,199 
            1,269,199 
$9,947
30576
WDCW
          8,155,998 
            8,114,847 
$63,596
54385
WDEF-TV
          1,731,483 
            1,508,250 
$11,820
32851
WDFX-TV
             271,499 
               270,942 
$2,123
43846
WDHN
             452,377 
               451,978 
$3,542
71338
WDIO-DT
             341,506 
               327,469 
$2,566
714
WDIQ
             663,062 
               620,124 
$4,860
53114
WDIV-TV
          5,425,162 
            5,424,963 
$42,515
71427
WDJT-TV
          3,085,540 
            3,081,475 
$24,150
39561
WDKA
             621,903 
               620,169 
$4,860
64017
WDKY-TV
          1,204,817 
            1,173,579 
$9,197
67893
WDLI-TV
          4,147,298 
            4,114,920 
$32,249
72335
WDPB
             596,888 
               596,888 
$4,678
83740
WDPM-DT
          1,365,977 
            1,364,744 
$10,695
1283
WDPN-TV*
        11,594,463
          11,467,616 
$89,872
6476
WDPX-TV
          6,833,712 
            6,761,949 
$52,993
28476
WDRB
          1,987,708 
            1,971,926 
$15,454
12171
WDSC-TV
          3,376,247 
            3,376,247 
$26,460
17726
WDSE
             330,994 
               316,643 
$2,482
71353
WDSI-TV
          1,100,302 
            1,042,191 
$8,168
71357
WDSU
          1,613,076 
            1,613,076 
$12,642
7908
WDTI
          2,095,312 
            2,094,395 
$16,414
65690
WDTN
          3,660,544 
            3,646,874 
$28,581
70592
WDTV
             962,532 
               850,394 
$6,665
25045
WDVM-TV
          3,074,837 
            2,646,508 
$20,741
4110
WDWL
          2,638,361 
            2,379,555 
$15,497
49421
WEAO
          3,919,602 
            3,892,146 
$30,503
71363
WEAR-TV
          1,524,131 
            1,523,479 
$11,940
7893
WEAU
             991,019 
               952,513 
$7,465
61003
WEBA-TV
             645,039 
               635,967 
$4,984
19561
WECN
          2,886,669 
            2,596,015 
$16,907
48666
WECT
          1,134,918 
            1,134,918 
$8,894
13602
WEDH
          5,328,800 
            4,724,167 
$37,023
13607
WEDN
          3,451,170 
            2,643,344 
$20,716
69338
WEDQ
          4,882,446 
            4,881,322 
$38,255
21808
WEDU
          5,379,887 
            5,365,612 
$42,050
13594
WEDW
          5,996,408 
            5,544,708 
$43,454
13595
WEDY
          5,328,800 
            4,724,167 
$37,023
24801
WEEK-TV
             698,238 
               698,220 
$5,472
6744
WEFS
          3,380,743 
            3,380,743 
$26,495
24215
WEHT
             847,299 
               835,128 
$6,545
721
WEIQ
          1,046,465 
            1,046,116 
$8,198
18301
WEIU-TV
             462,775 
               462,711 
$3,626
69271
WEKW-TV
          1,072,240 
               546,881 
$4,286
60825
WELF-TV
          1,491,382 
            1,414,528 
$11,086
26602
WELU
          2,248,146 
            2,020,075 
$13,156
40761
WEMT
          1,726,085 
            1,186,706 
$9,300
69237
WENH-TV
          4,500,498 
            4,328,222 
$33,920
71508
WENY-TV
             543,162 
               413,668 
$3,242
83946
WEPH
             604,105 
               602,833 
$4,724
81508
WEPX-TV
             859,535 
               859,535 
$6,736
25738
WESH*
          4,059,180 
            4,048,459
$31,728
65670
WETA-TV
          7,607,834 
            7,576,217 
$59,375
69944
WETK
             670,087 
               558,842 
$4,380
60653
WETM-TV
             721,800 
               620,074 
$4,860
18252
WETP-TV
          2,087,588 
            1,791,130 
$14,037
2709
WEUX
             380,569 
               373,680 
$2,929
72041
WEVV-TV
             752,417 
               750,555 
$5,882
59441
WEWS-TV
          4,112,984 
            4,078,299 
$31,962
72052
WEYI-TV
          3,715,686 
            3,652,991 
$28,628
72054
WFAA*
          6,927,782
            6,918,595 
$54,221
81669
WFBD
             814,185 
               813,564 
$6,376
69532
WFDC-DT
          8,155,998 
            8,114,847 
$63,596
10132
WFFF-TV
             592,012 
               506,744 
$3,971
25040
WFFT-TV
          1,088,489 
            1,088,354 
$8,529
11123
WFGC
          2,759,457 
            2,759,457 
$21,626
6554
WFGX
          1,440,245 
            1,437,744 
$11,268
13991
WFIE
             731,856 
               729,985 
$5,721
715
WFIQ
             546,563 
               544,258 
$4,265
64592
WFLA-TV
          5,450,176 
            5,446,917 
$42,687
22211
WFLD
          9,957,301 
            9,954,828 
$78,016
72060
WFLI-TV
          1,272,913 
            1,125,349 
$8,819
39736
WFLX
          5,740,086 
            5,740,086 
$44,985
72062
WFMJ-TV
          3,504,955 
            3,262,270 
$25,566
72064
WFMY-TV
          4,772,783 
            4,740,684 
$37,153
39884
WFMZ-TV*
        10,613,847 
          9,474,797 
$74,254
83943
WFNA
          1,391,519 
            1,390,447 
$10,897
47902
WFOR-TV
          5,398,266 
            5,398,266 
$42,306
11909
WFOX-TV
          1,602,888 
            1,602,888 
$12,562
40626
WFPT
          5,829,226 
            5,442,352 
$42,652
21245
WFPX-TV
          2,637,949 
            2,634,141 
$20,644
25396
WFQX-TV
             537,340 
               534,314 
$4,187
9635
WFRV-TV
          1,201,204 
            1,200,502 
$9,408
53115
WFSB
          4,752,788 
            4,370,519 
$34,252
6093
WFSG
             364,961 
               364,796 
$2,859
21801
WFSU-TV
             576,105 
               576,093 
$4,515
11913
WFTC
          3,787,177 
            3,770,207 
$29,547
64588
WFTS-TV
          5,077,970 
            5,077,719 
$39,794
16788
WFTT-TV
          4,523,828 
            4,521,879 
$35,438
72076
WFTV
          3,849,576 
            3,849,576 
$30,169
70649
WFTX-TV
          1,775,097 
            1,775,097 
$13,911
60553
WFTY-DT
          5,678,755 
            5,560,460 
$43,577
25395
WFUP
             217,655 
               216,861 
$1,700
60555
WFUT-DT
        19,992,096 
          19,643,518 
$153,946
22108
WFWA
          1,035,114 
            1,034,862 
$8,110
9054
WFXB
          1,393,865 
            1,393,510 
$10,921
3228
WFXG
          1,070,032 
            1,057,760 
$8,290
70815
WFXL
             793,637 
               785,106 
$6,153
19707
WFXP
             583,315 
               562,500 
$4,408
24813
WFXR
          1,426,061 
            1,286,450 
$10,082
6463
WFXT
          7,494,070 
            7,400,830 
$58,000
22245
WFXU
             211,721 
               211,721 
$1,659
43424
WFXV
             633,597 
               558,968 
$4,381
25236
WFXW
             274,078 
               270,967 
$2,124
41397
WFYI
          2,389,627 
            2,388,970 
$18,722
53930
WGAL*
          6,287,688
            5,610,833 
$43,972
2708
WGBA-TV
          1,170,375 
            1,170,127 
$9,170
24314
WGBC
             249,415 
               249,235 
$1,953
72099
WGBH-TV*
          7,711,842 
            7,601,732 
$59,575
12498
WGBO-DT
          9,771,815 
            9,769,552 
$76,564
72098
WGBX-TV
          7,476,751 
            7,378,958 
$57,829
72096
WGBY-TV
          4,470,009 
            3,739,675 
$29,308
72120
WGCL-TV
          6,027,276 
            5,961,471 
$46,720
62388
WGCU
          1,403,602 
            1,403,602 
$11,000
54275
WGEM-TV*
             361,598 
               356,682 
$2,795
27387
WGEN-TV
               43,037 
                 43,037 
$337
7727
WGFL
             759,234 
               759,234 
$5,950
25682
WGGB-TV
          3,443,447 
            3,005,875 
$23,557
11027
WGGN-TV
          1,991,462 
            1,969,331 
$15,434
9064
WGGS-TV
          2,759,326 
            2,705,067 
$21,200
72106
WGHP
          3,774,522 
            3,734,200 
$29,265
710
WGIQ
             363,849 
               363,806 
$2,851
12520
WGMB-TV
          1,739,804 
            1,739,640 
$13,634
25683
WGME-TV
          1,495,724 
            1,325,465 
$10,388
24618
WGNM
             742,533 
               741,501 
$5,811
72119
WGNO
          1,641,765 
            1,641,765 
$12,867
9762
WGNT
          1,875,612 
            1,875,578 
$14,699
72115
WGN-TV
          9,942,959 
            9,941,552 
$77,912
40619
WGPT
             578,294 
               344,300 
$2,698
65074
WGPX-TV
          2,765,350 
            2,754,743 
$21,589
64547
WGRZ
          1,878,725 
            1,812,309 
$14,203
63329
WGTA
          1,061,654 
            1,030,538 
$8,076
66285
WGTE-TV
          2,210,496 
            2,208,927 
$17,311
59279
WGTQ
               95,618 
                 92,019 
$721
59280
WGTU
             358,543 
               353,477 
$2,770
23948
WGTV
          5,880,594 
            5,832,714 
$45,711
7623
WGTW-TV
             807,797 
               807,797 
$6,331
24783
WGVK
          2,439,225 
            2,437,526 
$19,103
24784
WGVU-TV*
          1,825,744 
            1,784,264 
$13,983
21536
WGWG
             986,963 
               986,963 
$7,735
56642
WGWW
          1,677,166 
            1,647,976 
$12,915
58262
WGXA
             779,955 
               779,087 
$6,106
73371
WHAM-TV
          1,323,785 
            1,275,674 
$9,997
32327
WHAS-TV*
          1,955,983
            1,925,901 
$15,093
6096
WHA-TV
          1,636,473 
            1,629,171 
$12,768
13950
WHBF-TV*
          1,712,339 
            1,704,072 
$13,355
12521
WHBQ-TV
          1,736,335 
            1,708,345 
$13,388
10894
WHBR
          1,302,764 
            1,302,041 
$10,204
65128
WHDF
          1,553,469 
            1,502,852 
$11,778
72145
WHDH
          7,319,659 
            7,236,210 
$56,710
83929
WHDT
          5,640,324 
            5,640,324 
$44,203
70041
WHEC-TV
          1,322,243 
            1,279,606 
$10,028
67971
WHFT-TV
          5,417,409 
            5,417,409 
$42,456
41458
WHIO-TV
          3,896,757 
            3,879,363 
$30,403
713
WHIQ
          1,278,174 
            1,225,940 
$9,608
61216
WHIZ-TV
             910,864 
               831,894 
$6,520
65919
WHKY-TV
          3,038,732 
            2,974,919 
$23,314
18780
WHLA-TV
             467,264 
               443,002 
$3,472
48668
WHLT
             484,432 
               483,532 
$3,789
24582
WHLV-TV
          3,825,468 
            3,825,468 
$29,980
37102
WHMB-TV
          2,847,719 
            2,828,250 
$22,165
61004
WHMC
             943,543 
               942,807 
$7,389
36117
WHME-TV
          1,271,796 
            1,271,715 
$9,966
37106
WHNO
          1,499,653 
            1,499,653 
$11,753
72300
WHNS
          2,549,397 
            2,266,911 
$17,766
48693
WHNT-TV
          1,569,885 
            1,487,578 
$11,658
66221
WHO-DT*
          1,120,480 
            1,099,818 
$8,619
6866
WHOI
             679,446 
               679,434 
$5,325
72313
WHP-TV
          4,030,693 
            3,538,096 
$27,728
51980
WHPX-TV
          5,579,464 
            5,114,336 
$40,081
73036
WHRM-TV
             495,398 
               495,174 
$3,881
25932
WHRO-TV
          2,149,481 
            2,149,410 
$16,845
68058
WHSG-TV
          5,870,314 
            5,808,605 
$45,522
4688
WHSV-TV
             845,013 
               711,912 
$5,579
9990
WHTJ
             723,698 
               490,045 
$3,840
72326
WHTM-TV
          2,829,585 
            2,367,000 
$18,550
11117
WHTN
          1,872,713 
            1,856,716 
$14,551
27772
WHUT-TV
          7,649,763 
            7,617,337 
$59,697
18793
WHWC-TV
             994,710 
               946,335 
$7,416
72338
WHYY-TV
        10,379,045 
            9,982,651 
$78,234
5360
WIAT
          1,837,072 
            1,802,810 
$14,129
63160
WIBW-TV
          1,089,708 
            1,050,918 
$8,236
25684
WICD
          1,238,332 
            1,237,046 
$9,695
25686
WICS
          1,011,833 
            1,007,132 
$7,893
24970
WICU-TV
             740,115 
               683,435 
$5,356
62210
WICZ-TV
             976,771 
               780,174 
$6,114
18410
WIDP
          2,559,306 
            2,286,123 
$14,888
26025
WIFS
          1,400,358 
            1,397,144 
$10,949
720
WIIQ
             353,241 
               347,685 
$2,725
68939
WILL-TV
          1,178,545 
            1,158,147 
$9,076
6863
WILX-TV
          3,378,644 
            3,218,221 
$25,221
22093
WINK-TV
          1,851,105 
            1,851,105 
$14,507
67787
WINM
          1,001,485 
               971,031 
$7,610
41314
WINP-TV
          2,804,646 
            2,748,454 
$21,540
3646
WIPB
          1,962,078 
            1,961,899 
$15,375
48408
WIPL
             850,656 
               799,165 
$6,263
53863
WIPM-TV
          2,196,157 
            1,870,057 
$2,269
53859
WIPR-TV
          3,596,802 
            3,382,849 
$22,031
10253
WIPX-TV
          2,258,426 
            2,256,937 
$17,688
39887
WIRS
          1,153,382 
               916,310 
$4,706
71336
WIRT-DT
             127,001 
               126,300 
$990
13990
WIS
          2,644,715 
            2,600,887 
$20,383
65143
WISC-TV
          1,830,642 
            1,811,579 
$14,197
13960
WISE-TV
          1,070,155 
            1,070,155 
$8,387
39269
WISH-TV
          2,912,963 
            2,855,253 
$22,377
65680
WISN-TV
          2,938,180 
            2,926,133 
$22,932
73083
WITF-TV
          2,412,561 
            2,191,501 
$17,175
73107
WITI
          3,117,342 
            3,107,791 
$24,356
594
WITN-TV
          1,768,040 
            1,754,388 
$13,749
61005
WITV
          1,081,393 
            1,081,393 
$8,475
7780
WIVB-TV
          1,538,108 
            1,502,969 
$11,779
11260
WIVT
             856,453 
               607,256 
$4,759
60571
WIWN*
          3,338,845 
            3,323,941 
$26,050
62207
WIYC
             526,556 
               525,826 
$4,121
73120
WJAC-TV
          2,219,529 
            1,897,986 
$14,875
10259
WJAL*
          8,750,706 
            8,446,074 
$66,192
50780
WJAR
          6,537,858 
            6,428,263 
$50,378
35576
WJAX-TV
          1,630,782 
            1,630,782 
$12,780
27140
WJBF
          1,601,531 
            1,585,550 
$12,426
73123
WJBK
          5,748,623 
            5,711,224 
$44,759
37174
WJCL
             938,086 
               938,086 
$7,352
73130
WJCT
          1,624,624 
            1,624,033 
$12,728
29719
WJEB-TV
          1,607,510 
            1,607,510 
$12,598
65749
WJET-TV
             747,431 
               717,721 
$5,625
7651
WJFB
          1,744,291 
            1,736,932 
$13,612
49699
WJFW-TV
             277,530 
               268,295 
$2,103
73136
WJHG-TV
             864,121 
               859,823 
$6,738
57826
WJHL-TV*
          2,037,793 
            1,428,213 
$11,193
68519
WJKT
             654,460 
               653,378 
$5,121
1051
WJLA-TV*
          8,750,706
            8,447,643
$66,204
86537
WJLP
        21,384,863 
          21,119,366 
$165,512
9630
WJMN-TV
             160,991 
               154,424 
$1,210
61008
WJPM-TV
             623,965 
               623,813 
$4,889
58340
WJPX
          3,254,481 
            3,008,658 
$19,594
21735
WJRT-TV
          2,788,684 
            2,543,446 
$19,933
23918
WJSP-TV
          4,225,860 
            4,188,428 
$32,825
41210
WJTC
          1,347,474 
            1,346,205 
$10,550
48667
WJTV
             987,206 
               980,717 
$7,686
73150
WJW
          3,977,148 
            3,905,325 
$30,606
61007
WJWJ-TV
          1,008,890 
            1,008,890 
$7,907
58342
WJWN-TV
          1,962,885 
            1,690,961 
$4,706
53116
WJXT
          1,608,682 
            1,608,682 
$12,607
11893
WJXX
          1,618,191 
            1,617,272 
$12,675
32334
WJYS
          9,647,321 
            9,647,299 
$75,606
25455
WJZ-TV*
          9,253,891 
            8,902,229 
$69,767
73152
WJZY
          4,432,745 
            4,301,117 
$33,708
64983
WKAQ-TV
          3,697,088 
            3,287,110 
$21,407
6104
WKAR-TV
          1,693,373 
            1,689,830 
$13,243
34171
WKAS
             503,790 
               476,158 
$3,732
51570
WKBD-TV
          5,065,617 
            5,065,350 
$39,697
73153
WKBN-TV
          4,898,622 
            4,535,576 
$35,545
13929
WKBS-TV
             831,411 
               682,182 
$5,346
74424
WKBT-DT
             866,325 
               824,795 
$6,464
54176
WKBW-TV
          2,033,929 
            1,942,743 
$15,225
53465
WKCF
          4,032,154 
            4,031,823 
$31,597
73155
WKEF
          3,623,762 
            3,619,081 
$28,363
34177
WKGB-TV
             384,474 
               382,825 
$3,000
34196
WKHA
             511,281 
               400,721 
$3,140
34207
WKLE
             837,269 
               825,691 
$6,471
34212
WKMA-TV
             454,447 
               453,482 
$3,554
71293
WKMG-TV
          3,803,492 
            3,803,492 
$29,808
34195
WKMJ-TV
          1,426,739 
            1,417,865 
$11,112
34202
WKMR
             463,316 
               428,462 
$3,358
34174
WKMU
             329,306 
               328,918 
$2,578
42061
WKNO
          1,645,867 
            1,642,092 
$12,869
83931
WKNX-TV
          1,684,178 
            1,459,493 
$11,438
34205
WKOH
             550,854 
               547,801 
$4,293
67869
WKOI-TV
          3,660,544 
            3,646,874 
$28,581
34211
WKON
             905,003 
               895,953 
$7,022
18267
WKOP-TV
          1,555,654 
            1,382,098 
$10,832
64545
WKOW
          1,918,224 
            1,899,746 
$14,888
21432
WKPC-TV
          1,489,989 
            1,481,948 
$11,614
65758
WKPD
             242,844 
               241,796 
$1,895
34200
WKPI-TV
             469,081 
               408,968 
$3,205
27504
WKPT-TV
          1,131,213 
               887,806 
$6,958
58341
WKPV
          1,132,932 
               879,902 
$4,706
11289
WKRC-TV
          3,281,914 
            3,229,223 
$25,307
73187
WKRG-TV
          1,526,600 
            1,526,075 
$11,960
73188
WKRN-TV
          2,410,573 
            2,388,802 
$18,721
34222
WKSO-TV
             586,871 
               573,741 
$4,496
40902
WKTC
          1,386,422 
            1,385,850 
$10,861
60654
WKTV
          1,573,503 
            1,342,387 
$10,520
73195
WKYC
          4,154,903 
            4,099,508 
$32,128
24914
WKYT-TV
          1,174,615 
            1,156,978 
$9,067
71861
WKYU-TV
             411,448 
               409,310 
$3,208
34181
WKZT-TV
             957,158 
               927,375 
$7,268
18819
WLAE-TV
          1,397,967 
            1,397,967 
$10,956
36533
WLAJ
          1,865,669 
            1,858,982 
$14,569
2710
WLAX
             513,319 
               488,216 
$3,826
68542
WLBT
             948,671 
               947,857 
$7,428
39644
WLBZ
             373,129 
               364,346 
$2,855
69328
WLED-TV
             338,110 
               159,958 
$1,254
63046
WLEF-TV
             192,283 
               191,149 
$1,498
73203
WLEX-TV
             969,543 
               964,107 
$7,556
37806
WLFB
             808,036 
               680,534 
$5,333
37808
WLFG
          1,614,321 
            1,282,063 
$10,048
73204
WLFI-TV
          2,243,009 
            2,221,313 
$17,408
73205
WLFL
          3,640,360 
            3,636,542 
$28,500
11113
WLGA
             950,018 
               943,236 
$7,392
19777
WLII-DT
          2,801,102 
            2,591,533 
$16,877
37503
WLIO*
          1,067,232 
            1,050,170 
$8,230
38336
WLIW
        14,117,756 
          13,993,724 
$109,669
27696
WLJC-TV*
          1,401,072 
            1,281,256 
$10,041
71645
WLJT-DT
             385,493 
               385,380 
$3,020
53939
WLKY
          1,854,829 
            1,847,195 
$14,476
11033
WLLA
          2,041,934 
            2,041,852 
$16,002
17076
WLMB
          2,754,484 
            2,747,490 
$21,532
68518
WLMT
          1,736,552 
            1,733,496 
$13,585
22591
WLNE-TV
          5,705,441 
            5,630,394 
$44,125
74420
WLNS-TV
          1,865,669 
            1,858,982 
$14,569
73206
WLNY-TV
          7,501,199 
            7,415,578 
$58,116
84253
WLOO
             913,960 
               912,674 
$7,153
56537
WLOS*
          3,086,751 
            2,544,360 
$19,940
37732
WLOV-TV
             609,526 
               607,780 
$4,763
13995
WLOX
          1,182,149 
            1,170,659 
$9,174
38586
WLPB-TV
          1,219,624 
            1,219,407 
$9,556
73189
WLPX-TV
          1,021,171 
               921,974 
$7,226
66358
WLRN-TV
          5,447,399 
            5,447,399 
$42,691
73226
WLS-TV
        10,174,464 
          10,170,757 
$79,708
73230
WLTV-DT
          5,427,398 
            5,427,398 
$42,535
37176
WLTX
          1,580,677 
            1,578,645 
$12,372
37179
WLTZ
             689,521 
               685,358 
$5,371
21259
WLUC-TV
               92,246 
                 85,393 
$669
4150
WLUK-TV
          1,251,563 
            1,247,463 
$9,776
73238
WLVI
          7,319,659 
            7,236,210 
$56,710
36989
WLVT-TV*
        10,613,847 
          9,474,797 
$74,254
3978
WLWC
          3,281,532 
            3,150,875 
$24,693
46979
WLWT
          3,319,556 
            3,302,292 
$25,880
54452
WLXI
          4,021,948 
            4,004,902 
$31,386
55350
WLYH
          2,829,585 
            2,367,000 
$18,550
43192
WMAB-TV
             407,794 
               401,487 
$3,146
43170
WMAE-TV
             653,542 
               625,084 
$4,899
43197
WMAH-TV
          1,257,393 
            1,256,995 
$9,851
43176
WMAO-TV
             369,696 
               369,343 
$2,895
47905
WMAQ-TV
          9,914,395 
            9,913,272 
$77,690
59442
WMAR-TV
          9,203,498 
            9,065,260 
$71,044
43184
WMAU-TV
             642,328 
               636,504 
$4,988
43193
WMAV-TV
          1,008,339 
            1,008,208 
$7,901
43169
WMAW-TV
             732,079 
               718,446 
$5,630
46991
WMAZ-TV
          1,185,678 
            1,136,616 
$8,908
66398
WMBB
             935,027 
               914,607 
$7,168
43952
WMBC-TV
        18,706,132 
          18,458,331 
$144,658
42121
WMBD-TV
             733,039 
               732,987 
$5,744
83969
WMBF-TV
             445,363 
               445,363 
$3,490
60829
WMCF-TV
             593,205 
               589,513 
$4,620
9739
WMCN-TV
        10,379,045 
            9,982,651 
$78,234
19184
WMC-TV
          2,047,403 
            2,043,125 
$16,012
189357
WMDE
          6,384,827 
            6,257,910 
$49,043
73255
WMDN
             278,227 
               278,018 
$2,179
16455
WMDT
             731,931 
               731,931 
$5,736
39656
WMEA-TV
             774,785 
               746,033 
$5,847
39648
WMEB-TV
             511,761 
               494,574 
$3,876
70537
WMEC
             217,940 
               217,671 
$1,706
39649
WMED-TV
               30,488 
                 29,577 
$232
39662
WMEM-TV
               71,700 
                 69,981 
$548
41893
WMFD-TV
          1,561,367 
            1,324,244 
$10,378
41436
WMFP
          5,792,048 
            5,564,295 
$43,607
61111
WMGM-TV
             807,797 
               807,797 
$6,331
43847
WMGT-TV
             601,894 
               601,309 
$4,712
73263
WMHT
          1,622,458 
            1,472,559 
$11,540
68545
WMLW-TV
          1,822,297 
            1,822,217 
$14,281
53819
WMOR-TV
          5,386,517 
            5,386,358 
$42,213
81503
WMOW
             121,150 
               106,115 
$832
65944
WMPB
          6,489,215 
            6,375,063 
$49,961
43168
WMPN-TV
             856,237 
               854,089 
$6,693
65942
WMPT
          7,945,122 
            7,905,666 
$61,957
60827
WMPV-TV
          1,395,611 
            1,395,036 
$10,933
10221
WMSN-TV
          1,579,847 
            1,567,031 
$12,281
2174
WMTJ
          3,143,148 
            2,846,339 
$18,537
6870
WMTV
          1,548,616 
            1,545,459 
$12,112
73288
WMTW
          1,940,292 
            1,658,816 
$13,000
23935
WMUM-TV
             862,740 
               859,204 
$6,734
73292
WMUR-TV
          5,192,179 
            5,003,980 
$39,216
42663
WMVS*
          3,172,534 
            3,112,231 
$24,391
42665
WMVT*
          3,172,534 
            3,112,231 
$24,391
81946
WMWC-TV
             946,858 
               916,989 
$7,186
56548
WMYA-TV
          1,577,439 
            1,516,026 
$11,881
74211
WMYD
          5,750,989 
            5,750,873 
$45,070
20624
WMYT-TV
          4,432,745 
            4,301,117 
$33,708
25544
WMYV
          3,808,852 
            3,786,057 
$29,671
73310
WNAB
          2,072,197 
            2,059,474 
$16,140
73311
WNAC-TV
          7,310,183 
            6,959,064 
$54,538
47535
WNBC
        20,072,714 
          19,699,252 
$154,383
83965
WNBW-DT
             633,243 
               631,197 
$4,947
72307
WNCF
             667,683 
               665,950 
$5,219
50782
WNCN*
          3,795,494 
            3,783,131 
$29,648
57838
WNCT-TV
          1,933,527 
            1,879,655 
$14,731
41674
WNDU-TV
          1,807,909 
            1,783,617 
$13,978
28462
WNDY-TV
          2,912,963 
            2,855,253 
$22,377
71928
WNED-TV
          1,364,333 
            1,349,085 
$10,573
60931
WNEH
          1,261,482 
            1,255,218 
$9,837
41221
WNEM-TV
          1,617,082 
            1,612,561 
$12,638
49439
WNEO
          3,151,964 
            3,105,545 
$24,338
73318
WNEP-TV
          3,131,848 
            2,484,949 
$19,475
18795
WNET
        20,826,756 
          20,387,649 
$159,778
51864
WNEU
          3,471,700 
            3,354,177 
$26,287
23942
WNGH-TV
          3,715,479 
            3,482,438 
$27,292
67802
WNIN
             883,322 
               865,128 
$6,780
41671
WNIT
          1,298,159 
            1,298,159 
$10,174
48457
WNJB*
        20,787,272 
          20,036,393 
$157,025
48477
WNJN*
        20,787,272 
          20,036,393 
$157,025
48481
WNJS
          7,211,292 
            7,176,711 
$56,244
48465
WNJT
          7,211,292 
            7,176,711 
$56,244
73333
WNJU
        21,952,082 
          21,399,204 
$167,706
73336
WNJX-TV
          1,585,248 
            1,383,235 
$2,398
61217
WNKY
             385,619 
               383,911 
$3,009
71905
WNLO
          1,538,108 
            1,502,969 
$11,779
4318
WNMU
             181,730 
               177,763 
$1,393
73344
WNNE
             792,551 
               676,539 
$5,302
54280
WNOL-TV
          1,632,389 
            1,632,389 
$12,793
71676
WNPB-TV
          1,578,317 
            1,446,630 
$11,337
62137
WNPI-DT
             167,931 
               161,748 
$1,268
41398
WNPT
          2,260,463 
            2,227,570 
$17,457
28468
WNPX-TV
          2,216,131 
            2,209,662 
$17,317
61009
WNSC-TV
          2,072,821 
            2,067,933 
$16,206
61010
WNTV
          2,419,841 
            2,211,019 
$17,328
16539
WNTZ-TV
             344,704 
               343,849 
$2,695
7933
WNUV
          9,098,694 
            8,906,508 
$69,800
9999
WNVC
             723,698 
               490,045 
$3,840
10019
WNVT
          1,582,094 
            1,581,725 
$12,396
73354
WNWO-TV
          2,232,660 
            2,232,660 
$17,497
136751
WNYA
          1,540,430 
            1,406,032 
$11,019
30303
WNYB*
          1,785,269 
            1,756,096 
$13,763
6048
WNYE-TV
        19,185,983 
          19,015,910 
$149,028
34329
WNYI
          1,627,542 
            1,338,811 
$10,492
67784
WNYO-TV
          1,539,525 
            1,499,591 
$11,752
58725
WNYS-TV
          1,690,696 
            1,445,505 
$11,328
73363
WNYT*
          1,679,494 
            1,516,775 
$11,887
22206
WNYW
        20,075,874 
          19,753,060 
$154,805
69618
WOAI-TV
          2,525,811 
            2,513,887 
$19,701
66804
WOAY-TV
             569,330 
               416,995 
$3,268
41225
WOFL
          3,941,895 
            3,938,046 
$30,862
70651
WOGX
          1,112,408 
            1,112,408 
$8,718
8661
WOI-DT*
          1,173,757 
            1,170,432 
$9,173
39746
WOIO
          3,821,233 
            3,745,335 
$29,352
71725
WOLE-DT*1
          2,503,603 
            947,174 
$7,423
73375
WOLF-TV
          3,006,606 
            2,425,396 
$19,008
60963
WOLO-TV
          2,635,115 
            2,590,158 
$20,299
36838
WOOD-TV
          2,507,053 
            2,501,084 
$19,601
67602
WOPX-TV
          3,826,498 
            3,826,259 
$29,986
64865
WORA-TV
          2,733,629 
            2,586,149 
$2,893
73901
WORO-DT*
          3,243,301 
            3,022,553 
$20,711
60357
WOST
          1,193,381 
            1,027,391 
$6,691
66185
WOSU-TV
          2,649,515 
            2,617,817 
$20,516
131
WOTF-TV
          3,288,537 
            3,288,535 
$25,772
10212
WOTV
          2,277,566 
            2,277,258 
$17,847
50147
WOUB-TV
             756,762 
               734,988 
$5,760
50141
WOUC-TV
          1,713,515 
            1,649,853 
$12,930
23342
WOWK-TV*
          1,159,175 
            1,082,354 
$8,482
65528
WOWT
          1,380,979 
            1,377,287 
$10,794
31570
WPAN
             637,347 
               637,347 
$4,995
4190
WPBA
          5,217,180 
            5,200,958 
$40,760
51988
WPBF
          3,190,307 
            3,186,405 
$24,972
21253
WPBN-TV
             411,213 
               394,778 
$3,094
62136
WPBS-DT
             338,448 
               301,692 
$2,364
13456
WPBT
          5,416,604 
            5,416,604 
$42,450
13924
WPCB-TV
          2,934,614 
            2,800,516 
$21,948
64033
WPCH-TV
          5,948,778 
            5,874,163 
$46,036
4354
WPCT
             195,270 
               194,869 
$1,527
69880
WPCW
          3,393,365 
            3,188,441 
$24,988
17012
WPDE-TV
          1,764,645 
            1,762,758 
$13,815
52527
WPEC
          5,788,448 
            5,788,448 
$45,364
84088
WPFO
          1,329,690 
            1,209,873 
$9,482
54728
WPGA-TV
             559,495 
               559,004 
$4,381
60820
WPGD-TV
          2,355,629 
            2,343,715 
$18,368
73875
WPGH-TV
          3,132,507 
            3,007,511 
$23,570
2942
WPGX
             425,098 
               422,872 
$3,314
73879
WPHL-TV
        10,421,216 
          10,246,856 
$80,305
73881
WPIX
        20,638,932 
          20,213,158 
$158,411
53113
WPLG
          5,587,129 
            5,587,129 
$43,786
11906
WPMI-TV
          1,467,869 
            1,467,462 
$11,500
10213
WPMT
          2,412,561 
            2,191,501 
$17,175
18798
WPNE-TV
          1,132,868 
            1,132,699 
$8,877
73907
WPNT
          3,130,920 
            3,010,828 
$23,596
28480
WPPT*
        10,613,847 
          9,474,797
$74,254
51984
WPPX-TV
          8,206,117 
            7,995,941 
$62,664
47404
WPRI-TV
          7,254,721 
            6,990,606 
$54,785
51991
WPSD-TV
             883,812 
               878,287 
$6,883
12499
WPSG
        10,232,988 
            9,925,334 
$77,785
66219
WPSU-TV
          1,055,133 
               868,013 
$6,803
73905
WPTA
          1,099,180 
            1,099,180 
$8,614
25067
WPTD
          3,423,417 
            3,415,232 
$26,765
25065
WPTO
          2,912,159 
            2,893,581 
$22,677
59443
WPTV-TV
          5,840,102 
            5,840,102 
$45,769
57476
WPTZ
             792,551 
               676,539 
$5,302
8616
WPVI-TV*
        11,491,587 
          11,302,701 
$88,579
48772
WPWR-TV
          9,957,301 
            9,954,828 
$78,016
51969
WPXA-TV
          6,587,205 
            6,458,510 
$50,615
71236
WPXC-TV
          1,561,014 
            1,561,014 
$12,234
5800
WPXD-TV
          5,133,364 
            5,133,257 
$40,229
37104
WPXE-TV
          3,163,550 
            3,160,601 
$24,770
48406
WPXG-TV
          2,577,848 
            2,512,150 
$19,688
73312
WPXH-TV
          1,495,968 
            1,423,805 
$11,158
73910
WPXI
          3,300,896 
            3,197,864 
$25,062
2325
WPXJ-TV
          2,358,750 
            2,294,833 
$17,985
52628
WPXK-TV
          1,801,997 
            1,577,806 
$12,365
21729
WPXL-TV
          1,566,829 
            1,566,829 
$12,279
48608
WPXM-TV
          5,153,621 
            5,153,621 
$40,389
73356
WPXN-TV
        20,465,198 
          20,092,448 
$157,465
27290
WPXP-TV
          5,565,072 
            5,565,072 
$43,613
50063
WPXQ-TV
          3,281,532 
            3,150,875 
$24,693
70251
WPXR-TV
          1,375,640 
            1,200,331 
$9,407
40861
WPXS
          1,152,104 
            1,145,695 
$8,979
53065
WPXT
             760,491 
               735,051 
$5,761
37971
WPXU-TV
             690,613 
               690,613 
$5,412
67077
WPXV-TV
          1,905,128 
            1,905,128 
$14,930
74091
WPXW-TV
          8,091,469 
            8,044,165 
$63,042
21726
WPXX-TV
          1,562,675 
            1,560,834 
$12,232
73319
WQAD-TV
          1,079,594 
            1,066,743 
$8,360
65130
WQCW
          1,319,392 
            1,249,533 
$9,793
71561
WQEC
             183,969 
               183,690 
$1,440
41315
WQED
          3,529,305 
            3,426,684 
$26,855
3255
WQHA
          1,052,107 
               879,558 
$5,728
60556
WQHS-DT
          3,996,567 
            3,952,672 
$30,977
53716
WQLN
             602,212 
               571,790 
$4,481
52075
WQMY
             410,269 
               254,586 
$1,995
64550
WQOW
             369,066 
               358,576 
$2,810
5468
WQPT-TV
             595,685 
               595,437 
$4,666
64690
WQPX-TV
          1,644,283 
            1,212,587 
$9,503
52408
WQRF-TV
          1,326,695 
            1,305,762 
$10,233
2175
WQTO
          2,864,201 
            1,923,424 
$12,526
8688
WRAL-TV
          3,643,511 
            3,639,448 
$28,522
10133
WRAY-TV
          4,021,948 
            4,004,902 
$31,386
64611
WRAZ
          3,605,228 
            3,601,029 
$28,221
136749
WRBJ-TV
          1,030,831 
            1,028,010 
$8,057
3359
WRBL
          1,493,140 
            1,461,459 
$11,453
57221
WRBU
          2,737,188 
            2,734,806 
$21,433
54940
WRBW
          4,025,123 
            4,023,804 
$31,535
59137
WRCB
          1,587,742 
            1,363,582 
$10,686
47904
WRC-TV
          8,188,601 
            8,146,696 
$63,846
54963
WRDC
          3,624,288 
            3,620,526 
$28,374
55454
WRDQ
          3,931,023 
            3,931,023 
$30,807
73937
WRDW-TV
          1,564,584 
            1,533,682 
$12,019
66174
WREG-TV
          1,642,307 
            1,638,585 
$12,842
61011
WRET-TV
          2,419,841 
            2,211,019 
$17,328
73940
WREX
          2,303,027 
            2,047,951 
$16,050
54443
WRFB
          2,674,527 
            2,377,106 
$15,481
73942
WRGB*
          1,757,575 
            1,645,483 
$12,896
411
WRGT-TV
          3,252,046 
            3,219,309 
$25,230
74416
WRIC-TV
          1,996,265 
            1,939,664 
$15,201
61012
WRJA-TV
          1,127,088 
            1,119,936 
$8,777
412
WRLH-TV
          2,017,508 
            1,959,111 
$15,354
61013
WRLK-TV
          1,229,094 
            1,228,616 
$9,629
43870
WRLM
          3,919,602 
            3,892,146 
$30,503
74156
WRNN-TV
        19,853,836 
          19,615,370 
$153,726
73964
WROC-TV
          1,203,412 
            1,185,203 
$9,288
159007
WRPT
             110,009 
               109,937 
$862
20590
WRPX-TV
          2,637,949 
            2,634,141 
$20,644
62009
WRSP-TV
             904,190 
               902,682 
$7,074
40877
WRTV
          2,919,683 
            2,895,164 
$22,689
15320
WRUA
          2,905,193 
            2,552,782 
$16,625
71580
WRXY-TV
          1,633,655 
            1,633,655 
$12,803
48662
WSAV-TV
          1,000,315 
            1,000,309 
$7,839
6867
WSAW-TV
             652,442 
               646,386 
$5,066
36912
WSAZ-TV
          1,184,629 
            1,119,859 
$8,776
56092
WSBE-TV
          4,627,829 
            4,531,067 
$35,510
73982
WSBK-TV
          7,161,406 
            7,095,363 
$55,606
72053
WSBS-TV
               42,952 
                 42,952 
$337
73983
WSBT-TV
          1,691,194 
            1,682,136 
$13,183
23960
WSB-TV
          5,893,810 
            5,818,626 
$45,601
69446
WSCG
             867,516 
               867,490 
$6,799
64971
WSCV
          5,465,435 
            5,465,435 
$42,833
70536
WSEC
             522,349 
               521,730 
$4,089
49711
WSEE-TV
             613,176 
               595,476 
$4,667
21258
WSES
          1,548,117 
            1,513,982 
$11,865
73988
WSET-TV
          1,569,722 
            1,323,180 
$10,370
13993
WSFA
          1,168,636 
            1,133,724 
$8,885
11118
WSFJ-TV
          1,675,987 
            1,667,150 
$13,065
10203
WSFL-TV
          5,344,129 
            5,344,129 
$41,882
72871
WSFX-TV
             928,247 
               928,247 
$7,275
73999
WSIL-TV
             672,560 
               669,176 
$5,244
4297
WSIU-TV*
          1,019,939 
            937,070 
$7,344
74007
WSJV
          1,522,499 
            1,522,499 
$11,932
78908
WSKA
             546,588 
               431,354 
$3,381
74034
WSKG-TV
             892,439 
               624,282 
$4,892
76324
WSKY-TV
          1,934,585 
            1,934,519 
$15,161
57840
WSLS-TV
          1,447,286 
            1,277,753 
$10,014
21737
WSMH
          2,339,224 
            2,327,660 
$18,242
41232
WSMV-TV
          2,447,769 
            2,404,766 
$18,846
70119
WSNS-TV
          9,914,395 
            9,913,272 
$77,690
74070
WSOC-TV
          3,706,808 
            3,638,832 
$28,518
66391
WSPA-TV
          3,393,072 
            3,237,713 
$25,374
64352
WSPX-TV
          1,298,295 
            1,174,763 
$9,207
17611
WSRE
          1,355,168 
            1,354,307 
$10,614
63867
WSST-TV
             331,907 
               331,601 
$2,599
60341
WSTE-DT
          3,723,967 
            3,631,985 
$23,653
21252
WSTM-TV
          1,458,931 
            1,382,417 
$10,834
11204
WSTR-TV
          3,252,460 
            3,243,267 
$25,417
19776
WSUR-DT*2
          3,714,790 
            947,174 
$7,423
2370
WSVI
               50,601 
                 50,601 
$397
63840
WSVN
          5,588,748 
            5,588,748 
$43,799
73374
WSWB
          1,530,002 
            1,102,316 
$8,639
28155
WSWG
             381,004 
               380,910 
$2,985
71680
WSWP-TV
             858,726 
               659,416 
$5,168
74094
WSYM-TV
          1,516,677 
            1,516,390 
$11,884
73113
WSYR-TV
          1,329,933 
            1,243,035 
$9,742
40758
WSYT
          1,878,638 
            1,640,666 
$12,858
56549
WSYX
          2,635,937 
            2,584,043 
$20,251
65681
WTAE-TV
          2,995,755 
            2,860,979 
$22,421
23341
WTAJ-TV
          1,187,718 
               948,598 
$7,434
4685
WTAP-TV
             472,761 
               451,414 
$3,538
416
WTAT-TV
          1,153,279 
            1,153,279 
$9,038
67993
WTBY-TV
        15,858,470 
          15,766,438 
$123,562
29715
WTCE-TV
          2,620,599 
            2,620,599 
$20,538
65667
WTCI
          1,204,613 
            1,099,395 
$8,616
67786
WTCT
             584,661 
               584,006 
$4,577
28954
WTCV
          3,254,481 
            3,008,658 
$19,594
74422
WTEN
          1,902,431 
            1,613,747 
$12,647
9881
WTGL
          3,772,425 
            3,772,425 
$29,564
27245
WTGS
             967,792 
               967,630 
$7,583
70655
WTHI-TV
             928,934 
               886,846 
$6,950
70162
WTHR*
          2,949,339 
            2,901,633 
$22,740
147
WTIC-TV
          5,318,753 
            4,707,697 
$36,894
26681
WTIN-TV
          3,714,547 
            3,487,634 
$2,398
66536
WTIU
          1,131,685 
            1,131,161 
$8,865
1002
WTJP-TV
          1,947,743 
            1,907,300 
$14,948
4593
WTJR
             334,527 
               334,221 
$2,619
70287
WTJX-TV
             135,017 
               121,498 
$952
47401
WTKR
          2,142,272 
            2,142,084 
$16,788
82735
WTLF
             349,696 
               349,691 
$2,741
23486
WTLH
          1,038,086 
            1,038,086 
$8,135
67781
WTLJ
          1,622,365 
            1,621,227 
$12,706
65046
WTLV
          1,757,600 
            1,739,021 
$13,629
1222
WTLW
          1,646,714 
            1,644,206 
$12,886
74098
WTMJ-TV
          3,010,678 
            2,995,959 
$23,479
74109
WTNH
          7,845,782 
            7,332,431 
$57,464
19200
WTNZ
          1,699,427 
            1,513,754 
$11,863
590
WTOC-TV
             993,098 
               992,658 
$7,779
74112
WTOG
          4,796,964 
            4,796,188 
$37,588
4686
WTOK-TV
             410,134 
               404,555 
$3,170
13992
WTOL
          4,184,020 
            4,174,198 
$32,713
21254
WTOM-TV
               83,379 
                 81,092 
$636
74122
WTOV-TV
          3,892,886 
            3,619,899 
$28,369
82574
WTPC-TV*
          2,049,246 
            2,042,851 
$16,010
86496
WTPX-TV
             255,972 
               255,791 
$2,005
6869
WTRF-TV
          2,941,511 
            2,565,375 
$20,105
67798
WTSF
             593,934 
               552,040 
$4,326
11290
WTSP*
          5,511,840 
            5,494,925 
$43,064
4108
WTTA
          5,450,070 
            5,446,811 
$42,687
74137
WTTE
          2,636,341 
            2,591,715 
$20,311
22207
WTTG
          8,070,491 
            8,015,328 
$62,816
56526
WTTK
          2,817,698 
            2,794,018 
$21,897
74138
WTTO
          1,817,151 
            1,786,516 
$14,001
56523
WTTV
          2,362,145 
            2,359,408 
$18,491
10802
WTTW
          9,729,982 
            9,729,634 
$76,251
74148
WTVA
             717,035 
               709,726 
$5,562
22590
WTVC
          1,579,628 
            1,366,976 
$10,713
8617
WTVD*
          3,793,909 
            3,778,802 
$29,614
55305
WTVE
          5,156,905 
            5,152,997 
$40,384
36504
WTVF
          2,416,110 
            2,397,634 
$18,790
74150
WTVG
          4,274,274 
            4,263,894 
$33,416
74151
WTVH
          1,350,223 
            1,275,171 
$9,994
10645
WTVI
          2,853,540 
            2,824,869 
$22,138
63154
WTVJ
          5,458,451 
            5,458,451 
$42,778
595
WTVM
          1,498,667 
            1,405,957 
$11,018
72945
WTVO
          1,409,708 
            1,398,825 
$10,963
28311
WTVP
             679,017 
               678,672 
$5,319
51597
WTVQ-DT
             989,180 
               982,298 
$7,698
57832
WTVR-TV
          1,808,516 
            1,802,164 
$14,124
16817
WTVS
          5,511,639 
            5,511,255 
$43,192
68569
WTVT
          5,475,385 
            5,462,416 
$42,809
3661
WTVW
             791,430 
               789,720 
$6,189
35575
WTVX
          3,157,609 
            3,157,609 
$24,746
4152
WTVY
             974,532 
               971,173 
$7,611
40759
WTVZ-TV
          2,156,534 
            2,156,346 
$16,899
66908
WTWC-TV
          1,032,942 
            1,032,942 
$8,095
20426
WTWO
             737,757 
               731,769 
$5,735
81692
WTWV
          1,527,511 
            1,526,625 
$11,964
51568
WTXF-TV
        10,784,256 
          10,492,549 
$82,230
41065
WTXL-TV
          1,054,514 
            1,054,322 
$8,263
8532
WUAB
          3,821,233 
            3,745,335 
$29,352
12855
WUCF-TV
          3,772,425 
            3,772,425 
$29,564
36395
WUCW
          3,664,480 
            3,657,236 
$28,662
69440
WUFT
          1,372,142 
            1,372,142 
$10,753
413
WUHF
          1,152,580 
            1,147,972 
$8,997
8156
WUJA
          2,638,361 
            2,379,555 
$15,497
69080
WUNC-TV
          4,021,948 
            4,004,902 
$31,386
69292
WUND-TV
          1,506,640 
            1,506,640 
$11,808
69114
WUNE-TV
          1,931,274 
            1,527,025 
$11,967
69300
WUNF-TV
          2,447,306 
            2,066,422 
$16,195
69124
WUNG-TV
          3,267,425 
            3,253,352 
$25,497
60551
WUNI
          7,209,571 
            7,084,349 
$55,520
69332
WUNJ-TV
          1,081,274 
            1,081,274 
$8,474
69149
WUNK-TV
          2,018,916 
            2,013,516 
$15,780
69360
WUNL-TV
          2,614,031 
            2,545,330 
$19,948
69444
WUNM-TV
          1,029,109 
            1,029,109 
$8,065
69397
WUNP-TV
          1,018,414 
            1,009,833 
$7,914
69416
WUNU
          1,120,792 
            1,117,140 
$8,755
83822
WUNW
          1,109,237 
               570,072 
$4,468
6900
WUPA
          5,946,477 
            5,865,122 
$45,965
13938
WUPL
          1,632,100 
            1,632,100 
$12,791
10897
WUPV
          1,933,664 
            1,914,643 
$15,005
19190
WUPW
          2,074,890 
            2,073,548 
$16,250
23128
WUPX-TV
          1,102,435 
            1,089,118 
$8,535
65593
WUSA*
          8,750,706 
            8,446,074 
$66,192
4301
WUSI-TV
             304,747 
               304,747 
$2,388
60552
WUTB
          8,509,757 
            8,339,882 
$65,360
30577
WUTF-TV
          8,557,497 
            8,242,833 
$64,599
57837
WUTR
             526,114 
               481,957 
$3,777
415
WUTV
          1,405,230 
            1,380,902 
$10,822
16517
WUVC-DT
          3,768,817 
            3,748,841 
$29,380
48813
WUVG-DT
          6,029,495 
            5,965,975 
$46,755
3072
WUVN
          1,233,568 
            1,157,140 
$9,069
60560
WUVP-DT
        10,421,216 
          10,246,856 
$80,305
9971
WUXP-TV
          2,316,872 
            2,305,293 
$18,067
417
WVAH-TV
          1,373,707 
            1,300,402 
$10,191
23947
WVAN-TV
             979,764 
               978,920 
$7,672
65387
WVBT
          1,848,277 
            1,848,277 
$14,485
72342
WVCY-TV
          2,543,642 
            2,542,235 
$19,923
60559
WVEA-TV
          4,283,915 
            4,283,854 
$33,573
74167
WVEC*
          2,096,709 
            2,090,875 
$16,386
5802
WVEN-TV
          3,607,540 
            3,607,540 
$28,272
61573
WVEO
          1,153,382 
               916,310 
$4,706
69946
WVER
             760,072 
               579,703 
$4,543
10976
WVFX
             731,193 
               609,763 
$4,779
47929
WVIA-TV
          3,131,848 
            2,484,949 
$19,475
3667
WVII-TV
             368,022 
               346,874 
$2,718
70309
WVIR-TV
          1,944,353 
            1,801,429 
$14,118
74170
WVIT
          5,846,093 
            5,357,639 
$41,988
18753
WVIZ
          3,695,223 
            3,689,173 
$28,912
70021
WVLA-TV
          1,897,179 
            1,897,007 
$14,867
81750
WVLR
          1,412,728 
            1,292,471 
$10,129
35908
WVLT-TV
          1,888,607 
            1,633,633 
$12,803
74169
WVNS-TV
             911,630 
               606,820 
$4,756
11259
WVNY
             721,176 
               620,257 
$4,861
29000
WVOZ-TV
          1,132,932 
               879,902 
$4,706
71657
WVPB-TV
             780,268 
               752,747 
$5,899
60111
WVPT*
             756,714 
               632,580 
$4,958
70491
WVPX-TV
          4,147,298 
            4,114,920 
$32,249
66378
WVPY*
             756,202 
               632,155 
$4,954
67190
WVSN
          2,948,832 
            2,572,001 
$16,750
69943
WVTA
             760,072 
               579,703 
$4,543
69940
WVTB
             454,244 
               258,422 
$2,025
74173
WVTM-TV
          1,876,825 
            1,790,198 
$14,030
74174
WVTV
          2,999,694 
            2,990,991 
$23,440
77496
WVUA
          2,209,921 
            2,160,101 
$16,929
4149
WVUE-DT
          1,658,125 
            1,658,125 
$12,995
4329
WVUT
             273,293 
               273,219 
$2,141
74176
WVVA
          1,035,752 
               693,707 
$5,437
3113
WVXF
               85,191 
                 78,556 
$616
12033
WWAY
          1,206,281 
            1,206,281 
$9,454
30833
WWBT
          1,911,854 
            1,872,305 
$14,673
20295
WWCP-TV
          2,811,278 
            2,548,691 
$19,974
24812
WWCW
          1,390,985 
            1,212,308 
$9,501
23671
WWDP
          5,792,048 
            5,564,295 
$43,607
21158
WWHO
          2,879,726 
            2,805,564 
$21,987
14682
WWJE-DT
          7,209,571 
            7,084,349 
$55,520
72123
WWJ-TV
          5,374,064 
            5,373,712 
$42,114
166512
WWJX
             518,866 
               518,846 
$4,066
6868
WWLP
          3,838,272 
            3,077,800 
$24,121
74192
WWL-TV
          1,756,442 
            1,756,442 
$13,765
3133
WWMB
          1,460,406 
            1,458,374 
$11,429
74195
WWMT
          2,460,942 
            2,455,432 
$19,243
68851
WWNY-TV
             365,677 
               341,029 
$2,673
74197
WWOR-TV
        19,853,836 
          19,615,370 
$153,726
65943
WWPB
          2,015,352 
            1,691,003 
$13,252
23264
WWPX-TV
          3,892,904 
            3,196,922 
$25,054
68547
WWRS-TV
          2,235,958 
            2,212,123 
$17,336
61251
WWSB
          3,340,133 
            3,340,133 
$26,177
23142
WWSI
        11,269,831 
          11,098,540 
$86,979
16747
WWTI
             196,531 
               190,097 
$1,490
998
WWTO-TV
          5,541,816 
            5,541,816 
$43,431
26994
WWTV
          1,034,174 
            1,022,322 
$8,012
84214
WWTW
          1,527,511 
            1,526,625 
$11,964
26993
WWUP-TV
             116,638 
               110,592 
$867
23338
WXBU
          4,030,693 
            3,538,096 
$27,728
61504
WXCW
          1,749,847 
            1,749,847 
$13,714
61084
WXEL-TV
          5,416,604 
            5,416,604 
$42,450
60539
WXFT-DT
        10,174,464 
          10,170,757 
$79,708
23929
WXGA-TV
             608,494 
               606,801 
$4,755
51163
WXIA-TV
          6,179,680 
            6,035,828 
$47,303
53921
WXII-TV
          3,630,551 
            3,299,114 
$25,855
146
WXIN
          2,721,639 
            2,699,366 
$21,155
39738
WXIX-TV
          2,825,570 
            2,797,385 
$21,923
414
WXLV-TV
          4,362,761 
            4,333,737 
$33,963
68433
WXMI
          1,988,970 
            1,988,589 
$15,585
64549
WXOW
             425,378 
               413,264 
$3,239
6601
WXPX-TV
          4,566,037 
            4,564,088 
$35,769
74215
WXTV-DT
        19,992,096 
          19,643,518 
$153,946
12472
WXTX
             699,095 
               694,837 
$5,445
11970
WXXA-TV*
          1,680,670 
            1,546,103 
$12,117
57274
WXXI-TV
          1,178,402 
            1,163,073 
$9,115
53517
WXXV-TV
          1,201,440 
            1,199,901 
$9,404
10267
WXYZ-TV
          5,591,434 
            5,590,748 
$43,815
12279
WYCC
          9,729,982 
            9,729,634 
$76,251
77515
WYCI
               35,873 
                 26,508 
$208
70149
WYCW
          3,393,072 
            3,237,713 
$25,374
62219
WYDC
             393,843 
               262,013 
$2,053
18783
WYDN
          2,577,848 
            2,512,150 
$19,688
35582
WYDO
          1,097,745 
            1,097,745 
$8,603
25090
WYES-TV
          1,872,245 
            1,872,059 
$14,671
53905
WYFF
          2,626,363 
            2,416,551 
$18,939
49803
WYIN
          6,956,141 
            6,956,141 
$54,515
24915
WYMT-TV
          1,180,276 
               863,881 
$6,770
17010
WYOU*
          2,879,196 
            2,221,179 
$17,407
77789
WYOW
               91,233 
                 90,799 
$712
13933
WYPX-TV
          1,529,500 
            1,413,583 
$11,078
4693
WYTV
          4,898,622 
            4,535,576 
$35,545
5875
WYZZ-TV
          1,042,140 
            1,036,721 
$8,125
15507
WZBJ
          1,606,844 
            1,439,716 
$11,283
28119
WZDX
          1,557,490 
            1,452,851 
$11,386
70493
WZME
          5,996,408 
            5,544,708 
$43,454
81448
WZMQ
               73,423 
                 72,945 
$572
71871
WZPX-TV
          2,094,029 
            2,093,653 
$16,408
136750
WZRB
             952,279 
               951,693 
$7,458
418
WZTV
          2,311,143 
            2,299,730 
$18,023
83270
WZVI
               76,992 
                 75,863 
$595
19183
WZVN-TV
          1,916,098 
            1,916,098 
$15,016
49713
WZZM
          1,574,546 
            1,548,835 
$12,138

Note:  The list of call signs above include all feeable and exempt entities.  It is the responsibility of licensees to inform the Commission of any status changes.  As stated in the FY 2020 Report and Order and Notice of Proposed Rulemaking, the fee of full-power television stations in Puerto Rico have been adjusted to reflect losses in population on the island since the 2010 U.S. Census. 
* The call signs with an (*) denote VHF stations licensed with a power level that exceeds the maximum based on the maximum power level specified for channels 2-6 in 73.622(f)(6) and for channels 7-13 in 73.622(f)(7).  The population counts have been adjusted accordingly.

1 Call signs WOLE and WLII are stations in Puerto Rico that are linked together with a total fee of $24,300. 
2 Call signs WSUR and WLII are stations in Puerto Rico that are linked together with a total fee of $24,300.




APPENDIX H

FY 2019 Regulatory Fees

Regulatory fees for the categories shaded in gray are collected by the Commission in advance to cover the term of the license and are submitted at the time the application is filed.
			

Fee Category

Annual Regulatory Fee
(U.S. $s)
PLMRS (per license) (Exclusive Use) (47 CFR part 90)
25
Microwave (per license) (47 CFR part 101)	
25
Marine (Ship) (per station) (47 CFR part 80)
15
Marine (Coast) (per license) (47 CFR part 80)
40
Rural Radio (47 CFR part 22) (previously listed under the Land Mobile category)
10
PLMRS (Shared Use) (per license) (47 CFR part 90)
10
Aviation (Aircraft) (per station) (47 CFR part 87)			
10
Aviation (Ground) (per license) (47 CFR part 87)	
20
CMRS Mobile/Cellular Services (per unit) (47 CFR parts 20, 22, 24, 27, 80 and 90)
.19
CMRS Messaging Services (per unit) (47 CFR parts 20, 22, 24 and 90)
.08
Broadband Radio Service (formerly MMDS/ MDS) (per license) (47 CFR part 27)
Local Multipoint Distribution Service (per call sign) (47 CFR, part 101)

690

690
AM Radio Construction Permits
595
FM Radio Construction Permits
1,000
AM and FM Broadcast Radio Station Fees
See Table Below
Digital TV (47 CFR part 73) VHF and UHF Commercial Fee Factor
$.007224
See Appendix. J for fee amounts due, also available at
https://www.fcc.gov/licensing-databases/fees/regulatory-fees
	Construction Permits
4,450
Low Power TV, Class A TV, TV/FM Translators & Boosters (47 CFR part 74)
345
CARS (47 CFR part 78)	
1,225
Cable Television Systems (per subscriber) (47 CFR part 76), Including IPTV
.86
Direct Broadcast Service (DBS) (per subscriber) (as defined by section 602(13) of the Act)
.60
Interstate Telecommunication Service Providers (per revenue dollar)
.00317
Toll Free (per toll free subscriber) (47 CFR section 52.101 (f) of the rules)
.12
Earth Stations (47 CFR part 25)
425
Space Stations (per operational station in geostationary orbit) (47 CFR part 25) also includes DBS Service (per operational station) (47 CFR part 100)

159,625
Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25)
154,875
International Bearer Circuits - Terrestrial/Satellites (per Gbps circuit)
121
Submarine Cable Landing Licenses Fee (per cable system) 
See Table Below

FY 2019 RADIO STATION REGULATORY FEES
Population 
Served
AM Class A
AM Class B
AM Class C
AM Class D
FM Classes
A, B1 & C3
FM Classes
B, C, C0, C1 & C2
<=25,000
$950
$685
$595
$655
$1,000
$1,200
25,001 – 75,000
$1,425
$1,000
$895
$985
$1,575
$1,800
75,001 – 150,000
$2,150
$1,550
$1,350
$1,475
$2,375
$2,700
150,001 – 500,000
$3,200
$2,325
$2,000
$2,225
$3,550
$4,050
500,001 – 1,200,000
$4,800
$3,475
$3,000
$3,325
$5,325
$6,075
1,200,001 – 3,000,000
$7,225
$5,200
$4,525
$4,975
$7,975
$9,125
3,000,001 – 6,000,000
$10,825
$7,800
$6,775
$7,450
$11,950
$13,675
>6,000,000
$16,225
$11,700
$10,175
$11,200
$17,950
$20,500

FY 2019 International Bearer Circuits - Submarine Cable Systems

Submarine Cable Systems
(capacity as of December 31, 2018)
FY 2019 Regulatory Fees
Less than 50 Gbps
$12,575
50 Gbps or greater, but less than 250 Gbps
$25,150
250 Gbps or greater, but less than 1,000 Gbps
$50,300
1,000 Gbps or greater, but less than 4,000 Gbps
$100,600
4,000 Gbps or greater
$201,225


APPENDIX I
Final Regulatory Flexibility Analysis
1. As required by the Regulatory Flexibility Act of 1980, as amended (RFA), 5 U.S.C. § 603.  The RFA, 5 U.S.C. §§ 601-612 has been amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 847 (1996).
 an Initial Regulatory Flexibility Analysis (IRFA) was included in the Further Notice of Proposed Rulemaking. Assessment and Collection of Regulatory Fees for Fiscal Year 2019, Report and Order and Further Notice of Proposed Rulemaking, 34 FCC Rcd 8189 (2019) (FY 2019 FNPRM).
  The Commission sought written public comment on these proposals including comment on the IRFA.  This Final Regulatory Flexibility Analysis (FRFA) conforms to the IRFA. 5 U.S.C. § 604.
 
A. Need for, and Objectives of, the Report and Order  
2. In this Report and Order, the Commission assesses for the first time a regulatory fee on non-U.S. licensed space stations with United States market access, by including those non-U.S. licensed space stations in the current regulatory fee categories for GSO and NGSO space stations. This fee is assessed regardless of whether the foreign satellite operator obtains the market access through a declaratory ruling or through an earth station applicant as a point of communication.  In either case, the Commission’s review of the space station market access request is the same.  The earth station application may be filed by the foreign operator, one of its subsidiaries, or an independent third party.  Currently, the regulatory fee paid by an earth station licensee that has secured market access for a foreign satellite operator is the same as the fee paid by any other earth station licensee in its class, despite the additional Commission resources consumed by such market access requests.  For these reasons, and because it is inequitable and anticompetitive for U.S. licensed space stations to pay regulatory fees while non-U.S. licensed space stations with U.S. market access do not, the Commission assesses its existing GSO and NGSO regulatory fee categories on non-U.S. licensed space stations that have access to the United States market, either through a petition for market access or through an earth station.
B. Summary of the Significant Issues Raised by the Public Comments in Response to the IRFA
3. None.
C. Response to comments by the Chief Counsel for Advocacy of the Small Business Administration
4. Pursuant to the Small Business Jobs Act of 2010, which amended the RFA, the Commission is required to respond to any comments filed by the Chief Counsel for Advocacy of the Small Business Administration (SBA), and to provide a detailed statement of any change made to the proposed rules as a result of those comments.29 In this section respond specifically to any comment filed by Chief Counsel of SBA.  The Chief Counsel did not file any comments in response to the proposed rules in the Further Notice of Proposed Rulemaking in this proceeding
D. Description and Estimate of the Number of Small Entities to Which the Rules Will Apply:
5. The RFA directs agencies to provide a description of, and where feasible, an estimate of the number of small entities that may be affected by the proposed rules and policies, if adopted. 5 U.S.C. § 603(b)(3).
  The RFA generally defines the term “small entity” as having the same meaning as the terms “small business,” “small organization,” and “small governmental jurisdiction.” 5 U.S.C. § 601(6).
  In addition, the term “small business” has the same meaning as the term “small business concern” under the Small Business Act. 5 U.S.C. § 601(3) (incorporating by reference the definition of “small-business concern” in the Small Business Act, 15 U.S.C. § 632).  Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity for public comment, establishes one or more definitions of such term which are appropriate to the activities of the agency and publishes such definition(s) in the Federal Register.”
  A “small business concern” is one which: (1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any additional criteria established by the SBA. 15 U.S.C. § 632.
  Nationwide, there are a total of approximately 27.9 million small businesses, according to the SBA. See SBA, Office of Advocacy, “Frequently Asked Questions,” https://www.sba.gov/sites/default/files/advocacy/SB-FAQ-2016_WEB.pdf.
   
6. Small Businesses, Small Organizations, Small Governmental Jurisdictions.  Our actions, over time, may affect small entities that are not easily categorized at present.  We therefore describe here, at the outset, three broad groups of small entities that could be directly affected herein. See 5 U.S.C. § 601(3)-(6).
  First, while there are industry specific size standards for small businesses that are used in the regulatory flexibility analysis, according to data from the SBA’s Office of Advocacy, in general a small business is an independent business having fewer than 500 employees. See SBA, Office of Advocacy, “Frequently Asked Questions, Question 1 – What is a small business?” https://www.sba.gov/sites/default/files/advocacy/SB-FAQ-2016_WEB.pdf (June 2016).
  These types of small businesses represent 99.9% of all businesses in the United States which translates to 28.8 million businesses. See SBA, Office of Advocacy, “Frequently Asked Questions, Question 2- How many small businesses are there in the U.S.?” https://www.sba.gov/sites/default/files/advocacy/SB-FAQ-2016_WEB.pdf (June 2016).
  
7. Next, the type of small entity described as a “small organization” is generally “any not-for-profit enterprise which is independently owned and operated and is not dominant in its field.” 5 U.S.C. § 601(4).
  Nationwide, as of August 2016, there were approximately 356,494 small organizations based on registration and tax data filed by nonprofits with the Internal Revenue Service (IRS). Data from the Urban Institute, National Center for Charitable Statistics (NCCS) reporting on nonprofit organizations registered with the IRS was used to estimate the number of small organizations.  Reports generated using the NCCS online database indicated that as of August 2016 there were 356,494 registered nonprofits with total revenues of less than $100,000.   Of this number, 326,897 entities filed tax returns with 65,113 registered nonprofits reporting total revenues of $50,000 or less on the IRS Form 990-N for Small Exempt Organizations and 261,784 nonprofits reporting total revenues of $100,000 or less on some other version of the IRS Form 990 within 24 months of the August 2016 data release date.  See http://nccs.urban.org/sites/all/nccs-archive/html//tablewiz/tw.php where the report showing this data can be generated by selecting the following data fields: Report: “The Number and Finances of All Registered 501(c) Nonprofits”; Show: “Registered Nonprofits”; By: “Total Revenue Level (years 1995, Aug to 2016, Aug)”; and For: “2016, Aug” then selecting “Show Results.”
  
8. Finally, the small entity described as a “small governmental jurisdiction” is defined generally as “governments of cities, counties, towns, townships, villages, school districts, or special districts, with a population of less than fifty thousand.” 5 U.S.C. § 601(5).
  U.S. Census Bureau data from the 2012 Census of Governments See 13 U.S.C. § 161.  The Census of Government is conducted every five (5) years compiling data for years ending with “2” and “7”.  See also Program Description Census of Government https://factfinder.census.gov/faces/affhelp/jsf/pages/metadata.xhtml?lang=en&type=program&id=program.en.COG#
 indicate that there were 90,056 local governmental jurisdictions consisting of general purpose governments and special purpose governments in the United States. See U.S. Census Bureau, 2012 Census of Governments, Local Governments by Type and State: 2012 - United States-States, https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG02.US01.  Local governmental jurisdictions are classified in two categories - General purpose governments (county, municipal and town or township) and Special purpose governments (special districts and independent school districts).   
  Of this number there were 37, 132 General purpose governments (county See U.S. Census Bureau, 2012 Census of Governments, County Governments by Population-Size Group and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG06.US01.  There were 2,114 county governments with populations less than 50,000. 
, municipal and town or township See U.S. Census Bureau, 2012 Census of Governments, Subcounty General-Purpose Governments by Population-Size Group and State: 2012 - United States – States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG07.US01.  There were 18,811 municipal and 16,207 town and township governments with populations less than 50,000. 
) with populations of less than 50,000 and 12,184 Special purpose governments (independent school districts See U.S. Census Bureau, 2012 Census of Governments, Elementary and Secondary School Systems by Enrollment-Size Group and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG11.US01.  There were 12,184 independent school districts with enrollment populations less than 50,000.
 and special districts See U.S. Census Bureau, 2012 Census of Governments, Special District Governments by Function and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG09.US01.  The U.S. Census Bureau data did not provide a population breakout for special district governments.
) with populations of less than 50,000.  The 2012 U.S. Census Bureau data for most types of governments in the local government category show that the majority of these governments have populations of less than 50,000. See U.S. Census Bureau, 2012 Census of Governments, County Governments by Population-Size Group and State: 2012 - United States-States - https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG06.US01;   Subcounty General-Purpose Governments by Population-Size Group and State: 2012 - United States–States - https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG07.US01; and Elementary and Secondary School Systems by Enrollment-Size Group and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG11.US01.  While U.S. Census Bureau data did not provide a population breakout for special district governments, if the population of less than 50,000 for this category of local government is consistent with the other types of local governments the majority of the 38, 266 special district governments have populations of less than 50,000.
  Based on this data we estimate that at least 49,316 local government jurisdictions fall in the category of “small governmental jurisdictions.” Id.
  Governmental entities are, however, exempt from application fees. 47 U.S.C. § 158(d)(1)(A).
  
9. All Other Telecommunications.  The “All Other Telecommunications” category is comprised of establishments primarily engaged in providing specialized telecommunications services, such as satellite tracking, communications telemetry, and radar station operation. See U.S. Census Bureau, 2017 NAICS Definitions, NAICS Code “517919 All Other Telecommunications”, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?input=517919&search=2017+NAICS+Search&search=2017.
  This industry also includes establishments primarily engaged in providing satellite terminal stations and associated facilities connected with one or more terrestrial systems and capable of transmitting telecommunications to, and receiving telecommunications from, satellite systems. Id.
  Establishments providing Internet services or voice over Internet protocol (VoIP) services via client-supplied telecommunications connections are also included in this industry. Id.
  The SBA has developed a small business size standard for All Other Telecommunications, which consists of all such firms with annual receipts of $35 million or less. See 13 CFR § 121.201, NAICS code 517919.
  For this category, U.S. Census Bureau data for 2012 shows that there were 1,442 firms that operated for the entire year. U.S. Census Bureau, 2012 Economic Census of the United States, Table EC1251SSSZ4, Information: Subject Series - Estab and Firm Size: Receipts Size of Firms for the United States: 2012, NAICS code 517919, https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ4//naics~517919.
  Of those firms, a total of 1,400 had annual receipts less than $25 million and 15 firms had annual receipts of $25 million to $49, 999,999. Id.
  Thus, the Commission estimates that the majority of “All Other Telecommunications” firms potentially affected by our action can be considered small. 
E. Description of Projected Reporting, Recordkeeping and Other Compliance Requirements
10. This Report and Order does not adopt any new reporting, recordkeeping, or other compliance requirements.
F. Steps Taken to Minimize Significant Economic Impact on Small Entities, and Significant Alternatives Considered
11. The RFA requires an agency to describe any significant alternatives that it has considered in reaching its approach, which may include the following four alternatives, among others: (1) the establishment of differing compliance or reporting requirements or timetables that take into account the resources available to small entities; (2) the clarification, consolidation, or simplification of compliance or reporting requirements under the rule for small entities; (3) the use of performance, rather than design, standards; and (4) an exemption from coverage of the rule, or any part thereof, for small entities. 5 U.S.C. § 603(c)(1)–(c)(4).
   
12. This Report and Order does not adopt any new reporting requirements.  Therefore, no adverse economic impact on small entities will be sustained based on reporting requirements.  In keeping with the requirements of the Regulatory Flexibility Act, we have considered certain alternative means of mitigating the effects of fee increases to a particular industry segment.  For example, The Commission’s annual de minimis threshold of $1,000, replaced last year with a new section 9(e)(2) annual regulatory fee exemption of $1,000, will reduce burdens on small entities with annual regulatory fees that total $1,000 or less.  Also, regulatees may also seek waivers or other relief on the basis of financial hardship.  See 47 CFR §1.1166. 
G. Federal Rules that May Duplicate, Overlap, or Conflict 
13. None.

	Federal Communications Commission	FCC 20-64

APPENDIX J

Initial Regulatory Flexibility Analysis

1. As required by the Regulatory Flexibility Act of 1980, as amended (RFA), 5 U.S.C. § 603.  The RFA, 5 U.S.C. §§ 601-612 has been amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 847 (1996).
 the Commission prepared this Initial Regulatory Flexibility Analysis (IRFA) of the possible significant economic impact on small entities by the policies and rules proposed in the Notice of Proposed Rulemaking (Notice).  Written comments are requested on this IRFA.  Comments must be identified as responses to the IRFA and must be filed by the deadline for comments on this Notice.  The Commission will send a copy of the Notice, including the IRFA, to the Chief Counsel for Advocacy of the Small Business Administration (SBA). 5 U.S.C. § 603(a).
  In addition, the Notice and IRFA (or summaries thereof) will be published in the Federal Register. Id.
 
A. Need for, and Objectives of, the Proposed Rules  
2. The Notice seeks comment on regulatory fees for fiscal year (FY) 2020, as required by section 9 of the Communications Act of 1934, as amended (Communications Act or Act). 47 U.S.C. § 159.
  The Notice sets forth the proposed regulatory fees for FY 2020 for regulatees in the Wireless Telecommunications Bureau, Media Bureau, Wireline Competition Bureau, and International Bureau. The proposed regulatory fees are attached to the Notice in Appendices B and C.  This regulatory fee Notice is needed each year because the Commission is required by Congress to adopt regulatory fees each year “to recover the costs of carrying out the activities described in section 6(a) only to the extent, and in the total amounts, provided for in Appropriation Acts.” 47 U.S.C. § 159(a).
  The objective of the Notice is to propose regulatory fees for FY 2020 and adopt regulatory fee reform to improve the regulatory fee process.  The Notice seeks comment on the Commission’s proposed regulatory fees for FY 2020.  The Notice proposes to collect $339,000,000 in regulatory fees for FY 2020, as detailed in the proposed fee schedules in Appendix --, including a proposed increase in the DBS fee rate to 72 cents per subscriber and proposed fees for full-power broadcast televisions using the actual population covered by the station’s contour, as set forth in Appendix --.  Historically, under our old methodology, the regulatory fee for full-power broadcast television stations was based on the DMA groupings 1-10, 11-25, 26-50, 51-100, and the remaining markets (101-210), as well as satellite stations that traditionally pay a much lower fee.
B. Legal Basis
3. This action, including publication of proposed rules, is authorized under sections (4)(i) and (j), 159, and 303(r) of the Communications Act of 1934, as amended. 47 U.S.C. §§ 154(i) and (j), 159, and 303(r).
 
C. Description and Estimate of the Number of Small Entities to Which the Proposed Rules Will Apply
4. The RFA directs agencies to provide a description of, and where feasible, an estimate of the number of small entities that may be affected by the proposed rules and policies, if adopted. 5 U.S.C. § 603(b)(3).
  The RFA generally defines the term “small entity” as having the same meaning as the terms “small business,” “small organization,” and “small governmental jurisdiction.” 5 U.S.C. § 601(6).
  In addition, the term “small business” has the same meaning as the term “small business concern” under the Small Business Act. 5 U.S.C. § 601(3) (incorporating by reference the definition of “small-business concern” in the Small Business Act, 15 U.S.C. § 632).  Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity for public comment, establishes one or more definitions of such term which are appropriate to the activities of the agency and publishes such definition(s) in the Federal Register.”
  A “small business concern” is one which: (1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any additional criteria established by the SBA. 15 U.S.C. § 632.
 
5. Small Businesses, Small Organizations, Small Governmental Jurisdictions.  Our actions, over time, may affect small entities that are not easily categorized at present.  We therefore describe here, at the outset, three broad groups of small entities that could be directly affected herein. See 5 U.S.C. § 601(3)-(6).
  First, while there are industry specific size standards for small businesses that are used in the regulatory flexibility analysis, according to data from the SBA’s Office of Advocacy, in general a small business is an independent business having fewer than 500 employees. See SBA, Office of Advocacy, “Frequently Asked Questions, Question 1 – What is a small business?” https://www.sba.gov/sites/default/files/advocacy/SB-FAQ-2016_WEB.pdf (June 2016).
  These types of small businesses represent 99.9% of all businesses in the United States which translates to 28.8 million businesses. See SBA, Office of Advocacy, “Frequently Asked Questions, Question 2- How many small businesses are there in the U.S.?” https://www.sba.gov/sites/default/files/advocacy/SB-FAQ-2016_WEB.pdf (June 2016).
  
6. Next, the type of small entity described as a “small organization” is generally “any not-for-profit enterprise which is independently owned and operated and is not dominant in its field.” 5 U.S.C. § 601(4).
  Nationwide, as of August 2016, there were approximately 356,494 small organizations based on registration and tax data filed by nonprofits with the Internal Revenue Service (IRS). Data from the Urban Institute, National Center for Charitable Statistics (NCCS) reporting on nonprofit organizations registered with the IRS was used to estimate the number of small organizations.  Reports generated using the NCCS online database indicated that as of August 2016 there were 356,494 registered nonprofits with total revenues of less than $100,000.   Of this number, 326,897 entities filed tax returns with 65,113 registered nonprofits reporting total revenues of $50,000 or less on the IRS Form 990-N for Small Exempt Organizations and 261,784 nonprofits reporting total revenues of $100,000 or less on some other version of the IRS Form 990 within 24 months of the August 2016 data release date.  See http://nccs.urban.org/sites/all/nccs-archive/html//tablewiz/tw.php where the report showing this data can be generated by selecting the following data fields: Report: “The Number and Finances of All Registered 501(c) Nonprofits”; Show: “Registered Nonprofits”; By: “Total Revenue Level (years 1995, Aug to 2016, Aug)”; and For: “2016, Aug” then selecting “Show Results.”
  
7. Finally, the small entity described as a “small governmental jurisdiction” is defined generally as “governments of cities, counties, towns, townships, villages, school districts, or special districts, with a population of less than fifty thousand.” 5 U.S.C. § 601(5).
  U.S. Census Bureau data from the 2012 Census of Governments See 13 U.S.C. § 161.  The Census of Government is conducted every five (5) years compiling data for years ending with “2” and “7”.  See also Program Description Census of Government https://factfinder.census.gov/faces/affhelp/jsf/pages/metadata.xhtml?lang=en&type=program&id=program.en.COG#
 indicate that there were 90,056 local governmental jurisdictions consisting of general purpose governments and special purpose governments in the United States. See U.S. Census Bureau, 2012 Census of Governments, Local Governments by Type and State: 2012 - United States-States, https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG02.US01.  Local governmental jurisdictions are classified in two categories - General purpose governments (county, municipal and town or township) and Special purpose governments (special districts and independent school districts).   
  Of this number there were 37, 132 General purpose governments (county See U.S. Census Bureau, 2012 Census of Governments, County Governments by Population-Size Group and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG06.US01.  There were 2,114 county governments with populations less than 50,000. 
, municipal and town or township See U.S. Census Bureau, 2012 Census of Governments, Subcounty General-Purpose Governments by Population-Size Group and State: 2012 - United States – States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG07.US01.  There were 18,811 municipal and 16,207 town and township governments with populations less than 50,000. 
) with populations of less than 50,000 and 12,184 Special purpose governments (independent school districts See U.S. Census Bureau, 2012 Census of Governments, Elementary and Secondary School Systems by Enrollment-Size Group and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG11.US01.  There were 12,184 independent school districts with enrollment populations less than 50,000.
 and special districts See U.S. Census Bureau, 2012 Census of Governments, Special District Governments by Function and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG09.US01.  The U.S. Census Bureau data did not provide a population breakout for special district governments.
) with populations of less than 50,000.  The 2012 U.S. Census Bureau data for most types of governments in the local government category show that the majority of these governments have populations of less than 50,000. See U.S. Census Bureau, 2012 Census of Governments, County Governments by Population-Size Group and State: 2012 - United States-States - https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG06.US01;   Subcounty General-Purpose Governments by Population-Size Group and State: 2012 - United States–States - https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG07.US01; and Elementary and Secondary School Systems by Enrollment-Size Group and State: 2012 - United States-States. https://factfinder.census.gov/bkmk/table/1.0/en/COG/2012/ORG11.US01.  While U.S. Census Bureau data did not provide a population breakout for special district governments, if the population of less than 50,000 for this category of local government is consistent with the other types of local governments the majority of the 38, 266 special district governments have populations of less than 50,000.
  Based on this data we estimate that at least 49,316 local government jurisdictions fall in the category of “small governmental jurisdictions.” Id.
  Governmental entities are, however, exempt from application fees. 47 U.S.C. § 158(d)(1)(A).
  
8. Wired Telecommunications Carriers.  The U.S. Census Bureau defines this industry as “establishments primarily engaged in operating and/or providing access to transmission facilities and infrastructure that they own and/or lease for the transmission of voice, data, text, sound, and video using wired communications networks.  Transmission facilities may be based on a single technology or a combination of technologies.  Establishments in this industry use the wired telecommunications network facilities that they operate to provide a variety of services, such as wired telephony services, including VoIP services, wired (cable and IPTV) audio and video programming distribution, and wired broadband internet services.  By exception, establishments providing satellite television distribution services using facilities and infrastructure that they operate are included in this industry.” See 13 CFR § 120.201.  The Wired Telecommunications Carrier category formerly used the NAICS code of 517110. As of 2017 the U.S. Census Bureau definition shows the NAICS code as 517311 for Wired Telecommunications Carriers.  See U.S. Census Bureau, 2017 NAICS Definition, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517311&search=2017. 
  The SBA has developed a small business size standard for Wired Telecommunications Carriers, which consists of all such companies having 1,500 or fewer employees. See 13 CFR § 120.201, NAICS Code 517311 (previously 517110).
  U.S. Census Bureau data for 2012 show that there were 3,117 firms that operated that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.
  Of this total, 3,083 operated with fewer than 1,000 employees. Id.
 Thus, under this size standard, the majority of firms in this industry can be considered small.
9. Local Exchange Carriers (LECs).  Neither the Commission nor the SBA has developed a size standard for small businesses specifically applicable to local exchange services.  The closest applicable NAICS Code category is Wired Telecommunications Carriers. See 13 CFR § 121.201. The Wired Telecommunications Carrier category formerly used the NAICS code of 517110. As of 2017 the U.S. Census Bureau definition shows the NAICs code as 517311 for Wired Telecommunications Carriers.  See https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517311&search=2017.
  Under the applicable SBA size standard, such a business is small if it has 1,500 or fewer employees. Id.
  U.S. Census Bureau data for 2012 show that there were 3,117 firms that operated for the entire year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.
  Of that total, 3,083 operated with fewer than 1,000 employees. Id.
  Thus under this category and the associated size standard, the Commission estimates that the majority of local exchange carriers are small entities.
10. Incumbent LECs.  Neither the Commission nor the SBA has developed a small business size standard specifically for incumbent local exchange services.  The closest applicable NAICS Code category is Wired Telecommunications Carriers. See 13 CFR § 121.201. The Wired Telecommunications Carrier category formerly used the NAICS code of 517110. As of 2017 the U.S. Census Bureau definition shows the NAICs code as 517311 for Wired Telecommunications Carriers.  See, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517311&search=2017.
  Under the applicable SBA size standard, such a business is small if it has 1,500 or fewer employees. Id.
  U.S. Census Bureau data for 2012 indicate that 3,117 firms operated the entire year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.
  Of this total, 3,083 operated with fewer than 1,000 employees. Id. 
  Consequently, the Commission estimates that most providers of incumbent local exchange service are small businesses that may be affected by our actions.  According to Commission data, one thousand three hundred and seven (1,307) Incumbent Local Exchange Carriers reported that they were incumbent local exchange service providers. See Trends in Telephone Service, Federal Communications Commission, Wireline Competition Bureau, Industry Analysis and Technology Division at Table 5.3 (Sept. 2010) (Trends in Telephone Service).
  Of this total, an estimated 1,006 have 1,500 or fewer employees. Id.
  Thus, using the SBA’s size standard the majority of incumbent LECs can be considered small entities.  
11. Competitive Local Exchange Carriers (Competitive LECs), Competitive Access Providers (CAPs), Shared-Tenant Service Providers, and Other Local Service Providers.  Neither the Commission nor the SBA has developed a small business size standard specifically for these service providers.  The appropriate NAICS Code category is Wired Telecommunications Carriers and under that size standard, such a business is small if it has 1,500 or fewer employees. See 13 CFR § 121.201. The Wired Telecommunications Carrier category formerly used the NAICS code of 517110. As of 2017 the U.S. Census Bureau definition shows the NAICs code as 517311 for Wired Telecommunications Carriers.  See, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517311&search=2017. 
   U.S. Census Bureau data for 2012 indicate that 3,117 firms operated during that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.s
  Of that number, 3,083 operated with fewer than 1,000 employees. Id.
  Based on these data, the Commission concludes that the majority of Competitive LECS, CAPs, Shared-Tenant Service Providers, and Other Local Service Providers, are small entities.  According to Commission data, 1,442 carriers reported that they were engaged in the provision of either competitive local exchange services or competitive access provider services. See Federal Communications Commission, Wireline Competition Bureau, Industry Analysis and Technology Division, Trends in Telephone Service at Table 5.3 (Sept. 2010) (Trends in Telephone Service), https://apps.fcc.gov/edocs_public/attachmatch/DOC-301823A1.pdf.
  Of these 1,442 carriers, an estimated 1,256 have 1,500 or fewer employees. Id.
  In addition, 17 carriers have reported that they are Shared-Tenant Service Providers, and all 17 are estimated to have 1,500 or fewer employees. Id.
  Also, 72 carriers have reported that they are Other Local Service Providers. Id.
   Of this total, 70 have 1,500 or fewer employees. Id.
  Consequently, based on internally researched FCC data, the Commission estimates that most providers of competitive local exchange service, competitive access providers, Shared-Tenant Service Providers, and Other Local Service Providers are small entities. 
12. Interexchange Carriers (IXCs).  Neither the Commission nor the SBA has developed a small business size standard specifically for Interexchange Carriers.  The closest applicable NAICS Code category is Wired Telecommunications Carriers. See 13 CFR § 121.201. The Wired Telecommunications Carrier category formerly used the NAICS code of 517110. As of 2017 the U.S. Census Bureau definition shows the NAICs code as 517311 for Wired Telecommunications Carriers.  See U.S. Census Bureau, 2017 NAICS Definition, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517311&search=2017. 
 The applicable size standard under SBA rules is that such a business is small if it has 1,500 or fewer employees. Id. 
  U.S. Census Bureau data for 2012 indicate that 3,117 firms operated for the entire year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.
  Of that number, 3,083 operated with fewer than 1,000 employees. Id.
  According to internally developed Commission data, 359 companies reported that their primary telecommunications service activity was the provision of interexchange services. See Trends in Telephone Service, Federal Communications Commission, Wireline Competition Bureau, Industry Analysis and Technology Division at Table 5.3 (Sept. 2010) (Trends in Telephone Service).  https://apps.fcc.gov/edocs_public/attachmatch/DOC-301823A1.pdf.
  Of this total, an estimated 317 have 1,500 or fewer employees. Id.
  Consequently, the Commission estimates that the majority of interexchange service providers are small entities. 
13. Prepaid Calling Card Providers.  Neither the Commission nor the SBA has developed a small business size standard specifically for prepaid calling card providers.  The appropriate NAICS code category for prepaid calling card providers is Telecommunications Resellers.  This industry comprises establishments engaged in purchasing access and network capacity from owners and operators of telecommunications networks and reselling wired and wireless telecommunications services (except satellite) to businesses and households.  Establishments in this industry resell telecommunications; they do not operate transmission facilities and infrastructure.  Mobile virtual network operators (MVNOs) are included in this industry. U.S. Census Bureau, 2017 NAICS Definition, NAICS Code 517911” Telecommunications Resellers”, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517911&search=2017%20NAICS%20Search.
  The SBA has developed a small business size standard for the category of Telecommunications Resellers. 13 CFR § 121.201 (NAICS code 517911).
  Under that size standard, such a business is small if it has 1,500 or fewer employees. Id.
  U.S. Census Bureau data for 2012 show that 1,341 firms provided resale services during that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 NAICS Code 517911, https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517911. 
  Of that number, 1,341 operated with fewer than 1,000 employees. Id.  Available census data does not provide a more precise estimate of the number of firms that have employment of 1,500 or fewer employees; the largest category provided is for firms with “1000 employees or more.”
  Thus, under this category and the associated small business size standard, the majority of these resellers can be considered small entities.  According to Commission data, 193 carriers have reported that they are engaged in the provision of prepaid calling cards. See Trends in Telephone Service, at tbl. 5.3.
  All 193 carriers have 1,500 or fewer employees. Id.
  Consequently, the Commission estimates that the majority of prepaid calling card providers are small.
14. Local Resellers.  The SBA has not developed a small business size standard specifically for Local Resellers.  The SBA category of Telecommunications Resellers is the closest NAICs code category for local resellers.  The Telecommunications Resellers industry comprises establishments engaged in purchasing access and network capacity from owners and operators of telecommunications networks and reselling wired and wireless telecommunications services (except satellite) to businesses and households.  Establishments in this industry resell telecommunications; they do not operate transmission facilities and infrastructure.  Mobile virtual network operators (MVNOs) are included in this industry. U.S. Census Bureau, 2017 NAICS Definition, 517911 Telecommunications Resellers, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517911&search=2017%20NAICS%20Search.  
  Under the SBA’s size standard, such a business is small if it has 1,500 or fewer employees. 13 CFR § 121.201, NAICS code 517911.
  U.S. Census Bureau data from 2012 show that 1,341 firms provided resale services during that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 NAICS Code 517911, https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517911.
  Of that number, all operated with fewer than 1,000 employees. Id.  Available census data does not provide a more precise estimate of the number of firms that have employment of 1,500 or fewer employees; the largest category provided is for firms with “1000 employees or more.”
  Thus, under this category and the associated small business size standard, the majority of these resellers can be considered small entities.  According to Commission data, 213 carriers have reported that they are engaged in the provision of local resale services. See Trends in Telephone Service, Federal Communications Commission, Wireline Competition Bureau, Industry Analysis and Technology Division at Table 5.3 (Sept. 2010) (Trends in Telephone Service).  
  Of these, an estimated 211 have 1,500 or fewer employees and two have more than 1,500 employees. See id.
  Consequently, the Commission estimates that the majority of local resellers are small entities. 
15. Toll Resellers.  The Commission has not developed a definition for Toll Resellers.  The closest NAICS Code Category is Telecommunications Resellers.  The Telecommunications Resellers industry comprises establishments engaged in purchasing access and network capacity from owners and operators of telecommunications networks and reselling wired and wireless telecommunications services (except satellite) to businesses and households.  Establishments in this industry resell telecommunications; they do not operate transmission facilities and infrastructure.  MVNOs are included in this industry. U.S. Census Bureau, 2017 NAICS Definition, 517911 Telecommunications Resellers, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517911&search=2017%20NAICS%20Search.  
  The SBA has developed a small business size standard for the category of Telecommunications Resellers. 13 CFR § 121.201, NAICS code 517911.
  Under that size standard, such a business is small if it has 1,500 or fewer employees. Id.
  2012 Census Bureau data show that 1,341 firms provided resale services during that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 NAICS Code 517911, https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517911.
  Of that number, 1,341 operated with fewer than 1,000 employees. Id.  Available census data does not provide a more precise estimate of the number of firms that have employment of 1,500 or fewer employees; the largest category provided is for firms with “1000 employees or more.”
  Thus, under this category and the associated small business size standard, the majority of these resellers can be considered small entities.  According to Commission data, 881 carriers have reported that they are engaged in the provision of toll resale services. See Trends in Telephone Service, Federal Communications Commission, Wireline Competition Bureau, Industry Analysis and Technology Division at Table 5.3 (Sept. 2010) (Trends in Telephone Service).
  Of this total, an estimated 857 have 1,500 or fewer employees. See id.
  Consequently, the Commission estimates that the majority of toll resellers are small entities. The closest NAICS Code Category is Telecommunications Resellers.  The Telecommunications Resellers industry comprises establishments engaged in purchasing access and network capacity from owners and operators of telecommunications networks and reselling wired and wireless telecommunications services (except satellite) to businesses and households.  Establishments in this industry resell telecommunications; they do not operate transmission facilities and infrastructure.  MVNOs are included in this industry. U.S. Census Bureau, 2017 NAICS Definition, 517911 Telecommunications Resellers, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517911&search=2017%20NAICS%20Search.  
  The SBA has developed a small business size standard for the category of Telecommunications Resellers. 13 CFR § 121.201, NAICS code 517911.
  Under that size standard, such a business is small if it has 1,500 or fewer employees. Id.
  2012 Census Bureau data show that 1,341 firms provided resale services during that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 NAICS Code 517911, https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517911.
  Of that number, 1,341 operated with fewer than 1,000 employees. Id.  Available census data does not provide a more precise estimate of the number of firms that have employment of 1,500 or fewer employees; the largest category provided is for firms with “1000 employees or more.”
  Thus, under this category and the associated small business size standard, the majority of these resellers can be considered small entities.  According to Commission data, 881 carriers have reported that they are engaged in the provision of toll resale services. See Trends in Telephone Service, Federal Communications Commission, Wireline Competition Bureau, Industry Analysis and Technology Division at Table 5.3 (Sept. 2010) (Trends in Telephone Service).
  Of this total, an estimated 857 have 1,500 or fewer employees. See id.
  Consequently, the Commission estimates that the majority of toll resellers are small entities.
16. Other Toll Carriers.  Neither the Commission nor the SBA has developed a size standard for small businesses specifically applicable to Other Toll Carriers.  This category includes toll carriers that do not fall within the categories of interexchange carriers, operator service providers, prepaid calling card providers, satellite service carriers, or toll resellers.  The closest applicable NAICS code category is for Wired Telecommunications Carriers, as defined in paragraph 6 of this IRFA.  Under that size standard, such a business is small if it has 1,500 or fewer employees. See 13 CFR § 120.201, NAICS Code 517311 (previously 517110).
  U.S. Census Bureau data for 2012 show that there were 3,117 firms that operated that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.
  Of this total, 3,083 operated with fewer than 1,000 employees. Id.
  Thus, under this size standard, the majority of firms in this industry can be considered small.  According to Commission data, 284 companies reported that their primary telecommunications service activity was the provision of other toll carriage. Trends in Telephone Service, at tbl. 5.3.
  Of these, an estimated 279 have 1,500 or fewer employees. Id.
  Consequently, the Commission estimates that most Other Toll Carriers are small entities.
17. Wireless Telecommunications Carriers (except Satellite).  This industry comprises establishments engaged in operating and maintaining switching and transmission facilities to provide communications via the airwaves.  Establishments in this industry have spectrum licenses and provide services using that spectrum, such as cellular services, paging services, wireless internet access, and wireless video services. U.S. Census Bureau, 2012 NAICS Definitions, “517210 Wireless Telecommunications Carriers (Except Satellite).”  See https://factfinder.census.gov/faces/affhelp/jsf/pages/metadata.xhtml?lang=en&type=
ib&id=ib.en./ECN.NAICS2012.517210.
  The appropriate size standard under SBA rules is that such a business is small if it has 1,500 or fewer employees. 13 CFR § 121.201, NAICS code 517210.  
  For this industry, U.S. Census Bureau data for 2012 show that there were 967 firms that operated for the entire year. U.S. Census Bureau, 2012 Economic Census of the United States, Table EC1251SSSZ5, Information: Subject Series: Estab and Firm Size: Employment Size of Firms for the U.S.: 2012 NAICS Code 517210.  https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517210. 
  Of this total, 955 firms had employment of 999 or fewer employees and 12 had employment of 1000 employees or more. Id.  Available census data does not provide a more precise estimate of the number of firms that have employment of 1,500 or fewer employees; the largest category provided is for firms with “1000 employees or more.”
  Thus under this category and the associated size standard, the Commission estimates that the majority of wireless telecommunications carriers (except satellite) are small entities.
18. Television Broadcasting.  This Economic Census category “comprises establishments primarily engaged in broadcasting images together with sound.” U.S. Census Bureau, 2017 NAICS Definitions, “515120 Television Broadcasting,” https://www.census.gov/cgi-bin/sssd/naics/naicsrch?input=515120&search=2017+NAICS+Search&search=2017. 
  These establishments operate television broadcast studios and facilities for the programming and transmission of programs to the public. Id.
 These establishments also produce or transmit visual programming to affiliated broadcast television stations, which in turn broadcast the programs to the public on a predetermined schedule.  Programming may originate in their own studio, from an affiliated network, or from external sources.  The SBA has created the following small business size standard for such businesses: those having $41.5 million or less in annual receipts. 13 C.F.R. § 121.201; 2012 NAICS code 515120. 
  The 2012 Economic Census reports that 751 firms in this category operated in that year. U.S. Census Bureau, Table No. EC1251SSSZ4, Information: Subject Series - Establishment and Firm Size: Receipts Size of Firms for the United States: 2012 (515120 Television Broadcasting). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ4//naics~515120.
  Of that number, 656 had annual receipts of $25,000,000 or less. Id. 
  Based on this data we therefore estimate that the majority of commercial television broadcasters are small entities under the applicable SBA size standard. 
19. The Commission has estimated the number of licensed commercial television stations to be 1,377. Broadcast Station Totals as of June 30, 2018, Press Release (MB, rel. Jul. 3, 2018) (June 30, 2018 Broadcast Station Totals Press Release), https://docs.fcc.gov/public/attachments/DOC-352168A1.pdf.     
  Of this total, 1,258 stations (or about 91 percent) had revenues of $41.5 million or less, according to Commission staff review of the BIA Kelsey Inc. Media Access Pro Television Database (BIA) on November 16, 2017, and therefore these licensees qualify as small entities under the SBA definition.  In addition, the Commission has estimated the number of licensed noncommercial educational television stations to be 384. Id.
  Notwithstanding, the Commission does not compile and otherwise does not have access to information on the revenue of NCE stations that would permit it to determine how many such stations would qualify as small entities.  There are also 2,300 low power television stations, including Class A stations (LPTV) and 3,681 TV translator stations. Id.
  Given the nature of these services, we will presume that all of these entities qualify as small entities under the above SBA small business size standard.  
20. We note, however, that in assessing whether a business concern qualifies as “small” under the above definition, business (control) affiliations “[Business concerns] are affiliates of each other when one concern controls or has the power to control the other or a third party or parties controls or has the power to control both.” 13 C.F.R. § 21.103(a)(1).
 must be included. Our estimate, therefore likely overstates the number of small entities that might be affected by our action, because the revenue figure on which it is based does not include or aggregate revenues from affiliated companies. In addition, another element of the definition of “small business” requires that an entity not be dominant in its field of operation. We are unable at this time to define or quantify the criteria that would establish whether a specific television broadcast station is dominant in its field of operation. Accordingly, the estimate of small businesses to which rules may apply does not exclude any television station from the definition of a small business on this basis and is therefore possibly over-inclusive.  Also, as noted above, an additional element of the definition of “small business” is that the entity must be independently owned and operated.  The Commission notes that it is difficult at times to assess these criteria in the context of media entities and its estimates of small businesses to which they apply may be over-inclusive to this extent.
21. Radio Stations.  This Economic Census category “comprises establishments primarily engaged in broadcasting aural programs by radio to the public.  Programming may originate in their own studio, from an affiliated network, or from external sources.” U.S. Census Bureau, 2017 NAICS Definitions, “515112 Radio Stations,” https://www.census.gov/cgi-bin/sssd/naics/naicsrch?input=515112&search=2017+NAICS+Search&search=2017.  
   The SBA has established a small business size standard for this category as firms having $41.5 million or less in annual receipts. 13 CFR § 121.201; NAICS code 515112.
  Economic Census data for 2012 show that 2,849 radio station firms operated during that year. U.S. Census Bureau, Table No. EC1251SSSZ4, Information: Subject Series – Establishment and Firm Size: Receipts Size of Firms for the United States: 2012 NAICS Code 515112, https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ4//naics~515112. 
  Of that number, 2,806 firms operated with annual receipts of less than $25 million per year, 17 with annual receipts between $25 million and $49,999,999 million and 26 with annual receipts of $50 million or more. Id.
   Therefore, based on the SBA’s size standard the majority of such entities are small entities. 
22. According to Commission staff review of the BIA/Kelsey, LLC’s Media Access Pro Radio Database as of January 2018, about 11,261 (or about 99.9 percent) of 11,383 commercial radio stations had revenues of $41.5 million or less and thus qualify as small entities under the SBA definition. BIA/Kelsey, MEDIA Access Pro Database (viewed Jan. 26, 2018).
 The Commission has estimated the number of licensed commercial AM radio stations to be 4,633 stations and the number of commercial FM radio stations to be 6,738, for a total number of 11,371. Broadcast Station Totals as of June 30, 2018, Press Release (MB Jul. 3, 2018) (June 30, 2018 Broadcast Station Totals), https://docs.fcc.gov/public/attachments/DOC-352168A1.pdf.  
  We note the Commission has also estimated the number of licensed noncommercial (NCE) FM radio stations to be 4,128. Id.
  Nevertheless, the Commission does not compile and otherwise does not have access to information on the revenue of NCE stations that would permit it to determine how many such stations would qualify as small entities. We also note, that in assessing whether a business entity qualifies as small under the above definition, business control affiliations must be included. “[Business concerns] are affiliates of each other when one concern controls or has the power to control the other, or a third party or parties controls or has power to control both.”  13 C.F.R. § 121.103(a)(1).
  The Commission’s estimate therefore likely overstates the number of small entities that might be affected by its action, because the revenue figure on which it is based does not include or aggregate revenues from affiliated companies.  In addition, to be determined a “small business,” an entity may not be dominant in its field of operation. 13 C.F.R. § 121.102(b).
 We further note, that it is difficult at times to assess these criteria in the context of media entities, and the estimate of small businesses to which these rules may apply does not exclude any radio station from the definition of a small business on these basis, thus our estimate of small businesses may therefore be over-inclusive.  Also, as noted above, an additional element of the definition of “small business” is that the entity must be independently owned and operated.  The Commission notes that it is difficult at times to assess these criteria in the context of media entities and the estimates of small businesses to which they apply may be over-inclusive to this extent. 
23. Cable Companies and Systems (Rate Regulation).  The Commission has developed its own small business size standards for the purpose of cable rate regulation.  Under the Commission’s rules, a “small cable company” is one serving 400,000 or fewer subscribers nationwide. 47 CFR § 76.901(e).
  Industry data indicate that there are 4,600 active cable systems in the United States. The number of active, registered cable systems comes from the Commission’s Cable Operations and Licensing System (COALS) database on August 15, 2015.  See FCC, Cable Operations and Licensing System (COALS), www.fcc.gov/coals (last visited Oct. 25, 2016).
  Of this total, all but seven cable operators nationwide are small under the 400,000-subscriber size standard. S&P Global Market Intelligence, Top Cable MSOs as of 12/2016.
  In addition, under the Commission’s rate regulation rules, a “small system” is a cable system serving 15,000 or fewer subscribers. 47 CFR § 76.901(c).
  Commission records show 4,600 cable systems nationwide.  See supra Note 109.
  Of this total, 3,900 cable systems have fewer than 15,000 subscribers, and 700 systems have 15,000 or more subscribers, based on the same records. See FCC, Cable Operations and Licensing System (COALS), www.fcc.gov/coals (last visited Oct. 25, 2016).
  Thus, under this standard as well, we estimate that most cable systems are small entities.
24. Cable System Operators (Telecom Act Standard).  The Communications Act of 1934, as amended also contains a size standard for small cable system operators, which is “a cable operator that, directly or through an affiliate, serves in the aggregate fewer than one percent of all subscribers in the United States and is not affiliated with any entity or entities whose gross annual revenues in the aggregate exceed $250,000,000.” 47 CFR § 76.90(f) and notes ff. 1, 2, and 3.
  As of 2018, there were approximately 50,504,624 cable video subscribers in the United States. S&P Global Market Intelligence, U.S. Cable Subscriber Highlights, Basic Subscribers(actual) 2018, U.S. Cable MSO Industry Total.
  Accordingly, an operator serving fewer than 505,046 subscribers shall be deemed a small operator if its annual revenues, when combined with the total annual revenues of all its affiliates, do not exceed $250 million in the aggregate. 47 CFR § 76.901(f) and notes ff. 1, 2, and 3.
  Based on available data, we find that all but six incumbent cable operators are small entities under this size standard. S&P Global Market Intelligence, Top Cable MSOs 12/18Q.  The six cable operators all had more than 505,046 basic cable subscribers. 
  We note that the Commission neither requests nor collects information on whether cable system operators are affiliated with entities whose gross annual revenues exceed $250 million. The Commission receives such information on a case-by-case basis if a cable operator appeals a local franchise authority’s finding that the operator does not qualify as a small cable operator pursuant to section 76.901(f) of the Commission’s rules.  See 47 CFR § 76.901(f).
  Therefore we are unable at this time to estimate with greater precision the number of cable system operators that would qualify as small cable operators under the definition in the Communications Act.
25. Direct Broadcast Satellite (DBS) Service.  DBS service is a nationally distributed subscription service that delivers video and audio programming via satellite to a small parabolic “dish” antenna at the subscriber’s location.  DBS is included in SBA’s economic census category “Wired Telecommunications Carriers.” See 13 CFR § 120.201.  The Wired Telecommunications Carrier category formerly used the NAICS code of 517110. As of 2017 the U.S. Census Bureau definition shows the NAICS code as 517311 for Wired Telecommunications Carriers.  See, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517311&search=2017.
  The Wired Telecommunications Carriers industry comprises establishments primarily engaged in operating and/or providing access to transmission facilities and infrastructure that they own and/or lease for the transmission of voice, data, text, sound, and video using wired telecommunications networks. Id.
  Transmission facilities may be based on a single technology or combination of technologies.  Establishments in this industry use the wired telecommunications network facilities that they operate to provide a variety of services, such as wired telephony services, including VoIP services, wired (cable) audio and video programming distribution; and wired broadband internet services. See id.  Examples of this category are: broadband Internet service providers (e.g., cable, DSL); local telephone carriers (wired); cable television distribution services; long-distance telephone carriers (wired); CCTV services; VoIP service providers, using own operated wired telecommunications infrastructure; DTH services; telecommunications carriers (wired); satellite television distribution systems; and MMDS.
  By exception, establishments providing satellite television distribution services using facilities and infrastructure that they operate are included in this industry. Id. 
  The SBA determines that a wireline business is small if it has fewer than 1,500 employees. 13 CFR § 121.201, NAICS CODE 517110.
  U.S.  Census Bureau data for 2012 indicates that 3,117 wireline companies were operational during that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.
  Of that number, 3,083 operated with fewer than 1,000 employees. Id.
  Based on that data, we conclude that the majority of wireline firms are small under the applicable SBA standard.  Currently, however, only two entities provide DBS service, which requires a great deal of capital for operation: DIRECTV (owned by AT&T) and DISH Network. See Annual Assessment of the Status of Competition in the Market for the Delivery of Video Programming, Eighteenth Report, Table III.A.5, 32 FCC Rcd 568, 595 (Jan. 17, 2017).  
  DIRECTV and DISH Network each report annual revenues that are in excess of the threshold for a small business.  Accordingly, we must conclude that internally developed FCC data are persuasive that, in general, DBS service is provided only by large firms.
26. All Other Telecommunications.  The “All Other Telecommunications” category is comprised of establishments primarily engaged in providing specialized telecommunications services, such as satellite tracking, communications telemetry, and radar station operation. See U.S. Census Bureau, 2017 NAICS Definitions, NAICS Code “517919 All Other Telecommunications”, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?input=517919&search=2017+NAICS+Search&search=2017.
  This industry also includes establishments primarily engaged in providing satellite terminal stations and associated facilities connected with one or more terrestrial systems and capable of transmitting telecommunications to, and receiving telecommunications from, satellite systems. Id.
  Establishments providing Internet services or voice over Internet protocol (VoIP) services via client-supplied telecommunications connections are also included in this industry.Id.
  The SBA has developed a small business size standard for All Other Telecommunications, which consists of all such firms with annual receipts of $35 million or less. See 13 CFR § 121.201, NAICS code 517919.
  For this category, U.S. Census Bureau data for 2012 shows that there were 1,442 firms that operated for the entire year. U.S. Census Bureau, 2012 Economic Census of the United States, Table EC1251SSSZ4, Information: Subject Series - Estab and Firm Size: Receipts Size of Firms for the United States: 2012, NAICS code 517919, https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ4//naics~517919.
  Of those firms, a total of 1,400 had annual receipts less than $25 million and 15 firms had annual receipts of $25 million to $49, 999,999. Id.
  Thus, the Commission estimates that the majority of “All Other Telecommunications” firms potentially affected by our action can be considered small. 
27. RespOrgs.  Responsible Organizations, or RespOrgs, are entities chosen by toll free subscribers to manage and administer the appropriate records in the toll free Service Management System for the toll free subscriber. See 47 CFR § 52.101(b).
  Although RespOrgs are often wireline carriers, they can also include non-carrier entities.  Therefore, in the definition herein of RespOrgs, two categories are presented, i.e., Carrier RespOrgs and Non-Carrier RespOrgs.
28. Carrier RespOrgs. Neither the Commission, the U.S. Census, nor the SBA have developed a definition for Carrier RespOrgs.  Accordingly, the Commission believes that the closest NAICS code-based definitional categories for Carrier RespOrgs are Wired Telecommunications Carriers, 13 CFR § 121.201, NAICS code 517110.
 and Wireless Telecommunications Carriers (except satellite). Id.
 
29. The U.S. Census Bureau defines Wired Telecommunications Carriers as “establishments primarily engaged in operating and/or providing access to transmission facilities and infrastructure that they own and/or lease for the transmission of voice, data, text, sound, and video using wired communications networks.  Transmission facilities may be based on a single technology or a combination of technologies.  Establishments in this industry use the wired telecommunications network facilities that they operate to provide a variety of services, such as wired telephony services, including VoIP services, wired (cable) audio and video programming distribution, and wired broadband internet services.  By exception, establishments providing satellite television distribution services using facilities and infrastructure that they operate are included in this industry.” See 13 CFR § 120.201.  The Wired Telecommunications Carrier category formerly used the NAICS code of 517110. As of 2017 the U.S. Census Bureau definition shows the NAICS code as 517311 for Wired Telecommunications Carriers.  See U.S. Census Bureau, 2017 NAICS Definition, https://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517311&search=2017. 
  The SBA has developed a small business size standard for Wired Telecommunications Carriers, which consists of all such companies having 1,500 or fewer employees. See 13 CFR § 120.201, NAICS Code 517311 (previously 517110).
  U.S. Census Bureau data for 2012 show that there were 3,117 firms that operated that year. See U.S. Census Bureau, 2012 Economic Census of the United States, Table No. EC1251SSSZ5, Information: Subject Series - Estab & Firm Size: Employment Size of Firms: 2012 (517110 Wired Telecommunications Carriers). https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517110.
  Of this total, 3,083 operated with fewer than 1,000 employees. Id.
 Based on that data, we conclude that the majority of Carrier RespOrgs that operated with wireline-based technology are small.
30. The U.S. Census Bureau defines Wireless Telecommunications Carriers (except satellite) as establishments engaged in operating and maintaining switching and transmission facilities to provide communications via the airwaves, such as cellular services, paging services, wireless internet access, and wireless video services. U.S. Census Bureau, 2012 NAICS Definitions, “517210 Wireless Telecommunications Carriers (Except Satellite).”  See https://factfinder.census.gov/faces/affhelp/jsf/pages/metadata.xhtml?lang=en&type=
ib&id=ib.en./ECN.NAICS2012.517210.
  The appropriate size standard under SBA rules is that such a business is small if it has 1,500 or fewer employees. 13 CFR § 120.201, NAICS code 517120.
  Census data for 2012 show that 967 Wireless Telecommunications Carriers operated in that year.  Of that number, 955 operated with less than 1,000 employees. U.S. Census Bureau, 2012 Economic Census of the United States, Table EC1251SSSZ5, Information: Subject Series: Estab and Firm Size: Employment Size of Firms for the U.S.: 2012 NAICS Code 517210.  https://factfinder.census.gov/bkmk/table/1.0/en/ECN/2012_US/51SSSZ5//naics~517210
pid=ECN_2012_US_51SSSZ4&prodType=table.
  Based on that data, we conclude that the majority of Carrier RespOrgs that operated with wireless-based technology are small.
31. Non-Carrier RespOrgs.  Neither the Commission, the U.S. Census, nor the SBA have developed a definition of Non-Carrier RespOrgs.  Accordingly, the Commission believes that the closest NAICS code-based definitional categories for Non-Carrier RespOrgs are “Other Services Related to Advertising” 13 CFR § 120.201, NAICS code 541890.
 and “Other Management Consulting Services.” 13 CFR § 120.201, NAICS code 541618.

32. The U.S. Census defines Other Services Related to Advertising as comprising establishments primarily engaged in providing advertising services (except advertising agency services, public relations agency services, media buying agency services, media representative services, display advertising services, direct mail advertising services, advertising material distribution services, and marketing consulting services). http://www.census,gov/cgi-bin/sssd/naics.naicsrch.
  The SBA has established a size standard for this industry as annual receipts of $16.5 million dollars or less. 13 CFR § 120.201, NAICS code 541890.
  Census data for 2012 show that 5,804 firms operated in this industry for the entire year.  Of that number, 5,612 operated with annual receipts of less than $10 million. http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?
pid=ECN_2012_US_51SSSZ4&prodType=table.
  Based on that data we conclude that the majority of Non-Carrier RespOrgs who provide toll-free number (TFN)-related advertising services are small.
33. The U.S. Census defines Other Management Consulting Services as establishments primarily engaged in providing management consulting services (except administrative and general management consulting; human resources consulting; marketing consulting; or process, physical distribution, and logistics consulting).  Establishments providing telecommunications or utilities management consulting services are included in this industry. http://www.census,gov/cgi-bin/sssd/naics.naicsrch.
  The SBA has established a size standard for this industry of $16.5 million dollars or less. 13 CFR § 120.201, NAICS code 514618.
  Census data for 2012 show that 3,683 firms operated in this industry for that entire year.  Of that number, 3,632 operated with less than $10 million in annual receipts. http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?
pid=ECN_2012_US_51SSSZ4&prodType=table.
  Based on this data, we conclude that a majority of non-carrier RespOrgs who provide TFN-related management consulting services are small. The four NAICS code-based categories selected above to provide definitions for Carrier and Non-Carrier RespOrgs were selected because as a group they refer generically and comprehensively to all RespOrgs.   

34. In addition to the data contained in the four (see above) U.S. Census NAICS code categories that provide definitions of what services and functions the Carrier and Non-Carrier RespOrgs provide, Somos, the trade association that monitors RespOrg activities, compiled data showing that as of July 1, 2016 there were 23 RespOrgs operational in Canada and 436 RespOrgs operational in the United States, for a total of 459 RespOrgs currently registered with Somos.
D. Description of Projected Reporting, Recordkeeping and Other Compliance Requirements for Small Entities
35. This Notice does not propose any changes to the Commission’s current information collection, reporting, recordkeeping, or compliance requirements.   Licensees, including small entities, will be required to pay application fees after such fees are adopted.
E. Steps Taken to Minimize Significant Economic Impact on Small Entities, and Significant Alternatives Considered
36. The RFA requires an agency to describe any significant alternatives that it has considered in reaching its approach, which may include the following four alternatives, among others: (1) the establishment of differing compliance or reporting requirements or timetables that take into account the resources available to small entities; (2) the clarification, consolidation, or simplification of compliance or reporting requirements under the rule for small entities; (3) the use of performance, rather than design, standards; and (4) an exemption from coverage of the rule, or any part thereof, for small entities. 5 U.S.C. § 603(c)(1)–(c)(4).
  
37. The Notice seeks comment on the Commission’s proposed regulatory fees for FY 2020.  The Notice proposes to collect $339,000,000 in regulatory fees for FY 2020, as detailed in the proposed fee schedules in Appendix --, including an increase in the DBS fee rate to 72 cents per subscriber.  DBS providers are not small entities.  The Notice seeks comment on changing the methodology for assessing regulatory fees for full-power broadcast television stations to use the actual population to determine the regulatory fee.  In addition, the Notice seeks comment on the schedule of regulatory fees for all Commission regulatees for FY 2020.  The Commission’s annual de minimis threshold of $1,000 was replaced last year with a new section 9(e)(2) annual regulatory fee exemption of $1,000; this regulatory fee exemption will reduce burdens on small entities with annual regulatory fees that total $1,000 or less.
F. Federal Rules that May Duplicate, Overlap, or Conflict with the Proposed Rules
38. None.




117
	Federal Communications Commission	"FCC  XX-XXX"


STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY

Re: 	Assessment and Collection of Regulatory Fees for Fiscal Year 2020, MD Docket No. 20-105; Assessment and Collection of Regulatory Fees for Fiscal Year 2019, MD Docket No. 19-105.

Determining regulatory fees is a somewhat delicate matter, with the need to balance statutory requirements and constraints with the realities of the marketplace, where increasingly higher fees continue to squeeze licensees.  At the same time, we need to do our part to meet the requirements set in place by Congress, while being mindful of how federal spending affects our licensees and seeking ways to keep costs down within our own operations. See Michael O’Rielly, Further Improving the FCC’s Procedures, FCC.GOV, December 20, 2018, https://www.fcc.gov/news-events/blog/2018/12/20/further-improving-fccs-procedures.
  This year in particular we are facing truly unprecedented times, and I thank the Chairman for including questions in the FY2020 fee proposal to allow commenters to offer suggestions for mitigating the burden of regulatory fees during the pandemic, as many industries grapple with how to continue providing services while facing dramatically decreased revenue.  
To those who have filed comments opposing increased fees, I remain sympathetic.  The fee setting exercise is largely a zero-sum game, and absent congressional action, it is difficult to imagine broadening the base of payors.  Nonetheless, I am pleased that we were able to include a very small modification sought by certain VHF broadcasters, a welcome adjustment during the pandemic, even if it is not a wholesale reconfiguration.  
While I support the overall item, there are two areas related to the satellite industry that give me pause.  First, I continue to view our increases for DBS providers to be symptomatic of a broken approach, which is well-documented elsewhere.  Further, I have some concerns regarding the effects of shifting the balance of fees within the satellite industry to pull in foreign operators.  We note in this item the potential policy implications of other countries feeling compelled to follow our example and raise fees on American operators.  This is a real concern for those of us who have worked on satellite policy for many years and have seen firsthand, over and over, the proverbial arms race as countries compete for licensees through regulatory arbitrage.  While we do include a slight reform to the draft to avoid capturing within our fee structure certain foreign satellites communicating with U.S. aircrafts only outside the United States and also those that communicate with U.S.-licensed earth stations solely for tracking, telemetry and command (TT&C) purposes, we will need to closely monitor the ultimate effects of todayʼs action on the broader satellite market.  
I approve.




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