Federal Communications Commission FCC 22-68 Before the FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of Assessment and Collection of Regulatory Fees for Fiscal Year 2022 Review of the Commission’s Assessment and Collection of Regulatory Fees ) ) ) ) ) ) ) MD Docket No. 22-223 MD Docket No. 22-301 REPORT AND ORDER AND NOTICE OF INQUIRY Adopted: September 1, 2022 Released: September 2, 2022 Comment Date: 30 days after publication in the Federal Register Reply Comment Date: 60 days after publication in the Federal Register By the Commission TABLE OF CONTENTS Heading Paragraph # I. INTRODUCTION 1 II. BACKGROUND 2 III. REPORT AND ORDER 9 A. Allocating Full-time Equivalents 10 B. Space Station and Submarine Cable Regulatory Fees 22 1. Non-Geostationary Orbit System (NGSO) Regulatory Fees 22 2. Spacecraft Performing On-Orbit Servicing and Rendezvous and Proximity Operations 41 3. Submarine Cable Regulatory Fees 46 C. Broadcaster Regulatory Fees for FY 2022 50 D. De Minimis Threshold 61 E. Reclassification of FTEs 66 F. Commenters’ Proposals for New Regulatory Fee Categories 75 1. Holders of Experimental Licenses 76 2. Broadband Internet Access Service 81 3. Holders of Equipment Authorizations 87 4. Operators of Databases of Spectrum Used on an Unlicensed Basis 90 5. Users of Spectrum on an Unlicensed Basis 94 G. Advancing Diversity, Equity, Inclusion, and Accessibility 104 H. Flexibility for Regulatory Payors Due to COVID-19 Pandemic 105 IV. NOTICE OF INQUIRY 107 V. PROCEDURAL MATTERS 118 VI. ORDERING CLAUSES 134 APPENDIX A—LIST OF COMMENTERS APPENDIX B—CALCULATION OF FY 2022 REVENUE REQUIREMENTS AND PRO-RATA FEES APPENDIX C—FY 2022 REGULATORY FEES APPENDIX D—SOURCES OF PAYMENT UNIT ESTIMATES FOR FY 2022 APPENDIX E—FACTORS, MEASUREMENTS, AND CALCULATIONS THAT DETERMINE SIGNAL CONTOURS AND ASSOCIATED POPULATION COVERAGES APPENDIX F—SATELLITE CHARTS FOR FY 2022 REGULATORY FEES APPENDIX G—FY 2022 FULL-SERVICE BROADCAST TELEVISION STATIONS, BY CALL SIGN APPENDIX H—FY 2021 REGULATORY FEES APPENDIX I—FINAL REGULATORY FLEXIBILITY ANALYSIS APPENDIX J—RULE CHANGES I. INTRODUCTION 1. Each year, the Commission must adopt a schedule of regulatory fees to be collected by the end of September. For fiscal year (FY) 2022, the Commission is required to collect $381,950,000 in regulatory fees, pursuant to sections 9 and 9A of the Communications Act of 1934, as amended (Act or Communications Act), 47 U.S.C. § 159 (requiring the Commission to assess and collect regulatory fees to recover the costs of carrying out its activities in the total amounts provided for in Appropriations Acts); 47 U.S.C. § 159A (various provisions applicable to application and regulatory fees, e.g., notice to Congress and waiver provisions). and the Commission’s FY 2022 Appropriations Act. Consolidated Appropriations Act, 2022, Public Law No. 117-103, Division E - Financial Services and General Government Appropriations Act, 2022, Title V—Independent Agencies, Federal Communications Commission, Salaries and Expenses, 136 Stat. 268-269 (Mar. 15, 2022) (FY 2022 Consolidated Appropriations Act) (appropriating $381,950,000 to the Commission for salaries and expenses, and directing the Commission to collect $381,950,000 in offsetting collections for FY 2022). In this Report and Order, we adopt the regulatory fee schedule, as set forth in Appendices B and C, to collect $381,950,000 in congressionally required regulatory fees for FY 2022. 47 U.S.C. §§ 156, 159. The regulatory fee collection is guided by both the statutory authority in sections 6 and 9 of the Act and the explicit language of each fiscal year’s salaries and expenses appropriation directing the amount to be collected as an offsetting collection. In the attached Notice of Inquiry, we seek further comment on the Commission’s methodology for allocating indirect full-time equivalents (FTEs), previously raised in the FY 2022 NPRM. Assessment and Collection of Regulatory Fees for Fiscal Year 2021, Assessment and Collection of Regulatory Fees for Fiscal Year 2022, MD Docket Nos. 21-190, 22-223, Report and Order and Notice of Proposed Rulemaking, FCC 22-39, 2022 WL 2045858, at *18, para. 52 (June 2, 2022) (FY 2022 NPRM). A “Full Time Equivalent,” 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. See generally U.S. Executive Office of the President, Office of Management and Budget, Preparation, Submission, and Execution of the Budget (Washington: GPO, April 2021), https://www.whitehouse.gov/wp-content/uploads/2018/06/a11.pdf. See section 85.5(c) for a detailed explanation of how FTEs are calculated. 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 annual salaries and expenses (S&E) appropriation. 47 U.S.C. § 159(a), (b). Regulatory fees recover direct costs, such as salaries and expenses; indirect costs, such as overhead functions; statutorily required tasks that do not directly equate with oversight and regulation of a particular regulatee but instead benefit the Commission and the industry as a whole; and support costs, such as rent, utilities, and equipment. See Assessment and Collection of Regulatory Fees for Fiscal Year 2004, MD Docket No. 04-73, Report and Order, 19 FCC Rcd 11662, 11666, para. 11 (2004) (FY 2004 Report and Order). Regulatory fees must recover the total amount of the annual appropriation; therefore, they also cover the Commission’s costs incurred in oversight and regulation of entities that are statutorily exempt from paying regulatory fees (i.e., governmental and nonprofit entities, amateur radio operators, and noncommercial radio and television stations), 47 U.S.C. § 159(e)(1). entities that are exempt from payment of FY 2022 regulatory fees because their total assessed annual regulatory fees fall below the annual de minimis threshold, 47 U.S.C. § 159(e)(2). Section 9(e)(2) of the Act permits the Commission to exempt a party from paying regulatory fees if “in the judgment of the Commission, the cost of collecting a regulatory fee established under this section from a party would exceed the amount collected from such party.” and entities whose regulatory fees are waived. 47 U.S.C. § 159A(d); 47 CFR § 1.1166. 3. FTE Allocation. Each fiscal year, the Commission adjusts the regulatory fee schedule to reflect changes in the number of units subject to regulatory fees 47 U.S.C. § 159(c)(1)(A). and changes in the amount of the Commission’s appropriation. 47 U.S.C. § 159(c)(1)(B). In 2018, as part of the RAY BAUM’S Act, Consolidated Appropriations Act, 2018, Pub. L. No. 115-141, 132 Stat. 1084, Division P – RAY BAUM’S Act of 2018, Title I, § 103 (2018) (RAY BAUM’S Act). Our methodology for implementing our regulatory fee authority essentially remains unchanged by the RAY BAUM’S Act. In the FY 2019 Report and Order, the Commission analyzed the changes to the statutory regulatory fee authority and determined that “the fee assessment structure dictated by the statute fundamentally remains unchanged. Or, in other words, because the new section 9 of the Act closely aligns to how the Commission assessed and collected fees under the prior section 9 of the Act, we will hew closely to our prior methodology in assessing FY 2019 regulatory fees.” See Assessment and Collection of Regulatory Fees for Fiscal Year 2019, MD Docket No. 19-105, Report and Order and Further Notice of Proposed Rulemaking, 34 FCC Rcd 8189, 8192-93, paras. 7-8 (2019) (FY 2019 Report and Order). Congress revised the Commission’s regulatory fee authority by modifying section 9 of the Act and adding new section 9A. See RAY BAUM’S Act. The Commission adopted several rule amendments FY 2019 Report and Order, 34 FCC Rcd at 8209-212, paras. 56-60. to conform the rules to the RAY BAUM’S Act. Id. at 8193, para. 7; 47 U.S.C. § 159. However, the Commission rejected arguments that the RAY BAUM’S Act fundamentally changed how the Commission should calculate regulatory fees and that it was no longer required to base regulatory fees on the direct FTEs in core bureaus. FY 2019 Report and Order, 34 FCC Rcd at 8193, para. 8. Given the Act’s explicit language that fees must reflect FTEs, the FTE counts are by far the most administrable starting point for regulatory fee allocations. Id. In plain language, the Commission does not assign direct FTEs within a bureau to specific fee categories by rote or at random. Instead, the Commission assigns direct FTEs within a bureau to specific fee categories in a manner that reflects the time spent by FTEs on oversight and regulation of such regulatory fee category, which is the “benefit” to the payor in each fee category. The Commission has stated that “Section 9 is clear . . . that regulatory fee assessments are based on the burden imposed on the Commission, not benefits realized by regulatees.” Assessment and Collection of Regulatory Fees for Fiscal Year 2007, MD 07-81, Report and Order and Further Notice of Proposed Rulemaking, 22 FCC Rcd 15712, 15719, para. 19 (2007). Thus, the Commission explained it would continue to apportion regulatory fees across fee categories based on the number of non-auctions direct FTEs in each core bureau and to take into account factors that are reasonably related to the payor’s benefits. See FY 2019 Report and Order, 34 FCC Rcd at 8193, para. 9. 4. The Commission issues an annual Notice of Proposed Rulemaking seeking comment on the methodology for assessing regulatory fees and the proposed regulatory fees for the fiscal year. The annual Notice of Proposed Rulemaking, FY 2022 NPRM, was released on June 2, 2022. In addition to annual regulatory fee adjustments, See 47 U.S.C. § 159(c). Pursuant to section 9A of the Act, the Commission must notify Congress immediately upon adoption of any adjustment. See 47 U.S.C. § 159(A)(b)(1). the Commission is required to amend the regulatory fee schedule “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.” 47 U.S.C. § 159(d). Pursuant to section 9A of the Act, the Commission must notify Congress at least 90 days prior to making any amendments to the regulatory fee schedule effective. See 47 U.S.C. § 159(A)(b)(2). In implementing the Commission’s section 9 authority, the Commission considers the adoption of a new regulatory fee category or a change in an existing regulatory fee category only when it develops sufficient basis for making the change, and works to ensure that all changes serve the goal of ensuring that the Commission’s assessment of regulatory fees is fair, administrable, and sustainable. See Assessment and Collection of Regulatory Fees for Fiscal Year 2013, MD Docket Nos. 12-201, 13-58, 08-65, Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking, 28 FCC Rcd 7790, 7798-7807, paras. 17-40 (2013); Procedures for Assessment and Collection of Regulatory Fees for Fiscal Year 2012, MD Docket No. 12-20, Notice of Proposed Rulemaking, 27 FCC Rcd 8458, 8464-65, paras. 14-16 (2012) (FY 2012 Regulatory Fee Reform NPRM). 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. In adopting our fee schedule, we are also mindful of other general limits of fee authority. See National Cable Television Ass’n v. United States, 415 U.S. 336, 340-41 (1974) (construing Independent Offices Appropriations Act)(IOAA)); see also National Cable Television Ass'n v. FCC, 554 F.2d 1094, 1106 & n.42 (D.C. Cir. 1976). While IOAA no longer applies to the Commission, we remain cognizant of broader legal issues raised by user fee and/or regulatory fee precedent. See House of Representatives Report No. 99-453 (1985) at page 433 (noting the significance of National Cable and explaining that IOAA no longer applies to the Commission with the passage of other specific fee authority, application fees, in COBRA-85). 5. 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). See, e.g., FY 2019 Report and Order, 34 FCC Rcd at 8195, para. 14 (“we have long relied on direct FTE allocations because the Commission has found those allocations best reflect the ‘benefits provided to the payor of the fee by the Commission’s activities’—in the case of broadcast licensees, the work the Media Bureau does to grant licenses and oversee and regulate their operations.”); FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8461, para. 8 (“The Commission allocates FTEs according to the nature of the employees’ work. If the work performed by an employee can be assigned to a regulatory fee category in one of the four core licensing bureaus—Wireless Telecommunications, Media, Wireline Competition, and International—that employee’s time is counted as a direct FTE. If the work cannot be assigned to one of the bureau’s designated fee categories, the employee’s time is counted as an indirect FTE.”); Assessment and Collection of Regulatory Fees for Fiscal Year 2014, MD Docket Nos. 14-92, 13-140, 12-201, Report and Order, 29 FCC Rcd 10767, 10768, para. 2 (2014) (FY 2014 Report and Order) (explaining the reliance on direct FTEs for purposes of determining regulatory fee calculations). The Commission, therefore, typically assesses the allocation of FTEs by first determining the number of direct FTEs, those non-auctions Auctions expenses are separately funded and not part of the Commission’s S&E appropriation. The Commission recovers the costs of developing and implementing its section 309(j) spectrum auctions program as an offsetting collection against auction proceeds and subject to an annual cap. 47 U.S.C. § 309(j)(8)(B) (providing that “the salaries and expenses account of the Commission shall retain as an offsetting collection such sums as may be necessary from such proceeds for the costs of developing and implementing the program required by this subsection); FY 2022 Consolidated Appropriations Act (providing that “proceeds from the use of a competitive bidding system that may be retained and made available for obligation shall not exceed $128,621,000 for fiscal year 2022.”). For this reason, auctions FTEs are not included in the calculation of regulatory fees and the Commission’s methodology excludes all auction-related FTEs and their overhead from the regulatory fee calculations. To the extent that FTEs within core bureaus spend a portion of their time on auctions issues and a portion of their time on non-auctions issues, their time is split and only the non-auctions portion of their time is reflected in the relevant core bureau’s FTE count. Assessment and Collection of Regulatory Fees for Fiscal Year 2021, MD Docket No. 21-190, Report and Order and Notice of Proposed Rulemaking, 36 FCC Rcd 12990,12999-13000, para. 20 (2021) (FY 2021 Report and Order). FTEs whose work is focused on the industry segment in each in each core bureau (i.e., the Wireless Telecommunications Bureau, the Media Bureau, the Wireline Competition Bureau, and the International Bureau), and then attributing all other non-auction FTEs as indirect. See FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8460, para. 5 & n.5; Procedures for Assessment and Collection of Regulatory Fees for Fiscal Year 2012, MD Docket No. 12-116, Report and Order, 27 FCC Rcd 8390, 8392 paras. 3-5 (2012) (FY 2012 Report and Order). 6. The non-auctions FTEs that are not direct are considered indirect for purposes of calculating regulatory fees. There are 943 indirect FTEs, and they are in the FTEs in the Enforcement Bureau (187), Consumer and Governmental Affairs Bureau (111), Public Safety and Homeland Security Bureau (98), Chairwoman’s and Commissioners’ offices (22), Office of the Managing Director (136), Office of General Counsel (70), Office of the Inspector General (47), Office of Communications Business Opportunities (10), Office of Engineering and Technology (66), Office of Legislative Affairs (8), Office of Workplace Diversity (4), Office of Media Relations (12), Office of Economics and Analytics (78), and Office of Administrative Law Judges (4), along with some FTEs in the Wireline Competition Bureau (38) and the International Bureau (52) that the Commission has previously classified as indirect for regulatory fee purposes. The Commission has previously reassigned FTEs in core bureaus as indirect for regulatory fee purposes, due to the nature of their work assignments. For example, in 2013, the Commission allocated as indirect all but 28 International Bureau FTEs. Assessment and Collection of Regulatory Fees for Fiscal Year 2013, MD Docket Nos. 13-140, 12-201, 08-65, Report and Order, 28 FCC Rcd 12351, 12355-56, para. 14 (2013) (FY 2013 Report and Order). Subsequently, in the FY 2015 Report and Order, the Commission reassigned, for regulatory fee purposes, four International Bureau FTEs working on market access requests for non-U.S. licensed space stations as indirect. See Assessment and Collection of Regulatory Fees for Fiscal Year 2015, MD Docket No. 15-121, Report and Order and Further Notice of Proposed Rulemaking, 30 FCC Rcd 10268, 10278, para. 24 (2015) (FY 2015 Report and Order). Those four indirect FTEs have since been reclassified as direct. Assessment and Collection of Regulatory Rees for Fiscal Year 2020, MD Docket Nos. 20-105, 19-105, Report and Order and Notice of Proposed Rulemaking, 35 FCC Rcd 4976, 4991, para. 33 (2020) (FY 2020 NPRM). In 2017, the Commission assigned as indirect, for regulatory fee purposes, 38 FTEs in the Wireline Competition Bureau who work on non-high cost programs of the Universal Service Fund. Assessment and Collection of Regulatory Fees for Fiscal Year 2017, MD Docket No. 17-134, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 7057, 7061-64, paras. 10-15 (2017) (FY 2017 Report and Order). 7. The direct FTEs within each core bureau are then attributed to payor categories based on the nature of the FTE work. Our methodology for implementing our regulatory fee authority essentially remains unchanged by the RAY BAUM’S Act. See FY 2019 Report and Order, 34 FCC Rcd at 8192-93, para. 7 (“Accordingly, we find the fee assessment structure dictated by the statute fundamentally remains unchanged. Or, in other words, because the new section 9 closely aligns to how the Commission assessed and collected fees under the prior section 9, we will hew closely to our prior methodology in assessing FY 2019 regulatory fees.”). In section 9 of the Act, Congress prescribed that regulatees bear the FTE burden associated with their oversight and regulation by the relevant core bureaus. Assessment and Collection of Regulatory Fees for Fiscal Year 2019, MD Docket No. 19-105, Notice of Proposed Rulemaking, 34 FCC Rcd 3272, 3275-77, paras. 6-10 (2019) (FY 2019 NPRM). Because the amount the Commission must collect in an offsetting collection changes each year, fees will typically change each year as a mathematical consequence of the change in amount to be collected in the current year, The offsetting collection for FY 2022 has increased by $7,950,000 or 2.13% from the FY 2021 appropriated level of $374,000,000. FTE allocations in the core bureaus, and projected unit estimates. Section 9(c)(1)(B) of the Act contemplates such changes to the fee schedule necessary to result in the collection of the amount required by subsection 159(b). 47 U.S.C. § 159(c)(1)(B). For example, if the number of units in a regulatory fee category increases, the amount due per unit may decrease, depending on other factors. Such changes under section 9(c) of the Act fall under the section 9A(b)(1) Congressional notification requirements. 47 U.S.C. §§159A(b)(1), 159(c). Beyond those changed collection requirements, consideration of changes, additions, or deletions to the fee schedule is focused on the Commission’s FTE cost burden related to the regulatory fee category at issue. For example, in 2015, based upon an analysis of the regulatory and oversight work performed by FTEs in the Media Bureau, the Commission adopted a regulatory fee for Direct Broadcast Satellite (DBS), as a subcategory of the cable television and Internet Protocol television (IPTV) fee category. FY 2015 Report and Order, 30 FCC Rcd at 10276-77, paras. 19-20. Changes under section 9(d) of the Act fall under the section 9A(b)(2) 90-day notification to Congress. 47 U.S.C. §§ 159A(b)(2), 159(d). 8. In the FY 2022 NPRM, we sought comment on the methodology for assessing regulatory fees and on the schedule of FY 2022 regulatory fees. We also sought comment on several additional issues: (i) space station regulatory fees, including new regulatory fees for small satellites; (ii) continuing to use our methodology for calculating television broadcaster regulatory fees based on population; (iii) calculating the cost of collection of regulatory fees in establishing the annual de minimis threshold; (iv) reclassification of certain FTEs; (v) adopting new regulatory fee categories; and (vi) and how our proposals may promote or inhibit advances in diversity, equity, inclusion, and accessibility. We received ten comments and sixteen reply comments. Commenters are listed in Appendix A. III. REPORT AND ORDER 9. Pursuant to section 9 of the Act, in this Report and Order we adopt the regulatory fee schedule, as set forth in Appendices B and C for FY 2022, to collect $381,950,000 in regulatory fees as required by Congress. FY 2022 regulatory fees are listed in Appendices B and C. We note that certain of the fees proposed in our NPRM have changed as a result of our holdings in this order. A. Allocating Full-time Equivalents 10. We will continue to apportion regulatory fees across fee categories based on the number of non-auction direct FTEs in each core bureau (i.e., the Wireline Competition Bureau, the Wireless Telecommunications Bureau, the Media Bureau, and the International Bureau) and taking into account factors that are “reasonably related to the benefits provided to the payor of the fee by the Commission’s activities.” FY 2022 NPRM at *5-*7, paras. 15-19. See FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8461, para. 8 (“The Commission allocates FTEs according to the nature of the employees’ work. If the work performed by an employee can be assigned to a regulatory fee category in one of the four core licensing bureaus—Wireless Telecommunications, Media, Wireline Competition, and International—that employee’s time is counted as a direct FTE.”). The phrase “core” bureaus was first adopted in the FY 2012 Regulatory Fee Reform NPRM where the Commission explained that, under (prior) section 9(b)(1)(A), regulatory fees were calculated 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; 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. Id. at 8460, para. 5 & n.5. The Commission explained that “[f]or simplicity and ease of reference . . . we will refer to these four bureaus as the ‘core’ bureaus or the ‘core licensing’ bureaus.” Id. We expect that the work of the non-auctions FTEs in the four core bureaus with oversight and regulation of Commission licensees and regulatees will remain focused on the industry segment regulated by each of those bureaus. FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8465-66, paras. 19-20. For this reason, the Commission closely follows the statutory mandate to start with FTE counts and then potentially adjust fees to reflect other factors related to the benefits provided to the payor of the fee by the Commission’s activities. FY 2019 Report and Order, 34 FCC Rcd at 8195, para. 16. As the Commission stated in the FY 2019 Report and Order, given the Act’s requirement that fees must reflect FTE time before adjusting fees to take into account other factors, we continue to find FTE counts by far the most administrable starting point for regulatory fee allocations. Id. at para. 8. 11. NAB and the Joint Broadcasters question our methodology and argue that the Commission assigns a disproportionate share of the costs of the 343 indirect FTEs to the Media Bureau without any analysis performed as to what portion of those indirect FTEs actually work on Media Bureau issues. NAB Comments at 8; Joint Broadcasters Reply at 3. Specifically, the Joint Broadcasters argue that Media Bureau regulatees’ regulatory fees are inflated in order to cover costs for staff time not spent on broadcast-related issues. Joint Broadcasters Reply at 3. The Joint Broadcasters contend that the proportional allocation methodology, whereby regulatory fees are allocated based on the number of direct FTEs in the core bureaus, leads to fundamentally unfair results and that broadcasters subsidize the costs of the Commission’s indirect bureaus and offices. Id. 12. These commenters fail to recognize the fundamental task assigned to the Commission. The Commission must recover the full S&E appropriation through an offsetting collection. The S&E appropriation does not solely fund staff time spent directly regulating regulatory fee payors. The S&E appropriation funds all non-auctions-related costs, such as salaries and expenses of all non-auctions funded staff; indirect costs, such as overhead functions; statutorily required tasks that do not directly equate with oversight and regulation of a particular regulatee but instead benefit the Commission and the industry as a whole; support costs, such as rent, utilities, and equipment; and the costs incurred in regulating entities that are statutorily exempt from paying regulatory fees (i.e., governmental and nonprofit entities, amateur radio operators, and noncommercial radio and television stations), 47 U.S.C. § 159(e)(1). entities with total annual assessed fees below the de minimis threshold, 47 U.S.C. § 159(e)(2). and entities whose regulatory fees are waived. 47 U.S.C. § 159(d); 47 CFR § 1.1166. As the Commission explained in the FY 2019 Report and Order, Media Bureau regulatory fee payors are not alone in having to pay for exempt licensees; there are exempt licensees in most of the fee categories, such as Interstate Telecommunications Service Providers (ITSPs) and earth stations. FY 2019 Report and Order, 34 FCC Rcd at 8196-97, para. 19. For that reason, we do not examine whether all indirect FTEs work on Media Bureau issues or on any other core bureau issues. Instead, we recognize that the indirect FTEs’ work may not directly address oversight and regulation of just one particular regulatory fee category and may instead cover many different regulatory fee categories or issues not pertaining to any regulated industries. The statute requires the full collection of an amount equal to the annual S&E appropriation and requires that the mechanism used to apportion the collection is based on FTE burden. Thus, all Commission non-auctions FTEs must be accounted for in our regulatory fee assessments because, pursuant to section 9 of the Act, 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). In order to allocate regulatory fees based on all the non-auctions FTEs in the Commission’s bureaus and offices, the Commission bases this calculation on the number of FTEs within the Commission’s core bureaus, i.e., those bureaus that conduct oversight and regulation of issues that benefit the fee payors. See FY 2013 NPRM, 28 FCC Rcd at 7793-94, para. 7; FY 2013 Report and Order, 28 FCC Rcd at 12352-53, para. 6. 13. The State Broadcasters Associations contend that it is likely that throughout the Commission there are identifiable groups of indirect FTEs working in non-core bureaus and offices, or collaboratively across bureaus and offices, whose work in oversight and regulation can be identifiably shown to only benefit some but not all regulatory fee payors. State Broadcasters Associations Comments at 14. Accordingly, the State Broadcasters Associations argue that such indirect FTEs, whether handling Universal Service Fund or broadband Internet access service issues, should be excluded from the indirect FTEs proportionally allocated to media services categories. State Broadcasters Associations Comments at 15. But see NCTA Reply at 7-8 (asserting that it is disingenuous for broadcasters to contend that they do not benefit from the Commission’s broadband or Universal Service Fund work in light the fact that the expansion of new communications networks into new areas means new carriage opportunities for local broadcasters on the associated video services, and more opportunities for the broadcasters’ websites and streaming services to reach viewers). Thus, the State Broadcasters Associations propose creating a third regulatory fee category, which they label as “Intersectional FTE.” State Broadcasters Associations Comments at 15-16. They propose that this third regulatory category cover FTEs in the non-core bureaus and those in core bureaus who work on similar issues regulated by various bureaus but benefit a discrete group of regulatees. State Broadcasters Associations Comments at 15. SIA agrees that we should adopt a hybrid FTE to reflect the intersectional work that involves FTEs from non-core and core bureaus working together collaboratively or across bureaus. SIA Reply at 3. The State Broadcasters Associations argue that the work of indirect FTEs working on long-standing priorities of the Commission, such as Universal Service Fund program issues and broadband Internet access service, unfairly burdens regulatory fee payors who do not benefit from these programs yet are required to pay regulatory fees that cover a proportion of such indirect FTEs. State Broadcasters Associations Comments at 18. Essentially, the State Broadcasters Associations are of the opinion that there are some indirect FTEs who do not work on broadcast issues, Proceedings involving broadcast licenses in Media Bureau dockets are not the only issues that affect broadcasters. Broadcasters and their trade association participate in dockets other than Media Bureau dockets (e.g., non-core bureau dockets) that affect broadcast services. For example, NAB has been involved in a rulemaking proceeding regarding the unlicensed use of spectrum in the 6 GHz band. Unlicensed Use of the 6 GHz Band, ET Docket No. 18-295, Report and Order and Further Notice of Proposed Rulemaking, 35 FCC Rcd 3852 (2020) (6 GHz Report and Order), aff’d in part and remanded in part, AT&T Servs. Inc., v. FCC, 21 F.4th 841, 853-54 (D.C. Cir. 2021) (AT&T). This proceeding “open[ed up] the entire 6 GHz band [(5.925–7.125 GHz)] for unlicensed indoor lower power access points.” 6 GHz Report and Order, 35 FCC Rcd at 3860, para. 18. The Commission found that “[t]hese access points will be ideal for connecting devices in homes and businesses such [as] smartphones, tablet devices, laptops, and Internet-of-Things devices to the Internet.” Id. at 3854, para. 3. NAB’s position is, in part, that the Commission should prohibit unlicensed mobile hot spots and transportable devices to operate in the 6 GHz band to limit the potential for interference to licensed incumbents. See NAB Reply in ET Docket No. 18-295, GN Docket No. 17-183 at 2 (filed Mar. 23, 2021). See also NAB’s comments filed in Amendment of Part 15 of the Commission’s Rules for Unlicensed Operations in the Television Bands, Repurposed 600 MHz Band, 600 MHz Bands and Duplex Gap, and Channel 37, ET Docket No. 14-165, GN Docket No. 12-268, ET Docket No. 20-36, ET Docket No. 04-186 at 1-8 (filed July 1, 2022) contending that the Commission should require all TV white spaces devices to recheck the white spaces database every hour to prevent harmful interference. We also note that other non-core bureaus and offices, such as the Enforcement Bureau and the Office of Administrative Law Judges, handle broadcast licensee matters. See, e.g., FCC, Enforcement Bureau, Investigative and Adjudicatory Areas, https://www.fcc.gov/eb-iaa (last visited Aug. 3, 2022); FCC, Office of Administrative Law Judges, Administrative Law Judges Headlines, https://www.fcc.gov/administrative-law-judges (last visited Aug. 3, 2022). and therefore broadcasters should not be assessed regulatory fees that include such indirect FTEs, i.e., their regulatory fees should be reduced. State Broadcasters Associations Comments at 18; NAB Reply at 6-10. 14. Additionally, the Satellite Coalition claims that regulatory fees are especially burdensome for the satellite industry, as some satellite companies pay millions of dollars per year solely to cover indirect FTE costs. Satellite Coalition Reply at 6. The Satellite Coalition contends that by undertaking a reassessment of whether FTEs currently classified as indirect can be assigned directly to one or more categories of fee payors, the Commission can greatly improve the fee structure’s fairness. Id. at 7. Similarly, NAB contends that our regulatory fee methodology and allocation of indirect FTEs results in a system that is arbitrary and capricious, inequitable, and unlawful. NAB Comments at 8. 15. Again, we note that the regulatory fees must cover the entire appropriation, including those FTEs who may work on issues for which we do not have regulatory fee categories. We therefore continue to find that, consistent with section 9 of the Act, regulatory fees are not based on a precise allocation of specific employees with certain work assignments each year and instead are based on a higher-level approach. As the Commission has explained previously, indirect FTE time covers a wide range of issues; the variety of issues handled by the indirect FTEs in non-core bureaus may also include services that are not specifically correlated with one core bureau, let alone one specific category of regulatees. FY 2019 Report and Order, 34 FCC Rcd at 8196, para. 18; FY 2015 Report and Order, 30 FCC Rcd at 10275, para. 17. Indirect FTE work also includes matters that are not specific to any regulatory fee category, and many Commission attorneys, engineers, analysts, and other staff work on a variety of issues during a single fiscal year. For example, indirect FTEs that devote time to broadband Internet access services or Universal Service Fund issues may also work on a variety of other issues during the fiscal year. Thus, we affirm the longstanding holding that the non-auctions work of certain bureaus and offices within the Commission are properly designated as indirect. Even if we could calculate indirect FTE time assignments at a granular level with accuracy, using any particular window of time less than the full year would not be accurate for the entire fiscal year. Moreover, we note that basing regulatory fees on specific assignments, instead of overall FTE time, would result in significant unplanned shifts in regulatory fees as assignments change over time. FY 2019 Report and Order, 34 FCC Rcd at 8196, para. 18. As the Commission observed in the FY 2012 Regulatory Fee Reform NPRM, with respect to the administrability of trying to allocate indirect FTEs to core bureaus, “if in one year the Public Safety and Homeland Security Bureau handles rulemakings related to broadcasting, but in the following year focuses on wireless services, the resulting shift in FTE allocations could have a substantial impact on the size of regulatory fees, which could then shift significantly again the very next year.” FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8465, para. 15. 16. Further, much of the work that could be assigned to a single category of regulatees is likely to be interspersed with the work that FTEs do on behalf of many entities that do not pay regulatory fees, e.g., governmental entities, non-profit organizations, and regulatees that have an exemption. See, e.g., 47 U.S.C. § 159(e). Indirect FTE time covers matters that are not specifically related to a regulated service, but instead support the Commission generally. Additionally, indirect FTE time is devoted to issues that are not specifically limited to one type of regulated industry. Finally, we note that regulatory fees are a zero-sum situation, so any decrease to the fees paid by one category of regulatees, such as broadcasters, necessitates an increase in fees for others. See FY 2019 Report and Order, 34 FCC Rcd at 8195, para. 16. For this reason, there must be a very strong rationale for changing the manner of proportionally allocating indirect FTEs to certain fee categories based on direct FTEs because any such changes will impact the fees of other regulatory fee categories. We disagree with the commenters’ contention that our methodology is arbitrary and capricious, inequitable, and unlawful. Instead, we conclude that our methodology is consistent with the requirements of section 9 of the Act that “fees reflect the full-time equivalent number of employees within the bureaus and offices of the Commission.” 47 U.S.C. § 159(d). 17. Additionally, we find that even if the State Broadcasters Associations’ proposal were consistent with section 9 of the Act, it would not be administrable given the resources it would take to calculate and the resulting constantly shifting nature of the regulatory fee burdens. NCTA Reply at 5. The State Broadcasters Associations’ proposal would require resources of both staff and presumably information technology devoted to this proposed new system. Additionally, it would require a close monitoring and analysis of all the work of all indirect FTEs in the Commission over the course of the entire year. As NCTA states, “the idea that the Commission should undertake an analysis of hundreds of employees’ daily undertakings, monitoring them and changing their indirect allocation to different fee categories as the employees receive new assignments and work on different issues throughout the day is nonsensical.” Id. Thus, we do not believe that added granularity would change the overall result, or improve our regulatory fee methodology, but would simply consume more staff resources and increase the indirect FTE time devoted to regulatory fee administration. Even if we could conduct such a monitoring accurately, it would still be unable to account for the vast majority of indirect FTE time that cannot be allocated specifically to regulatory fee categories. This proposal would result in attributing some indirect FTE time to various regulatory fee categories in a manner that would fluctuate constantly, depending on the work done in bureaus and offices during the year, and others that could not be so attributed at all. See CTIA Reply at 5 (observing that indirect FTE allocations based upon individual proceedings or policy issues would be an insurmountably complex task, particularly when they involve the interests of regulatees from multiple bureaus, and would result in unpredictable and rapid shifts in regulatory fee rates from year to year). We are not adopting a regulatory fee methodology that would result in dramatic swings in fees from one year to the next; instead we take a higher level approach for consistency as well as administrability. Our approach is most accurate when we look at the work of a larger group such as a division, office, or bureau, consistent with the language of section 9 of the Act that “fees reflect the full-time equivalent number of employees within the bureaus and offices of the Commission.” 47 U.S.C. § 159(d). 18. NAB argues that the Media Bureau regulatees have a high regulatory fee burden because, unlike other core bureaus, the Commission has not reclassified any Media Bureau FTEs as indirect. NAB Comments at 10. With respect to the commenters’ complaint about the high number of FTEs in the Media Bureau, we recognize that the FTEs in the Media Bureau perform a variety of functions of which commenters may not be aware, e.g., bureau staff develops, recommends, and administers the policy and licensing programs for the regulation of media, including cable television, broadcast television and radio, and satellite services in the United States and its territories. The Media Bureau advises and recommends to the Commission, or acts for the Commission under delegated authority, in matters pertaining to multichannel video programming distribution, broadcast radio and television, direct broadcast satellite service policy, and associated matters. During calendar year 2021, the Media Bureau reviewed and processed over 60,000 applications, reports or special requests. The Media Bureau anticipates handling a similar number of filings during 2022. The Media Bureau will, among other things: provide oversight of the radio and television industry including enforcement actions; process applications for authorization, assignment, transfer, and renewal of over 32,000 licensed broadcast radio and television stations, and related matters; conduct rulemaking proceedings concerning the legal, engineering, and economic aspects of the media industry; resolve waiver petitions, issue declaratory rulings, and conduct and participate in adjudications related to the media industry; ensure the smooth transition of full power, Class A, LPTV, and translator stations as a result of the Incentive Auction repack and process the reimbursement claims submitted to the $2.75 billion TV Broadcaster Relocation Fund from these stations, FM stations, and multichannel video programming distributors; and work with the International Bureau on applications and other broadcast matters implicating international rules and policies, including foreign ownership, international broadcast stations, section 325(c) matters, spectrum coordination with Canada and Mexico, and broadcasting issues at the International Telecommunications Union. Thus, the high number of FTEs in the Media Bureau is due to the many functions performed in the Media Bureau for the industry. This is inaccurate. In FY 2019, we had such reclassifications from core bureaus, including the Media Bureau. FY 2019 Report and Order, 34 FCC Rcd at 8194, para. 11. The Commission reassigned staff from other bureaus and offices to the new Office of Economics and Analytics, effective December 11, 2018. See Establishment of the Office of Economics and Analytics, Order, 33 FCC Rcd 1539 (2018); FCC Opens Office of Economics And Analytics, Federal Communications Commission News Release, December 11, 2018, https://www.fcc.gov/document/fcc-opens-office-economics-and-analytics. This resulted in the reassignment of 95 FTEs (of which 64 were not auctions-funded) as indirect FTEs because all FTEs in the Office of Economics and Analytics are indirect. The Commission also reassigned Equal Employment Opportunity enforcement staff from the Media Bureau to the Enforcement Bureau, effective March 15, 2019, resulting in a reduction of seven direct FTEs in the Media Bureau. See Transfer of EEO Audit and Enforcement Responsibilities to Enforcement Bureau, Public Notice, 34 FCC Rcd 1370 (EB 2019). These reassignments resulted in a reduction in direct FTEs in the Wireline Competition Bureau (from 123 FTEs to 100.8 FTEs), Wireless Telecommunications Bureau (from 89 FTEs to 80.5 FTEs), and Media Bureau (from 131 FTEs to 115.1 FTEs). FY 2019 Report and Order, 34 FCC Rcd at 8194, para. 11. 19. NAB also argues that the Commission should ensure that broadcasters bear no responsibility for the 84 direct FTEs in the Media Bureau that the Commission has stated to Congress are working to promote a 100% broadband policy, and that these 84 Media Bureau FTEs should be reclassified as indirect. NAB Comments at 13. NAB claims that the Commission must immediately subtract 84 FTEs from the Media Bureau’s count of direct FTEs. NAB Reply at 7. The statement to Congress to which NAB refers is the description of the Commission’s Strategic Goals and the distribution of FTEs for each Strategic Goal. See FCC, 2022 Budget Estimates to Congress (May 2021) at 15, https://docs.fcc.gov/public/attachments/DOC-372853A1.pdf. (FCC 2022 Budget Estimates to Congress). The goal NAB refers to is the Commission’s Strategic Goal to “Pursue a “100 Percent” Broadband Policy.” The Strategic Goal NAB refers to—Pursue a “100 Percent” Broadband Policy—is described as follows: The COVID-19 pandemic put a spotlight on the serious broadband gaps that exist across the country, including in rural infrastructure, affordability for low-income Americans, and at-home access for students. This continuing digital divide means millions of Americans do not have meaningful access to essential infrastructure for 21st century success. In response to the COVID-19 pandemic and the challenges that many Americans face, the agency should advance access to communications that are essential for Americans to work remotely, learn remotely, receive healthcare, and engage in commerce. To this end, the FCC will pursue policies to help bring affordable, reliable, high-speed broadband to 100 percent of the country. Id. at 9. The other goals are to Promote Diversity, Equity, Inclusion, and Accessibility; Empower Consumers; Enhance Public Safety and National Security; Advance America’s Global Competitiveness; and Foster Operational Excellence. Id. at 15. These Strategic Goals are part of the Commission’s policy to develop a regulatory environment to encourage private sector to build, maintain, and upgrade next-generation networks so that the benefits of advanced communications services are available to all Americans. Id. at 7. The Commission, like every other federal agency, adopts strategic goals as part of its long term planning process pursuant to federal financial management requirements. An agency strategic plan is one of three main elements required by the Government Performance and Results Act (GPRA) of 1993 (P.L. 103-62) and the GPRA Modernization Act of 2010 (P.L. 111-352), codified at 5 U.S.C. § 306, Agency strategic plans. Pursuant to GPRA and the Office of Management and Budget’s implementing guidance in OMB Circular A-11, Preparation, Submission, and Execution of the Budget, federal agency budgets must include an Annual Performance Plan. The Annual Performance Plan must be based on the Strategic Goals contained in the agency’s four year Strategic Plan. The financial reporting statutes also require agencies to identify the resources that support such strategic goals. Id. The strategic goals are not aligned with a particular regulatory fee category and the exercise is guided by a wholly distinct statutory scheme. 5 U.S.C. § 306 (directing in section 306(a)(2) each agency to adopt “general goals and objectives, including outcome-oriented goals, for the major functions and operations of the agency”). Moreover, the attribution of staff to any strategic goal in an agency planning document is certainly not accomplished using the framework of section 9 of the Communications Act or the relevant legal principles that apply to agency fee setting activities. In addition, such strategic goals are intended to align with higher level priority goals of the overall federal government. Such goals should also “contribute to the Federal Government priority goals” required by section 1120(a) of title 31. 5 U.S.C. § 306(a)(3). As such, a notation that staff support a specific strategic goal is not a sound rationale for reassigning staff from direct to indirect or vice versa. Moreover, we note that the FTE time allocated to each strategic goal, as listed in the FCC 2022 Budget Estimates to Congress, are simply estimates of the FTE time allocated to each strategic goal and does not represent the actual FTE time spent in FY 2022 on each of the Commission’s Strategic Goals. We therefore reject NAB’s contention that planning documents guided by a wholly different statutory scheme form the basis to reassign most or all of the Media Bureau FTEs as indirect. 20. Thus, we decline, at this time, to change the methodology by which we allocate FTEs. We note that we seek further comment below, in the attached Notice of Inquiry, on the Commission’s regulatory fee methodology for allocating indirect FTEs. See infra Section IV. Currently, there are 943 indirect FTEs. The indirect FTEs are the FTEs in the Enforcement Bureau (187), Consumer and Governmental Affairs Bureau (111), Public Safety and Homeland Security Bureau (98), Chairwoman’s and Commissioners’ offices (22), Office of the Managing Director (136), Office of General Counsel (70), Office of the Inspector General (47), Office of Communications Business Opportunities (10), Office of Engineering and Technology (66), Office of Legislative Affairs (8), Office of Workplace Diversity (4), Office of Media Relations (12), Office of Economics and Analytics (78), and Office of Administrative Law Judges (4), along with some FTEs in the Wireline Competition Bureau (38) and the International Bureau (52) that the Commission has previously classified as indirect for regulatory fee purposes. See supra note 27. While we do not change our established methodology, we update the way we account for the 38 Wireline Competition Bureau FTEs that we previously reclassified as indirect in 2017. We do this in order to maintain the accuracy of our proportional allocation. See infra paras. 70-71. 21. The number of direct FTEs are determined within each core bureau and a percentage of the total amount to be collected in regulatory fees for a given fiscal year is calculated. There are 329 direct FTEs: $32.70 million (8.56% of the total FTE allocation, 28 direct FTEs) in fees from International Bureau regulatees; $81.74 million (21.40% of the total FTE allocation, 70 direct FTEs) in fees from Wireless Telecommunications Bureau regulatees; $129.62 million (33.94% of the total FTE allocation, 111 direct FTEs) from Wireline Competition Bureau regulatees; and $137.89 million (36.10% of the total FTE allocation, 120 direct FTEs) from Media Bureau regulatees.  The regulatory fees we adopt here are based on the established methodology, applied to the allocated FTEs, and based on the Commission’s appropriation amount of $381,950,000.  B. Space Station and Submarine Cable Regulatory Fees 1. Non-Geostationary Orbit System (NGSO) Regulatory Fees 22. We adopt fee rates for NGSO space stations for FY 2022 and decline to create additional regulatory fee categories for FY 2022. In the Report and Order attached to the FY 2022 NPRM, we adopted a methodology for calculating the regulatory fee for small satellites and small spacecraft (together, small satellites) based on 1/20th (5%) of the average of the non-small satellite NGSO space station Space stations are divided into two main categories: (1) geostationary orbit (GSO) space stations and (2) non-geostationary orbit (NGSO) systems. regulatory fee rates from the current fiscal year on a per license basis. FY 2022 NPRM at *8-*14, paras. 21-42. In the FY 2022 NPRM, we sought comment on the proposed regulatory fee rates for the subcategories of NGSO - small satellite, NGSO - less complex space stations, and NGSO - other space stations for FY 2022, and addressed regulatory fee proposals in the record regarding spacecraft performing on-orbit servicing (OOS) and rendezvous and proximity operations (RPO). Id. at *8-*16, paras. 21-47. We also tentatively concluded that the addition of a new regulatory fee category for OOS and RPO operations would be premature, but sought further comment on whether and how to assess fees for these types of spacecraft, and other types of satellites servicing other satellites, which operate near to the geostationary orbit (GSO) arc. Id. at *15-*16, paras. 45-47. 23. NGSO Fee Allocation. We maintain the 20/80 allocation between “less complex” and “other” NGSO space station fees, respectively, within the NGSO fee category. In 2020, the Commission adjusted the allocation of FTEs among GSO and NGSO space station and earth station operators. FY 2020 NPRM, 35 FCC Rcd at 4993-95, paras. 39-45. The Commission noted the disparity in the number of units between GSO space stations (98) and NGSO systems (seven), and observed that many satellites can be operated under a single NGSO license while counting as a single unit for regulatory fee purposes, but only one satellite can be operated per GSO space station license. Id. at 4993, para. 40. To ensure that regulatory fees more closely reflected the FTE oversight and regulation for each space station category, the Commission allocated 80% of space station regulatory fees to GSOs and 20% of the space station regulatory fees to NGSOs. Id. at 4993, para. 41. In 2021, the Commission adopted two new fee subcategories: “less complex” NGSO systems and all other NGSO systems identified as “other” NGSO systems, both under the broader category of “Space Stations (Non-Geostationary Orbit).” FY 2021 NPRM, 36 FCC Rcd at 8583, para. 6. “Less complex” NGSO systems are defined as NGSO satellite systems planning to communicate with 20 or fewer U.S. authorized earth stations that are primarily used for Earth Exploration Satellite Service (EESS) and/or Automatic Identification System (AIS). Id. at 8583-84, para. 7. EESS is defined under the Commission rules as “a radiocommunication service between earth stations and one or more space stations… in which… information relating to the characteristics of the Earth and its natural phenomena, including data relating to the state of the environment, is obtained from active sensors or passive sensors on Earth satellites… .” 47 CFR § 2.1(c). “Less complex” NGSO fees and “other” NGSO fees were split within the broader NGSO fee category on a 20/80 basis. FY 2021 Report and Order, 36 FCC Rcd at 13018-19, para. 58. 24. In the Report and Order attached to the FY 2022 NPRM, the Commission adopted a fee methodology for the “small satellites” and decided that, as the “small satellite” fee is calculated, considering that “small satellites” are NGSO space stations, the fees generated from this “small satellite” fee category will be deducted from the fee amount to be collected from the total NGSO space stations fees, and the remainder of the NGSO space stations fees will continue to be allocated on a 20/80 basis between “less complex” and “other” NSGO space stations respectively. FY 2022 NPRM at *12, para. 35. 25. The Satellite Coalition first claims that the “Commission no longer can assume that EESS systems are less complex because they communicate with fewer than 20 U.S. earth stations.” Satellite Coalition Comments at 9. The Satellite Coalition contends that distinguishing “less complex” and “other” NGSOs based on the number of earth stations is no longer accurate because two of the best-known EESS systems, Spire Global and Planet Labs, already communicate with more than 20 FCC-licensed antennas. Id. at 9-10. The Satellite Coalition also observes that EESS systems are developing substitutes for dedicated, proprietary earth station networks, with some EESS systems relaying data via satellite systems that have established ground infrastructure, others associating with “ground station-as-a-service” organizations, Id. at 11. and others downlinking data directly to user terminals, including more ubiquitous mobile terminals. Id. at 11. The Satellite Coalition contends that the Commission should require licensees of EESS systems to report the total number of FCC-licensed antennas with which their systems communicate. Id. at 12. 26. The EESS Coalition disagrees with the Satellite Coalition and argues that in the year since the Commission’s 2021 decision there are “no new arguments or developments” that warrant the alterations to the NGSO fee categories sought by the Satellite Coalition. EESS Coalition Reply at 2. The EESS Coalition further argues that considerations regarding the number of earth stations as a proxy for the complexity of a system have not altered. Id. at 9. The EESS Coalition contends that, under our rules, an “earth station” could not be defined as a single antenna. Id. at 10. The EESS Coalition further disagrees that the fee allocation needs to be altered as EESS systems may begin to require more earth stations to meet demand because the Commission previously clarified that systems planning to communicate with greater than 20 earth stations would not meet the definition of “less complex.” Id. at 11-12 (citing FY 2021 Report and Order, 36 FCC Rcd at 13017-18, para. 57). Likewise, the EESS Coalition contends that the fact that EESS systems have been improving their technology is not a reason to change the fee allocation when the Satellite Coalition provides no explanation of how or why the introduction of new use cases that are not directly regulated by the Commission, or the use of third-party ground stations, support the conclusion that there are additional burdens on the Commission’s responsibilities. Id. at 9. 27. As an initial matter, we emphasize that we previously concluded that 20 or fewer planned earth stations is an accurate proxy to determine whether a primarily AIS and/or EESS system is “less complex” and that EESS systems are less burdensome to regulate than other types of services, such as NGSO FSS systems, when those EESS systems plan to communicate with 20 or fewer earth stations. FY 2021 Report and Order, 36 FCC Rcd at 13014-18, paras. 50-57. In adopting the 20 earth stations or fewer proxy for the “less complex” NGSO space station fee category, the Commission clarified that it is the number of planned earth stations in the system design provided in the NGSO space station application that is relevant, since some more complex NGSO systems may communicate with a small number of earth stations during the initial operational phases, but actually intend to communicate with a significantly larger set of earth stations. Id. We will address the Satellite Coalition’s comments to the extent that it raises new arguments. 28. We find that distinguishing “less complex” EESS systems based on whether those systems plan to communicate with 20 or fewer earth stations is still an accurate proxy. See also id. at 13017-18, para. 57 (“We also disagree… that our consideration of numbers of earth stations presupposes that EESS systems require no more than 20 earth stations to support their network.”). The Satellite Coalition argues that the Commission meant to define earth stations as antennas. Satellite Coalition Comments at 9-10. Notwithstanding the assertions of the Satellite Coalition, a single call sign, not an antenna, equates to a single earth station license. Contra id. at 10, n.36. The Commission’s definition of "earth station,” which incorporates the Commission’s definition of “station,” demonstrates that an antenna is merely part of an “earth station.” See 47 CFR § 2.1 (defining “earth station” as “[a] station located either on the earth's surface or within the major portion of earth's atmosphere and intended for communication: (1) With one or more space stations; or (2) With one or more stations of the same kind by means of one or more reflecting satellites or other objects in space”). A “station” includes “[o]ne or more transmitters or receivers or a combination of transmitters and receivers, including the accessory equipment, necessary at one location for carrying on a radiocommunication service[.]” See 47 CFR § 2.1. While an antenna may be an important piece of equipment in transmitting or receiving signals, additional accessories are needed to successfully carry out a radiocommunication, which, together with one or more antennas, constitute a “station.” Moreover, it is not apparent how the number of antennas at a particular earth station location supports a conclusion that there are additional burdens on the Commission’s responsibilities for regulatory fee purposes. 29. In addition, we disagree that we should change the 20/80 allocation now because EESS systems are developing substitutes for dedicated, proprietary earth station networks. While in the future this may result in our reconsideration of planned 20 earth stations as the dividing line between a “less complex” and “other” system, for FY 2022, we agree with the EESS Coalition that we do not have evidence that “less complex” systems’ new technology has made those NGSO systems more burdensome to regulate. EESS Coalition Reply at 9. Based on our current experience, the 20/80 split continues to be accurate and closely reflect the percentage of the FTE time spent to regulate less complex NGSO space stations and “other” NGSO space stations. 30. Finally, we remind all operators that the fee payors have an obligation to pay the correct fee amount corresponding to their actual fee category. If a non-small satellite NGSO system is listed as “less complex” but actually communicates with more than 20 earth stations, such fee payor has an obligation to correct that listing mistake to be billed the fee amount that correspond to “other” NGSO space station fee category. In the FY 2022 NPRM, we listed systems in various categories and gave the fee payors a chance to verify and correct any mistakes in our space stations list. Based on the information we received, we believe all operational “less complex” space stations are now listed in the appropriate category. We note that the public record in the International Bureau Filing System (IBFS) contains the call signs of FCC-licensed earth stations with which “less complex” systems presently communicate, with the particular NGSO system listed as a point of communication. See, e.g., Deadline for Submission of Information on Earth Station and Satellite Use of the 3.7-4.2 GHz Band, GN Docket No. 18-122, Public Notice, 34 FCC Rcd 2287 (IB/WTB/OET 2019) (calling for operators to provide information regarding their C-band usage by providing the call signs of earth stations operating in the band). Since we also include earth stations that have been authorized by other U.S. federal government agencies when determining the total number of earth stations with which a “less complex” system communicates, See FY 2021 NPRM, 36 FCC Rcd at 8584, para. 7, n.27 (stating that in the context of determining whether a system plans to communicate with 20 or fewer earth stations, we count those earth stations that are or will be operating pursuant to an FCC license or have been authorized by other U.S. federal government agencies and include earth stations located on U.S.-registered vessels or aircraft). and such information is not typically in IBFS, if needed, we may consider other options to verify the information, including an annual reporting requirement regarding the number of earth stations for future fiscal years, to aid in the administrability of and increase transparency in our maintenance of the list of “less complex” space station systems. See FY 2021 Report and Order, 36 FCC Rcd at 13018, para. 57 (“As indicated, we are using “fewer than 20 earth stations” as a proxy and at the application stage, if we determine that a space system is planning to communicate with more than 20 earth stations based on the system design, such system design and plans would indicate that the space system would not fall into the “less complex” system category for regulatory fee purposes.”). 31. Second, the Satellite Coalition also argues that the characteristics that the Commission previously noted that make EESS systems distinct from other NGSO systems, such as those NGSO systems providing fixed-satellite service (FSS), are breaking down. Satellite Coalition Comments at 8. The Satellite Coalition asserts that EESS systems now are developing a global presence and have significant spectrum needs and use multiple bands, while the significance of processing rounds has been diminished. Id. at 13-15, 17-18. Processing rounds are used by the International Bureau to authorize NGSO systems, including those that may require “always on” availability of the requested spectrum, or availability over larger geographic areas, which is consistent with those “more complex” systems planning to communicate with 20 or more U.S. licensed earth stations. See FY 2021 NPRM, 36 FCC Rcd at 8585-8586, para. 12, n.43. The Satellite Coalition contends that the Commission should not be assessing radically different regulatory fees for NGSO systems that are becoming functionally indistinct and competing for the same or similar customers. Id. at 15-16. 32. The EESS Coalition counters that many of the developments to EESS systems to which the Satellite Coalition cites took place prior to the FY 2021 regulatory fee proceeding during which the 20/80 allocation was adopted. EESS Coalition Reply at 4. The EESS Coalition further posits that the distinctions between the two regulatory fee categories remain consistent with those analyzed in the FY 2021 Report and Order. Id. at 5. For example, processing rounds have not become less intensive. Id. at 6-7. Similarly, EESS systems have not increased their global presence with activities to the extent that the Commission would be required to expend significant staff resources for representation at international forums and multilateral coordination. Id. at 8. We conclude that the 20/80 allocation among “less complex” and “other” NGSOs remains fair and our definition of “less complex” does not need to be modified. At this time, we are not persuaded that EESS systems communicating with 20 or fewer earth stations have increased in complexity as to justify a change in our definition or the 20/80 allocation. As the EESS Coalition points out, the work involving the processing rounds remains at around the same level, “less complex” systems’ global presence has not increased the FTEs’ work at a level that justifies a change, and in some cases the use of spectrum despite increased use of bandwidth of “less complex” systems remains the same. See id. at 6-8. Although the Satellite Coalition argues that some “less complex” EESS operators do not meet the criteria of “less complex” because their systems communicate with greater than 20 planned FCC-licensed antennas, See Satellite Coalition Comments at 13-15, 17-18. the criteria we identified in the Report and Order attached to the FY 2021 NPRM remain valid. If EESS operators communicate with more than 20 earth stations, they would no longer be considered “less complex.” See also FY 2021 Report and Order, 36 FCC Rcd at 13017-18, para. 57 (“[I]f we determine that a space system is planning to communicate with more than 20 earth stations based on the system design, such system design and plans would indicate that the space system would not fall into the “less complex” system category for regulatory fee purposes.”). Given that we determine the complexity of the NGSO system based on the system design provided at the NGSO space station application stage, FY 2021 NPRM, 36 FCC Rcd at 8585-86, para. 12. and that none of our already designated “less complex” systems actually communicate with greater than 20 earth stations, we find that the Satellite Coalition’s examples of “less complex” systems that we have already designated as “less complex” do not establish a sufficient basis upon which to change the 20/80 allocation at this time. While we acknowledge that the technology associated with “less complex” EESS system is changing, and this in some instances involves changes including increases in bandwidth, number of earth stations, amount of time in which spectrum is used, or other such changes, the changes identified appear at this time to be expected incremental changes consistent with the general characteristics identified for less complex systems. Accordingly, we find that the 20/80 allocation still fairly represents Commission resources spent and benefits received by operators. 33. Third, the Satellite Coalition argues that adoption of a fee category for small satellites should result in a re-evaluation of the regulatory fees between “less complex” systems and “other” NGSO systems. Satellite Coalition Comments at 21. The Satellite Coalition also argues that, if we were to broaden our definition of “small satellites” for regulatory fee purposes as OSK suggests, we would be excluding from the “less complex” category a greater number of satellite systems that fall on the “less complex” range of the scale. Satellite Coalition Reply at 9. As discussed below, we decline to adopt OSK’s proposal, and this additional argument is moot. The Satellite Coalition argues that, because Commission resources devoted to the regulation and oversight of “small satellites” is minimal, “small satellites” are the least complex NGSO systems among the types of constellations that formerly were included in the “less complex” NGSO fee category, and now that “small satellites” have their own fee category, only systems that demand relatively more Commission oversight remain in the “less complex” fee category for FY 2022 and going forward. Satellite Coalition Comments at 19-20. The EESS Coalition disagrees because the Commission previously “note[d] that while there may be overlap in the types of services being provided in some instances, there are also important differences between small satellites and ‘less complex’ and ‘other’ NGSO space station systems.” EESS Coalition Reply at 8-9 (citing FY 2021 Report and Order, 36 FCC Rcd at 13028-29, para. 80). 34. We decline to reconsider the “less complex” fee allocation due to the adoption of a small satellite fee category. A new regulatory fee category was created for small satellites in 2019. Streamlining Licensing Procedures for Small Satellites, IB Docket No. 18-86, Report and Order, 34 FCC Rcd 13077, 13118-19, para. 105 (2019) (Small Satellite Report and Order). The 20/80 fee allocation among “less complex” NGSO systems and “other” NGSO systems was not proposed until 2021. FY 2021 NPRM, 36 FCC Rcd 8580, 8595, para. 35. As a result, parties had notice that small satellites would be assessed fees separately when we accepted comments regarding the 20/80 NGSO fee allocation. Even when we adopted the 20/80 NGSO fee allocation, we left open the question as to how we would integrate the small satellite fee category into the overall space stations fee category rather than guaranteeing that the fee would be integrated into the “less complex” NGSO fee category. FY 2021 Report and Order, 36 FCC Rcd at 13029, para. 83. We also did not yet have any operational small satellites that were assessed fees in FY 2021, so small satellite licenses were not factored into the “less complex” allocation. Id. at 13027, para. 77 (“FY 2022 will be the first year where regulatory fees are assessed for small satellites…”). As such, we see no need to reconsider the 20/80 allocation following integration of the small satellite fee category into the overall NGSO space station fee category at this time. 35. Small Satellite Regulatory Fees. We decline to broaden the definition of “small satellites” for regulatory fee purposes. In the Small Satellite Report and Order, the Commission adopted a new, optional licensing process for small satellites and spacecraft, a type of NGSO space station. Small Satellite Report and Order, 34 FCC Rcd at 13080, 13082, paras. 10, 16. Small spacecraft are NGSO space stations designed to operate beyond Earth’s orbit, and which conform to a set of criteria similar in many respects to those of “small satellites.” See 47 CFR §§ 25.103, 25.123. In that proceeding, the Commission also adopted a small satellite regulatory fee category for licensed and operational space stations authorized under the process adopted in that proceeding. Small Satellite Report and Order, 34 FCC Rcd at 13118-19, para. 105. This new category would include small spacecraft non-Earth orbit missions as well. Id. The Commission also established a separate application fee for applicants under this part 25 streamlined process. Id. at 13115, para. 99. It has been a long-standing requirement that regulatory fees are assessed on a licensee or grantee of U.S. market access only upon certification of operation of a single satellite in its system. See Assessment and Collection of Regulatory Fees for Fiscal Year 1997, MD Docket No. 96-186, Report and Order, 12 FCC Rcd 17161, 17191, para. 75 (1997) (FY 1997 Report and Order). The Commission found that these actions would enable such applicants to choose a streamlined licensing procedure resulting in an easier application process, a lower application fee and a shorter timeline for review than exists for non-small satellite applicants. Small Satellite Report and Order, 34 FCC Rcd at 13118-19, para. 105. Satellites licensed through the streamlined process have characteristics that distinguish them from traditional NGSO satellite space stations, such as having a lower mass, shorter duration missions, more limited spectrum needs, and detailed certifications that must be submitted by the applicant. Id. at 13083-84, para. 19; see also Assessment and Collection of Regulatory Fees for Fiscal Year 2018, MD Docket No. 18-175, Report and Order and Order, 33 FCC Rcd 8497, 8499, n.21 (2018) (FY 2018 Report and Order). To apply under the small satellite streamlined rules, an applicant must certify that, among other things: (i) 10 or fewer satellites will operate under a single license; (ii) the maximum in-orbit lifetime of any individual satellite is six years, including time to de-orbit the satellite; (iii) the maximum mass of any individual satellite will be 180 kilograms, including propellant; (iv) the satellite(s) will be deployed below a 600-kilometer altitude or have the capability to perform collision avoidance and de-orbit maneuvers using propulsion; (v) any individual satellite is 10 centimeters or larger in its smallest dimension, and (vi) radiofrequency operations will be compatible with existing operations in the requested frequency bands and not materially constrain future operations of other satellites in those frequency bands. See Small Satellite Report and Order, 34 FCC Rcd at 13083-84, para. 19 (including a complete list of criteria). 36. We are assessing regulatory fees for small satellites for the first time in FY 2022 because there were five licenses for operational space stations in this small satellite regulatory fee category as of the start of the fiscal year on October 1, 2021. We are adopting a small satellite fee, on a per-license basis, of $12,215. This fee is based on calculating 1/20th (5%) of the average regulatory fee rate for a non-small NGSO system in FY 2022, which we calculated to be $244,299 (the average of the “less complex” NGSO space station fee of $143,705 and the “other” NGSO space station fee of $344,892, which would be the fee rates before the small satellite fees are calculated into the total NGSO space station fee category). Then we calculate the actual fee rate for non-small NGSO systems (i.e., NGSO - less complex space stations and NGSO - other space stations) after subtracting the total fee amount that would be allocated to operational small satellites from the total NGSO space station revenues. We are using the methodology adopted in the Report and Order attached to the FY 2022 NPRM to calculate the regulatory fee for small satellites. The fee is based on 1/20th (5%) of the average of the non-small satellite NGSO space station regulatory fee rates from the current fiscal year on a per license basis. FY 2022 NPRM at *8-*14, paras. 21-42. For purposes of the discussion regarding small satellites, we use the term “per license” to mean either a license or grant of U.S. market access. This accommodates fluctuations in the number of NGSO space stations fee payors and results in an appropriately low regulatory fee for small satellites. Id. at *11, para. 31. In addition, this averaging methodology provides a middle ground and an opportunity to gain more experience in regulating small satellites, while also recognizing that small satellites are part of a separate fee category and not within either the “less complex” or “other” NGSO space stations fee categories. Id. at *11-*12, paras. 32-35. Our small satellite methodology also takes into account our expectation that FTEs will spend approximately twenty times more time on regulating one non-small NGSO space station system compared to the time spent for regulating one small satellite license. Id. at *11, para. 33. 37. OSK requests that we broaden the definition of “small satellites” for the purposes of regulatory fee assessment to include all systems that meet the criteria enumerated in the Small Satellite Report and Order, regardless of whether they seek license processing under the small satellite processing rules of section 25.122. OSK Comments at 1-4. OSK contends that the substantial difference in regulatory fee treatment between “small satellites” and NGSO – “less complex” (almost $130,000 per year) has significant ramifications for small satellite operators, such as OSK, who elect not to utilize the Commission’s new regulatory scheme for small satellites. Id. at 3. According to OSK, if we assess regulatory fees based on the actual characteristics of the system, rather than the licensing treatment sought, we can increase efficiency and ensure equitable treatment for similarly situated systems. Id. at 3. By not assessing regulatory fees based on the actual characteristics of the system, OSK contends that small satellite operators will be forced to contort their constellations to fit under the section 25.122 framework in order to avoid unreasonable fee burdens, thereby removing all optionality the Commission sought to provide through the streamlined licensing regime. Id. at 4. 38. SIA responds that OSK’s proposal should be rejected because it would require the Commission to individually determine whether every satellite system that applies for Commission authorization meets the criteria enumerated in the Small Satellite Report and Order, regardless of whether they seek license processing under section 25.122, which would significantly add to the administrative burden of the Commission. SIA Reply at 5. SIA adds that, rather than changing the definition of a fee category, applicants with individual licensing issues should make use of the existing processes available for regulatees who are concerned about their fees by petitioning for waiver, deferral, or fee determinations. Id. at 5. 39. We decline to broaden the definition of “small satellites” for the purposes of regulatory fee assessment and conclude that only space stations licensed pursuant to the streamlined small satellite licensing process under sections 25.122 and 25.123 of our rules are eligible to be assessed the small satellite regulatory fee. As we noted in the FY 2022 NPRM, the streamlined small satellite rules are designed to lower the regulatory burden and reduce staff resources required for licensing, but the rules also restrict the benefits received by these licensees. FY 2022 NPRM at *8, para. 24. For example, license terms are limited to six years, including deorbit time, and only 10 satellites are permitted on a single license. FY 2022 NPRM at *8, para. 23 & n.62. In the Small Satellite Report and Order, the Commission made clear that the licensing process for small satellites is “optional.” Small Satellite Report and Order, 34 FCC Rcd at 13078, para. 2. The Commission further adopted a new category in the regulatory fee schedule that is separate from the existing fee categories for satellites licensed pursuant the streamlined process and stated that the small satellite fee subcategory would apply to licensed and operational satellite systems “authorized under the new process adopted in this proceeding.” Id. at 13118-19, para. 105. Therefore, licensees that could be eligible to receive authorization pursuant to the streamlined small satellite licensing process but choose not to seek authorization pursuant to the streamlined small satellite licensing process have sufficient awareness that the regulatory fee category associated with licenses obtained through small satellite licensing process is separate. Such licensees must pay the regulatory fees associated with non-small satellites, which in turn reflect a higher regulatory oversight cost and significantly greater benefits for the fee payors. In the Report and Order attached to the FY 2022 NPRM, we discussed in detail the FTE time associated with regulating licenses issued pursuant to the streamlined small satellite licensing process and the differences in benefits received by small satellite and non-small satellite fee payors. See e.g., FY 2022 NPRM at para. 33. 40. FY 2022 NGSO Space Stations Regulatory Fee Rates. We adopt the below regulatory fee rates for NGSO space stations, as follows for FY 2022: NGSO - Small Satellite FY 2022 Fee (per license) NGSO - Other Space Station FY 2022 Fee (per system) NGSO - Less Complex Space Station FY 2022 Fee (per system) $12,215 $340,005 $141,670 2. Spacecraft Performing On-Orbit Servicing and Rendezvous and Proximity Operations 41. Due to the nature of the OOS and RPO, or more generally in-space servicing industries, we will continue to evaluate each such spacecraft on a case-by-case basis until we gain more experience in understanding how such spacecraft fit into our regulatory structure. In the FY 2022 NPRM, we sought comment on adopting regulatory fee categories for spacecraft performing OOS and RPO. FY 2022 NPRM at *15-*18, paras. 45-46. We noted that there have been a limited number of such operations and except for GSO servicing missions. We previously stated that we expect that most OOS and RPO operations will be NGSO. Id. at *18, para. 46. We tentatively concluded that it is too early to identify exactly where operations, such as those in low-Earth orbit (LEO), might fit into the regulatory fee structure in the future. Id. 42. SIA supports our earlier conclusion that it is premature to adopt new fee categories for OOS and RPO, as there is currently too much variation in the industry, and such operations continue to require a case-by-case review. SIA Comments at 6-7. SIA also notes that even Astroscale, which supports a fee for RPO operations, acknowledges that such operations are part of a “nascent infrastructure.” Id. at 6 (citing Comments of Astroscale, MD Docket No. 21-190, at 2 (filed Oct. 21, 2021)). 43. Other commenters favor the creation of a new fee category and propose how we may define the services that may be contained in this new category. Spaceflight argues that OOS missions are a new industry sector involving relatively low-cost systems and a high regulatory fee could limit the commercial applications for such systems. Spaceflight Comments at 7. Spaceflight states that OOS might support NGSO or GSO satellites and should be their own category. Id. at 3. Spaceflight observes that until recently the fact that these missions have been authorized under Special Temporary Authority (STA) has made Commission regulatory fees a non-issue, but now that the Commission is requiring some of these missions to be licensed under part 25, the issue of the appropriate regulatory fees must be decided. Spaceflight Reply at 2. Spaceflight also recommends that the Commission define “OOS Missions” as spacecraft whose primary function is to provide OOS, including concepts of operations such as deployment via orbital transfer vehicle (OTV), hosting, or RPO. Spaceflight Comments at 3. Turion adds that the proposed OOS regulatory fee category should include space situational awareness (SSA) and space domain awareness (SDA) and, in the absence of an OOS regulatory fee category, SSA and SDA should fall under a new regulatory fee category, separate from the standard NGSO fee category. Turion Reply at 6. Astroscale requests that, rather than using the terms OOS and RPO when discussing the creation of a new fee category, we use the term “in-space servicing” to correlate the language with the In-Space Servicing, Assembly, and Manufacturing (ISAM) National Strategy. Astroscale Reply at 1-2. Astroscale suggests “in-space servicing” be defined as activities in space “by a servicer spacecraft or servicing agent on a client space object which require rendezvous and/or proximity operations.” Astroscale Reply at 2; see Spaceflight Reply at 4-5 (“Spaceflight has used the term “OOS” for purposes of consistency, but with expectation that terminology will be aligned going forward using a more appropriate term such as “in-space” services.”). Astroscale also contends that the Commission must not continue to regulate in-space servicing systems on a mission-by-mission basis and notes that three distinct ISAM operators have multiple granted or pending full part 25 licenses and 15 STAs have been granted to support commercial ISAM activities since 2016. Astroscale Reply at 3. Astroscale adds that a fee category for in-space servicing is needed to solve existing ambiguity and because ISAM operations challenge the current fee structure established by orbital regime since an in-space servicing spacecraft can change between NGSO and GSO operations over their servicing lifetime. Id. at 4. 44. Two commenters support an interim regulatory fee at the same amount as the small satellite fee. Spaceflight Comments at 3-4; Turion Reply at 3-4. Spaceflight and Turion observe that many of the factors used in determining the small satellite regulatory fee, such as interference protection, limited duration, smaller investment, less adjudication, multiple licenses or market grants, and limited number of missions overall, are also present in missions involving their own spacecraft, as well other OOS spacecraft. Spaceflight Comments at 4-6. Spaceflight and Turion propose that an interim regulatory fee should apply per OOS mission license, i.e., 1/20th (5%) of the average of the non-small satellite NGSO and non-OOS regulatory fee rates from the current fiscal year. Spaceflight Comments at 6-7; Turion Reply at 4-5. Turion argues that, if the Commission should label OOS spacecraft as standard NGSOs, despite their meeting the small satellite criteria and not operating as conventional satellites, then they should receive similar regulatory fee treatment to small satellite missions. Turion Reply at 3. SIA responds that an interim regulatory fee schedule is unnecessary, as the assessment of how OOS services fit into the current regime at the licensing stage is sufficient for the time being. SIA Reply at 4. 45. We are unable to adopt a new regulatory fee for in-space servicing operations for FY 2022 now, as we are required to notify Congress at least 90 days prior to creating such a change to the regulatory fee schedule. Section 9(d) of the Act contemplates such amendments to the regulatory fee schedule. See 47 U.S.C. § 159(d). However, pursuant to section 9(A)(b)(2), the Commission must notify Congress at least 90 days prior to making any amendment under section 9(d) of the Act effective. 47 U.S.C. § 159(A)(b)(2). Moreover, even absent the notice requirement, we find that the record is not sufficient to support such action at this time. As such, we defer this issue to a future fiscal so that we can more effectively address this issue once the regulatory framework under which space stations performing in-space servicing operations, including OOS, RPO, SSA, and SDA operations, and the scope of those operations, is better understood. As SIA, Spaceflight, and Astroscale acknowledge, in-space servicing is a relatively new industry. SIA Comments at 6; Spaceflight Comments at 6; Spaceflight Reply at 2; Astroscale Reply at 3. Missions, which can include satellite refueling, inspecting and repairing in-orbit spacecraft, capturing and removing debris, and transforming materials through manufacturing while in space, have the potential to benefit all space stations, the sustainability of the outer space environment and the space-based services. See generally Space Innovation; Facilitating Capabilities for In-space Servicing, Assembly, and Manufacturing, IB Docket No. 22-271, IB Docket No. 22-272, Notice of Inquiry, FCC-22-66, (rel. Aug. 8, 2022) (Space Innovation NOI). We note that these systems are still nascent. See FY 2022 NPRM, at *16, para. 46 n.136. To date, the International Bureau, Satellite Division has authorized two spacecraft for communications while conducting these types of operations with GSO satellites. Space Logistics, LLC, IBFS File No. SAT-LOA-20170224-00021; Call Sign S2990 (granted June 20, 2019) (MEV-1); Space Logistics, LLC, IBFS File No. SAT-LOA-20191210-00144; Call Sign S3059 (granted March 25, 2020) (MEV-2); see also Caleb Henry, FCC begins approval of Orbital ATK satellite-servicing mission for Intelsat-901 (Dec. 12, 2017), https://spacenews.com/fcc-begins-approval-of-orbital-atk-satellite-servicing-mission-for-intelsat-901/. The Satellite Division has also authorized one spacecraft for communications while conducting these types of operations in non-geostationary orbit. Spaceflight, Inc., IBFS File No. SAT-LOA-20220111-00007 (granted May 10, 2022). The Satellite Division also authorized on an STA basis several U.S. earth stations to communicate with the non-U.S-licensed Astroscale NGSO spacecraft for TT&C during a mission involving RPO. See, e.g., IBFS File Nos. SES-STA-20200113-00043, SES-STA-20200811-00859, SES-STA-20200117-00055. For FY 2022, only two in-space servicing spacecraft were operating pursuant to full part 25 licenses, which is a marginal number in comparison to the total number of systems operating pursuant to full part 25 licenses that we are regulating during this fiscal year. Space Logistics LLC, IBFS File No. SAT-LOA-20191210-00144 (granted Mar. 25, 2020); Space Logistics LLC, IBFS File No. SAT-LOA-20170224-00021 (granted June 20, 2019). We need more experience with these operations and in understanding the FTE time required to support them. At this time, we do not have the experience or the robust record needed to establish definitions and methodologies for a new fee category for these operations that would fairly recover any costs that might be associated with such services. See FY 2022 NPRM, at *16, para. 46 n.137. A review of the licensing and regulatory fee history of small satellites shows that adopting a fair, sustainable and administrable fee system is generally only possible after the service is established and well defined with operational rules. In that instance, the first service rule took effect on August 19, 2020, and we are only in the position to assess fees on such systems for FY 2021. See Federal Communications Commission, Streamlining Licensing Procedures for Small Satellites, 85 Fed. Reg. 43711 (July 20, 2020). For the same reasons, we decline to adopt an interim fee, including one equivalent to the fee assessed for systems authorized under the streamlined small satellite licensing process. As we gain more experience in oversight and regulation of this industry, we will better understand how to recover any regulatory costs and benefits that might be associated with these operations. We also expect to gain more insight into this industry through the record associated with our Notice of Inquiry regarding commercial and other non-governmental ISAM activities. See generally Space Innovation NOI. 3. Submarine Cable Regulatory Fees 46. We reject the Submarine Cable Coalition’s request to revise the Commission’s regulatory fee methodology for submarine cable operators, which is based upon the lit capacity of the fiber-optic submarine cable. Assessment and Collection of Regulatory Fees for Fiscal Year 2008, MD Docket No. 08-65, Second Report and Order, 24 FCC Rcd 4208, 4214-15, paras. 15-16 (2009) (Submarine Cable Order); FY 2019 Report and Order, 34 FCC Rcd at 8204-05, paras. 39-41; FY 2020 Report and Order, 36 FCC Rcd at 1753, para. 55; FY 2021 Report and Order, 36 FCC Rcd at 13010-11, para. 42). We find that the Submarine Cable Coalition provides no persuasive argument that the Commission’s assessment of these regulatory fees based on capacity is contrary to the Communications Act and is not reasonably related to the benefits provided. Submarine Cable Coalition Comments at 3-5. The Submarine Cable Coalition consists of Cable & Wireless Networks; GlobeNet Cabos Submarinos America, Inc.; GU Holdings Inc. (an indirect, wholly-owned subsidiary of Google LLC); Hawaiki Submarine Cable USA LLC; SETAR; and Tata Communications (Americas), Inc. Id. at 1-2. In the 2009 Submarine Cable Order, based on a consensus proposal made by a large number of submarine cable operators (Consensus Proposal), the Commission adopted a new methodology for assessing International Bearer Circuit (IBC) fees. As the Commission has stated, “IBC fees consist of (1) active terrestrial and satellite circuits, and (2) lit submarine cable systems.” FY 2020 Report and Order, 36 FCC Rcd at 1753, para. 55; FY 2021 Report and Order, 36 FCC Rcd at 13010-11, para. 42. Prior to 2009, IBC regulatory fees were collected based on the number of 64 kbps circuits for each of the three types of facilities used to provide international service. FY 2020 Report and Order, 36 FCC Rcd at 1753, para. 55; FY 2021 Report and Order, 36 FCC Rcd at 13011, para. 42. Instead of assessing IBC fees based on 64 kbps circuits for all types of IBCs, the Commission began assessing regulatory fees for submarine cable operators on a per cable landing license basis, with higher fees for larger capacity submarine cable systems and lower fees for smaller capacity submarine cable systems. Submarine Cable Order, 24 FCC Rcd at 4214-15, paras. 13-18. The parties to the Consensus Proposal were: AT&T, Verizon, Apollo Submarine Cable System, Ltd.; Brasil Telecom of America, Inc.; Columbus Networks USA, Inc.; ARCOS-1 USA, Inc.; A.SUR Net, Inc.; Level 3 Communications, LLC; Hibernia-Atlantic US LLC; Marine Cable Corp.; Pacific Crossing Limited and its subsidiary PC Landing Corp.; Reliance Globalcom Limited and its indirect subsidiary FLAG Network USA Limited; and Tata Communications (US) Inc. Id. at 4208, n.3. In the 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 4216, para. 20; FY 2021 Report and Order, 36 FCC Rcd at 13011, n.147; FY 2020 Report and Order, 36 FCC Rcd at 1753, n.162. The Commission adopted a five-tier structure for assessing fees on submarine cables systems based on lit capacity. Submarine Cable Order, 24 FCC Rcd at 4214-15, paras. 15-16; FY 2020 Report and Order, 36 FCC Rcd at 1753, para. 55; FY 2021 Report and Order, 36 FCC Rcd at 13010-11, para. 42; see also FY 2019 Report and Order, 34 FCC Rcd at 8204-05, paras. 39-41. As the Commission explained, it “base[s] the regulatory fee recovery on lit capacity because that is the amount of capacity that submarine cable operators are able to provide services over and the regulatory fee is in part recovering the costs related to the regulation and oversight of such services.” FY 2019 Report and Order, 34 FCC Rcd at 8204-05, para. 41. The Commission explained that it will define operational submarine cable systems as either “large” or “small” submarine cable systems based on the capacity of each system and the “small” systems will be further subdivided into additional subcategories. Submarine Cable Order, 24 FCC Rcd at 4214, para. 15; FY 2019 Report and Order, 34 FCC Rcd at 8204, para. 39. The Commission noted that it “anticipate[s] that the subcategories of small systems and the definitions of large and small systems may change as the submarine cable industry changes.” Submarine Cable Order, 24 FCC Rcd at 4214, n.39. The Commission concluded that this methodology served the public interest and was competitively neutral because it included both common carrier and non-common carrier submarine cable operators. Submarine Cable Order, 24 FCC Rcd at 4212-13, paras. 8-9. The Commission also explained that the methodology would be easier to administer and for submarine cable operators to comply with. Id. at 4213, para. 10; FY 2019 Report and Order, 34 FCC Rcd at 8204, para. 39. The Commission explained that, “[b]y ‘flat’ we mean that the regulatory fee is no longer based on the number of active circuits, but is assessed on a per cable system basis . . . we are permitting carriers to pay a lower fee for smaller submarine cable systems.” Submarine Cable Order, 24 FCC Rcd at 4210, para. 2 & n.12. The Commission further stated that a lower fee for licensees of smaller cable systems would mitigate concerns that a flat fee may create a barrier to entry for new entrants. Submarine Cable Order, 24 FCC Rcd at 4215, para. 18. In the FY 2020 Report and Order, the Commission found that lit capacity was an appropriate measure by which to assess IBC fees for submarine cables. FY 2020 Report and Order, 36 FCC Rcd at 1752, para. 53. Subsequently, in the FY 2021 Report and Order, the Commission adopted the same tiers for assessing fees on submarine cable operators for FY 2021 as in FY 2020, which are based on the lit capacity of the fiber-optic submarine cable. FY 2021 Report and Order, 36 FCC Rcd at 13010, para. 42. 47. The Submarine Cable Coalition reiterates in this proceeding the arguments rejected by the Commission in the FY 2020 and FY 2021 proceedings. Submarine Cable Coalition at 3-5; see, e.g., FY 2020 Report and Order, 36 FCC Rcd at 1754, para. 58; FY 2021 Report and Order, 36 FCC Rcd at 13011-12, paras. 43-45. The Submarine Cable Coalition contends that the “regulatory fee structure based upon cable system capacity is contrary to the mandate of the Communications Act, is overly burdensome, and is disconnected from the Commission’s responsibilities for regulatory oversight of the submarine cable industry.” Submarine Cable Coalition Comments at 3 (citing Submarine Cable Coalition Comments, MD Docket 20-105, at 3-8 (filed June 12, 2020); Submarine Cable Coalition Comments, MD Docket 21-190, at 3-4 (filed June 3, 2021)). The Submarine Cable Coalition argues that our methodology “fails to take into consideration that the size of a system is not tied to the number of customers, nor the amount of revenue that it will generate.” Id. at 4. According to the Submarine Cable Coalition, “[t]he location of the system, the existence of competing systems, market demands, whether the system is operated on a private basis, and various [other] system specific factors [make] the assessment of the claimed ‘benefits’ by the Commission a highly nuanced and fact-specific endeavor.” Id. The Submarine Cable Coalition further contends that “the Commission must continue to lower the burden on the submarine cable operators” Id. (arguing that “the proposed FY 2022 regulatory fees are still over 25% higher on the upper echelon of submarine cable operators by capacity than the requisite fees in Fiscal Year 2019”). and “[t]his continued large increase on the top end of the scale remains unjustified as the amount of regulatory work that is undertaken by the Commission regarding submarine cable regulatees is fixed—the procedures do not vary by the potential traffic the cable is able to carry, nor has that level of regulatory work increased by any significant metric in the preceding period.” Id. Lumen, on the other hand, states that “capacity is a reasonable way to distinguish those submarine cable providers who benefit more from the Commission’s activities from those who benefit less.” Lumen Reply at 2. Lumen agrees that the fees for IBCs as a group, which includes submarine cable systems, should be reduced, Id. at 1, 3. but supports the Commission’s longstanding practice of assessing fees based on capacity. Id. at 1-3. 48. We disagree with the Submarine Cable Coalition’s contention that the Commission’s regulatory fee methodology is contrary to the Communications Act and that the Commission has not developed regulatory fees that are reasonably related to the benefits provided. Submarine Cable Coalition Comments at 3-4. The Submarine Cable Coalition provides no additional or new support for its arguments, nor does it propose an alternative methodology that the Commission could administer in an equitable and efficient manner. The Commission has long held that capacity is a reasonable basis to assess regulatory costs among the submarine cable regulatees that benefit from the Commission’s work. See, e.g., FY 2021 Report and Order, 36 FCC Rcd at 13010-12, paras. 42-45; FY 2020 Report and Order, 36 FCC Rcd at 1752-55, 1759, paras. 53-60, 74-75; FY 2019 Report and Order, 34 FCC Rcd at 8204-06, paras. 39-45. The Commission has historically used capacity to assess IBCs. See FY 2021 Report and Order, 36 FCC Rcd at 13012, para. 44; FY 2020 Report and Order, 36 FCC Rcd at 1753, para. 56. When Congress established the Commission’s regulatory fee authority in 1993, it adopted a statutory schedule of regulatory fees that included assessing a fee on carriers based on active 64 kbps international circuits. FY 2021 Report and Order, 36 FCC Rcd at 13012, para. 44 (citation omitted); FY 2020 Report and Order, 36 FCC Rcd at 1753-54, para. 56 (citation omitted); Section 6003(a) of the Omnibus Budget Reconciliation Act of 1993, Pub. L. No. 103–66, Title VI, § 6003(a), 107 Stat 312, 397-401. The Commission continued to assess IBC fees on 64 kbps circuits until 2009 when it adopted a new fee structure based on the Consensus Proposal from the submarine cable industry, but that new structure still used capacity of the submarine cable system for determining the fees so that smaller submarine cable systems were paying a lower fee than larger systems. FY 2021 Report and Order, 36 FCC Rcd at 13012, para. 44; FY 2020 Report and Order, 36 FCC Rcd at 1753-54, para. 56. As the Commission has previously stated, the fee assessment on submarine cables covers the costs for regulatory activity concerning submarine cables as well as the services provided over the submarine cables. FY 2020 Report and Order, 36 FCC Rcd at 1753, para. 55 (citing FY 2015 Report and Order, 30 FCC Rcd at 10273, para. 12). For instance, the regulatory fees paid by submarine cable operators also cover the services provided to common carriers using the submarine cable circuits in addition to the services that the International Bureau provides to submarine cable operators. FY 2015 Report and Order, 30 FCC Rcd at 10273-74, para. 12. Further, regulatory fees, such as IBC fees, are not intended to recover only the costs of Title II regulation, but also the costs of the Commission’s enforcement, policy and rulemaking, user information, and international activities. See FY 1997 Report and Order, 12 FCC Rcd at 17188, paras. 68-69. The Commission has found that almost all of the IBC work benefits all international telecommunications service providers no matter what facilities those services are provided over—submarine cable systems, terrestrial facilities, or satellites. FY 2020 Report and Order, 36 FCC Rcd at 1754, para. 57. Submarine cable licensees benefit from work that includes among others, maintaining the licensing database, enforcing benchmarks, coordination with other U.S. government agencies, including coordinating with other U.S. agencies’ undersea activities to protect submarine cables, 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. Id. We find it reasonable to continue to assess higher regulatory fees on licensees with larger facilities that benefit more from the Commission’s work and thus should pay a larger proportion of the Commission’s costs. FY 2020 Report and Order, 36 FCC Rcd at 1754, para. 58; FY 2019 Report and Order, 34 FCC Rcd at 8205, para. 43. The Commission has noted, “[w]hile there may be situations in which it would be equitable to set aside differences in capacity for the sake of administrability, to say that a system with roughly 65,000 times the capacity of another system should pay not a penny more in regulatory fees hardly seems equitable or reflective of the benefits each system owner receives from its Commission license and Commission oversight.” FY 2019 Report and Order, 34 FCC Rcd at 8205, para. 43. We agree with Lumen’s assessment that the Commission’s use of capacity to set fees for submarine cables satisfies the requirement of the statute. Lumen Reply at 2. As Lumen further states, the statute “requires only that the Commission set fees ‘tak[ing] into account factors that are reasonably related to the benefits provided to the payor of the fee by the Commission’s activities’” and does not require “perfect alignment between fees and benefits.” Id. at 2 (quoting 47 U.S.C. § 159(d)). We find there are no significant reasons in the record or changes in the marketplace to modify our regulatory fee framework for submarine cable systems. 49. Since FY 2009, when the Commission adopted the new methodology for assessing submarine cable fees, the level of lit capacity for submarine cable systems has increased and the Commission has expanded the different tiers to take into account this change and accommodate for this rapid growth in capacity. However, the basic methodology for calculating submarine cable fees based on capacity has not changed. Submarine cable fees are still calculated on the basis of “1” unit, “.5” units, “.25” units and so forth. Furthermore, we note that the regulatory fees for FY 2022 have been reduced from those assessed in FY 2021; the assessment per unit is now $137,715 compared to $151,910 in FY 2021. See FY 2021 Report and Order, 36 FCC Rcd at 13044, Appendix C. As discussed above, lit capacity remains a reasonable basis to apportion regulatory costs among the submarine cable regulatees that benefit from the Commission’s work, and our fee methodology with respect to submarine cables continues to reasonably reflect the FTE costs for our regulatory activity concerning submarine cables as well as the services provided over the submarine cables. Accordingly, for FY 2022, we adopt the regulatory fees below for submarine cable systems. FY 2022 International Bearer Circuits - Submarine Cable Systems Submarine Cable Systems (lit capacity as of December 31, 2021) Fee Ratio FY 2022 Regulatory Fees Less than 50 Gbps .0625 Units $8,610 50 Gbps or greater, but less than 250 Gbps .125 Units $17,215 250 Gbps or greater, but less than 1,500 Gbps .25 Units $34,430 1,500 Gbps or greater, but less than 3,500 Gbps .5 Units $68,860 3,500 Gbps or greater, but less than 6,500 Gbps 1.0 Unit $137,715 6,500 Gbps or greater 2.0 Units $275,430 C. Broadcaster Regulatory Fees for FY 2022 50. FY 2021 Broadband DATA Act. We decline to modify our methodology to continue to exempt broadcasters’ from the costs associated with the Commission’s broadband work. As part of our FY 2021 appropriation, Congress directed the Commission to assess and collect $374 million in regulatory fees, of which $33 million was specifically earmarked to be made available for implementing the Broadband DATA Act. Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, Div. E, Title V, Federal Communications Commission, 134 Stat. 1182 (2020) (Consolidated Appropriations Act, 2021) (appropriating $374,000,000 to the Commission for salaries and expenses and directing the Commission to collect $374,000,000 in offsetting collections for FY 2021). Of the $374,000,000 appropriation, Congress directed that “$33,000,000 shall be made available until expended for implementing Title VIII of the Communications Act of 1934 (47 U.S.C. 641 et seq.), as added by the Broadband DATA Act (Public Law 116–130).” Id. The Broadband Deployment Accuracy and Technological Availability Act, Pub. L. No. 116-130, 134 Stat. 228 (2020) (codified at 47 U.S.C. §§ 641-646) (Broadband DATA Act) contemplated that a future appropriation for implementations costs might be partially offset by regulatory fees. Section 805 of the Broadband DATA Act provides that the Commission “may not use funds from the universal service programs” to pay for any costs associated with the Broadband DATA Act, but the Commission “may recover costs associated with this title under section 9 to the extent provided for in an appropriation Act, as required under subsection (a) of that section.” The Broadband DATA Act is available at https://www.congress.gov/116/plaws/publ130/PLAW-116publ130.pdf (last visited Aug. 12, 2022). Separately, Congress appropriated an additional $65 million for Broadband DATA Act implementation, which is not recovered through regulatory fees. Consolidated Appropriations Act, 2021, Division N, Title IX, § 906. Among other things, the Broadband DATA Act required the Commission to collect standardized, granular data on the availability and quality of both fixed and mobile broadband Internet access services, to create a common dataset of all locations where fixed broadband Internet access service can be installed (the Fabric), and to create publicly available coverage maps. See Broadband DATA Act § 802(a)(1)(A), (b). The Broadband DATA Act further requires the Commission to establish processes for (1) the collection of verified data for use in the coverage maps; (2) the submission of challenges to the coverage maps, the broadband availability data submitted by service providers, and the Fabric; and (3) the submission of specific crowdsource information about the development and availability of broadband service. Id. § 802(a)(1)(B)(i), (iii), (iv). As part of its collection of information, the Broadband DATA Act required the Commission to include uniform standards for the reporting of broadband internet access service data from “each provider of terrestrial fixed, fixed wireless, or satellite broadband internet access service.” Broadband DATA Act, § 802(b)(2). The statute defines “broadband internet access service” to mean “the same meaning given the term in section 8.1(b) of title 47, Code of Federal Regulations, or any successor regulation.” Broadband DATA Act, § 801(1). That Commission rule, in turn, defines “broadband internet access service” as “a mass-market retail service by wire or radio that provides the capability to transmit data to and receive data from all or substantially all internet endpoints, including any capabilities that are incidental to and enable the operation of the communications service, but excluding dial-up internet access service” and this term “also encompasses any service that the Commission finds to be providing a functional equivalent of the service.” 47 CFR § 8.1(b). Congress recognized that specific Commission resources would be utilized in carrying out the requirements of the Broadband DATA Act. See, e.g., H.R. Rep. No. 116-456, https://www.congress.gov/116/crpt/hrpt456/CRPT-116hrpt456.pdf (last visited Aug. 12, 2022) (Committee Report); the Joint Explanatory Statement for the Consolidated Appropriations Act, 2021, https://docs.house.gov/billsthisweek/20201221/BILLS-116RCP68-JES-DIVISION-E.pdf (last visited Aug. 12, 2022) (Explanatory Statement). The Committee Report provides that “[t]he Committee provides significant funding for upfront costs associated with implementation of the Broadband DATA Act. The Committee anticipates funding related to the Broadband DATA Act will decline considerably in future years and expects the FCC to repurpose a significant amount of staff currently working on economic, wireline, and wireless issues to focus on broadband mapping.” Committee Report at 59. The Explanatory Statement also provided that “[i]n addition to adopting the House report language on Broadband Maps, the agreement provides substantial dedicated resources for the FCC to implement the Broadband DATA Act. The FCC is directed to submit a report to the Committees on Appropriations within 90 days of enactment of this Act providing a detailed spending plan for these resources. In addition, the FCC, in coordination with the NTIA, shall outline the specific roles and responsibilities of each agency as it relates to the National Broadband Map and implementation of the Broadband DATA Act. The FCC is directed to report in writing to the Committees every 30 days on the date, amount, and purpose of any new obligation made for broadband mapping and any updates to the broadband mapping spending plan.” Explanatory Statement at p.30. 51. In the FY 2021 Report and Order, we adjusted the Commission’s approach to assessing regulatory fees for broadcasters to account for the unusual circumstances accompanying the Broadband DATA Act earmark. FY 2021 Report and Order, 36 FCC Rcd 12995-999, paras. 11-16. In this limited instance, given the one-time nature and magnitude of the earmark, the statutory text, the legislative history, and the record in this proceeding, we excluded one group of regulatees– broadcasters or “Media Services” licensees – from part of their share of indirect costs. Id. at 12998-999, para. 16. We concluded that, although we modified our methodology with respect to the $33 million earmark, this one-time modification was consistent with the Commission’s longstanding goals of implementing a fair, sustainable, and administrable regulatory fee regime. Id. at 12996-997, para. 13. The Commission therefore reduced broadcasters’ regulatory fees by approximately 8.88% for FY 2021 and adopted a lower fee factor for full-service television broadcasters for FY 2021. Id. at 13007-3008, para. 36. In doing so, all other fee payors within the core bureaus, including cable, DBS, and IPTV providers regulated by the Media Bureau, had to absorb these indirect costs to ensure that the Commission collected the full annual appropriation. Id. at 12998-999, para. 16. (The Commission stated: “In doing so, we recognize that all other fee payors within the core bureaus, including cable, DBS and IPTV providers regulated by the Media Bureau, will need to absorb these indirect costs because we are required by Congress to collection the full annual appropriation.”) 52. NAB argues that the Commission should continue to exempt broadcasters from paying for the Commission’s ongoing broadband data mapping work. NAB Reply at 7. In FY 2022, however, Congress did not provide an earmark for a particular purpose, and the accompanying direction regarding use of staff resources. See FY 2022 Consolidated Appropriations Act. Thus, the reason for the methodology change in FY 2021 is not present for FY 2022. We therefore decline to make this modification to our methodology for FY 2022. “Media Services” licensees will be assessed regulatory fees based on the current allocation FTE percentage calculated for FY 2022. NAB also mischaracterizes the Commission’s modification in methodology in FY 2021 as a determination that broadcasters do not benefit from broadband related activities. NAB Comments at 14 & Reply at 7. But see CTIA Reply at 6 (observing that we excluded broadcasters from the Broadband DATA Act earmark only because it was one-time, large, and explicitly quantified by Congress and the broadcasters do not, and cannot, identify similar circumstances here). Instead, the Commission recognized that the earmark was limited to a unique mapping task and Congress gave the Commission direction regarding the staff resources it anticipated would be used to carry out the discrete task, which did not include Media FTEs. In the FY 2021 Report and Order, the Commission found that broadcasters do not in their capacity as broadcast licensees offer broadband Internet access service; however, the Commission did not conclude that broadcasters do not benefit from broadband related Commission activities. FY 2021 Report and Order, 36 FCC Rcd at 12998-99, para. 16. The Commission did not make a finding that any group of regulatees do not benefit from broadband-related activities. 53. Commenters argue that broadcasters’ regulatory fees have increased by approximately 13% from FY 2021 to FY 2022 with no explanation for such an increase by the Commission. See, e.g., State Broadcasters Associations Comments at 5-10; NAB Comments at 2, 6-7; NRB Reply at 1-2; Joint Broadcasters Reply at 1. This proposed increase of 12%-13% between FY 2021 and FY 2022 regulatory fee rates was due to the reduction in regulatory fee rates for broadcasters (AM, FM, TV, LPTV) due to the Broadband DATA Act earmark in FY 2021. As discussed below, however, these figures are no longer accurate due to a correction to our allocation of direct FTEs that were previously reassigned as indirect in 2017. That said, as we explained above, because the amount the Commission must collect in an offsetting collection changes each year, regulatory fees will typically change each year as a mathematical consequence of the change in amount to be collected in the current year, FTE allocations in the core bureaus, and projected unit estimates. See supra para. 7. Thus, any regulatory fee increases may not necessarily correlate to the Commission’s overall increase in its appropriation for a fiscal year. 54. The NJBA contends that we should consider an across-the-board reduction of all fees for broadcasters given the “emerging technologies and the eloquent simplicity of regulating [the broadcast] industry, along with broadcasters’ longstanding special place in the fabric of American society.” NJBA Comments at 1. But see CTIA Reply at 4 (disagreeing that broadcasters should receive a reduction in fees because they have a “different mission” than other regulatees and have a “special place in the fabric of American society). Specifically, the NJBA states that the broadcast industry has largely been governed by the market and enjoys a prolific and symbiotic relationship with the public and, unlike the other technologies competing for Commission resources, broadcasters do not charge their audiences ever-increasing user charges, subscription rates and fees for the services they provide. NJBA Comments at 2. Commenters add that broadcasters have been particularly hard hit by the COVID-19 pandemic, with severe reductions in advertisement revenues. NJBA Comments at 2-3; Joint Broadcasters Reply at 1. Similarly, NAB explains that broadcasters do not have a subscriber base to whom they can pass on costs and they are required to provide a free service to the public and are dependent on advertising revenues to cover their costs. NAB Comments at 29; NRB Reply at 1. 55. We recognize that many entities, including broadcasters, sustained economic losses during the COVID-19 pandemic. We also recognize the broadcasters do not have a subscriber base to whom they can pass through regulatory fees. However, we emphasize that we must collect the full FY 2022 appropriation and cannot exempt regulatees from regulatory fees unless they are expressly exempted under the statute. As CTIA observes, pursuant to section 9 of the Act, regulatory fees are based on the level of Commission staffing or staff activity undertaken by the relevant core bureaus; neither Commission policy objectives nor regulatee success in the marketplace are relevant factors in calculating regulatory fees and fulfilling the statutory charge of section 9 of the Act. CTIA Reply at 2-4. Thus, we cannot reduce FY 2022 fees across-the-board for one category of fee payor; 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. FY 2020 NPRM, 35 FCC Rcd at 5004, para. 74 (explaining the statutory limits that would constrain any potential relief the FCC might offer during the COVID-19 Pandemic based on economic considerations). As we indicated above, regulatory fees are a zero-sum situation. See supra para. 16. If the Commission freezes one set of regulatees’ fees, it will need to increase another set of regulatees’ fees to make up for any resulting shortfall, and in doing so, the Commission would be failing to base regulatory fees on FTEs as statutorily required. Id. We therefore decline to make such changes, requested by NAB and others, based on policy considerations inconsistent with section 9 of the Act. 56. UHF/VHF Stations. We decline to adjust the Commission’s treatment of VHF stations for purposes of assessing regulatory fees. NJBA observes that, while the Commission in 2014 determined that VHF TV stations had become “less desirable” than UHF stations, the proposed regulatory fee structure provides no acknowledgement of this nor any discount to VHF stations. NJBA Comments at 3-4. NJBA contends that many UHF stations are paying less than VHF stations and that UHF stations can offer a variety of services that traditional VHF stations cannot offer (especially low band VHF stations). Id. Therefore, NJBA states that it is more logical that with the ability to offer a wider array of services and thereby obtain greater revenues, UHF stations should be assessed greater regulatory fees commensurate with these additional avenues of revenue attainment that VHF stations that cannot secure. Id. 57. The Commission previously discussed the treatment of VHF stations. Assessment and Collection of Regulatory Fees for Fiscal Year 2020, MD Docket No. 20-205, Report and Order and Further Notice of Proposed Rulemaking, 36 FCC Rcd 1731, 1739, para. 22 (2020) (FY 2020 Report and Order); FY 2020 NPRM, 35 FCC Rcd at 4997, para. 52. Specifically, the Commission observed that, in the FY 2020 NPRM, it declined to categorically lower regulatory fees for VHF stations to account for signal limitations. FY 2020 NPRM, 35 FCC Rcd at 4997, para. 52. The Commission concluded 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. Id. As such, the Commission recognized that the Media Bureau had granted waivers to allow VHF stations that demonstrate signal disruptions to exceed the maximum power level specified for channels 2-6 in 73.622(f)(6) and for channels 7-13 in 73.622(f)(7)—and that it would not penalize such stations by assessing them at their higher power levels needed to overcome such interference but instead at the power levels authorized by our rules. Id. As the Commission determined at that time, such an approach more narrowly targets the issue that NJBA complains about by ensuring that VHF broadcasters that actually experience increased interference can get the relief they need to reach consumers without sweeping other broadcasters into the mix. FY 2020 Report and Order, 36 FCC Rcd at 1739, para. 22. 58. Methodology for Full Service TV Regulatory Fees. We will continue to use the population-based methodology for full-service television broadcasters as proposed for FY 2022. In FY 2020, the Commission completed the transition to a population-based full-power broadcast television regulatory fee, finding it to be more equitable. Id. at 1738, para 19. 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). See Assessment and Collection of Regulatory Fees for Fiscal Year 2018, MD Docket 18-175, Report and Order and Notice of Proposed Rulemaking, 33 FCC Rcd 5091, 5101-102, at para. 27 (2018) (FY 2018 NPRM). In the FY 2018 NPRM, the Commission 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. Id. at 5102, para. 28. In the FY 2018 Report and Order, the Commission adopted the new methodology and determined that we would fully transition to the methodology by FY 2020, and in the interim, for FY 2019, 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 8501-8502, para. 14. As we stated in the FY 2022 NPRM, we do not reopen that decision relating to these regulatory fees being based on population at this time. FY 2022 NPRM at *16, para. 48. In the FY 2022 NPRM, we sought comment on the use of population-based fees for full-power broadcast television stations based on the station’s terrain-limited contour. Id. We now adopt a factor of .84 of one cent ($.008430) per population served for FY 2022 full-power broadcast television station fees. Id. We multiply the population served by the factor to reach the population-based fee. Id. The population data for each licensee and the population-based fee (population multiplied by the factor of $.008430) for each full-power broadcast television station, including each satellite station, is listed in Appendix G. For those VHF stations whose power had to be increased to obtain a clearer signal, the Commission will continue to use a population count based on that station’s lower VHF power level rather than at the increased power level. As the Commission stated in the FY 2020 NPRM, “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).” FY 2020 NPRM, 35 FCC Rcd at 4997, para. 52. 59. NJBA disagrees with this methodology and contends that a population-based fee approach to assign regulatory fees is incongruent with how a station should be assessed fees in correlation to the revenue it achieves from its Nielsen DMA revenue share. NJBA Comments at 4. NJBA argues that the DMA approach is a more accurate approach to assessing fees correlating with how stations derive revenue. Id. NJBA’s argument is that its members had relatively low revenues compared to major network stations in New York City. NJBA Comments at 4. Essentially, NJBA appears to seek a waiver for its members of a portion of the regulatory fee based on its individual financial circumstances, i.e., advertising revenue, and we decline to grant this blanket request. Under our rules, parties can seek a waiver, reduction, or deferment on a case-by-case basis of the fee, interest charge, or penalty “in any specific instance for good cause shown, where such action would promote the public interest.” 47 U.S.C. § 159A(d). Where financial hardship is the asserted basis for a waiver, the Commission has consistently interpreted that to require a showing that the requesting party “lacks sufficient funds to pay the regulatory fees and to maintain its service to the public.” FY 2019 Report and Order, 34 FCC Rcd at 8207, para. 50. 60. NJBA also notes that the term Noise Limited Contour (NLSC) implies that it is the contour within which a perfect picture would appear at each television receiver. NJBA Comments at 4. NJBA contends that this approach does not consider the effects on a signal that may result from the distance it may travel; the effects of terrain; building blockages which often occur in major city settings; and interference levels from co-channel and adjacent channel signals. Id. NJBA’s argument is that certain stations experience a high degree of interference from environmental noise and signal blockage from tall buildings near its transmitter. Id. We recognize that in various parts of the country, broadcasters may face such interference or signal blockage issues; however, as we discussed in the FY 2020 Report and Order, FY 2020 Report and Order, 36 FCC Rcd at 1739-40, para. 23 adjudicating the circumstances of every station in the context of a cross-industrywide rulemaking would be administratively impractical, and the Commission’s rule already provides a more appropriate venue for relief. We recognize that the population-based methodology increases fees for some licensees and reduces fees for others, but in the end the population-based metric better conforms with the actual service authorized here—broadcasting television to the American people. Id. at 1738, para. 19. NJBA members can seek a waiver, reduction, or deferment on a case-by-case basis of the fee, interest charge, or penalty “in any specific instance for good cause shown, where such action would promote the public interest.” 47 U.S.C. § 159A(d). Where financial hardship is the asserted basis for a waiver, the Commission has consistently interpreted that to require a showing that the requesting party “lacks sufficient funds to pay the regulatory fees and to maintain its service to the public.” FY 2019 Report and Order, 34 FCC Rcd at 8207, para. 50. D. De Minimis Threshold 61. We decline to increase the de minimis threshold amount above $1,000. Section 9(e)(2) of the Act permits the Commission to exempt a party from paying regulatory fees if “in the judgment of the Commission, the cost of collecting a regulatory fee established under this section from a party would exceed the amount collected from such party.” 47 U.S.C. § 159(e)(2). A regulatee’s de minimis status is not a permanent exemption from regulatory fees.  Rather, each regulatee will need to reevaluate annually to determine whether its total liability for annual regulatory fees falls at or below the de minimis threshold given any changes that the Commission may make in its regulatory fees each fiscal year. As we explained in the FY 2022 NPRM, the Commission’s process for collecting delinquent regulatory fee debt involves a number of steps, including data compilation, preparation, and validation; invoicing; debt transfer for third party collection; responding to debtor questions and disputes; and processing payments. FY 2022 NPRM at *17, para. 50. The Commission periodically calculates its collection costs for purposes of determining the de minimis threshold by estimating the number of FTE hours spent on each collection task times the value of FTE time expended on the task, to arrive at the estimated total cost of each task. The totals for each task are then added together to determine the total estimated cost of collection. The total estimated cost of collection divided by the estimated number of delinquent regulatory fee debts for that fiscal year yields the average cost of collecting an unpaid regulatory fee. 62. For FY 2019, the last year the Commission reviewed the de minimis threshold, the Commission concluded that its average cost of collection did not exceed $1,000 and, therefore, the $1,000 de minimis threshold was still appropriate. FY 2019 Report and Order, 34 FCC Rcd at 8206-07, para. 47. In the FY 2022 NPRM, we sought comment on NAB’s proposal to increase the annual $1,000 de minimis threshold. FY 2022 NPRM at *17, paras. 49-51. We asked commenters advocating for a higher de minimis threshold to discuss how we should calculate our collection costs and the steps in the Commission’s regulatory fee process that should be included in the calculation. Id. For example, we asked whether the calculation should begin when the Commission collects data on a payor’s regulatory fee status, prior to the regulatory fee due date, rather than when the regulatory fee becomes delinquent, as is our current practice, and whether the calculation should include the Commission’s cost of processing waiver and installment payment requests. Id. 63. NAB, SIA, and the State Broadcasters Associations support a review of the $1,000 de minimis threshold. NAB Comments at 31-33; SIA Comments at 6-7; State Broadcasters Associations Comments at 18-19. SIA suggests that, in light of inflation and other economic changes since 2019 when the Commission last addressed the de minimis threshold, FY 2019 Report and Order, 34 FCC Rcd at 8206-07, paras. 46-48. the Commission’s cost of collecting regulatory fees may have increased. NAB Comments at 32 & Reply at 15; SIA Comments at 6. NAB and the State Broadcasters Associations support expanding the Commission’s calculation of its regulatory fee collection costs to include the cost of collecting payor fee data, costs incurred prior to the regulatory fee due date and the cost of processing and resolving waiver and installment payment requests. NAB Comments at 32-33; State Broadcasters Associations Comments at 18-19. Specifically, NAB, SIA, and Richards each suggest that an appropriate factor in setting the de minimis threshold is to provide a higher threshold of relief to smaller broadcasters. To that end, NAB proposes that the de minimis threshold be increased to $1,200 to ensure that radio broadcasters that were below the de minimis threshold last year, but facing higher FY 2022 regulatory fees, will still be exempt in FY 2022. NAB Comments at 33. Richards suggests increasing the de minimis threshold to $3,000 in order to exempt most AM and FM stations serving populations under 500,000, which are the stations Richards believes will be hardest hit by the increase in FY 2022 regulatory fees. Richards Comments at 2. 64. We acknowledge that the de minimis threshold has the collateral effect of providing financial relief to some regulatees. However, it does not follow from the wording of section 9(e)(2) of the Act that providing relief for financially strapped regulatees is a factor that can be considered in setting this threshold. Moreover, raising the threshold on such a basis would result in exempting classes or categories of fee payors in a manner contrary to the limited waiver provisions for regulatory fees. 47 U.S.C. § 159A(d). Nothing in the text of the statute supports using policy factors outside of the cost of collection in establishing the de minimis threshold. Thus, in response to commenters’ request for a review of the de minimis threshold, we calculated the average cost of collecting FY 2021 regulatory fees and included the cost of collecting payor fee data and the cost of processing waiver and installment plan requests, as both NAB and the State Broadcasters Associations suggest. NAB Comments at 33; State Broadcasters Associations Comments at 18-19. Even including the additional costs (without determining whether they are appropriately included in this calculation), the Commission’s average cost of collection has not increased above the $1,000 de minimis threshold. Thus, we conclude that the cost of collecting regulatory fees, including the costs of collecting payor fee data and processing waiver and installment requests, does not justify an increase to the existing $1,000 de minimis threshold. 65. Both NAB and the State Broadcasters Associations suggest that the Commission define the “cost of collection” to encompass all annual costs of administering the regulatory fee program. NAB Comments at 33; State Broadcasters Associations Comments at 18. While we agree with NAB that section 9(e)(2) of the Act 47 U.S.C. § 159(e)(2). does not provide a definition of costs of collection, we do not agree that the cost of collecting a regulatory fee should be expanded to include all of the Commission’s costs of administering the regulatory fee program each year. NAB Comments at 33. In support of its expansive definition of collection costs, NAB cites to a statutory provision defining the cost of the collection of a fee assessed by the U.S. Coast Guard to include “the reasonable administrative, accounting, personnel, contract, equipment, supply, training and travel expenses of calculation, assessing, collection, enforcing, reviewing, adjusting, and reporting” the fee. NAB Comments at 33 & n.98 (citing 14 U.S.C. § 946(h). We think NAB’s reliance on 14 U.S.C. § 946(h) is misplaced, for the simple reason that had Congress intended to define cost of collection in section 9 of the Act as expansively as it did in 14 U.S.C. § 946(h), it would have done so. We believe that a common sense interpretation of the language of section 9(e)(2) of the Act includes only those costs incurred by the Commission once the Commission has established that the annual fees are owed, which occurs when the Commission’s regulatory fee Report and Order is released. In making this determination, we rely in part on the Debt Collection Improvement Act of 1996, as amended, 31 U.S.C. § 3701 et seq. (DCIA), which governs the federal administrative debt collection process for most federal agencies, including the Commission. Under the DCIA, collection of debt begins after an agency has determined that the debt is due. See 31 U.S.C. § 3701(b)(1) (defining “debt” or “claim” to mean an amount of funds or property, including a fee, that an appropriate agency official has determined is owed) and 31 U.S.C. § 3711(a) (directing agencies to collect debts owed to them). Thus, we would here include costs once the regulatory fee becomes a debt, which occurs when the annual regulatory fee report and order is released. Id. We therefore hold that the Commission’s cost of collection for the purpose of establishing a de minimis threshold under section 9(e)(2) of the Act means collection costs incurred by the Commission after the Commission’s regulatory fee Report and Order is released, including the costs the Commission incurs collecting payor fee data and processing waiver and installment plan requests. E. Reclassification of FTEs 66. Universal Service Fund Activities. We decline, at this time, to reclassify certain indirect FTEs as direct FTEs for regulatory fee purposes. We note that we seek further comment below, in the attached Notice of Inquiry, on the Commission’s regulatory fee methodology for allocating indirect FTEs. See infra Section IV. Nevertheless, we correct the manner in which we apportion the 38 previously reallocated core bureau FTEs in order to advance the overall implementation of our proportional methodology. In 2017, the Commission allocated as indirect, for regulatory fee purposes, 38 FTEs in the Wireline Competition Bureau who work on non-high cost programs of the Universal Service Fund. FY 2017 Report and Order, 32 FCC Rcd at 7061-64, paras. 10-15. The Commission determined that changes in the Universal Service Fund regulatory landscape required it to reexamine whether the FTEs working on universal service issues as Wireline Competition Bureau direct FTEs should be reallocated as indirect. Id. at 7061, para. 10. The FTE count was based on an analysis by the Office of Managing Director and Wireline Competition Bureau staff of the number of FTE hours dedicated to working on each of the Universal Service Fund programs. Id. In the FY 2022 NPRM, we sought comment generally on whether prior reclassifications of FTEs from direct to indirect produce a more accurate regulatory fee assessment. FY 2022 NPRM at *18, para. 52. 67. Initially, Universal Service Fund programs were focused on wireline services; however, as the Commission observed, by 2017, wireless carriers and broadband providers were also involved in the E-Rate, Lifeline, and Rural Healthcare programs. Id. In addition, the E-Rate, Lifeline, and Rural Healthcare programs tie funding eligibility to the beneficiary, i.e., a school, a library, a low-income individual or family, or a rural health care provider, and not to Commission regulatees. Id. The Commission observed that wireless carriers serve a substantial, if not majority, of Lifeline subscribers. Id. Also, satellite operators, Wi-Fi network installers, and fiber builders can all receive funding through the E-Rate and Rural Health Care universal service programs. Id. Similarly, Multichannel Video Programming Distributors (MVPDs) that also provide supported services, receive universal service funding because they provide telecommunications and broadband Internet access services that are eligible for support in those programs. Id. The Commission further noted that contributions to the Universal Service Fund are required from service providers using any technology that has end-user interstate telecommunications. Id.; 47 CFR § 54.706(a). Moreover, applicants in these programs are not regulatees, they are schools and libraries and health care providers; the bulk of the Commission’s oversight and regulation of these programs (i.e., the Commission’s FTE costs) are not generated by regulatees. FY 2017 Report and Order, 32 FCC Rcd at 7061, para. 10. The Commission therefore concluded that ITSPs were no longer the sole or even majority contributors or beneficiaries of these three programs. Id. For these reasons, the Commission concluded that reallocating these Wireline Competition Bureau FTEs as indirect FTEs would also be more consistent with how FTEs working on Universal Service Fund issues were treated elsewhere in the Commission. Id. 68. NAB contends that this reclassification of 38 FTEs is a wholesale abandonment of the statutory requirement that fees be adjusted to reflect benefits received by the payor by the Commission’s activities. NAB Comments at 12-13; Letter from the National Association of Broadcasters to Marlene H. Dortch, Secretary, FCC, MD Docket No. 22-223 (filed July 27, 2022). According to NAB, broadcasters have been unfairly forced to pay for a portion of the 38 FTEs in the Wireline Competition Bureau that the Commission determined were working on Universal Service Fund programs. NAB Comments at 11. The Joint Broadcasters contend that broadcasters will subsidize Commission functions that have no connection whatsoever to the broadcast industry or the Media Bureau that oversees it. Joint Broadcasters Reply at 2. NAB claims that, at a minimum, the Commission must ensure that broadcasters bear no responsibility for the 38 FTEs working on non-high cost USF programs in the Wireline Competition Bureau. NAB Reply at 7-10. NAB further argues that over the last five years broadcasters have likely paid more than $25 million in regulatory fees to support the activities of FTEs that, according to NAB, the Commission agrees do not benefit or regulate broadcasters. NAB Reply at 9. 69. We disagree that this example of 38 indirect FTEs who work on non-high cost Universal Service Fund issues was an improper assignment of FTEs under section 9 of the Act. Indirect FTEs work on issues that may include more than one regulated service or work on matters that are not related to services regulated by the Commission. All costs that are not directly related to regulation and oversight by the core bureaus must also be recovered by regulatory fees. This does not include auctions-related costs; auctions expenses are recovered from auctions proceeds. This includes salaries and expenses, overhead functions, statutorily required tasks that do not directly equate with oversight and regulation of a particular regulatee but instead benefit the Commission and the industry as a whole, support costs such as rent, utilities, and equipment, and the costs incurred in regulating entities that are statutorily exempt from paying regulatory fees (i.e., governmental and nonprofit entities, amateur radio operators, and noncommercial radio and television stations), 47 U.S.C. § 159(e)(1). entities with total annual assessed fees below the de minimis threshold, 47 U.S.C. § 159(e)(2). and entities whose regulatory fees are waived. 47 U.S.C. § 159(d); 47 CFR § 1.1166. As the Commission explained in the FY 2019 Report and Order, Media Bureau regulatory fee payors are not alone in having to pay for exempt licensees; there are exempt licensees in most of the fee categories, such as ITSPs and earth stations. FY 2019 Report and Order, 34 FCC Rcd at 8196-97, para. 19. Indirect FTEs in the Commission devote their time to a large variety of issues, some of which may not directly affect every Commission regulatee, including broadcasters. 70. With that said, while we continue to find that the Commission was supported in its decision in 2017 to reassign the 38 FTEs in the Wireline Competition Bureau who work on non-high cost programs of the Universal Service Fund as indirect, we agree with broadcast commenters that the method for calculating the fees associated with these indirect FTEs should be corrected given the record in this proceeding, as well as the Commission’s prior findings. The Commission has previously acknowledged, in 2016, that broadcasters receive no oversight, regulation, or other benefits of the nature we typically consider relevant for our regulatory fee analysis when looking at the activity of these indirect Universal Service Fund FTEs. Assessment and Collection of Regulatory Fees for Fiscal Year 2016, Report and Order, 31 FCC Rcd 10339, 10347, para. 24 (2016) (FY 2016 Report and Order) (“Further, ITTA’s proposal to reassign some or all of the Wireline Competition Bureau FTEs working on universal service as indirect FTEs ignores licensees not involved in high-cost and Lifeline universal service issues, such as radio and television broadcasters, that would be responsible for contributing to the cost of those Wireline Competition Bureau FTEs.”) Indeed, when the Commission reassigned these 38 non-high-cost Universal Service Fund FTEs in 2017, it dismissed the burden on broadcasters based on the general difficulty in precisely allocating every FTE without revisiting its 2016 acknowledgment. FY 2017 Report and Order 32 FCC Rcd at 7063, para. 11. (“CenturyLink also agrees with this proposal and observes that the concern that the reallocation would impose a burden on broadcasters which do not participate in the universal service program is misplaced ‘as there is no completely pure way to precisely allocate every Commission FTE.’”) In short, despite these acknowledgments that broadcasters did not benefit from Universal Service Fund activities, the Commission failed to take appropriate measures to ensure that the proportional fee allocation methodology was not adversely impacted by the reassignment of the 38 non-high-cost FTEs. We remedy that today. While we adhere to the principle that our analysis here does not require scientific precision and need only be reasonable, in this instance, the record, See, e.g., NAB Comments at 12-13 (arguing that the proportional allocation of the 38 indirect FTEs should not have included broadcasters); Joint Broadcaster Comments at 14-15; NAB Reply at 8-9; NAB August 15 Ex Parte; State Broadcasters Association August 15 Ex Parte at 2. the Commission’s own prior findings, and our own review clearly substantiate the view that broadcasters do not benefit from these Universal Service Fund-related activities. Furthermore, we have prior experience implementing this type of change given our decision last year to exclude broadcasters from paying regulatory fees associated with the implementation of the Broadband DATA Act. FY 2021 Report and Order, 36 FCC Rcd at 12995-99, paras. 11-17. In contrast, when FTEs are reassigned to a non-core bureau or office (as discussed below in the Office of Economics and Analytics context, for example), it is often difficult to precisely track workflows and tasks that were previously attributed to a specific core bureau. Indeed, the scopes of work will often change and staff that previously worked on tasks within a single core bureau will now be working on issues across the industry. In such circumstances, we see no practicable way, at present, to update the Commission’s proportional allocation methodology. The accompanying Notice of Inquiry will examine these issues in more detail. We also note that Commission decisions to reallocate direct FTEs to indirect FTEs without also moving the FTEs into a non-core bureau or office are rare and are only warranted when unique circumstances support refinement of the Commission’s general methodology for calculating regulatory fees. As such, we are not routinely faced with circumstances in which updates to our general methodology should be considered. While we acknowledge that other commenters in this proceeding have raised arguments about the Commission’s allocation of indirect FTEs more generally, See, e.g., Submarine Cable Coalition Comments at 2; SIA Comments at 5-6 (“However, reclassification of direct FTEs as indirect and then distributing them proportionately based on core bureau does not fully address the inequities created by the current indirect FTE fee division”); SIA Reply (commenters broadly support the Commission reviewing its process to apportion indirect FTEs to more accurately reflect the parties benefitted by the regulatory activities of those FTEs); OneWeb/SES/Telesat, August 8 Ex Parte at 1-2 (“The Commission must more fairly assign the 75% of its costs classified as indirect. The evidence shows that using direct cost proportions as a proxy for assigning indirect costs is inaccurate – the Commission should instead review the work done by indirect FTEs to assess whether the costs can be directly assigned to specific payor categories. In particular, costs for FTEs in the Office of Economics and Analytics that work on auction items and for FTEs in the Enforcement and Consumer and Governmental Affairs Bureaus should be reviewed and assigned on a more tailored basis”); Satellite Coalition Reply at 6 (“A number of commenters observe that the Commission’s practice of assuming that all FTEs outside the core licensing bureaus should be assigned based on the proportional number of direct FTEs in each bureau is a vast oversimplification that distorts the regulatory fee burden….The Commission has demonstrated its ability to perform the additional analysis needed to assign currently indirect FTEs more accurately. For instance, the Commission in 2014 determined that Enforcement Bureau regional and field office investigations ‘were almost evenly split between wireless and broadcast-related cases’ and that the Enforcement Bureau ‘as a whole… is primarily focused on enforcement activity in the wireline, wireless, and broadcast or media industries, and only occasionally addresses Act and rule violations by International Bureau licensees.’”) we find that the record currently before us is not sufficiently developed to support affording similar relief to other regulatory fee payors based upon indirect FTE areas of work at this time. However, we believe that these issues would benefit from additional comment, as set forth in the accompanying Notice of Inquiry. 71. Therefore, we will exclude “Media Services” licensees from recovery of the funds associated with the 38 indirect FTEs who work on non-high cost Universal Service Fund issues. We find that this correction to the manner in which we apportion the 38 previously reallocated core bureau FTEs is supported given the nature of this FTE reassignment; the weight of the record with respect to this issue; and the unusual position of broadcasters vis-à-vis other Commission regulatees in this instance. Furthermore, once implemented, this correction is easily repeatable each year, so long as the FTE reassignment remains warranted. In excluding “Media Services” licensees from the recovery of the funds associated with the 38 indirect FTEs who work on non-high cost Universal Service Fund issues, we recognize that all other fee payors within the core bureaus, including cable, DBS and IPTV providers regulated by the Media Bureau, will need to absorb these indirect costs because we are required by Congress to collection the full annual appropriation. 72. Office of Economics and Analytics. In FY 2019, the Commission reassigned staff from other bureaus and offices to establish the Office of Economics and Analytics (OEA), effective December 11, 2018. See Establishment of the Office of Economics and Analytics, Order, 33 FCC Rcd 1539 (2018); FCC Opens Office of Economics And Analytics, Federal Communications Commission News Release, December 11, 2018, https://www.fcc.gov/document/fcc-opens-office-economics-and-analytics. This resulted in the reassignment of 95 FTEs (of which 64 were not auctions-funded) as indirect FTEs. SIA contends that in any given year the rulemaking proceedings reviewed by OEA are not distributed across bureaus proportionally based on the number of direct FTEs and thus, the benefits from the work of OEA do not necessarily accrue proportionally to all payors. SIA Comments at 5. We note that all Commission-level drafts from core and non-core bureaus are reviewed by OEA, and OEA is also responsible for other economic-related activities that benefit the Commission. This function, assisting all bureaus and offices in the Commission with economic analysis, is appropriately considered indirect. CTIA observes that SIA’s suggestion, that the Commission allocate OEA FTEs among certain core bureaus based on the type of rulemakings and other matters during a given year, would not proffer accurate FTE time allocations, and it would fail to reflect the wide variety of issues OEA reviews from non-core bureaus. CTIA Reply at 6. 73. SIA also contends that a large portion of the FTE time in OEA involves auctions and is therefore outside the scope of International Bureau payors and International Bureau regulatees should not be responsible for this portion of indirect FTEs. SIA Comments at 5. As we have previously stated, all auctions expenses are separately funded and are not part of the Commission’s annual S&E appropriation supported by regulatory fees. See supra n.25; FY 2021 Report and Order at paras 18-20; FY 2015 Report and Order, 30 FCC Rcd at 10276, para 18; see also FY 2019 NPRM, 34 FCC Rcd at 3272, para 10 (reminding commenters that FTE time devoted to developing and implementing the Commission’s spectrum auctions is not included in the calculation of regulatory fees and is not offset by the collection of regulatory fees). Pursuant to statute, the Commission recovers the costs of developing, implementing, and maintaining its section 309(j) spectrum auctions program as an offsetting collection against auction proceeds and subject to an annual cap which is articulated in the annual S&E appropriation. 47 U.S.C. § 309(j)(8)(B) (providing that “the salaries and expenses account of the Commission shall retain as an offsetting collection such sums as may be necessary from such proceeds for the costs of developing and implementing the program required by this subsection.”). For a more detailed discussion of auctions funding, see n.25, supra. Thus, time devoted to developing and implementing auctions is tracked separately from other non-auctions work performed by FTEs, and is offset by the auction proceeds that the Commission is permitted to retain pursuant to section 309(j)(8) of the Act and the Commission’s annual appropriation statute. FY 2015 Report and Order, 30 FCC Rcd at 10276, para. 18. For this reason, auctions FTEs are not included in the calculation of regulatory fees, and the Commission’s methodology excludes all auctions-related FTEs and their overhead from the regulatory fee calculations. To the extent that FTE time within core bureaus is spent on auctions issues and on non-auctions issues, only the non-auctions portion is reflected in the core bureau’s FTE count. FY 2021 Report and Order, 36 FCC Rcd at 12999-13000, para. 20. Thus, only direct non-auctions FTE time is used in the calculation of the regulatory fee rate and consequently impact the overall regulatory fee calculations. 74. Further, SIA suggests that the Commission allocate the indirect FTEs in OEA’s Auction Division to regulatory fee payors who benefit from auctions; and classify OEA’s Associate Chief, Wireline, and Associate Chief, Media as direct FTEs allocated to Media and Wireline, respectively, and then divide the Associate Chief, Wireless and Spectrum indirect FTEs among the remaining core licensing bureaus. SIA Comments at 5. We reject this proposal. As an initial matter, we note that an FTE is a full-time equivalent, not an employee, and is based on the hours of work devoted to the regulation and oversight of the fee categories and not a particular job title. See supra para. 7. Further, the FTE time working on auctions issues is not included in our regulatory fee calculations and is funded separately. The OEA FTEs numbers attributed to non-auctions work derive from FTE levels in the Data Division, Economic Analysis Division, and Industry Analysis Division, as well as in OEA’s Front Office. Staff in OEA review all Commission-level items, from all the Commission’s bureaus and offices, including the International Bureau, as well as providing economic analysis to the Commission and drafting white papers. The FTEs in OEA provide economic and data analysis to the entire Commission and are appropriately allocated as indirect FTEs. Moreover, SIA’s suggestion that we allocate the indirect OEA FTEs into thirds, to the Media, Wireline, and the remaining core licensing bureaus, i.e., one-sixth of the FTEs to the International Bureau, would likely assign more indirect FTEs to the International Bureau than we do under our current methodology. Currently, 8.56% of the total FTE allocation is from International Bureau regulatees; 21.40% of the total FTE allocation is from Wireless Telecommunications Bureau regulatees; 33.94% of the total FTE allocation is from Wireline Competition Bureau regulatees; and 36.10% of the total FTE allocation is from Media Bureau regulatees. F. Commenters’ Proposals for New Regulatory Fee Categories 75. In the Notice of Proposed Rulemaking attached to the FY 2021 Report and Order, the Commission sought comment on adopting new regulatory fee categories and on ways to improve our regulatory fee process regarding any and all categories of service. FY 2021 Report and Order, 36 FCC Rcd at 13026, paras. 73-74 The Commission asked commenters supporting such new fees how to define any new fee category and how to calculate and assess such fees on an annual basis. Id. at 13026, para. 73. In the FY 2022 NPRM, we sought additional comment on these issues. FY 2022 NPRM at *18, para. 53. Commenters supporting new regulatory fee categories advocate such fees for holders of experimental licenses; Satellite Coalition Comments at 3. broadband Internet access service; Id. at 3-6. holders of equipment authorizations; Id. at 4. database administrators that charge fees to enable unlicensed operations; Id. and entities using spectrum on an unlicensed basis, including large technology companies. NAB Reply at 10-15. As we discuss below, we reject these proposals to create these new regulatory fee categories. Given the record developed in response to the Notice of Proposed Rulemaking attached to the FY 2021 Report and Order and in response to the FY 2022 NPRM, we find that there is an insufficient basis for adding these new regulatory fee categories at this time. 1. Holders of Experimental Licenses 76. The Satellite Coalition and SIA propose that the Commission adopt a regulatory fee category for holders of experimental licenses and state that this would involve the same process used for other licensed entities: the Commission would calculate the number of FTEs engaged in experimental licensing activities to determine the percentage of the total regulatory fee revenue requirement associated with experimental licensees (including direct and indirect costs) and then divide that amount among experimental license holders. Satellite Coalition Comments at 3; SIA Comments at 3 & Reply at 3-4. CTIA disagrees and observes that the FTEs in the Office of Engineering and Technology (OET) that work on experimental licenses are appropriately classified as indirect because their duties affect multiple core bureaus and their regulatees, including satellite regulatees authorized by the International Bureau. CTIA Reply at 7-8. We are not convinced that an experimental license is the same as other Commission licenses and that it should be subject to a regulatory fee. 77. OET typically grants over 2,000 experimental licenses each year, including Special Temporary Authority (STA). Many commercial services and technologies deployed today were first tested under the experimental licensing program. Where such technologies result in new licensing frameworks or services, the resultant services usually are subject to regulatory fees. For example, some small satellite operators initially sought to operate commercial systems under the experimental licensing program rather than seeking licensing under part 25 of the Commission’s rules before the streamlined small satellite rules were adopted. When adopting the streamlined small satellite licensing rules, the Commission also adopted a separate regulatory fee category for small satellites. See Small Satellite Report and Order, 34 FCC Rcd at 13080-81, 13118-19, paras. 11-13, 105; see also Streamlining Licensing Procedures for Small Satellites, Notice of Proposed Rulemaking, 33 FCC Rcd 4152, 4154, para. 3 (2018). The experimental radio service permits broad experimentation, including assessing equipment intended to operate in existing Commission services, proof of concept testing and evaluation of new radio technologies, equipment designs, radio wave propagation characteristics, and service concepts related to the use of the radio spectrum. The experimental radio service rules prescribe flexible rules to encourage manufacturers, inventors, entrepreneurs, and students to experiment across a wide range of frequencies, power, emissions, and applications. (See 47 CFR part 5, et seq.). Thus, many experimental licenses are filed by universities, research and development companies, technology manufacturers, and medical institutions which often are non-profit entities. 78. The Commission issues a variety of experimental licenses that range in duration from a few days to six months for STAs, generally two years for conventional experimental licenses, Up to five years is permitted by rule with sufficient justification. 47 CFR § 5.71. five years for experimental program licenses, and 10 years for experimental licenses in spectrum bands above 95 GHz. In a typical year, the Commission generally issues only a few five-year licenses and no 10-year licenses. There is no renewal process for STAs. Further, applicants seeking extension of conventional experimental licenses must include sufficient justification for continued experimentation; 47 CFR § 5.71(a). otherwise, such applicants are referred to the appropriate service bureau to seek a service license. If service rules for the applicable spectrum are needed, applicants may petition the Commission for rulemaking to modify allocations or service rules in such a way as to permit the tested technology to obtain a license to operate. Experimental licenses (except for above 95 GHz licenses) are not permitted to be used to offer commercial service. However, market trials are permitted under certain circumstances to allow applicants to evaluate product performance and customer acceptability prior to the production stage. Under a market trial, the experimental licensee retains ownership of all equipment and must collect all such equipment at the end of the trial or render such equipment inoperable. 47 CFR § 5.602(e). Further, experimental licenses are issued on a limited, non-harmful interference basis for operation within a band in which (typically) regulatory fee payors enjoy primary or secondary use. Additionally, experimental licenses do not provide the holder with any vested spectrum use rights and the Commission can require licensees to discontinue experimental operations at any time without undertaking any further administrative process, such as an adjudication. 47 CFR § 5.83. 79. OET’s experimental authorization processes thus are distinct from authorization processes applicable to other types of licenses and the regulated entities holding them, and essentially fall under OET’s functions of evaluating evolving technology for interference potential, facilitating the introduction of nascent technologies, and maintaining the U.S. Table of Frequency Allocations. 47 CFR § 0.31. As such, in reviewing those applications, OET ensures that experimental uses will not interfere with the primary and secondary users in the relevant bands, who, unlike experimental license holders, do have spectrum rights associated with a license in an authorized service. Where the core bureaus regulate the regulatory fee payors, they also provide the benefit of protecting such primary and secondary uses of the spectrum. Thus, while Commission resources are expended on processing experimental applications, these licenses are approved for a proposed experiment or range of experiments, and not for an actual operational service under established service rules providing some level of interference protection. Experimental licensing is often an important option for academic researchers on restricted budgets who are developing new technological solutions. Therefore, imposing regulatory fees on these licensees potentially could stifle a Commission function and policy objective of promoting new, efficient technology by precluding some academic researchers or small start-up technology developers from developing and testing new technologies and systems. Moreover, experimental authorizations present challenges in determining a fair, administrable, and sustainable regulatory fee system. As a starting point, many experimental license applicants are exempt from regulatory fees under the statute. 47 U.S.C. § 159(e)(1); 47 CFR § 1.1162. Additionally, given the transient nature of such authorizations, determining what operational period is sufficient to merit assessment of regulatory fees would require significant analysis. Experimental licenses can be discontinued at any time and are issued for varying time periods based on the unique needs of the applicant. Given the varying types of experimental authorizations, and the limited authority granted, it is likely we would have to consider multiple regulatory fee categories and multiple ways of allocating proportional fees to such categories. Commenters have not provided any analysis of the experimental authorizations in the record to allow us to make such determinations here. Moreover, in addition to the exempt status of many applicants, it is likely we would find that many experimental authorizations, if subject to regulatory fees, do not result in any collection because the payor’s total assessment falls under the de minimis threshold. The Commission increased the de minimis threshold to $1,000 in 2017. FY 2017 Report and Order, 32 FCC Rcd at 7073, para. 40. Thus, we find that the record here is not sufficient for the Commission to establish a fair and administrable system for assessing regulatory fees for such experimental licenses. 80. Further, as we stated previously, OET provides engineering and technical expertise to the Commission as a whole and supports each of the agency’s four core bureaus. FY 2021 Report and Order, 36 FCC Rcd at 13001, para. 23. FTEs within OET are appropriately classified as indirect because the FTE time devoted to OET work affects multiple core bureaus within the Commission and its regulatees. Id. at 13001-3002, paras. 23-24. Because the experimental license typically is not used for a commercial service, and OET oversight helps to ensure that experimental licensees do not interfere with other (non-experimental) licensees, “it is consistent with the principles of section 9 of the Communications Act for other (non-experimental) licensees to pay the costs of OET’s work on experimental licenses. OET’s FTE work on experimental licenses already is captured under the Commission’s current regulatory fee framework. Moreover, we find that the Satellite Coalition’s and SIA’s proposals for such a new fee category could discourage communications industry innovation, and thus undermine the rationale for the Experimental Radio Service. See Satellite Coalition Comments. We therefore decline to adopt a new regulatory fee category for holders of experimental licenses. 2. Broadband Internet Access Service 81. We also decline to create a new regulatory fee category for broadband Internet access services at this time. There is no specific bureau or office in the Commission with oversight of all broadband services, because these oversight activities are spread out among all core bureaus, and broadband issues are a part of a variety of Commission initiatives and proceedings. NAB and Satellite Coalition argue that the Commission should expand the base of regulatory fee categories to include a broadband Internet access service fee category to which the Commission should allocate all broadband-related costs. NAB Comments at 15-23; Satellite Coalition Comments at 3-4. But see WISPA Reply at 1-2 (contending that the Commission has provided no notice that it may consider adopting a new regulatory fee category for broadband Internet service providers so that broadcasters can recover their costs, or for any other purported reason, and that, due to this lack of notice, the Commission lacks legal authority to add such a new regulatory fee category). Although we disagree with WISPA regarding a lack of notice, as we discuss below, we are not adopting a new regulatory fee category for broadband Internet access service at this time. 82. Specifically, NAB contends that the Commission should revise its methodology to reallocate broadband costs among only those fee payors that benefit from the Commission’s broadband activities. NAB Comments at 15-23. NAB argues that requiring broadcasters to pay for these costs is unfair since broadcasters do not benefit from the Commission’s broadband activities. Id. at 16, 22-23. NAB suggests that the Commission modify its existing information collection systems to obtain the data necessary to assess regulatory fees on either a subscription or revenue basis. Id. at 24. NAB contends that broadband Internet access service providers began submitting data, including subscription counts, in the annual Broadband Data Collection and that the Commission could use this information to assess fees on a per-subscriber basis. Id. NAB further proposes that we place this regulatory fee category within the Wireline Competition Bureau and reallocate FTEs that work primarily on broadband related issues in the other core and noncore bureaus and offices of the Commission to this fee category, to the extent necessary. Id. 83. In the FY 2021 Report and Order, in addressing the assessment of regulatory fees to cover the costs of implementation of the Broadband DATA Act as part of the Commission’s FY 2021 appropriation, we specifically stated that we do not have sufficient information to form the basis of designating a new broadband regulatory fee category. FY 2021 Report and Order, 36 FCC Rcd at 12999, para. 17. We indicated the information that we do not presently possess but that would be important in designating a new regulatory fee category and determining the unit measure within a fee category would include the amount of broadband Internet access services offered by entities that also provide services subject to existing regulatory fees and by entities that provide broadband Internet access services that are not currently subject to regulatory fees. Id. Commenters still have not provided us with this information or identified Commission regulatory efforts involving FTEs specific to this industry segment to support a separate regulatory fee category for this service. 84. Further, we are unconvinced that a broadband Internet access service regulatory fee category is necessary or that such a category appropriately belongs in the Wireline Competition Bureau. Broadband Internet access services are offered through various technical means and by widely differing entities and to distinct user groups, e.g., wireless service providers, wireline service providers (including VoIP), cable operators, and satellite operators, to consumers and businesses, on both a retail and a wholesale basis. This service is not only offered by different types of providers, but is also delivered to end users in different ways. Commenters have not shown that a particular group of FTEs within the Commission is providing oversight and regulation for broadband Internet access services and that other parties (besides these broadband Internet access service providers) are responsible for all of the regulatory fees associated with those FTEs. It appears that the contrary is true: broadband Internet access services are involved in many Commission initiatives and proceedings and such services are offered by service providers regulated by all the core bureaus and already responsible for regulatory fees. Such a regulatory fee category, if adopted, would likely not change broadcasters’ regulatory fees, except for those broadcasters offering broadband services. See Authorizing Permissive Use of the “Next Generation” Broadcast Television Standard, GN Docket No. 16-142, Second Further Notice of Proposed Rulemaking, FCC 21-116 (2021); Public Notice, Media Bureau Announces Effective Date Of New Broadcast Internet Rules, 36 FCC Rcd 5765 (MB 2021) (announcing effective date of new rules to encourage the provision of new Broadcast Internet services enabled by ATSC 3.0, the “Next Generation” broadcast television standard referred to as Next Generation or NextGen TV, that can complement the nation’s 5G wireless networks and update the regulatory landscape in order to foster the efficient and robust use of broadcast spectrum capacity for the provision of Broadcast Internet services.). At least one large broadcaster has announced that it provides broadband services. Sinclair Broadcast Group’s One Media 3.0 and its D.C. station WIAV-CD deliver EduCast, a broadcast Internet product for K-12 and college learners without broadband Internet services at home. Jon Lafayette, Broadcasting and Cable, “NextGen TV Being Used To Deliver Remote Learning in Washington, D.C.,” (Aug. 16, 2021), https://www.nexttv.com/news/nextgen-tv-being-used-to-deliver-remote-learning-in-washington-dc (explaining that a receiver connects to a TV antenna that receives the broadcast signal digital content it carries and establishes a Wi-Fi hotspot in the home that students connect to with their tablet, laptop, or smartphone). Therefore, to include this proposed regulatory fee category under the Wireline Competition Bureau, as suggested by NAB, would increase the Wireline Competition Bureau’s regulatory fee contribution based on time spent not only by staff in the Wireline Competition Bureau on broadband matters, but by staff in the other offices and bureaus within the Commission. 85. The Satellite Coalition, in arguing that the Commission adopt a broadband Internet access service regulatory fee category, contends that the Commission has already calculated that 550 FTEs across a wide variety of offices and bureaus work on the Commission’s broadband policy as part of its Strategic Goal to bring affordable, high-speed broadband to 100% of the country. Satellite Coalition Comments at 3-4. The Strategic Goals that the Satellite Coalition refers to are Pursue a “100 Percent” Broadband Policy; Promote Diversity, Equity, Inclusion, and Accessibility; Empower Consumers; Enhance Public Safety and National Security; Advance America’s Global Competitiveness; and Foster Operational Excellence. See FCC 2022 Budget Estimates to Congress at 15. We do not agree with Satellite Coalition’s contention that the 2022 Strategic Goals apply to assessing regulatory fees. The Commission’s Strategic Goals do not pertain to any specific regulatory fee category, but rather are developed and used as part of planning exercises mandated by a wholly unrelated statutory scheme. Under section 9(d) of the Act, 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). The Strategic Goals do not specifically pertain to regulation or oversight of services, but instead are more general goals developed as part of long term planning exercises required of all federal agencies as explained above. As we indicated above, such strategic goals are intended to align with higher level priority goals of the overall federal government. See supra para. 19. Such goals should also “contribute to the Federal Government priority goals” required by section 1120(a) of title 31. 5 U.S.C. § 306(a)(3). Thus, staff support of a specific strategic goal is not a sound rationale for adopting a new regulatory fee category. See supra para. 19. 86. Additionally, NAB argues that broadening the base of regulatory fee payors to include broadband Internet access service providers would ensure a more fair and sustainable regulatory fee system. NAB Comments at 24. However, NAB’s proposal does not establish a sufficient basis for the creation of such a category and that a broadband Internet access services regulatory fee category, if adopted, would be fair, administrable, or sustainable for the reasons elaborated above. See supra para. 4; NCTA Reply at 9-14. As NCTA notes, the Commission has taken historic actions to discount broadband Internet access service for those who cannot afford it and now would not be the time to unravel that work by adopting a new set of regulatory fees that would increase the cost-burden of these services. NCTA Reply at 17. We also are not persuaded that such a new regulatory fee category, if adopted, would reduce broadcasters’ regulatory fees. Given the various uncertainties, we find it unlikely that adding a new fee category for broadband Internet access service would make a significant difference in the broadcasters’ regulatory fees. The total amount we collect from each core bureau is based on the number of non-auctions FTEs in each bureau, and adding a new broadband Internet access fee category or categories would not change the number of Media Bureau FTEs working on broadcast issues. Moreover, as indicated above, broadband Internet access services are a part of many Commission initiatives and proceedings and such services are offered by service providers regulated by all the core bureaus (and these providers already pay regulatory fees on their regulated services). See supra para. 84. For these reasons, particularly due to the lack of information in the record to support the need for adoption of such a new regulatory fee category, we are not creating a new fee category for broadband Internet access services at this time. Specifically, we find that section 9 of the Act does not require creation of this category and commenters have not shown, on the basis of the record in this proceeding, that such a category would satisfy the factors that the Commission has relied on when it has found a basis to create a new regulatory fee category. See supra para. 4. 3. Holders of Equipment Authorizations 87. We decline to adopt the Satellite Coalition’s proposal that the Commission adopt a regulatory fee category for holders of equipment authorizations. Satellite Coalition Comments at 4. Satellite Coalition argues that the costs associated with equipment authorizations can be assessed on equipment manufacturers that benefit from Commission staff who implement policies designed to ensure compliance with relevant regulatory standards. Id. We find, however, that OET FTE time on equipment authorizations is appropriately classified as indirect because such work affects multiple core bureaus and their regulatees, including satellite regulatees authorized by the International Bureau. See CTIA Reply at 7-8. OET provides engineering and technical expertise to the Commission as a whole and supports each of the four core bureaus. Notably, part of OET’s role is to participate in matters “not within the jurisdiction of any single bureau” or “affecting more than one bureau,” similar to other offices with indirect FTEs such as the Office of General Counsel and the Office of Economics and Analytics. See 47 CFR § 0.31(g). Section 0.31 of the Commission’s rules provides the functions of OET and section 0.241 provides the delegated authority. 47 CFR §§ 0.31, 241. Some of OET’s duties and responsibilities that affect multiple core bureaus and their regulatees include maintaining the U.S. Table of Frequency Allocations; managing the Experimental Licensing and Equipment Authorization programs; regulating the operation of devices; and conducting engineering and technical studies. See FCC, Engineering & Technology, https://www.fcc.gov/engineering-technology (last visited August 4, 2022). For a longer description of OET’s functions and delegation, see also 47 CFR §§ 0.31, 0.241. Federal Communications Commission 2021 Budget Estimates to Congress, February 2020, at 109-10, https://www.fcc.gov/document/fy-2021-fcc-budget-estimate. The matters handled by OET benefit the Commission’s work as a whole as well as all service sectors to which the Commission’s core bureaus devote FTE resources. Much of OET’s work in making spectrum available on an unlicensed basis and overseeing the equipment authorization program indirectly benefits multiple industry sectors. For example, there is no separate process for devices capable of operating wholly or partly under the Commission’s device rule, as many devices, including some broadcast receiving equipment (e.g., smart TVs) operate on several spectrum bands under rules for both licensed services and operations on an unlicensed basis. 88. The equipment authorization program is one of the principal ways the Commission ensures that radio frequency devices operate effectively without causing harmful interference and otherwise comply with the Commission’s rules. The Commission’s equipment authorization program promotes efficient use of the radio spectrum and addresses various responsibilities associated with certain treaties and international regulations, 47 CFR § 2.901. while ensuring that radio frequency (RF) devices in the United States comply with the Commission’s technical requirements before they can be marketed in or imported to the United States. See 47 CFR part 2 subpart I, §§ 2.801 et seq. (Marketing of Radio Frequency Devices); part 2 subpart J, §§ 2.901 et seq. (Equipment Authorization Procedures); part 2 subpart K, §§ 2.1201 et seq. (Importation of Devices Capable of Causing Harmful Interference). The Office of Engineering and Technology (OET) administers day-to-day operation of the equipment authorization program. See 47 CFR § 0.241(b). OET’s Laboratory Division maintains a webpage devoted to the equipment authorization program. See the FCC, Engineering & Technology, Laboratory Division, Equipment Authorization Approval Guide, https://www.fcc.gov/engineering-technology/laboratory-division/general/equipment-authorization (last visited Aug. 12, 2022). As a general matter, for an RF device to be marketed or operated in the United States, it must have been authorized for use by the Commission, although a limited number of categories of RF equipment are exempt from this requirement. See, e.g., 47 CFR § 15.103. For background on exempt equipment, see NPRM, 36 FCC Rcd at 10593-94, para. 31. The Commission’s equipment authorization program provides for two pathways: certification and supplier’s declaration of conformity (SDoC). Applicants for equipment certification are required to file their applications, which must include certain specified information, with an FCC-recognized Telecommunications Certification Body (TCB). 47 CFR §§ 2.907; 2.911; see NPRM, 36 FCC Rcd at 10598-99, para. 44. See also 47 CFR § 2.960 (“Recognition of Telecommunication Certification Bodies”). The Commission, through its Office of Engineering and Technology (OET), OET provides engineering and technical expertise to the Commission and supports each of the four core bureaus, including maintaining the U.S. Table of Frequency Allocations; managing the Experimental Licensing and Equipment Authorization programs; regulating the operation of devices; and conducting engineering and technical studies. oversees the certification process, and provides guidance to applicants, TCBs, and test labs with regard to required testing and other information associated with certification procedures and processes, including guidance provided via correspondence or found in pre-approval guidance or OET’s knowledge database system (KDB). See, e.g., §§ 2.947(a)(3) and 2.1093(d)(2) which state that advisory information regarding measurement procedures can be found in the KDB. See also FCC, Office of Engineering and Technology, Office of Engineering and Technology Laboratory Division Knowledge Database, https://apps.fcc.gov/oetcf/kdb (last visited Aug. 12, 2022). Applications that involve new technology or for which there are no FCC-recognized test procedures require a TCB to obtain pre-approval guidance from the Commission before the application may be approved. 47 CFR § 2.964. The SDoC procedures, which are available for specific equipment generally considered to have reduced potential to cause RF interference, provide for equipment to be authorized based on the responsible party’s self-declaration that the equipment complies with the pertinent Commission requirements. Certification requires three components that SDoC does not: First, certification requires use of a third-party FCC-recognized Telecommunication Certification Body (TCB), based on an evaluation of supporting documentation and test data contained in an application submitted by the responsible party (e.g., the manufacturer or importer) to the TCB. Second, compliance testing for certification must be performed by an FCC-recognized accredited testing laboratory. Third, technical parameters and descriptive information for all certified equipment are posted on a Commission-maintained public database (https://www.fcc.gov/oet/ea/fccid). See 47 CFR §§ 2.907 et seq. Because the SDoC process is based on self-declaration, there is no direct oversight of that process by OET staff. As we noted in the FY 2021 Report and Order, OET FTE resources for equipment authorizations are typically limited to overseeing the equipment authorization program. 89. Because there are multiple categories of equipment authorization procedures, including exemption and self-authorization, the implementation of regulatory fees assessed to holders of equipment authorizations presents challenges in determining a fair, administrable, and sustainable fee system.. Additionally, equipment authorization generally applies to the functionality of a particular device, not the production of each unit (i.e., an entity needs to complete the equipment authorization process only once for a device regardless of how many units of such devices are produced). Thus, unlike licenses, equipment authorizations are obtained once and are not subject to validity for a defined time period. Further, the equipment authorization procedures that are applicable to RF devices permitted to be imported or marketed into the U.S. do not require the Commission to collect information from or communicate directly with the manufacturer of every device. Commenters have not provided sufficient analysis in the record to allow us to determine a fair, administrable, and sustainable regulatory fee system for the holders of equipment authorization. For these reasons, we find that the OET FTEs are appropriately categorized as indirect and we reject the proposal to adopt a new fee category for holders of equipment authorizations. 4. Operators of Databases of Spectrum Used on an Unlicensed Basis 90. We also decline to adopt the Satellite Coalition’s proposal that the Commission adopt a new regulatory fee category for database operators that charge fees to enable unlicensed use of certain frequency bands. Satellite Coalition Comments at 4. The Satellite Coalition asserts that these operators benefit from Commission rulemakings that enable them to administer unlicensed use of spectrum, and thus, that they should contribute their share to the Commission’s budget. Id. It argues that pursuant to the RAY BAUM’S Act we are no longer limited to looking at FTEs in core bureaus when determining regulatory fees. Id. The Wi-Fi Alliance disagrees and contends that the proposal to impose fees on operators of databases would impede use of 6 GHz spectrum, which in many cases will require access to an automated frequency coordination operator and its database. Wi-Fi Alliance Reply at 8-9. 91. As we have previously discussed, pursuant to section 9 of the Act, regulatory fees are to be derived by determining “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.” See supra para. 4; 47 U.S.C. § 159(d). Specifically, section 9 of the Act directs the Commission to consider “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) (emphasis added). The Commission’s FTE activities for these database operators includes the establishment of database rules and ensuring that database administrators have the technical expertise to develop and operate the relevant databases. After a database is set up, Commission involvement with the operator is generally sporadic. The function of the databases is to prevent harmful interference from occurring to incumbent licensed operations by unlicensed use of certain frequency bands thereby enabling the more efficient use of radio spectrum. The services provided by operators of databases are essentially available to any user of the relevant frequency bands on an unlicensed basis. We note that users of those databases pay operators to access the databases, and are required to use such databases to prevent harmful interference to other users. See 47 CFR §§ 15.711(a), (c)(2), (d)(2), (k)(5), 15.70(k)(1). The Commission often recognizes multiple database administrators. In those cases, users can patronize any database administrator and there is no guarantee how much, if any, coordination a particular database administrator will undertake and, thus, no guarantee that a database administrator will even receive benefits from its relationship with the Commission. 92. Moreover, the suggestion that we create a regulatory fee category for only these database administrators ignores the fact that, under the Commission’s rules, there are a variety of database administrators and spectrum coordinators (e.g., television white space devices, 6 GHz devices, and fixed, personal/portable, and mobile devices). Thus, focusing only on database administrators enabling the use of spectrum on an unlicensed basis would result in indirectly assessed regulatory fees on certain users of spectrum on an unlicensed basis. As explained below, we decline to create a regulatory fee category for users of spectrum on an unlicensed basis, either directly or indirectly. 93. Further, the Commission’s FTE activities related to operators of databases of spectrum on an unlicensed basis benefit a wide variety of industry segments, both licensed and unlicensed, and is consistent with the treatment of these FTEs, which work primarily in the Office of Engineering and Technology, as indirect. Thus, we do not find that there are sufficient benefits (i.e., FTE work in oversight or regulation) provided each fiscal year to these database operators by the Commission’s activities of such a magnitude that it warrants creation of a regulatory fee category for database operators at this time. We acknowledge that in establishing the regime that allows for such database operators to support Commission licensees, FTE time is devoted to adopting a regulatory regime that allows for the database operators to perform a such functions. This is, however, generally a one-time effort and it would arbitrary to assess fees year after year based on such one-time efforts. We therefore decline to adopt a new regulatory fee category for operators of these databases. 5. Users of Spectrum on an Unlicensed Basis 94. We decline to adopt NAB’s proposal to adopt a new regulatory fee category for users of spectrum on an unlicensed basis, including large technology companies. NAB Reply at 10-15. Commenters generally oppose NAB’s proposal. See, e.g., INCOMPAS, CCIA, and DiMA Comments; Joint Manufacturers Comments. The Wi-Fi Alliance states that there is no basis for creating a new fee category to include, directly or indirectly, users of spectrum on an unlicensed basis, and doing so would not be fair, administrable, or sustainable. Wi-Fi Alliance Reply at 4. Other commenters also oppose the proposal to adopt a regulatory fee category for the use of spectrum on an unlicensed basis. INCOMPAS, CCIA, and DiMA Comments at 1-6; Joint Manufacturers Reply at 1-3. NCTA observes that no commenter has even clarified who they think falls into the fee category, let alone presented any type of proposal or detailed explanation of how the Commission might assess such fees. NCTA Reply at 14. 95. NAB has not provided a sufficient basis, consistent with section 9 of the Act, for the adoption of a new regulatory fee category for users of spectrum on an unlicensed basis. The Commission has adopted new fee categories based in part on the benefits to the payor, i.e., FTE work in oversight and regulation, on several occasions. In those instances, the Commission determined that significant FTE resources of a core bureau were being spent on oversight and regulatory activities with respect to a specific service necessitating a new regulatory fee category. The most recent addition of a new fee category to the regulatory fee schedule was in 2020, in the Report and Order attached to the FY 2020 NPRM, where the Commission added non-U.S. licensed space stations with U.S. market access grants to the regulatory fee schedule. FY 2020 NPRM, 35 FCC Rcd at 4979-91, paras. 7-34. In 2017, the Commission added non-common carrier terrestrial IBCs to the regulatory fee schedule, in order to include both common carrier and non-common carrier terrestrial IBCs in the schedule. FY 2017 Report and Order, 32 FCC Rcd at 7071-72, paras 34-35. In 2015, the Commission added a new fee category for DBS as a subcategory of the cable television and IPTV fee category, based on the oversight and regulation of this industry by the same group of Media Bureau FTEs. FY 2015 Report and Order, 30 FCC Rcd at 10276-77, paras. 19-20. Subsequently, in the FY 2021 Report and Order, the Commission placed all DBS, cable television, and IPTV providers in the same fee category at the same per subscriber regulatory fee. FY 2021 Report and Order at para. 28. In 2014, the Commission adopted a new regulatory fee category for toll-free numbers because FTEs, primarily in the Wireline Competition Bureau, are devoted to toll-free number oversight and regulation. FY 2014 Report and Order, 29 FCC Rcd at 10778, paras. 26-27 (summarizing the legal rationale for adoption of a fee on toll-free numbers and the FTEs involved in toll-free issues). In 2013, the Commission broadened the cable television category to include IPTV providers. FY 2013 Report and Order, 28 FCC Rcd at 12362-63, paras. 32-33. Those circumstances are not present here. As noted above, FTEs in OET, which is responsible for oversight and regulation of spectrum used on an unlicensed basis, have historically been classified as “indirect” FTEs because OET’s work benefits the Commission and the industry as a whole and is not specifically focused on the regulatees and licensees of a core bureau. See supra para. 87. Even when we consider only FTE time working on oversight and regulation of spectrum used on an unlicensed basis and devices capable of operating wholly or in part on such spectrum, the treatment of such costs as indirect is appropriate. Many devices, including those operating wholly or in part on an unlicensed basis, are exempt from equipment authorization requirements. Moreover, devices that are not exempt are tested by third party labs and, if certification is required, certified by Telecommunications Certification Bodies. These devices either are exempt from equipment authorization requirements because the devices are unlikely to cause interference or authorized via a Supplier’s Declaration of Conformity (SDOC), a form of self-certification, subject to market surveillance for compliance. Devices in both unlicensed and licensed services may be exempt. See, e.g., 47 CFR §§ 15.103, 25.129, 90.203. Even with respect to devices that require certification, such certifications are granted by outside third parties (Telecommunications Certification Bodies (TCBs)), under Commission oversight. See generally 47 CFR § 2.901 et seq. Direct costs of device testing and applicant certifications necessary to demonstrate compliance with our technical and equipment authorization rules are paid directly by manufacturers to FCC-recognized labs and TCBs. Those costs are not borne by the Commission and are not recovered through regulatory fees. 47 CFR § 2.962 – (f)(3) states that TCBs may establish and assess fees for processing certification applications and other Commission-required tasks. See Amendment of Parts 0, 1, 2, and 15 of the Commission’s Rules regarding Authorization of Radiofrequency Equipment, Amendment of Part 68 regarding Approval of Terminal Equipment by Telecommunications Certification Bodies, ET Docket No. 13-44, Report and Order, 29 FCC Rcd 16335 (2014). As such, OET’s oversight requires only a portion of FTE resources, thus supporting our continued treatment of such costs as part of overall OET indirect costs, as opposed to segregable direct costs, and the Commission’s current regulatory framework does not include an easy way to distinguish devices that operate on an unlicensed (as opposed to licensed) basis. Devices often operate on spectrum that is used on an unlicensed basis and spectrum that is used on a licensed basis, and the Commission’s Equipment Authorization process does not currently permit us to easily identify a separate set of devices that operate on spectrum used on an unlicensed (as opposed to licensed) basis. 96. In interpreting and applying section 9 of the Act, the Commission has developed a framework to ensure that the resulting fee category fee schedules are fair, administrable, and sustainable. Thus, in evaluating new regulatory fee categories, we consider if assertion of our authority would be fair, administrable, and sustainable while examining any “benefit” provided to the payor by the Commission’s FTE activities in oversight and regulation. On the basis of the record developed here, we find that NAB’s proposal for a new fee category for users of spectrum on an unlicensed basis does not satisfy these factors. 97. The Commission has explained that a regulatory fee category is unfair if it combines either uses or users that are too different from one another. See FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8464, para. 14. See also, Electronic Industries Ass'n v. FCC, 554 F.2d 1109, 1116 (D.C. Cir. 1976) (when discussing IOAA, explain that each recipient class should be “the smallest unit that is practical.”) The Commission bases regulatory fee categories on services or facilities used. Use of spectrum on an unlicensed basis is nearly ubiquitous in modern-day society, and confers widespread benefits. Because of the large variety of uses of spectrum on an unlicensed basis, including for non-communications purposes, there is no specific user, service, or facility using this spectrum that could form the basis for a regulatory fee category of similar services. INCOMPAS, CCIA, and DiMA Comments at 3-4 (noting that “unlicensed spectrum users” could include an unworkably broad range of manufacturers of Internet of Things (IoT) and Bluetooth devices, such as thermostats, baby monitors, refrigerators, wireless earbuds, and smart speakers, as well as internet services that consumers and small businesses utilize via local Wi-Fi devices, including online banking, news websites, social media, and music streaming). Entities use spectrum on an unlicensed basis in a variety of ways, including healthcare, security systems, thermostats, alarm systems, baby monitors, fitness trackers, home appliances, garage door openers, cordless phones, in-vehicle rear seat passenger detection systems, wireless power transfer, law enforcement radars, microwave ovens, Wi-Fi networks, Bluetooth speakers, Internet of Things (IoT) industrial networks, and other consumer devices. Chip makers, component makers, device makers, device users, internet providers, content providers, mobile network operators, vendors, enterprise users, and consumers all use spectrum on an unlicensed basis Under authorization from the Commission, many spectrum bands can be used for unlicensed purposes on a non-interference basis to licensed users. However, the heaviest use on an unlicensed basis occurs in the 902-928 MHz, 2400-2483.5 MHz, and 5150-7125 MHz bands, and is predominantly in Wi-Fi networks. The latter band encompasses eight spectrum ranges and comprises the Unlicensed National Information Infrastructure (U-NII). U-NII spectrum at 5850-7125 MHz has recently been allocated, and development of that band for Wi-Fi use is ongoing. in various ways and such users include individuals, state and local governments, corporations, non-profit organizations, schools, libraries, and other groups. The variety of users and spectrum bands used on an unlicensed basis creates a broad group of potential payors. Moreover, the Commission itself does not distinguish between these numerous and expanding uses of spectrum on an unlicensed basis in its regulations. Thus, grouping all users of spectrum on an unlicensed basis together, including devices such as baby monitors, garage door openers, field disturbance sensors, medical imaging systems, cordless phones, Wi-Fi networks, Bluetooth speakers, Internet of Things (IoT) industrial networks, and consumer devices would not result in a fair or rational way to assess regulatory fees. 98. Second, we find that such a fee for users of spectrum on an unlicensed basis would be virtually impossible to define or administer, based on the record developed in this proceeding. The request here is analogous to seeking to set a fee on a generalized public benefit of Commission action. While the terminology of “public” versus “private” benefit is not always a beneficial distinction in the discussion of fees, it is nevertheless helpful to understand that the request here is to find a way to fee an activity – use of spectrum on an unlicensed basis – that greatly benefits the public. Our fee scheme, however, is not set up to fee public benefits. Principles of Federal Appropriations Law, Third Edition, Volume 3, Chapter 12 - Acquisition of Goods and Services, Part D - User Charges, 3. The Independent Offices Appropriation Act, 12 GAO-RB pt. D, s. 3 (2015). To adopt a fee on the use of spectrum on an unlicensed basis would be imposing a fee on billions of devices related to a wide variety of applications and industries, a base which continually grows and evolves over time. As commenters observe, because of the large variety of uses of spectrum on an unlicensed basis, it is difficult to determine who would be responsible for paying such regulatory fees as the Commission has no way of identifying the owner and user of the unlicensed devices using this spectrum, and there is no specific service with which to form a regulatory fee category of similar services. See INCOMPAS, CCIA, and DiMA Comments at 3-4; WISPA Reply at 3 (contending that there would be no rational way to design and implement a regulatory fee program for unlicensed spectrum users without sweeping in nearly every sector of the economy and that it would be impossible to narrow the scope in any predictable or non-arbitrary manner). We find that the variety of uses of spectrum on an unlicensed basis creates such a broad group of potential payors as to render it virtually meaningless to attempt to identify them because it would be hard to find a consumer or a business that does not use spectrum on an unlicensed basis nearly every day. As the Wi-Fi Alliance observes, imposing new regulatory fees on users of spectrum on an unlicensed basis could affect an unreasonably wide range of entities and individuals, including consumers. Wi-Fi Alliance Reply at 7. 99. With such a large group of users of spectrum on an unlicensed basis, adopting a new regulatory fee category for these users would be the equivalent of asking every industry and consumer to pay this fee, resulting in a regulatory fee scheme far more extensive than our current regulatory fee system and would reach all households and businesses. Such a fee would be logistically infeasible to collect, at least on the basis of this record. If we would adopt such a category, the fee would most likely be de minimis if imposed on such a large number of entities. Section 9(e)(2) of the Communications Act permits the Commission to exempt a party from paying regulatory fees if “in the judgment of the Commission, the cost of collecting a regulatory fee established under this section from a party would exceed the amount collected from such party. . . .” The de minimis threshold is currently $1,000, and applies to a payor’s total annual regulatory fees. 100. NAB argues that users of spectrum on an unlicensed basis place a significant ongoing burden on Commission resources in furtherance of their businesses because the Commission will be involved in amending and monitoring the spectrum use process, responding to requests from the innovation economy to use spectrum in new ways and for new technologies, and enforcing its rules, not only to prevent interference to licensed users, but to ensure the end user can actually use the devices and products. NAB Reply at 12 (citing State Broadcasters FY 2021 Reply at 10). We are not convinced that the mere fact that FTE time involved in oversight and regulation of such spectrum use is a sufficient reason to adopt a new regulatory fee category. As discussed above, there is no particular service, industry, or other discrete group of potential regulatory fee payors for the use of spectrum on an unlicensed basis, because essentially all consumers and manufacturers have devices that use spectrum on an unlicensed basis. NAB has concerns regarding Microsoft’s use of spectrum on an unlicensed basis. See NAB, Advocacy, “Congress Should Prevent Any Microsoft Spectrum Grab,” available at https://www.nab.org/advocacy/issue.asp?id=4206&issueid=1087 (last visited Aug. 4, 2022). Moreover, the Commission previously has observed that regulatees rely on consistency of treatment in regulatory fees from year to year and thus the Commission has hesitated to make changes which would result in rapid shifts in regulatory fees. See, e.g., FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8464-65, para. 15 (“A fee system that strictly aligned FTEs with these activities and Bureaus on an ongoing basis would require a complex time and accounting system like the one the Commission tried in 1997 and 1998 and abandoned in 1999 due in part to the unpredictability and rapid shifts in fee rates that it created for fee payors. Keeping the fee schedule up to date could result in large shifts in fees from year to year, as the Commission’s priorities and areas of focus change.”); FY 2020 NPRM, 35 FCC Rcd at 4980, para. 8, n.25 (citing the FY 2012 Regulatory Fee Reform NPRM and noting a need to avoid such shifts). We therefore find that, in this instance, creating such categories does not serve the Commission’s goal of having an administrable framework. For the most part, the users of such devices, consumers and manufacturers, do not have contact with the Commission. Further, even if we could ascertain such users at one point in time, this information would have to be updated continually. 101. Additionally, a regulatory fee category related to use of spectrum on an unlicensed basis, assessed on devices, if adopted, would not be sustainable for the same reasons elaborated above. Ever-changing technology results in increased use of spectrum on an unlicensed basis over time and the Commission would have to continually re-assess this regulatory fee category to ensure that it is being implemented in a fair and equitable manner among all regulatory fee payors. With respect to the logistics of imposing an annual regulatory fee on users of devices capable of using spectrum on an unlicensed basis, it is unclear whether and how device manufacturers or distributors would be responsible for paying such a fee. The Commission establishes rules for and administers the equipment authorization program to ensure that RF devices used in the United States operate effectively without causing harmful interference and otherwise comply with the Commission’s rules. However, under the current equipment authorization regime, the Commission does not collect information from or communicate with all device manufacturers because, many devices only require SDoC s or are exempt from authorization because they pose a limited potential of causing harmful interference. Further, the Commission has no reasonable means by which to comprehensively identify each and every individual user of RF devices on an unlicensed basis. Individual users of RF devices using spectrum on an unlicensed basis include millions of owners of commonly used devices, such as cordless telephones, garage door openers, baby monitors, microwave ovens, wireless headphones, personal medical devices, smart TVs, and even cellphones and smart phones, among other countless examples of consumer devices. Thus, it would be nearly impossible for the Commission to annually assess and collect the regulatory fees each year in a fair and sustainable manner consistent with section 9 of the Communications Act. 47 U.S.C. § 159. 102. Finally, NAB contends that the Commission cannot continue to place the burden of paying for use of spectrum on an unlicensed basis on broadcasters who are forced to compete with some of the world’s largest technology companies unencumbered by regulatory fee burdens in the name of administrative simplicity. NAB Reply at 15; see also Comments from the National Association of Broadcasters to the Federal Communications Commission for FY 2021, MD Docket No. 21-190, at 12-15 (filed Oct. 21, 2021); Reply Comments from the Television Affiliates Association to the Federal Communications Commission for FY 2021, MD Docket No. 21-190 (Nov. 5, 2021). Contrary to NAB’s implication, the “Big Tech” companies, such as Amazon, Google, Facebook, and Microsoft, referenced by NAB in its previous proposal in response to the Commission’s Notice of Proposed Rulemaking appended to the FY 2021 Report and Order, pay regulatory fees for their services that are on the regulatory fee schedule, such as submarine cables. For some articles discussing their submarine cables, see, e.g., Google Cloud, Infrastructure, “All about cables: A guide to posts on our infrastructure under the sea,” (June 11, 2021), https://cloud.google.com/blog/products/infrastructure/learn-about-googles-subsea-cables; Microsoft, Stories, “Mariea: The future of subsea cable,” https://news.microsoft.com/marea/ (last visited Aug. 4, 2022); and Reuters, Technology, “Facebook, Amazon seek U.S. approval to operate undersea data cable,” (Aug. 13, 2021), https://www.reuters.com/technology/facebook-amazon-seek-us-approval-operate-undersea-data-cable-2021-08-13/(last visited Aug. 4, 2022). Some “Big Tech” companies are a subset of the users of spectrum on an unlicensed basis. Thus, our above reasons for declining to adopt a regulatory fee category for users of spectrum on an unlicensed basis apply equally to any such “Big Tech” companies on the sole basis of being users of spectrum on an unlicensed basis, as proposed by commenters. The Commission previously sought comment on whether to assess regulatory fees on large technology companies on alternative grounds, “such as any advantages they receive because of the Commission’s universal service or other activities[.]” FY 2021 Report and Order, 36 FCC Rcd at 13206, para. 73. We do not make any findings in this regard at this time. 103. Further, we decline to create a new regulatory fee category for the use of spectrum on an unlicensed basis premised on competitive considerations in the advertising industry. See NAB, “Is Big Tech a Threat to Local Media?” available at https://www.nab.org/bigTech/default.asp (last visited Aug. 4, 2022) (explaining that when local news is online, “Big Tech” controls what is presented and the share of advertising revenue that the broadcasters who supply the news receive). We have described above the record evidence demonstrating the broad and varied universe of users of spectrum on an unlicensed basis. There is no evidence in the record of any discernable and practicable overlap between the universe of users of spectrum on an unlicensed basis and the advertising industry, and commenters do not explain how the Commission separately regulates or expends FTE resources on those that might be competing with broadcasters for advertising revenues. Thus, competition for advertising revenues is not a sufficient basis for creating a new regulatory fee category under section 9 of the Act. Accordingly, as we discussed above, we find that a new regulatory fee category for users of spectrum on an unlicensed basis, on the basis of the instant record, is not statutorily required and would be inconsistent with section 9 of the Act and the Commission’s precedent thereunder, and we decline to adopt such regulatory fee categories at this time. We recognize the value in encouraging the development and innovation of technologies and decline to take such unprecedented action without a sufficient basis for making this change to the regulatory fee schedule. Commenters observe that a regulatory fee on the use of spectrum on an unlicensed basis could discourage innovation. See, e.g., INCOMPAS, CCIA, and DiMA Comments at 3; Coalition of Trade Associations and Public Interest Organizations Comments at 1-2 (stating that the Commission’s decision “to permit unlicensed operations in the 6 GHz band, for example, will empower innovations such as AR/VR, drones, connected vehicles, telehealth, precision agriculture, and AI.”). G. Advancing Diversity, Equity, Inclusion, and Accessibility 104. In the FY 2022 NPRM, we sought comment on how our proposals may promote or inhibit advances in diversity, equity, inclusion, and accessibility, as well the scope of the Commission’s relevant legal authority. FY 2022 NPRM at *18, para 54. NCTA raises some concerns that establishing new regulatory fee categories for users of spectrum on an unlicensed basis or on broadband Internet access services could interfere with the Commission’s efforts to advance diversity, equity, inclusivity, and accessibility. NCTA Reply at 18-19 (noting that that establishing new regulatory fee categories for users of spectrum on an unlicensed basis and on broadband Internet access services would have a disproportionately negative impact on promoting greater broadband equity and inclusivity for low-income, communities of color, and on individuals living with disabilities who typically rely on wireless data and devices for everyday tasks). NCTA also asserts that establishing these new regulatory fee categories will frustrate the Commission’s efforts to encourage the creation of innovative technologies and foster diversity in ownership of communications facilities and services. NCTA Reply at 18-19. While we recognize the concerns raised by NCTA, we emphasize that such diversity and equity considerations do not impact our methodology for establishing regulatory fee rates. Such considerations do not allow the Commission to shift fees from one party of fee payors to another nor to raise fees for any purpose other than as an offsetting collection in the amount of our annual S&E appropriation, consistent with the requirements of section 9 of the Act. Moreover, because we decline to adopt these new regulatory fee categories proposed by commenters in this item, for reasons previously discussed in prior sections, we need not address the concerns raised by NTCA in this proceeding. H. Flexibility for Regulatory Payors Due to COVID-19 Pandemic 105. In 2020 and 2021, we provided relief to regulatees experiencing financial hardship caused or exacerbated by the COVID-19 pandemic. FY 2020 Report and Order, 36 FCC Rcd at 1760-61, paras. 80-84; FY 2021 Report and Order, 36 FCC Rcd at 13024-25, paras. 69-71. In light of the ongoing pandemic and the likely continuing economic effect on certain Commission regulatees, See e.g., Goldman Sachs, Survey: Small Businesses on the Brink. Omicron Hurting Main Street, Leading Small Business Owners to Overwhelmingly Support Congress Passing Additional Aid (January 24, 2022), https://www.goldmansachs.com/citizenship/10000-small-busineses/US/infographics/small-businesses-on-the-brink/index.html (last visited Aug. 4, 2022). we find good cause exists to provide again the following temporary relief measures for FY 2022. See 47 CFR § 1.3. We anticipate that many regulatees will avail themselves of these measures, as they did in FY 2020 and FY 2021, and that implementing the measures will provide needed relief to those regulatees. First, we waive the requirement under section 1.1166 of the Commission’s rules that regulatees seeking waiver (or reduction) and deferral of their regulatory fees on financial grounds related to the pandemic file separate pleadings for each form of relief sought. 47 CFR § 1.1166(a), (c), (d). Instead, regulatees may combine their requests for relief in a single pleading. Second, we waive the paper filing requirement under section 1.1166 47 CFR § 1.1166(a). and instruct regulatees to instead file their requests electronically, to regfeerelief@fcc.gov. Third, parties seeking to pay their regulatory fees over time may submit their installment payment requests to regfeerelief@fcc.gov, and combine their installment payment requests with requests for waiver, reduction and deferral, in a single pleading. Fourth, OMD will continue to exercise its delegated authority to partially waive section 1.1910 of the Commission’s rules (i.e., the red-light rule) 47 CFR § 1.1940. to allow regulatees on red light and experiencing financial hardship to nonetheless request waiver, reduction, deferral, and/or installment payment of their FY 2022 regulatory fees. In doing so, we maintain the requirement that such regulatees resolve all delinquent debt they owe to the Commission in advance of the Commission’s decision on their relief requests. The Commission implemented the red light rule in 2004 as an administrative debt collection tool pursuant to its authority under the Communications Act and the Debt Collection Improvement Act of 1996, as amended, 31 U.S.C. § 3701, et seq. (DCIA), Implementation of the Debt Collection Improvement Act of 1996 and Adoption of Rules Governing Applications and Requests for Benefits by Delinquent Debtors, MD Docket No. 02-339, Report and Order, 19 FCC Rcd 6540, 6541, paras. 3, 4 (2004) (Red Light Order). The Commission also amended section 0.231 of its rules to delegate to OMD and the Office of General Counsel the authority to determine and collect debt owed to the Commission, utilizing all available debt collection tools. Red Light Order, 19 FCC Rcd at 6545, para. 16; 47 CFR § 0.231; see also 47 CFR § 0.11(a)(10) (delegating authority to OMD to interpret rules and regulations pertaining to fees). Fifth, OMD will continue to use its existing authority OMD’s delegated authority under section 0.231 of the Commission’s rules includes utilizing installment payment agreements to collect debt owed to the Commission. 47 CFR § 0.231(f); see id. § 1.1914. The Commission has the discretion to determine the rate of interest it will charge for installment payment and debt, 31 CFR § 901.9(b)(2); 47 CFR § 1.1940(b)(2), and to require a down payment. See 31 CFR § 901.8; 47 CFR § 1.1914 (in which the Federal Claims Collection Standards and the Commission’s rules implementing the DCIA permit agencies to grant and shape the terms of installment payment of debt). to reduce the interest rate normally charged on installment payment of regulatory fee debt owed to the Commission to a nominal rate and forgo the down payment normally required to grant installment payment requests. Finally, we partially waive the requirement that fee payors submit all documentation supporting a request for waiver, deferral or reduction of regulatory fees at the same time the underlying request is submitted. 47 CFR § 1.1166(c), (d). This allows fee payors to provide supplemental documents if requested by OMD as necessary to render decisions on regulatees’ requests for relief. FY 2019 Report and Order, 34 FCC Rcd at 8208, para. 53 (eliminating any obligation by the Commission to consult its records for data pertinent to a waiver request and instead, required that a ”party seeking regulator fee relief on any basis include with its request all documents and information the requestor believes to be relevant to prove its case”). OMD has delegated authority under section 0.231 of the Commission’s rules to determine requests to waive, reduce and defer regulatory fees and thus, to waive the requirement that all supporting documentation be submitted with the request. 47 CFR § 0.231(f). We direct the Managing Director to release one or more public notices describing in more detail the relief we have described herein. 106. We remind regulatees that we cannot relax the standard for granting a waiver or deferral of fees, penalties, or other charges for late payment of regulatory fees under section 9A of the Act. 47 U.S.C. § 159A(d). Under the statute, the Commission may only waive a regulatory fee, penalty, or interest charge if it finds there is good cause for the waiver and that the waiver is in the public interest. Id. In our FY 2019 Report and Order, in the context of explaining the implications to the revisions to our regulatory fee authority, we explained in detail the rules pertaining to waiver, reduction, deferral and the responsibility for payment of regulatory fees. FY 2019 Report and Order, 34 FCC Rcd at 8207-08, paras 49-53. The Commission has only granted financial hardship waivers when the requesting party has shown it “lacks sufficient funds to pay the regulatory fees and to maintain its service to the public.” FY 2020 Report and Order, 36 FCC Rcd at 1762, para. 87. Other statutory limitations include that the Commission must act on waiver requests individually, Section 9 of the Act does not permit the Commission to exempt any group of regulatees, other than those expressly exempted under the statute. 47 U.S.C. § 159(e). Instead, the statute requires a case-by-case determination to waive regulatory fees or related charges. See id. § 159A(d); FY 2020 Report and Order, 36 FCC Rcd at 1761-62, para. 86; FY 2019 Report and Order, 34 FCC Rcd at 8207, para. 50. and cannot extend the deadline we set for payment of fees beyond September 30. 47 U.S.C. § 159(b). September 30 marks the end of the Commission’s fiscal year. The Commission is required to collect the full amount of its appropriation in the offsetting regulatory fee collection for any given fiscal year by the fiscal year end. 47 U.S.C. § 159(b) (“The 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.”). IV. NOTICE OF INQUIRY 107. In this Notice of Inquiry, the Commission seeks further comment on its methodology for allocating indirect FTEs, as raised in the FY 2022 NPRM. FY 2022 NPRM at *18, para. 53. While we found above that the record supported a limited correction to the method used for calculating the fees associated with certain indirect FTEs in the Universal Service Fund context, we seek to more broadly explore these issues outside of the short timeframe necessitated by the annual regulatory fee proceeding. The responses we receive will help us determine if there are lines of inquiry worth exploring in order to further revise our methodology. Finally, we hope that the comments and replies will allow interested parties to gain a better understanding of the regulatory fee process and the issues of importance to the various groups affected by our regulatory fee policies. 108. Historically, the Commission assesses the allocation of FTEs by first determining the number of non-auctions direct FTEs in each “core bureau” (i.e., the Wireless Telecommunications Bureau, the Media Bureau, the Wireline Competition Bureau, and the International Bureau) and then attributing all other non-auctions Commission FTEs as indirect. See FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8460, para. 5 & n.5; FY 2012 Report and Order, 27 FCC Rcd at 8392, paras. 3-5. The direct FTEs within each core bureau are then attributed to regulatory fee categories based on the nature of the FTE work. Our methodology for implementing our regulatory fee authority essentially remains unchanged by the RAY BAUM’S Act. See FY 2019 Report and Order, 34 FCC Rcd at 8192-93, para. 7. We expect that the work of the non-auctions direct FTEs in the four core bureaus will remain focused on the industry segment regulated by each of those bureaus. FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8465-66, paras. 19-20. For this reason, the Commission starts with direct FTE counts in the core bureaus and then potentially adjusts fees to reflect other factors related to the payor’s benefits. FY 2019 Report and Order, 34 FCC Rcd at 8195, para. 16. 109. We initially seek comment on whether we should expand the definition of “core bureau” to include other bureaus and offices within the Commission. Commenters should discuss the additional offices or bureaus we should consider “core” for regulatory fee purposes and why. We encourage commenters to review both the function and delegations of each office when considering this question. See 47 CFR § 0.231 (delegated authority of the Office of Managing Director); 47 CFR § 0.251 (delegated authority of the General Counsel); 47 CFR § 0.241 (delegated authority of the Chief of the Office of Engineering and Technology); 47 CFR § 0.271 (delegated authority of the Office of Economic and Analytics); 47 CFR § 0.311 (delegated authority of the Enforcement Bureau). Is the work of the office or bureau focused on a specific industry segment regulated by that office or bureau? If so, what is the industry segment? Is the office or bureau responsible for regulating other work not related to a specific industry segment? Commenters should address whether expanding the Commission’s definition of “core bureau” is feasible, administrable, sustainable, and consistent with section 9 of the Act. 110. Unlike the work of direct FTEs, the work of FTEs designated as indirect benefits the Commission and the industry as a whole and is not specifically focused on the regulatees and licensees of a core bureau. See FY 2021 Report and Order, 36 FCC Rcd at 13001, para. 22. Thus, indirect FTEs generally work on a wide variety of issues which may include services that are not specifically correlated with one core bureau, let alone one specific category of regulatees. FY 2019 Report and Order, 34 FCC Rcd at 8196, para. 18; FY 2015 Report and Order, 30 FCC Rcd at 10275, para. 17. Further, much of the work that could be assigned to a single category of regulatees is likely to be interspersed with the work that indirect FTEs perform on behalf of many entities that do not pay regulatory fees, e.g., governmental entities, non-profit organizations, and regulatees that have an exemption. See, e.g., 47 U.S.C. § 159(e) In addition to the fact that indirect FTEs work on matters that are not specific to any regulatory fee category, many Commission attorneys, engineers, analysts, and other staff work on a variety of issues even during a single fiscal year. Due to the variety of issues handled by many indirect FTEs, analyzing the work of such indirect FTEs for regulatory fee purposes and basing regulatory fees on specific assignments during any snapshot or incremental period of time, such as a year or two, would result in significant unplanned shifts in regulatory fees as assignments change. FY 2019 Report and Order, 34 FCC Rcd at 8196, para. 18. As the Commission observed in the FY 2012 Regulatory Fee Reform NPRM, with respect to the administrability of trying to allocate indirect FTEs to core bureaus, “if in one year the Public Safety and Homeland Security Bureau handles rulemakings related to broadcasting, but in the following year focuses on wireless services, the resulting shift in FTE allocations could have a substantial impact on the size of regulatory fees, which could then shift significantly again the very next year.” FY 2012 Regulatory Fee Reform NPRM, 27 FCC Rcd at 8465, para. 15. 111. In calculating regulatory fees, the Commission allocates indirect FTEs proportionally based on the allocation percentage of direct FTEs of each core bureau. In essence, if a core bureau’s contribution to the regulatory fee burden is calculated to be 40%, then it is also responsible for 40% of the indirect costs. Commenters argue that this results in regulatory fee payors paying being unfairly burdened by costs of FTEs that do not directly provide oversight and regulation to such fee payors. See, e.g., State Broadcasters Associations Comments at 16-18; NAB Comments at 7-10. We seek comment on whether the Commission should change its current methodology for calculating regulatory fees to minimize burdens on certain regulatory fee payors, while still collecting the entire appropriation, as required by section 9 of the Act. To the extent that commenters support amending the methodology, the proposals made must allow for the full collection of our annual appropriation. In other words, a proposed system that only provides that regulatees pay fees for the direct time of staff in the core bureaus would be per se contrary to our statutory mandate. Comments filed in the Notice of Inquiry docket proposing such amendments should provide full scale examples of the potential changes to the current methodology and explain how those changes would be consistent with section 9 of the Act. 112. As discussed above, we find that broadcasters should not be required to pay for a portion of the 38 indirect FTEs working on Universal Service Fund issues that are in the Wireline Competition Bureau but are designated as indirect FTEs. NAB Comments at 12-13. Although we affirmed the Commission’s previous finding in 2017 that these 38 FTEs were properly allocated as indirect FTEs for regulatory fee purposes, are there indirect FTEs that commenters believe should be considered direct FTEs for regulatory fee purposes? For example, in FY 2019, the Commission reassigned staff from other bureaus and offices to the Office of Economics and Analytics, effective December 11, 2018. See Establishment of the Office of Economics and Analytics, MD Docket No. 18-3, Order, 33 FCC Rcd 1539 (2018); FCC Opens Office of Economics And Analytics, Federal Communications Commission News Release, December 11, 2018, https://www.fcc.gov/document/fcc-opens-office-economics-and-analytics. This resulted in the reassignment of 95 FTEs (of which 64 were not auctions-funded) as indirect FTEs. The Commission also reassigned Equal Employment Opportunity enforcement staff from the Media Bureau to the Enforcement Bureau, effective March 15, 2019, resulting in a reduction of seven direct FTEs in the Media Bureau. See Transfer of EEO Audit and Enforcement Responsibilities to Enforcement Bureau, DA 19-186, Public Notice, 34 FCC Rcd 1370 (EB 2019). These reassignments resulted in a reduction in direct FTEs in the Wireline Competition Bureau (from 123 FTEs to 100.8 FTEs), Wireless Telecommunications Bureau (from 89 FTEs to 80.5 FTEs), and Media Bureau (from 131 FTEs to 115.1 FTEs). In 2013, the Commission allocated all International Bureau FTEs except for 28 as indirect. See FY 2013 Report and Order, 28 FCC Rcd at 12355-56, para. 14. Should we reconsider these assignments and now consider these FTEs direct FTEs in a core bureau instead of indirect? Commenters should discuss whether this allocation is still reasonable. Should we re-evaluate the number of direct and indirect FTEs in the International Bureau? For each category of FTE a commenter proposes to be reassigned, the commenter should explain how such reassignment is appropriate under both the Act and also the body of precedent relating to federal agency fee setting. 47 U.S.C. § 159(d); supra note 23. If these reassignments are still appropriate, should we consider other corrections to our fee calculation methodology, as we did in the Universal Service Fund context? 113. As indicated in the FY 2022 NPRM, early in each fiscal year, the Commission receives FTE data from its Human Resources Office, and identifies FTE data at the core bureau level (i.e., direct FTEs), which are then used to determine the FTE allocations for the four core bureaus. FY 2022 NPRM at *3, para. 6. These FTE data are then filtered down to the various fee categories within each core bureau based on the fee category percentages for each bureau. Id. We encourage commenters in looking at the question to consider how indirect FTE time devoted to work on one or more regulated services could be considered direct FTE time. How should time be calculated for purposes of regulatory fees if FTE time is devoted to issues involving different regulated services at the same time (e.g., voice services)? 114. Commenters should also consider that indirect FTEs may be difficult to disaggregate in a manner that is easy to administer and transparent with respect to how it applies to certain regulated services. For example, a complex enforcement investigation involving a space station operator could result in many Enforcement Bureau indirect FTEs working on space station issues on a temporary basis instead of on other issues. Would allocating those indirect FTEs as direct FTEs for the International Bureau unfairly increase the regulatory fees for all space station licensees or all International Bureau regulatees for that fiscal year? Is there a way to disaggregate the time indirect FTEs may spend on issues associated with core bureaus in a way that would not result in significant regulatory fee increases from year to year? Taking into consideration practical limits on what the Commission may accomplish using existing systems and also limited staff time, how frequently should FTE time be analyzed for reassessments of the work done by indirect FTEs? 115. Other indirect FTEs may not be able to disaggregate the issues that they handle or may work on matters that do not correlate with any particular regulated service. Commenters who advocate analyzing the indirect FTE time to determine if their time can be allocated to specific regulated services should explain how to address indirect FTE time that cannot be specifically disaggregated into work performed for certain regulated services. SIA observes that the current indirect FTE allocation method is appropriate for certain non-core bureaus and offices, such as the Office of the General Counsel. SIA Comments at 6. Are there other bureaus and offices that commenters consider to be more appropriately designated as indirect? State Broadcasters Associations suggest that the Commission adopt a third classification of intersectional FTEs to avoid unfair burdens on broadcasters. State Broadcasters Associations Comments at 16-18. SIA suggests an alternative allocation mechanism for indirect FTEs in cases where the work is not always proportional. SIA Comments at 5. Commenters should also specifically address these alternatives to the Commission’s current methodology. Commenters should explain how we could implement these alternative suggestions, consistent with section 9 of the Act. Moreover, commenters should consider if such changes might result in a more complicated fee system that nevertheless results in the setting similar fee amounts but requires more time and Commission resources to manage. 116. One commenter, the State Broadcasters Associations, suggest that the Commission adopt a third classification of intersectional FTEs. State Broadcasters Associations Comments at 16-18. SIA suggests an alternative allocation mechanism for indirect FTEs in cases where the work is not always proportional. SIA Comments at 5. Commenters should also specifically address these alternatives to the Commission’s current regulatory fee methodology. Commenters should explain how we could implement these alternative suggestions, consistent with section 9 of the Act. Moreover, commenters should consider if such changes might result in a more complicated fee system that nevertheless results in the setting similar fee amounts but requires more time and Commission resources to manage. 117. Commenters advocating allocating indirect FTEs as direct for regulatory fee purposes should explain how we should assess FTE time in order to make the reallocation. Commenters are encouraged to consider practical aspects of FTE time. For example, how should FTEs devoted to administrative matters, such as releasing and posting Commission and Bureau level items, be categorized? Should such FTE time be considered indirect, or should each released item be analyzed to determine to which core bureau it is associated? How should FTE time devoted to matters encompassing voice issues (i.e., wireless and wireline, including VoIP) be characterized? Is there a fair way to allocate such FTE time among or between bureaus or should that FTE time be considered indirect? We note that our regulatory fee methodology must be consistent with the requirements of section 9 of the Communications Act that “fees reflect the full-time equivalent number of employees within the bureaus and offices of the Commission.” 47 U.S.C. § 159(d). Commenters should recognize that cherry picking certain groups of FTEs from indirect bureaus and offices and reassigning them as direct FTEs for regulatory fee purposes could result in a less equitable methodology overall and achieve a result inconsistent with their intention of reducing their regulatory fees. Finally, commenters should recognize that any new methodology they propose must be consistent with section 9 of the Act, fair, administrable, and sustainable. V. PROCEDURAL MATTERS 118. Included below are procedural items as well as our current payment and collection methods. 119. Credit Card Transaction Levels. In accordance with Treasury Financial Manual, Volume I, Part 5, Chapter 7000, Section 7055.20—Transaction Maximums, 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. Treasury Financial Manual, Volume I, part 5, Chapter 7000, Section 7055.30, Prohibition on Splitting Transactions. Note that the Treasury Financial Manual, Volume I, Part 5, Chapter 7000, Credit and Debit Card Collection Transactions was updated on June 23, 2022, effective October 1, 2022, reducing the credit card limit of intra-governmental transactions (government-to-government) from $24,99.99 to $10,000.00. 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 the CORES system. Further details will be provided regarding payment methods and procedures at the time of FY 2022 regulatory fee collection in Fact Sheets, https://www.fcc.gov/regfees. 120. Payment Methods. During the fee season for collecting regulatory fees, regulatees can pay their fees by credit card through Pay.gov, Treasury Financial Manual, Volume I, Part 5, Chapter 7000, Section 7055—Transaction Maximums. ACH, debit card, Id. 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, an FCC 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 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. 121. De Minimis Regulatory Fees, Section 9(e)(2) Exemption. Under the de minimis rule, and pursuant to our analysis under section 9(e)(2) of the Act, a regulatee is exempt from paying regulatory fees if the sum total of all of its annual regulatory fee liabilities is $1,000 or less for the fiscal year. FY 2019 Report and Order, 34 FCC Rcd at 8206-8207, paras. 46-48; 47 U.S.C. § 159(e)(2). The de minimis threshold applies only to filers of annual regulatory fees, not regulatory fees paid through multi-year filings, and it is not a permanent exemption. Each regulatee will need to reevaluate the total annual fee liability each fiscal year to determine whether it meets the de minimis exemption. 122. 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, 2021 for AM/FM radio stations and VHF/UHF broadcast television stations. Regulatory fees must be paid for all broadcast facility licenses granted on or before October 1, 2021. · Wireline (Common Carrier) Services: Regulatory fees must be paid for authorizations that were granted on or before October 1, 2021. In instances where a permit or license is transferred or assigned after October 1, 2021, 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, 2021. · 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, 2021. The number of subscribers, units, or telephone numbers on December 31, 2021 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, 2021, 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 seven regulatory fee categories in our Schedule of Regulatory Fees pay “small multi-year wireless regulatory fees.” These multiyear licenses are for PLMRS (exclusive), PLMRS (shared), Microwave, Marine (ship), Aviation (aircraft), Marine (coast), and Aviation (ground). Entities pay these regulatory fees in advance for the entire amount period covered by the 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 2022. · 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, 2021. 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 2021, rather than on a count as of December 31, 2021. Regulatory fees also must be paid for CARS licenses that were granted on or before October 1, 2021. In instances where a permit or license is transferred or assigned after October 1, 2021, 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, 2021. In instances where a permit or license is transferred or assigned after October 1, 2021, responsibility for payment rests with the holder of the permit or license as of the fee due date. · International Services (Earth Stations and Space Stations): Regulatory fees must be paid for (1) earth stations, (2) geostationary orbit space stations and non-geostationary orbit satellite systems, and 3) small satellite space stations that were licensed and operational on or before October 1, 2021. In instances where a permit or license is transferred or assigned after October 1, 2021, responsibility for payment rests with the holder of the permit or license as of the fee due date. · 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, 2021. Regulatory fees for terrestrial and satellite IBCs are to be paid based on active (used or leased) international bearer circuits as of December 31, 2021 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, 2021. 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, 2021, responsibility for payment rests with the holder of the permit or license as of the fee due date. 123. Commercial Mobile Radio Service (CMRS) and Mobile Services Assessments. The Commission compiled 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 and Order on Reconsideration, 20 FCC Rcd 12259, 12264, paras. 38-44 (2005). We have included non-geographic numbers in the calculation of the number of subscribers for each CMRS provider in Appendix B and the CMRS regulatory fee rate. CMRS provider regulatory fees are calculated and should be paid based on the inclusion of non-geographic numbers. CMRS providers can adjust the total number of subscribers, if needed. This information of telephone numbers (subscriber count) will be posted on the Commission’s electronic filing and payment system (Fee Filer). 124. 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. 125. 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, 2020), 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. 126. Effective Date. Providing a 30-day period after Federal Register publication before this Report and Order becomes effective as normally required by 5 U.S.C. § 553(d) will not allow sufficient time to collect the FY 2022 fees before FY 2022 ends on September 30, 2022. For this reason, pursuant to 5 U.S.C. § 553(d)(3), we find there is good cause to waive the requirements of section 553(d), and this Report and Order will become effective upon publication in the Federal Register. Because payments of the regulatory fees will not actually be due until late September, persons affected by the Report and Order will still have a reasonable period in which to make their payments and thereby comply with the rules established herein. 127. Regulatory Flexibility Act. The Regulatory Flexibility Act of 1980, as amended (RFA), See 5 U.S.C. §§ 601–612. The RFA, 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). requires that an agency prepare a regulatory flexibility analysis for notice and comment rulemakings, unless the agency certifies that “the rule will not, if promulgated, have a significant economic impact on a substantial number of small entities.” See 5 U.S.C. § 605(b). The Commission has prepared a Final Regulatory Flexibility Analysis (FRFA) concerning the possible impact of this Report and Order on small entities. The FRFA is set forth in Appendix I. 128. Paperwork Reduction 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). 129. Congressional Review Act. The Commission has determined, and the Administrator of the Office of Information and Regulatory Affairs, Office of Management and Budget, concurs that this rule is non-major under the Congressional Review Act, 5 U.S.C. § 804(2). The Commission will send a copy of this Report and Order to Congress and the Government Accountability Office pursuant to 5 U.S.C. § 801(a)(1)(A). 130. Ex Parte Rules. 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. Although the Commission’s rules do not generally require ex parte presentations to be treated as “permit but disclose” in Notice of Inquiry proceedings, see id. § 1.1204(b)(1), we exercise our discretion in this instance and find that the public interest is served by making ex parte presentations available to the public in order to encourage a robust record. See id. § 1.1200(a). 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 rule 1.1206(b). 47 CFR § 1.1206(b). In proceedings governed by rule 1.49(f) 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). 47 CFR § 1.49(f). Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules. 131. Comment Filing Procedures. 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 in response to the Notice of Inquiry 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) and must be filed under MD Docket No. 22-301. 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: https://www.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 45 L Street, NE, 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, DA 20-304, Public Notice, 35 FCC Rcd 2788 (2020), https://www.fcc.gov/document/fcc-closes-headquarters-open-window-and-changes-hand-delivery-policy. 132. Availability of Documents. Comments, reply comments, and ex parte submissions will be publicly available online via ECFS. These documents will also be available for public inspection during regular business hours in the FCC Reference Information Center, when FCC Headquarters reopen to the public. 133. 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 and Governmental Affairs Bureau at (202) 418-0530 (voice). VI. ORDERING CLAUSES 134. 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 Inquiry IS HEREBY ADOPTED. 135. IT IS FURTHER ORDERED that the FY 2022 section 9 regulatory fees assessment requirements and the rules set forth in Appendix J ARE ADOPTED as specified herein. 136. IT IS FURTHER ORDERED that the Report and Order SHALL BE EFFECTIVE upon publication in the Federal Register. 137. 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 the Chief Counsel for Advocacy of the Small Business Administration. FEDERAL COMMUNICATIONS COMMISSION Marlene H. Dortch Secretary APPENDIX A List of Commenters Name of Commenter Abbreviated Name Date Filed Alabama Broadcasters Association, Alaska Broadcasters Association, Arizona Broadcasters Association, Arkansas Broadcasters Association, California Broadcasters Association, Colorado Broadcasters Association, Connecticut Broadcasters Association, Florida Association of Broadcasters, Georgia Association of Broadcasters, Hawaii Association of Broadcasters, Idaho State Broadcasters Association, Illinois Broadcasters Association, Indiana Broadcasters Association, Iowa Broadcasters Association, Kansas Association of Broadcasters, Kentucky Broadcasters Association, Louisiana Association of Broadcasters, Maine Association of Broadcasters, MD/DC/DE Broadcasters Association, Massachusetts Broadcasters Association, Michigan Association of Broadcasters, Minnesota Broadcasters Association, Mississippi Association of Broadcasters, Missouri Broadcasters Association, Montana Broadcasters Association, Nebraska Broadcasters Association, Nevada Broadcasters Association, New Hampshire Association of Broadcasters, New Jersey Broadcasters Association, New Mexico Broadcasters Association, The New York State Broadcasters Association, Inc., North Carolina Association of Broadcasters, North Dakota Broadcasters Association, Ohio Association of Broadcasters, Oklahoma Association of Broadcasters, Oregon Association of Broadcasters, Pennsylvania Association of Broadcasters, Radio Broadcasters Association of Puerto Rico, Rhode Island Broadcasters Association, South Carolina Broadcasters Association, South Dakota Broadcasters Association, Tennessee Association of Broadcasters, Texas Association of Broadcasters, Utah Broadcasters Association, Vermont Association of Broadcasters, Virginia Association of Broadcasters, Washington State Association of Broadcasters, West Virginia Broadcasters Association, Wisconsin Broadcasters Association, and Wyoming Association of Broadcasters State Broadcasters Associations 7/5/22 Cable & Wireless Networks; GlobeNet Cabos Submarinos Americas, Inc.; GU Holdings, Inc. (wholly-owned subsidiary of Google LLC); Hawaiki Submarine Cable USA LLC; SETAR; Tata Communications (Americas), Inc. Submarine Cable Coalition 7/5/22 Computer & Communications Industry Association (CCIA); Digital Media Association (DiMA), INCOMPAS, and Internet Association INCOMPAS, CCIA, and DiMA 7/5/22 K. M. Richards Richards 6/6/22 National Association of Broadcasters NAB 7/5/22 New Jersey Broadcasters Association NJBA 7/5/22 Orbital Sidekick, Inc. OSK 7/5/22 O3b Limited; SES Americom, Inc.; Telesat Canada; and WorldVu Satellites Limited d/b/a OneWeb Satellite Coalition 7/5/22 Satellite Industry Association SIA 7/5/22 Spaceflight, Inc. Spaceflight 7/5/22 Reply Comments Name of Commenter Abbreviated Name Date Filed AGM California, Inc.; AGM Nevada, LLC; Alabama Media, LLC; Brayden Madison Broadcasting, L.L.C.; Coxswain Media, LLC; Davis Broadcasting Inc. of Columbus; Equity Communications, LP; Florida Keys Media, LLC; Galaxy Syracuse Licensee LLC; Galaxy Utica Licensee LLC; Golden Isles Broadcasting; Gulf South Radio, Inc.; Heh Communications, LLC; Holladay Broadcasting of Louisiana, LLC; Inland Empire Broadcasting Corp.; Jam Communications, Inc.; Kensington Digital Media, L.L.C.; Kensington Digial Media Of Indiana, L.L.C.; KLAX Licensing, Inc.; KLOS Radio Holdings, LLC; KPWR Radio Holdings, LLC; KRZZ Licensing, Inc.; KWHY-22 Broadcasting, LLC; KXOL Licensing, Inc.; KXOS Radio Holdings, LLC; L.M. Communications, Inc.; L.M. Communications of Kentucky, LLC; L.M. Communications of South Carolina, Inc.; Meridian Media Group, LLC; Meruelo Radio Holdings, LLC; Mississippi Broadcasters, LLC; New South Radio, Inc.; Partnership Radio, L.L.C.; Pathfinder Communications Corporation; QBS Broadcasting, LLC; Sarkes Tarzian, Inc.; SBR Broadcasting Corporation; Serge Martin Enterprises, Inc.; Spanish Broadcasting System Holding Company, Inc.; Talking Stick Communications, L.L.C.; WCMQ Licensing, Inc.; Winton Road Broadcasting Co., LLC; WKLC, Inc.; WLEY Licensing, Inc.; WMEG Licensing, Inc.; WPAT Licensing, Inc.; WPYO Licensing, Inc.; WRMA Licensing, Inc.; WRXD Licensing, Inc.; WSBS Licensing, Inc.; WSKQ Licensing, Inc.; WSUN Licensing, Inc.; WXDJ Licensing, Inc. Joint Broadcasters 7/18/22 American Lighting Association, Association of Equipment Manufacturers, Association of Home Appliance Manufacturers, National Electrical Manufacturers Association, North American Association of Food Equipment Manufacturers, Outdoor Power Equipment Institute, Plumbing Manufacturers International, Power Tool Institute, and Wi-SUN Alliance Joint Manufacturers 7/18/22 Astroscale U.S. Astroscale 7/18/22 CTIA—The Wireless Association® CTIA 7/18/22 Lumen Lumen 7/18/22 Maxar Technologies Inc.; Amazon Web Services, Inc.; Planet Labs PBC; BlackSky Global LLC; Care Weather Technologies, Inc.; Hedron Space Inc.; HawkEye 360, Inc.; Spire Global Inc.; Astro Digital US, Inc.; Umbra Lab, Inc.; and Loft Orbital Solutions Inc. EESS Coalition 7/18/22 National Association of Broadcasters NAB 7/18/22 National Religious Broadcasters NRB 7/13/22 NCTA—The Internet & Television Association NCTA 7/18/22 O3b Limited; SES Americom, Inc.; Telesat Canada; and WorldVu Satellites Limited d/b/a OneWeb Satellite Coalition 7/18/22 Satellite Industry Association SIA 7/18/22 Spaceflight, Inc. Spaceflight 7/18/22 TechFreedom TechFreedom 7/18/22 Turion Space Corp. Turion 7/18/22 Wi-Fi Alliance® Wi-Fi Alliance 7/18/22 WISPA – Broadband Without Boundaries WISPA 7/18/22 Ex Partes Name or abbreviated name of Filer Ex Parte Filing Date Filed NAB Letter from Rick Kaplan, Chief Legal Officer and Executive Vice President, NAB, to Marlene H. Dortch, Secretary, FCC 7/27/22 NAB Letter from Rick Kaplan, Chief Legal Officer and Executive Vice President, NAB, to Marlene H. Dortch, Secretary, FCC 7/28/22 OneWeb, SES, and Telesat Letter from Karis A. Hastings, SatCom Law, LLC, to Marlene H. Dortch, Secretary, FCC 8/5/22 OneWeb, SES, and Telesat Letter from Karis A. Hastings, SatCom Law, LLC, to Marlene H. Dortch, Secretary, FCC 8/8/22 NAB Letter from Rick Kaplan, Chief Legal Officer and Executive Vice President, NAB, to Marlene H. Dortch, Secretary, FCC 8/9/22 Telesat Letter from Elisabeth Neasmith, Director, Telesat, to Marlene H. Dortch, Secretary, FCC 8/12/22 East Arkansas Broadcasters Letter from Bobby Caldwell, CEO, East Arkansas Broadcasters, to Marlene H. Dortch, Secretary, FCC 8/12/22 WNRP (AM) Letter from David E. Hoxeng, Owner, WNRP (AM), to Marlene H. Dortch, Secretary, FCC 8/12/22 State Broadcasters Associations Letter from Lauren Lynch Flick, attorney for the State Broadcasters Associations, to Marlene H. Dortch, Secretary, FCC 8/12/22 Wheeler Broadcasting Letter from Leonard Wheeler, President, Wheeler Broadcasting, to Marlene H. Dortch, Secretary, FCC 8/15/22 South Seas Broadcasting and Delta Radio Letter from Larry Fuss, owner, South Seas Broadcasting and Delta Radio, to Marlene H. Dortch, Secretary, FCC 8/15/22 State Broadcasters Associations Letter from Lauren Lynch Flick, attorney for the State Broadcasters Associations, to Marlene H. Dortch, Secretary, FCC 8/15/22 State Broadcasters Associations Letter from Lauren Lynch Flick, attorney for the State Broadcasters Associations, to Marlene H. Dortch, Secretary, FCC 8/15/22 NAB Letter from Rick Kaplan, Chief Legal Officer and Executive Vice President, NAB, to Marlene H. Dortch, Secretary, FCC 8/15/22 Bryan Broadcasting Letter from Ben Downs, Vice President and General Manager, Bryan Broadcasting, to Marlene H. Dortch, Secretary, FCC 8/15/22 Bustos Media Letter from Amador S. Bustos, President, Bustos Media Holdings, LLC, to Marlene H. Dortch, Secretary, FCC 8/18/22 Kaspar Broadcasting Letter from Russ Kaspar, President, Kaspar Broadcasting Co., Inc. to Marlene H. Dortch, Secretary, FCC 8/18/22 State Broadcasters Associations Letter from Lauren Lynch Flick, attorney for the State Broadcasters Associations, to Marlene H. Dortch, Secretary, FCC 8/19/22 Cromwell Radio Letter from Bayard H. Walters, President, Cromwell Group, Inc., to Jessica Rosenworcel, Chairwoman, FCC 8/22/22 Mountain Top Media Letter from Cindy May Johnson, President, Mountain Top Media, LLC, to Marlene H. Dortch, Secretary, FCC 8/22/22 NAB Letter from Rick Kaplan, Chief Legal Officer and Executive Vice President, NAB, to Marlene H. Dortch, Secretary, FCC 8/31/22 2 Federal Communications Commission FCC 22-68 APPENDIX B Calculation of FY 2022 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 2022 Payment Units Yrs FY 2021 Revenue Estimate Pro-Rated FY 2022 Revenue Require-ment Computed FY 2022 Regulatory Fee Rounded FY 2022 Reg. Fee Expected FY 2022 Revenue PLMRS (Exclusive Use) 750 10 75,000 187,500 25.00 25 187,500 PLMRS (Shared use) 12,500 10 990,000 1,250,000 10.00 10 1,250,000 Microwave 18,000 10 4,750,000 4,500,000 25.00 25 4,500,000 Marine (Ship) 6,900 10 922,500 1,035,000 15.00 15 1,035,000 Aviation (Aircraft) 4,200 10 390,000 420,000 10.00 10 420,000 Marine (Coast) 210 10 16,000 84,000 40.00 40 84,000 Aviation (Ground) 350 10 110,000 70,000 20.00 20 70,000 AM Class A1 62 1 290,745 316,755 5,109 5,110 316,820 AM Class B1 1,443 1 3,610,880 3,930,011 2,724 2,725 3,932,175 AM Class C1 825 1 1,291,125 1,407,030 1,706 1,705 1,406,625 AM Class D1 1,421 1 4,267,835 4,648,721 3,271 3,270 4,646,670 FM Classes A, B1 & C31 3,125 1 8,886,395 9,804,141 3,137 3,135 9,796,875 FM Classes B, C, C0, C1 & C21 3,137 1 11,100,080 12,005,143 3,827 3,825 11,999,025 AM Construction Permits 2 5 1 3,660 3,275 655 655 3,275 FM Construction Permits2 16 1 58,850 18,320 1,145 1,145 18,320 Digital Television5 (including Satellite TV) 3.283 billion population 1 25,416,380 27,674,061 .0084303 .008430 27,673,145 Digital TV Construction Permits2 4 1 20,400 20,800 5,199 5,200 20,800 LPTV/Class A/Translators FM Trans/Boosters 5,466 1 1,649,920 1,799,713 329.3 330 1,803,780 CARS Stations 135 1 233,250 231,341 1,714 1,715 231,525 Cable TV Systems, including IPTV & DBS 66,500,000 1 76,244,000 76,851,478 1.1557 1.16 77,140,000 Interstate Telecommunication Service Providers $27,700,000,000 1 120,400,000 125,327,520 0.004524 0.00452 125,204,000 Toll Free Numbers 34,700,000 1 4,020,000 4,306,310 0.12410 0.12 4,164,000 CMRS Mobile Services (Cellular/Public Mobile) 535,000,000 1 75,600,000 73,140,629 0.1367 0.14 74,900,000 CMRS Messaging Services 1,500,000 1 136,000 120,000 0.0800 0.080 120,000 BRS/3 LMDS 1,225 350 1 1 756,250 206,910 722,750 206,500 590 590 590 590 722,750 206,500 Per Gbps circuit Int’l Bearer Circuits Terrestrial (Common & Non-Common) & Satellite (Common & Non-Common) 12,000 1 468,700 467,047 38.92 39 468,000 Submarine Cable Providers (See chart at bottom of Appendix C)4 64.438 1 8,839,554 8,873,891 137,713 137,715 8,874,010 Earth Stations 2,900 1 1,785,000 1,798,221 620.1 620 1,798,000 Space Stations (Geostationary) 139 1 17,177,685 17,244,609 124,062 124,060 17,244,340 Space Stations (Non-Geostationary, Other) 10 1 3,435,550 3,400,062 340,006 340,005 3,400,050 Space Stations (Non-Geostationary, Less Complex) 6 1 858,865 850,015 141,669 141,670 850,020 Space Stations (Non-Geostationary, Small Satellite) 5 1 0 61,075 12,215 12,215 61,075 ****** Total Estimated Revenue to be Collected 373,920,077 384,066,626 384,549,196 ****** Total Revenue Requirement 374,000,000 381,950,000 381,950,000 Difference (79,923) 2,116,626 2,599,196 Notes on Appendix B 1 The fee amounts listed in the column entitled “Rounded New FY 2022 Regulatory Fee” constitute a weighted average broadcast regulatory fee by class of service. The actual FY 2022 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 FY 2022 Schedule of 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) (Includes Non-Geographic telephone numbers) .14 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) 590 590 AM Radio Construction Permits 655 FM Radio Construction Permits 1,145 AM and FM Broadcast Radio Station Fees See Table Below Digital TV (47 CFR part 73) VHF and UHF Commercial Fee Factor $.008430 See Appendix G for fee amounts due, also available at https://www.fcc.gov/licensing-databases/fees/regulatory-fees Digital TV Construction Permits 5,200 Low Power TV, Class A TV, TV/FM Translators & FM Boosters (47 CFR part 74) 330 CARS (47 CFR part 78) 1,715 Cable Television Systems (per subscriber) (47 CFR part 76), Including IPTV and Direct Broadcast Satellite (DBS) 1.16 Interstate Telecommunication Service Providers (per revenue dollar) .00452 Toll Free (per toll free subscriber) (47 CFR section 52.101 (f) of the rules) .12 Earth Stations (47 CFR part 25) 620 Space Stations (per operational station in geostationary orbit) (47 CFR part 25) also includes DBS Service (per operational station) (47 CFR part 100) 124,060 Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25) (Other) 340,005 Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25) (Less Complex) 141,670 Space Stations (per license/call sign in non-geostationary orbit) (47 CFR part 25) (Small Satellite) 12,215 International Bearer Circuits - Terrestrial/Satellites (per Gbps circuit) $39 Submarine Cable Landing Licenses Fee (per cable system) See Table Below FY 2022 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 $1,050 $755 $655 $720 $1,145 $1,310 25,001 – 75,000 $1,575 $1,135 $985 $1,080 $1,720 $1,965 75,001 – 150,000 $2,365 $1,700 $1,475 $1,620 $2,575 $2,950 150,001 – 500,000 $3,550 $2,550 $2,215 $2,435 $3,870 $4,430 500,001 – 1,200,000 $5,315 $3,820 $3,315 $3,645 $5,795 $6,630 1,200,001 – 3,000,000 $7,980 $5,740 $4,980 $5,470 $8,700 $9,955 3,000,001 – 6,000,000 $11,960 $8,600 $7,460 $8,200 $13,040 $14,920 >6,000,000 $17,945 $12,905 $11,195 $12,305 $19,570 $22,390 FY 2022 International Bearer Circuits - Submarine Cable Systems Submarine Cable Systems (capacity as of December 31, 2021) Fee Ratio FY 2022 Regulatory Fees Less than 50 Gbps .0625 Units $8,610 50 Gbps or greater, but less than 250 Gbps .125 Units $17,215 250 Gbps or greater, but less than 1,500 Gbps .25 Units $34,430 1,500 Gbps or greater, but less than 3,500 Gbps .5 Units $68,860 3,500 Gbps or greater, but less than 6,500 Gbps 1.0 Unit $137,715 6,500 Gbps or greater 2.0 Units $275,430 APPENDIX D Sources of Payment Unit Estimates for FY 2022 In order to calculate individual service fees for FY 2022, we adjusted FY 2021 payment units for each service to more accurately reflect expected FY 2022 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, where 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. As more current data is received after the Notice of Proposed Rulemaking (NPRM) is released, the Commission sometimes adjusts the NPRM fee rates to reflect the new information in the Report and Order. This is intended to make sure that the fee rates in the Report and Order reflect more recent and accurate information. We sought verification for these estimates from multiple sources and, in all cases, we compared FY 2022 estimates with actual FY 2021 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 2022 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 2022 payment units are based on FY 2021 actual payment units, it does not necessarily mean that our FY 2022 projection is exactly the same number as in FY 2021. We have either rounded the FY 2022 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 2021 payment data. CMRS Messaging Services Based on WTB reports, and FY 2021 payment data. AM/FM Radio Stations Based on CDBS data, adjusted for exemptions, and actual FY 2021 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 2021 payment units. LPTV, Translators and Boosters, Class A Television Based on LMS data, adjusted for exemptions, and actual FY 2021 payment units. BRS (formerly MDS/MMDS)LMDS Based on WTB reports and actual FY 2021 payment units. Based on WTB reports and actual FY 2021 payment units. Cable Television Relay Service (CARS) Stations Based on data from Media Bureau’s COALS database and actual FY 2021 payment units. Cable Television System Subscribers, Including IPTV Subscribers Based on publicly available data sources for estimated subscriber counts, trend information from past payment data, and actual FY 2021 payment units. Interstate Telecommunication Service Providers Based on FCC Form 499-A worksheets due in April 2022, and any data assistance provided by the Wireline Competition Bureau. Earth Stations Based on International Bureau licensing data and actual FY 2021 payment units. Space Stations (GSOs & NGSOs) Based on International Bureau data reports and actual FY 2021 payment units. International Bearer Circuits Based on assistance provided by the International Bureau, any data submissions by licensees, adjusted as necessary, and actual FY 2021 payment units. Submarine Cable Licenses Based on International Bureau license information, and actual FY 2021 payment units. Federal Communications Commission FCC 22-68 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 Satellite Charts for FY 2022 Regulatory Fees U.S.-Licensed Space Stations LICENSEE CALL SIGN SATELLITE NAME TYPE DIRECTV Enterprises, LLC S2922 SKY-B1 GSO DIRECTV Enterprises, LLC S2640 DIRECTV T11 GSO DIRECTV Enterprises, LLC S2711 DIRECTV RB-1 GSO DIRECTV Enterprises, LLC S2632 DIRECTV T8 GSO DIRECTV Enterprises, LLC S2669 DIRECTV T9S GSO DIRECTV Enterprises, LLC S2641 DIRECTV T10 GSO DIRECTV Enterprises, LLC S2797 DIRECTV T12 GSO DIRECTV Enterprises, LLC S2930 DIRECTV T15 GSO DIRECTV Enterprises, LLC S2673 DIRECTV T5 GSO DIRECTV Enterprises, LLC S2133 SPACEWAY 2 GSO DIRECTV Enterprises, LLC S3039 DIRECTV T16 GSO DISH Operating L.L.C. S2931 ECHOSTAR 18 GSO DISH Operating L.L.C. S2738 ECHOSTAR 11 GSO DISH Operating L.L.C. S2694 ECHOSTAR 10 GSO DISH Operating L.L.C. S2740 ECHOSTAR 7 GSO DISH Operating L.L.C. S2790 ECHOSTAR 14 GSO EchoStar Satellite Operating Corporation S2811 ECHOSTAR 15 GSO EchoStar Satellite Operating Corporation S2844 ECHOSTAR 16 GSO EchoStar Satellite Services L.L.C. S2179 ECHOSTAR 9 GSO ES 172 LLC S2610 EUTELSAT 174A GSO ES 172 LLC S3021 EUTELSAT 172B GSO Horizon-3 Satellite LLC S2947 HORIZONS-3e GSO Hughes Network Systems, LLC S2663 SPACEWAY 3 GSO Hughes Network Systems, LLC S2834 ECHOSTAR 19 GSO Hughes Network Systems, LLC S2753 ECHOSTAR XVII GSO Intelsat License LLC/ViaSat, Inc. S2160 GALAXY 28 GSO Intelsat License LLC, Debtor-in-Possession S2414 INTELSAT 10-02 GSO Intelsat License LLC, Debtor-in-Possession S2972 INTELSAT 37e GSO Intelsat License LLC, Debtor-in-Possession S2854 NSS-7 GSO Intelsat License LLC, Debtor-in-Possession S2409 INELSAT 905 GSO Intelsat License LLC, Debtor-in-Possession S2405 INTELSAT 901 GSO Intelsat License LLC, Debtor-in-Possession S2408 INTELSAT 904 GSO Intelsat License LLC, Debtor-in-Possession S2804 INTELSAT 25 GSO Intelsat License LLC, Debtor-in-Possession S2959 INTELSAT 35e GSO Intelsat License LLC, Debtor-in-Possession S2237 INTELSAT 11 GSO Intelsat License LLC, Debtor-in-Possession S2785 INTELSAT 14 GSO Intelsat License LLC, Debtor-in-Possession S2380 INTELSAT 9 GSO Intelsat License LLC, Debtor-in-Possession S2831 INTELSAT 23 GSO Intelsat License LLC, Debtor-in-Possession S2915 INTELSAT 34 GSO Intelsat License LLC, Debtor-in-Possession S2863 INTELSAT 21 GSO Intelsat License LLC, Debtor-in-Possession S2750 INTELSAT 16 GSO Intelsat License LLC, Debtor-in-Possession S2715 GALAXY 17 GSO Intelsat License LLC, Debtor-in-Possession S2154 GALAXY 25 GSO Intelsat License LLC, Debtor-in-Possession S2253 GALAXY 11 GSO Intelsat License LLC, Debtor-in-Possession S2381 GALAXY 3C GSO Intelsat License LLC, Debtor-in-Possession S2887 INTELSAT 30 GSO Intelsat License LLC, Debtor-in-Possession S2924 INTELSAT 31 GSO Intelsat License LLC, Debtor-in-Possession S2647 GALAXY 19 GSO Intelsat License LLC, Debtor-in-Possession S2687 GALAXY 16 GSO Intelsat License LLC, Debtor-in-Possession S2733 GALAXY 18 GSO Intelsat License LLC, Debtor-in-Possession S2385 GALAXY 14 GSO Intelsat License LLC, Debtor-in-Possession S2386 GALAXY 13 GSO Intelsat License LLC, Debtor-in-Possession S2422 GALAXY 12 GSO Intelsat License LLC, Debtor-in-Possession S2387 GALAXY 15 GSO Intelsat License LLC, Debtor-in-Possession S2704 INTELSAT 5 GSO Intelsat License LLC, Debtor-in-Possession S2817 INTELSAT 18 GSO Intelsat License LLC, Debtor-in-Possession S2960 JCSAT-RA GSO Intelsat License LLC, Debtor-in-Possession S2850 INTELSAT 19 GSO Intelsat License LLC, Debtor-in-Possession S2368 INTELSAT 1R GSO Intelsat License LLC, Debtor-in-Possession S2988 TELKOM-2 GSO Intelsat License LLC, Debtor-in-Possession S2789 INTELSAT 15 GSO Intelsat License LLC, Debtor-in-Possession S2423 HORIZONS 2 GSO Intelsat License LLC, Debtor-in-Possession S2846 INTELSAT 22 GSO Intelsat License LLC, Debtor-in-Possession S2847 INTELSAT 20 GSO Intelsat License LLC, Debtor-in-Possession S2948 INTELSAT 36 GSO Intelsat License LLC, Debtor-in-Possession S2814 INTELSAT 17 GSO Intelsat License LLC, Debtor-in-Possession S2410 INTELSAT 906 GSO Intelsat License LLC, Debtor-in-Possession S2406 INTELSAT 902 GSO Intelsat License LLC, Debtor-in-Possession S2939 INTELSAT 33e GSO Intelsat License LLC, Debtor-in-Possession S2382 INTELSAT 10 GSO Intelsat License LLC, Debtor-in-Possession S2751 NEW DAWN GSO Intelsat License LLC, Debtor-in-Possession S3023 INTELSAT 39 GSO Leidos, Inc. S2371 LM-RPS2 GSO Ligado Networks Subsidiary, LLC S2358 SKYTERRA-1 GSO Ligado Networks Subsidiary, LLC AMSC-1 MSAT-2 GSO Novavision Group, Inc. S2861 DIRECTV KU-79W GSO Satellite CD Radio LLC S2812 FM-6 GSO SES Americom, Inc. S2415 NSS-10 GSO SES Americom, Inc. S2162 AMC-3 GSO SES Americom, Inc. S2347 AMC-6 GSO SES Americom, Inc. S2826 SES-2 GSO SES Americom, Inc. S2807 SES-1 GSO SES Americom, Inc. S2892 SES-3 GSO SES Americom, Inc. S2180 AMC-15 GSO SES Americom, Inc. S2445 AMC-1 GSO SES Americom, Inc. S2135 AMC-4 GSO SES Americom, Inc. S2713 AMC-18 GSO SES Americom, Inc. S2433 AMC-11 GSO SES Americom, Inc./Alascom, Inc. S2379 AMC-8 GSO Sirius XM Radio Inc. S2710 FM-5 GSO Sirius XM Radio Inc. S3033 XM-7 GSO Sirius XM Radio Inc. S3034 XM-8 GSO Skynet Satellite Corporation S2933 TELSTAR 12V GSO Skynet Satellite Corporation S2357 TELSTAR 11N GSO ViaSat, Inc. S2747 VIASAT-1 GSO XM Radio LLC S2617 XM-3 GSO XM Radio LLC S2616 XM-4 GSO Non-U.S.-Licensed Space Stations – Market Access Through Petition for Declaratory Ruling     SATELLITE SATELLITE LICENSEE CALL SIGN COMMON NAME TYPE ABS Global Ltd. S2987 ABS-3A GSO DBSD Services Ltd S2651 DBSD G1 GSO Empresa Argentina de Soluciones Satelitales S.A. S2956 ARSAT-2 GSO European Telecommunications Satellite Organization S3031 EUTELSAT 133 WEST A GSO Eutelsat S. A. S3056 EUTELSAT 8 WEST B GSO Gamma Acquisition L.L.C. S2633 TerreStar 1 GSO Hispamar Satélites, S.A. S2793 AMAZONAS-2 GSO Hispamar Satélites, S.A. S2886 AMAZONAS-3 GSO Hispasat, S.A. S2969 HISPASAT 30W-6 GSO Inmarsat PLC S2932 Inmarsat-4 F3 GSO Inmarsat PLC S2949 Inmarsat-3 F5 GSO Intelsat License LLC S3058 HISPASAT 143W-1 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. S2828 SES-4 GSO New Skies Satellites B.V. S2950 SES-10 GSO Satelites Mexicanos, S.A. de C.V. S2695 EUTELSAT 113 WEST A GSO Satelites Mexicanos, S.A. de C.V. S2926 EUTELSAT 117 WEST B GSO Satelites Mexicanos, S.A. de C.V. S2938 EUTELSAT 115 WEST B GSO Satelites Mexicanos, S.A. de C.V. S2873 EUTELSAT 117 WEST A GSO SES Satellites (Gibraltar) Ltd. 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 Embratel Tvsat Telecommunicacoes S.A. S2677 STAR ONE C1 GSO Embratel Tvsat Telecommunicacoes S.A. S2678 STAR ONE C2 GSO Embratel Tvsat Telecommunicacoes S.A. S2845 STAR ONE C3 GSO Telesat Brasil Capacidade de Satelites Ltda. S2821 ESTRELA DO SUL 2 GSO Telesat Canada S2674 ANIK F1R GSO Telesat Canada S2703 ANIK F3 GSO Telesat Canada S2646/S2472 ANIK F2 GSO Telesat International Ltd. S2955 TELSTAR 19 VANTAGE GSO Viasat, Inc. S2902 VIASAT-2 GSO Non-U.S.-Licensed Space Stations - Market Access Through Earth Station Licenses ITU Name (if available) Common Name Call Sign GSO/NGSO APSTAR VI APSTAR 6 M292090 GSO AUSSAT B 152E OPTUS D2 M221170 GSO CAN-BSS3 and CAN-BSS ECHOSTAR 23 SM1987/SM2975 GSO Ciel Satellite Group Ciel-2 E050029 GSO Eutelsat 65 West A Eutelsat 65 West A E160081 GSO INMARSAT 4F1 INMARSAT 4F1 KA25 GSO INMARSAT 5F2 INMARSAT 5F2 E120072 GSO INMARSAT 5F3 INMARSAT 5F3 E150028 GSO JCSAT-2B JCSAT-2B M174163 GSO NIMIQ 5 NIMIQ 5 E080107 GSO QUETZSAT-1(MEX) QUETZSAT-1 NUS1101 GSO Superbird C2 Superbird C2 M334100 GSO WILDBLUE-1 WILDBLUE-1 E040213 GSO Yamal 300K Yamal 300K M174162 GSO Non-Geostationary Space Stations (NGSO) U.S.-Licensed NGSO Systems ITU Name (if available) Common Name Call Sign NGSO ORBCOMM License Corp ORBCOMM S2103 Other Iridium Constellation LLC IRIDIUM S2110 Other Space Exploration Holdings, LLC SPACEX Ku/Ka-Band S2983/S3018 Other Swarm Technologies SWARM S3041 Other Planet Labs Flock/Skysats S2912 Less Complex Maxar License WorldView 1,2 & 3, GeoEye-1 S2129/S2348 Less Complex BlackSky Global Global S3032 Less Complex Astro Digital U.S., Inc. LANDMAPPER S3014 Less Complex Hawkeye 360 HE360 S3042 Less Complex Non-U.S.-Licensed NGSO Systems – Market Access Through Petition for Declaratory Ruling ITU Name (if available) Common Name Call Sign NGSO Telesat Canada TELESAT Ku/Ka-Band S2976 Other Kepler Communications, Inc. KEPLER S2981 Other WorldVu Satellites Ltd. ONEWEB S2963 Other Myriota Pty. Ltd MYRIOTA S3047 Other O3b Ltd. O3b S2935 Other NGSO Systems that Are Partly U.S.-Licensed and Partly Non-U.S.-Licensed with Market Access Through Petition for Declaratory Ruling ITU Name (if available) Common Name Call Sign NGSO Globalstar License LLC GLOBALSTAR S2115 Other Spire Global LEMUR & MINAS S2946/S3045 Less Complex NGSO Systems Licensed Under the Streamlined Small Satellite Rules ITU Name (if available) Common Name Call Sign NGSO Capella Space Corp. Capella-2, Capella-3, Capella-4 S3073 Small Satellite Capella Space Corp. Capella-5, Capella-6 S3080 Small Satellite Loft Orbital Solutions Inc. YAM-2 S3052 Small Satellite Loft Orbital Solutions Inc. YAM-3 S3072 Small Satellite R2 Space, Inc. XR-1 S3067 Small Satellite APPENDIX G FY 2022 Full-Service Broadcast Television Stations by Call Sign Service Area Terrain Limited Terrain Limited Facility Id. Call Sign Population Population Fee Amount 3246 KAAH-TV 955,391 879,906 $ 7,418 18285 KAAL 589,502 568,169 $ 4,790 11912 KAAS-TV 220,262 219,922 $ 1,854 56528 KABB 2,474,296 2,456,689 $ 20,710 282 KABC-TV 17,540,791 16,957,292 $ 142,950 1236 KACV-TV 372,627 372,330 $ 3,139 33261 KADN-TV 877,965 877,965 $ 7,401 8263 KAEF-TV 138,085 122,808 $ 1,035 2728 KAET 4,217,217 4,184,386 $ 35,274 2767 KAFT 1,204,376 1,122,928 $ 9,466 62442 KAID 711,035 702,721 $ 5,924 4145 KAII-TV 188,810 165,396 $ 1,394 67494 KAIL 1,947,635 1,914,765 $ 16,141 13988 KAIT 861,149 845,812 $ 7,130 40517 KAJB 383,886 383,195 $ 3,230 65522 KAKE 803,937 799,254 $ 6,738 804 KAKM 380,240 379,105 $ 3,196 148 KAKW-DT 2,615,956 2,531,813 $ 21,343 51598 KALB-TV 943,307 942,043 $ 7,941 51241 KALO 954,557 910,409 $ 7,675 40820 KAMC 391,526 391,502 $ 3,300 8523 KAMR-TV 366,476 366,335 $ 3,088 65301 KAMU-TV 346,892 342,455 $ 2,887 2506 KAPP 319,797 283,944 $ 2,394 3658 KARD 703,234 700,887 $ 5,908 23079 KARE 3,924,944 3,907,483 $ 32,940 33440 KARK-TV 1,212,038 1,196,196 $ 10,084 37005 KARZ-TV 1,113,486 1,095,224 $ 9,233 32311 KASA-TV 1,161,837 1,119,457 $ 9,437 41212 KASN 1,175,627 1,159,721 $ 9,776 7143 KASW 4,174,437 4,160,497 $ 35,073 55049 KASY-TV 1,145,133 1,100,391 $ 9,276 33471 KATC 1,348,897 1,348,897 $ 11,371 13813 KATN 97,466 97,128 $ 819 21649 KATU 3,030,547 2,881,993 $ 24,295 33543 KATV 1,257,777 1,234,933 $ 10,410 50182 KAUT-TV 1,637,333 1,636,330 $ 13,794 21488 KAUU 381,413 380,355 $ 3,206 6864 KAUZ-TV 381,671 379,435 $ 3,199 73101 KAVU-TV 319,618 319,484 $ 2,693 49579 KAWB 186,919 186,845 $ 1,575 49578 KAWE 136,033 133,937 $ 1,129 58684 KAYU-TV 809,464 750,766 $ 6,329 29234 KAZA-TV 14,973,535 13,810,130 $ 116,419 17433 KAZD 6,776,778 6,774,172 $ 57,106 1151 KAZQ 1,097,010 1,084,327 $ 9,141 35811 KAZT-TV 436,925 359,273 $ 3,029 4148 KBAK-TV 1,510,400 1,263,910 $ 10,655 16940 KBCA 479,260 479,219 $ 4,040 53586 KBCB 1,256,193 1,223,883 $ 10,317 69619 KBCW 8,227,562 7,375,199 $ 62,173 22685 KBDI-TV 4,042,177 3,683,394 $ 31,051 56384 KBEH 17,736,497 17,695,306 $ 149,171 65395 KBFD-DT 953,207 834,341 $ 7,033 169030 KBGS-TV 159,269 156,802 $ 1,322 61068 KBHE-TV 140,860 133,082 $ 1,122 48556 KBIM-TV 205,701 205,647 $ 1,734 29108 KBIN-TV 912,921 911,725 $ 7,686 33658 KBJR-TV 275,585 271,298 $ 2,287 83306 KBLN-TV 297,384 134,927 $ 1,137 63768 KBLR 1,964,979 1,915,861 $ 16,151 53324 KBME-TV 123,571 123,485 $ 1,041 10150 KBMT 743,009 742,369 $ 6,258 22121 KBMY 119,993 119,908 $ 1,011 49760 KBOI-TV 715,191 708,374 $ 5,972 55370 KBRR 149,869 149,868 $ 1,263 66414 KBSD-DT 155,012 154,891 $ 1,306 66415 KBSH-DT 102,781 100,433 $ 847 19593 KBSI 756,501 754,722 $ 6,362 66416 KBSL-DT 49,814 48,483 $ 409 4939 KBSV 1,352,166 1,262,708 $ 10,645 62469 KBTC-TV 3,697,981 3,621,965 $ 30,533 61214 KBTV-TV 734,008 734,008 $ 6,188 6669 KBTX-TV 4,404,648 4,401,048 $ 37,101 35909 KBVO 1,498,015 1,312,360 $ 11,063 58618 KBVU 135,249 120,827 $ 1,019 6823 KBYU-TV 2,389,548 2,209,060 $ 18,622 33756 KBZK 123,523 109,131 $ 920 21422 KCAL-TV 17,499,483 16,889,157 $ 142,376 11265 KCAU-TV 714,315 706,224 $ 5,953 14867 KCBA 3,088,394 2,369,803 $ 19,977 27507 KCBD 414,804 414,091 $ 3,491 9628 KCBS-TV 17,853,152 16,656,778 $ 140,417 49750 KCBY-TV 89,156 73,211 $ 617 33710 KCCI 1,109,952 1,102,514 $ 9,294 9640 KCCW-TV 284,280 276,935 $ 2,335 63158 KCDO-TV 2,798,103 2,650,225 $ 22,341 62424 KCDT 698,389 657,101 $ 5,539 83913 KCEB 417,491 417,156 $ 3,517 57219 KCEC 3,831,192 3,613,287 $ 30,460 10245 KCEN-TV 1,795,767 1,757,018 $ 14,812 13058 KCET 16,875,019 15,402,588 $ 129,844 18079 KCFW-TV 177,697 140,192 $ 1,182 132606 KCGE-DT 123,930 123,930 $ 1,045 60793 KCHF 1,118,671 1,085,205 $ 9,148 33722 KCIT 382,477 381,818 $ 3,219 62468 KCKA 953,680 804,362 $ 6,781 41969 KCLO-TV 138,413 132,157 $ 1,114 47903 KCNC-TV 3,794,400 3,541,089 $ 29,851 71586 KCNS 8,270,858 7,381,656 $ 62,227 33742 KCOP-TV 17,386,133 16,647,708 $ 140,340 19117 KCOS 1,014,396 1,014,205 $ 8,550 63165 KCOY-TV 664,655 459,468 $ 3,873 33894 KCPQ 4,439,875 4,312,133 $ 36,351 53843 KCPT 2,507,879 2,506,224 $ 21,127 33875 KCRA-TV 10,612,483 6,500,774 $ 54,802 9719 KCRG-TV 1,136,762 1,107,130 $ 9,333 60728 KCSD-TV 273,553 273,447 $ 2,305 59494 KCSG 174,814 164,765 $ 1,389 33749 KCTS-TV 4,177,824 4,115,603 $ 34,695 41230 KCTV 2,547,456 2,545,645 $ 21,460 58605 KCVU 684,900 674,585 $ 5,687 10036 KCWC-DT 44,216 39,439 $ 332 64444 KCWE 2,459,924 2,458,302 $ 20,723 51502 KCWI-TV 1,043,811 1,042,642 $ 8,789 42008 KCWO-TV 50,707 50,685 $ 427 166511 KCWV 207,398 207,370 $ 1,748 24316 KCWX 3,961,268 3,954,787 $ 33,339 68713 KCWY-DT 80,904 80,479 $ 678 22201 KDAF 6,648,507 6,645,226 $ 56,019 33764 KDBC-TV 1,015,564 1,015,162 $ 8,558 79258 KDCK 43,088 43,067 $ 363 166332 KDCU-DT 753,204 753,190 $ 6,349 38375 KDEN-TV 3,376,799 3,351,182 $ 28,250 17037 KDFI 6,684,439 6,682,487 $ 56,333 33770 KDFW 6,659,312 6,657,023 $ 56,119 29102 KDIN-TV 1,088,376 1,083,845 $ 9,137 25454 KDKA-TV 3,611,796 3,450,690 $ 29,089 60740 KDKF 71,413 64,567 $ 544 4691 KDLH 263,422 260,394 $ 2,195 41975 KDLO-TV 208,354 208,118 $ 1,754 55379 KDLT-TV 639,284 628,281 $ 5,296 55375 KDLV-TV 96,873 96,620 $ 815 25221 KDMD 375,328 373,408 $ 3,148 78915 KDMI 1,141,990 1,140,939 $ 9,618 56524 KDNL-TV 2,987,219 2,982,311 $ 25,141 24518 KDOC-TV 17,503,793 16,701,233 $ 140,791 1005 KDOR-TV 1,112,060 1,108,556 $ 9,345 60736 KDRV 519,706 440,002 $ 3,709 61064 KDSD-TV 64,314 59,635 $ 503 53329 KDSE 42,896 41,432 $ 349 56527 KDSM-TV 1,096,220 1,095,478 $ 9,235 49326 KDTN 6,602,327 6,600,186 $ 55,640 83491 KDTP 26,564 24,469 $ 206 33778 KDTV-DT 7,959,349 7,129,638 $ 60,103 67910 KDTX-TV 6,680,738 6,679,424 $ 56,308 126 KDVR 3,644,912 3,521,884 $ 29,689 18084 KECI-TV 211,745 193,803 $ 1,634 51208 KECY-TV 399,372 394,379 $ 3,325 58408 KEDT 513,683 513,683 $ 4,330 55435 KEET 177,313 159,960 $ 1,348 37103 KEKE 97,959 94,560 $ 797 41983 KELO-TV 705,364 646,126 $ 5,447 34440 KEMO-TV 8,270,858 7,381,656 $ 62,227 2777 KEMV 619,889 559,135 $ 4,714 26304 KENS 2,544,094 2,529,382 $ 21,323 63845 KENV-DT 47,220 40,677 $ 343 18338 KENW 87,017 87,017 $ 734 50591 KEPB-TV 576,964 523,655 $ 4,414 56029 KEPR-TV 453,259 433,260 $ 3,652 49324 KERA-TV 6,681,083 6,677,852 $ 56,294 40878 KERO-TV 1,285,357 1,164,979 $ 9,821 61067 KESD-TV 166,018 159,195 $ 1,342 25577 KESQ-TV 1,334,172 572,057 $ 4,822 50205 KETA-TV 1,702,441 1,688,227 $ 14,232 62182 KETC 2,913,924 2,911,313 $ 24,542 37101 KETD 3,323,570 3,285,231 $ 27,694 2768 KETG 426,883 409,511 $ 3,452 12895 KETH-TV 6,088,821 6,088,677 $ 51,328 55643 KETK-TV 1,031,567 1,030,122 $ 8,684 2770 KETS 1,185,111 1,166,796 $ 9,836 53903 KETV 1,355,714 1,350,740 $ 11,387 92872 KETZ 526,890 523,877 $ 4,416 68853 KEYC-TV 544,900 531,079 $ 4,477 33691 KEYE-TV 2,732,257 2,652,529 $ 22,361 60637 KEYT-TV 1,419,564 1,239,577 $ 10,450 83715 KEYU 339,348 339,302 $ 2,860 34406 KEZI 1,113,171 1,065,880 $ 8,985 34412 KFBB-TV 93,519 91,964 $ 775 125 KFCT 795,114 788,747 $ 6,649 51466 KFDA-TV 385,064 383,977 $ 3,237 22589 KFDM 732,665 732,588 $ 6,176 65370 KFDX-TV 381,703 381,318 $ 3,215 49264 KFFV 4,020,926 3,987,153 $ 33,612 12729 KFFX-TV 409,952 403,692 $ 3,403 83992 KFJX 515,708 505,647 $ 4,263 42122 KFMB-TV 3,947,735 3,699,981 $ 31,191 53321 KFME 393,045 392,472 $ 3,309 74256 KFNB 80,382 79,842 $ 673 21613 KFNE 54,988 54,420 $ 459 21612 KFNR 10,988 10,965 $ 92 66222 KFOR-TV 1,616,459 1,615,614 $ 13,620 33716 KFOX-TV 1,023,999 1,018,549 $ 8,586 41517 KFPH-DT 347,579 282,838 $ 2,384 81509 KFPX-TV 963,969 963,846 $ 8,125 31597 KFQX 186,473 163,637 $ 1,379 59013 KFRE-TV 1,721,275 1,705,484 $ 14,377 51429 KFSF-DT 7,348,828 6,528,430 $ 55,035 66469 KFSM-TV 906,728 884,919 $ 7,460 8620 KFSN-TV 1,836,607 1,819,585 $ 15,339 29560 KFTA-TV 818,859 809,173 $ 6,821 83714 KFTC 61,990 61,953 $ 522 60537 KFTH-DT 6,080,688 6,080,373 $ 51,258 60549 KFTR-DT 17,560,679 16,305,726 $ 137,457 61335 KFTS 74,936 65,126 $ 549 81441 KFTU-DT 113,876 109,731 $ 925 34439 KFTV-DT 1,794,984 1,779,917 $ 15,005 664 KFVE 82,902 73,553 $ 620 592 KFVS-TV 895,871 873,777 $ 7,366 29015 KFWD 6,666,428 6,660,565 $ 56,149 35336 KFXA 875,538 874,070 $ 7,368 17625 KFXB-TV 373,280 368,466 $ 3,106 70917 KFXK-TV 934,043 931,791 $ 7,855 84453 KFXL-TV 862,531 854,678 $ 7,205 56079 KFXV 1,225,732 1,225,732 $ 10,333 41427 KFYR-TV 130,881 128,301 $ 1,082 25685 KGAN 1,083,213 1,057,597 $ 8,916 34457 KGBT-TV 1,239,001 1,238,870 $ 10,444 7841 KGCW 949,575 945,476 $ 7,970 24485 KGEB 1,186,225 1,150,201 $ 9,696 34459 KGET-TV 917,927 874,332 $ 7,371 53320 KGFE 114,564 114,564 $ 966 7894 KGIN 230,535 228,338 $ 1,925 83945 KGLA-DT 1,645,641 1,645,641 $ 13,873 34445 KGMB 953,398 851,088 $ 7,175 58608 KGMC 1,936,675 1,914,168 $ 16,136 36914 KGMD-TV 94,323 93,879 $ 791 36920 KGMV 193,564 162,230 $ 1,368 10061 KGNS-TV 267,236 259,548 $ 2,188 34470 KGO-TV 8,637,074 7,929,294 $ 66,844 56034 KGPE 1,699,131 1,682,082 $ 14,180 81694 KGPX-TV 685,626 624,955 $ 5,268 25511 KGTF 161,885 160,568 $ 1,354 40876 KGTV 3,960,667 3,682,219 $ 31,041 36918 KGUN-TV 1,398,527 1,212,484 $ 10,221 34874 KGW 3,026,617 2,878,510 $ 24,266 63177 KGWC-TV 80,475 80,009 $ 674 63162 KGWL-TV 38,125 38,028 $ 321 63166 KGWN-TV 469,467 440,388 $ 3,712 63170 KGWR-TV 51,315 50,957 $ 430 4146 KHAW-TV 95,204 94,851 $ 800 60353 KHBS 631,770 608,052 $ 5,126 27300 KHCE-TV 2,353,883 2,348,391 $ 19,797 26431 KHET 959,060 944,568 $ 7,963 21160 KHGI-TV 233,973 229,173 $ 1,932 36917 KHII-TV 953,895 851,585 $ 7,179 29085 KHIN 1,041,244 1,039,383 $ 8,762 17688 KHME 181,345 179,706 $ 1,515 47670 KHMT 175,601 170,957 $ 1,441 47987 KHNE-TV 203,931 202,944 $ 1,711 34867 KHNL 953,398 851,088 $ 7,175 60354 KHOG-TV 765,360 702,984 $ 5,926 4144 KHON-TV 953,207 886,431 $ 7,473 34529 KHOU 6,083,336 6,081,785 $ 51,269 4690 KHQA-TV 318,469 316,134 $ 2,665 34537 KHQ-TV 822,371 774,821 $ 6,532 30601 KHRR 1,227,847 1,166,890 $ 9,837 34348 KHSD-TV 188,735 185,202 $ 1,561 24508 KHSL-TV 625,904 608,850 $ 5,133 69677 KHSV 2,059,794 2,020,045 $ 17,029 64544 KHVO 94,226 93,657 $ 790 23394 KIAH 6,099,694 6,099,297 $ 51,417 34564 KICU-TV 8,233,041 7,174,316 $ 60,479 56028 KIDK 305,509 302,535 $ 2,550 58560 KIDY 116,614 116,596 $ 983 53382 KIEM-TV 174,390 160,801 $ 1,356 66258 KIFI-TV 324,422 320,118 $ 2,699 16950 KIFR 2,180,045 2,160,460 $ 18,213 10188 KIII 569,864 566,796 $ 4,778 29095 KIIN 1,365,215 1,335,707 $ 11,260 34527 KIKU 953,896 850,963 $ 7,174 63865 KILM 17,256,205 15,804,489 $ 133,232 56033 KIMA-TV 308,604 260,593 $ 2,197 66402 KIMT 654,083 643,384 $ 5,424 67089 KINC 2,002,066 1,920,903 $ 16,193 34847 KING-TV 4,074,288 4,036,926 $ 34,031 51708 KINT-TV 1,015,582 1,015,274 $ 8,559 26249 KION-TV 2,400,317 855,808 $ 7,214 62427 KIPT 171,405 170,455 $ 1,437 66781 KIRO-TV 4,058,101 4,030,968 $ 33,981 62430 KISU-TV 311,827 307,651 $ 2,593 12896 KITU-TV 712,362 712,362 $ 6,005 64548 KITV 953,207 839,906 $ 7,080 59255 KIVI-TV 710,819 702,619 $ 5,923 47285 KIXE-TV 467,518 428,118 $ 3,609 13792 KJJC-TV 82,749 81,865 $ 690 14000 KJLA 17,929,100 16,794,896 $ 141,581 20015 KJNP-TV 98,403 98,097 $ 827 53315 KJRE 16,187 16,170 $ 136 59439 KJRH-TV 1,416,108 1,397,311 $ 11,779 55364 KJRR 45,515 44,098 $ 372 7675 KJTL 379,594 379,263 $ 3,197 55031 KJTV-TV 406,283 406,260 $ 3,425 13814 KJUD 31,229 30,106 $ 254 36607 KJZZ-TV 2,388,965 2,209,183 $ 18,623 83180 KKAI 953,400 919,742 $ 7,753 58267 KKAP 957,786 923,172 $ 7,782 24766 KKCO 206,018 172,628 $ 1,455 35097 KKJB 629,939 624,784 $ 5,267 22644 KKPX-TV 7,588,288 6,758,490 $ 56,974 35037 KKTV 2,892,126 2,478,864 $ 20,897 35042 KLAS-TV 2,094,297 1,940,030 $ 16,354 52907 KLAX-TV 367,212 366,839 $ 3,092 3660 KLBK-TV 387,783 387,743 $ 3,269 65523 KLBY 31,102 31,096 $ 262 38430 KLCS 16,875,019 15,402,588 $ 129,844 77719 KLCW-TV 381,889 381,816 $ 3,219 51479 KLDO-TV 250,832 250,832 $ 2,115 37105 KLEI 175,045 138,087 $ 1,164 56032 KLEW-TV 164,908 148,256 $ 1,250 35059 KLFY-TV 1,355,890 1,355,409 $ 11,426 54011 KLJB 1,027,104 1,012,309 $ 8,534 11264 KLKN 1,161,979 1,122,111 $ 9,459 52593 KLML 270,089 218,544 $ 1,842 47975 KLNE-TV 123,324 123,246 $ 1,039 38590 KLPA-TV 414,699 414,447 $ 3,494 38588 KLPB-TV 749,053 749,053 $ 6,315 749 KLRN 2,374,472 2,353,440 $ 19,839 11951 KLRT-TV 1,171,678 1,152,541 $ 9,716 8564 KLRU 2,614,658 2,575,518 $ 21,712 8322 KLSR-TV 564,415 508,157 $ 4,284 31114 KLST 199,067 169,551 $ 1,429 24436 KLTJ 6,034,131 6,033,867 $ 50,865 38587 KLTL-TV 423,574 423,574 $ 3,571 38589 KLTM-TV 694,280 688,915 $ 5,808 38591 KLTS-TV 947,141 944,257 $ 7,960 68540 KLTV 1,069,690 1,051,361 $ 8,863 12913 KLUJ-TV 1,195,751 1,195,751 $ 10,080 57220 KLUZ-TV 1,079,718 1,019,302 $ 8,593 11683 KLVX 2,044,150 1,936,083 $ 16,321 82476 KLWB 1,065,748 1,065,748 $ 8,984 40250 KLWY 541,043 538,231 $ 4,537 64551 KMAU 213,060 188,953 $ 1,593 51499 KMAX-TV 10,767,605 7,132,240 $ 60,125 65686 KMBC-TV 2,506,035 2,504,622 $ 21,114 35183 KMCB 69,357 66,203 $ 558 41237 KMCC 2,064,592 2,010,262 $ 16,947 42636 KMCI-TV 2,429,392 2,428,626 $ 20,473 38584 KMCT-TV 267,004 266,880 $ 2,250 22127 KMCY 71,797 71,793 $ 605 162016 KMDE 35,409 35,401 $ 298 26428 KMEB 221,810 203,470 $ 1,715 39665 KMEG 708,748 704,130 $ 5,936 35123 KMEX-DT 17,628,354 16,318,720 $ 137,567 40875 KMGH-TV 3,815,224 3,574,344 $ 30,132 35131 KMID 383,449 383,439 $ 3,232 16749 KMIR-TV 2,760,914 730,764 $ 6,160 63164 KMIZ 532,025 530,008 $ 4,468 53541 KMLM-DT 293,290 293,290 $ 2,472 52046 KMLU 711,951 708,107 $ 5,969 47981 KMNE-TV 47,232 44,189 $ 373 24753 KMOH-TV 199,885 184,283 $ 1,554 4326 KMOS-TV 804,745 803,129 $ 6,770 41425 KMOT 81,517 79,504 $ 670 70034 KMOV 3,035,077 3,029,405 $ 25,538 51488 KMPH-TV 1,725,397 1,697,871 $ 14,313 73701 KMPX 6,678,829 6,674,706 $ 56,268 44052 KMSB 1,321,614 1,039,442 $ 8,762 68883 KMSP-TV 3,832,040 3,805,141 $ 32,077 12525 KMSS-TV 1,068,120 1,066,388 $ 8,990 43095 KMTP-TV 5,252,062 4,457,617 $ 37,578 35189 KMTR 589,948 520,666 $ 4,389 35190 KMTV-TV 1,346,549 1,344,796 $ 11,337 77063 KMTW 761,521 761,516 $ 6,420 35200 KMVT 184,647 176,351 $ 1,487 32958 KMVU-DT 308,150 231,506 $ 1,952 86534 KMYA-DT 200,764 200,719 $ 1,692 51518 KMYS 2,273,888 2,267,913 $ 19,119 54420 KMYT-TV 1,314,197 1,302,378 $ 10,979 35822 KMYU 133,563 130,198 $ 1,098 993 KNAT-TV 1,157,630 1,124,619 $ 9,481 24749 KNAZ-TV 332,321 227,658 $ 1,919 47906 KNBC 17,859,647 16,555,232 $ 139,561 81464 KNBN 145,493 136,995 $ 1,155 9754 KNCT 1,751,838 1,726,148 $ 14,551 82611 KNDB 118,154 118,122 $ 996 82615 KNDM 72,216 72,209 $ 609 12395 KNDO 314,875 270,892 $ 2,284 12427 KNDU 475,612 462,556 $ 3,899 17683 KNEP 101,389 95,890 $ 808 48003 KNHL 277,777 277,308 $ 2,338 125710 KNIC-DT 2,398,296 2,383,294 $ 20,091 59363 KNIN-TV 708,289 703,838 $ 5,933 48525 KNLC 2,981,508 2,978,979 $ 25,113 48521 KNLJ 655,000 642,705 $ 5,418 84215 KNMD-TV 1,135,642 1,108,358 $ 9,343 55528 KNME-TV 1,148,741 1,105,095 $ 9,316 47707 KNMT 2,887,142 2,794,995 $ 23,562 48975 KNOE-TV 733,097 729,703 $ 6,151 49273 KNOP-TV 87,904 85,423 $ 720 10228 KNPB 604,614 462,732 $ 3,901 55362 KNRR 25,957 25,931 $ 219 35277 KNSD 3,861,660 3,618,321 $ 30,502 19191 KNSN-TV 611,981 459,485 $ 3,873 23302 KNSO 1,824,786 1,803,796 $ 15,206 35280 KNTV 8,525,818 8,027,505 $ 67,672 144 KNVA 2,550,225 2,529,184 $ 21,321 33745 KNVN 495,902 470,252 $ 3,964 69692 KNVO 1,247,014 1,247,014 $ 10,512 29557 KNWA-TV 822,906 804,682 $ 6,783 59440 KNXV-TV 4,183,943 4,173,022 $ 35,179 59014 KOAA-TV 1,608,528 1,203,731 $ 10,147 50588 KOAB-TV 207,070 203,371 $ 1,714 50590 KOAC-TV 1,957,282 1,543,401 $ 13,011 58552 KOAM-TV 595,307 584,921 $ 4,931 53928 KOAT-TV 1,132,372 1,105,116 $ 9,316 35313 KOB 1,152,841 1,113,162 $ 9,384 35321 KOBF 201,911 166,177 $ 1,401 8260 KOBI 562,463 519,063 $ 4,376 62272 KOBR 211,709 211,551 $ 1,783 50170 KOCB 1,629,783 1,629,152 $ 13,734 4328 KOCE-TV 17,446,133 16,461,581 $ 138,771 84225 KOCM 1,434,325 1,433,605 $ 12,085 12508 KOCO-TV 1,716,569 1,708,085 $ 14,399 83181 KOCW 83,807 83,789 $ 706 18283 KODE-TV 740,156 731,512 $ 6,167 66195 KOED-TV 1,497,297 1,459,833 $ 12,306 50198 KOET 658,606 637,640 $ 5,375 51189 KOFY-TV 5,252,062 4,457,617 $ 37,578 34859 KOGG 190,829 161,310 $ 1,360 166534 KOHD 201,310 197,662 $ 1,666 35380 KOIN 3,028,482 2,881,460 $ 24,291 35388 KOKH-TV 1,627,116 1,625,246 $ 13,701 11910 KOKI-TV 1,366,220 1,352,227 $ 11,399 48663 KOLD-TV 1,216,228 887,754 $ 7,484 7890 KOLN 1,225,400 1,190,178 $ 10,033 63331 KOLO-TV 959,178 826,985 $ 6,971 28496 KOLR 1,076,144 1,038,613 $ 8,756 21656 KOMO-TV 4,132,260 4,087,435 $ 34,457 65583 KOMU-TV 551,658 542,544 $ 4,574 35396 KONG 4,006,008 3,985,271 $ 33,596 60675 KOOD 113,416 113,285 $ 955 50589 KOPB-TV 3,059,231 2,875,815 $ 24,243 2566 KOPX-TV 1,501,110 1,500,883 $ 12,652 64877 KORO 560,983 560,983 $ 4,729 6865 KOSA-TV 340,978 338,070 $ 2,850 34347 KOTA-TV 174,876 152,861 $ 1,289 8284 KOTI 298,175 97,132 $ 819 35434 KOTV-DT 1,417,753 1,403,838 $ 11,834 56550 KOVR 10,784,477 7,162,989 $ 60,384 51101 KOZJ 429,982 427,991 $ 3,608 51102 KOZK 839,841 834,308 $ 7,033 3659 KOZL-TV 992,495 963,281 $ 8,120 35455 KPAX-TV 206,895 193,201 $ 1,629 67868 KPAZ-TV 4,190,080 4,176,323 $ 35,206 6124 KPBS 3,584,237 3,463,189 $ 29,195 50044 KPBT-TV 340,080 340,080 $ 2,867 77452 KPCB-DT 30,861 30,835 $ 260 35460 KPDX 2,970,703 2,848,423 $ 24,012 12524 KPEJ-TV 368,212 368,208 $ 3,104 41223 KPHO-TV 4,195,073 4,175,139 $ 35,196 61551 KPIC 156,687 105,807 $ 892 86205 KPIF 265,080 258,174 $ 2,176 25452 KPIX-TV 8,226,463 7,360,625 $ 62,050 58912 KPJK 7,884,411 6,955,179 $ 58,632 166510 KPJR-TV 3,402,088 3,372,831 $ 28,433 13994 KPLC 1,406,085 1,403,853 $ 11,834 41964 KPLO-TV 55,827 52,765 $ 445 35417 KPLR-TV 2,991,598 2,988,106 $ 25,190 12144 KPMR 1,731,370 1,473,251 $ 12,420 47973 KPNE-TV 92,675 89,021 $ 750 35486 KPNX 4,180,982 4,176,442 $ 35,207 77512 KPNZ 2,394,311 2,208,707 $ 18,619 73998 KPOB-TV 144,525 143,656 $ 1,211 26655 KPPX-TV 4,186,998 4,171,450 $ 35,165 53117 KPRC-TV 6,099,422 6,099,076 $ 51,415 48660 KPRY-TV 42,521 42,426 $ 358 61071 KPSD-TV 19,886 18,799 $ 158 53544 KPTB-DT 322,780 320,646 $ 2,703 81445 KPTF-DT 84,512 84,512 $ 712 77451 KPTH 660,556 655,373 $ 5,525 51491 KPTM 1,414,998 1,414,014 $ 11,920 33345 KPTS 832,000 827,866 $ 6,979 50633 KPTV 2,998,460 2,847,263 $ 24,002 82575 KPTW 80,374 80,012 $ 675 1270 KPVI-DT 271,379 264,204 $ 2,227 58835 KPXB-TV 6,062,458 6,062,238 $ 51,105 68695 KPXC-TV 3,362,518 3,341,951 $ 28,173 68834 KPXD-TV 6,555,157 6,553,373 $ 55,245 33337 KPXE-TV 2,437,178 2,436,024 $ 20,536 5801 KPXG-TV 3,026,219 2,882,598 $ 24,300 81507 KPXJ 1,138,632 1,135,626 $ 9,573 61173 KPXL-TV 2,257,007 2,243,520 $ 18,913 35907 KPXM-TV 3,507,312 3,506,503 $ 29,560 58978 KPXN-TV 17,256,205 15,804,489 $ 133,232 77483 KPXO-TV 953,329 913,341 $ 7,699 21156 KPXR-TV 828,915 821,250 $ 6,923 10242 KQCA 10,077,891 6,276,197 $ 52,908 41430 KQCD-TV 35,623 33,415 $ 282 18287 KQCK 3,220,160 3,162,711 $ 26,662 78322 KQCW-DT 1,128,198 1,123,324 $ 9,470 35525 KQDS-TV 304,935 301,439 $ 2,541 35500 KQED 8,195,398 7,283,828 $ 61,403 35663 KQEH 8,195,398 7,283,828 $ 61,403 8214 KQET 2,981,040 2,076,157 $ 17,502 5471 KQIN 596,371 596,277 $ 5,027 17686 KQME 188,783 184,719 $ 1,557 61063 KQSD-TV 32,526 31,328 $ 264 8378 KQSL 196,316 139,439 $ 1,175 20427 KQTV 1,494,987 1,401,160 $ 11,812 78921 KQUP 697,016 551,824 $ 4,652 306 KRBC-TV 229,395 229,277 $ 1,933 166319 KRBK 983,888 966,187 $ 8,145 22161 KRCA 17,540,791 16,957,292 $ 142,950 57945 KRCB 8,783,441 8,503,802 $ 71,687 41110 KRCG 684,989 662,418 $ 5,584 8291 KRCR-TV 423,000 402,594 $ 3,394 10192 KRCW-TV 2,966,912 2,842,523 $ 23,962 49134 KRDK-TV 349,941 349,929 $ 2,950 52579 KRDO-TV 2,622,603 2,272,383 $ 19,156 70578 KREG-TV 149,306 95,141 $ 802 34868 KREM 817,619 752,113 $ 6,340 51493 KREN-TV 810,039 681,212 $ 5,743 70596 KREX-TV 145,700 145,606 $ 1,227 70579 KREY-TV 74,963 65,700 $ 554 48589 KREZ-TV 148,079 105,121 $ 886 43328 KRGV-TV 1,247,057 1,247,029 $ 10,512 82698 KRII 133,840 132,912 $ 1,120 29114 KRIN 949,313 923,735 $ 7,787 25559 KRIS-TV 565,052 563,805 $ 4,753 22204 KRIV 6,078,936 6,078,846 $ 51,245 14040 KRMA-TV 3,722,512 3,564,949 $ 30,053 14042 KRMJ 174,094 159,511 $ 1,345 20476 KRMT 2,956,144 2,864,236 $ 24,146 84224 KRMU 85,274 72,499 $ 611 20373 KRMZ 36,293 33,620 $ 283 47971 KRNE-TV 47,473 38,273 $ 323 60307 KRNV-DT 955,490 792,543 $ 6,681 65526 KRON-TV 8,573,167 8,028,256 $ 67,678 53539 KRPV-DT 65,943 65,943 $ 556 48575 KRQE 1,135,461 1,105,093 $ 9,316 57431 KRSU-TV 1,000,289 998,310 $ 8,416 82613 KRTN-TV 84,231 68,550 $ 578 35567 KRTV 92,645 90,849 $ 766 84157 KRWB-TV 111,538 110,979 $ 936 35585 KRWF 85,596 85,596 $ 722 55516 KRWG-TV 894,492 661,703 $ 5,578 48360 KRXI-TV 725,391 548,865 $ 4,627 307 KSAN-TV 135,063 135,051 $ 1,138 11911 KSAS-TV 752,513 752,504 $ 6,344 53118 KSAT-TV 2,539,658 2,502,246 $ 21,094 35584 KSAX 365,209 365,209 $ 3,079 35587 KSAZ-TV 4,203,126 4,178,448 $ 35,224 38214 KSBI 1,577,231 1,575,865 $ 13,285 19653 KSBW 5,083,461 4,429,165 $ 37,338 19654 KSBY 535,029 495,562 $ 4,178 82910 KSCC 517,740 517,740 $ 4,365 10202 KSCE 1,015,148 1,010,581 $ 8,519 35608 KSCI 17,446,133 16,461,581 $ 138,771 72348 KSCW-DT 915,691 910,511 $ 7,676 46981 KSDK 2,986,776 2,979,047 $ 25,113 35594 KSEE 1,761,193 1,746,282 $ 14,721 48658 KSFY-TV 670,536 607,844 $ 5,124 17680 KSGW-TV 62,178 57,629 $ 486 59444 KSHB-TV 2,432,205 2,431,273 $ 20,496 73706 KSHV-TV 943,947 942,978 $ 7,949 29096 KSIN-TV 340,143 338,811 $ 2,856 34846 KSIX-TV 74,884 74,884 $ 631 35606 KSKN 731,818 643,590 $ 5,425 70482 KSLA 1,017,556 1,016,667 $ 8,571 6359 KSL-TV 2,390,742 2,206,920 $ 18,604 71558 KSMN 320,813 320,808 $ 2,704 33336 KSMO-TV 2,401,201 2,398,686 $ 20,221 28510 KSMQ-TV 524,391 507,983 $ 4,282 35611 KSMS-TV 1,589,263 882,948 $ 7,443 21161 KSNB-TV 658,560 656,650 $ 5,536 72359 KSNC 174,135 173,744 $ 1,465 67766 KSNF 621,919 617,868 $ 5,209 72361 KSNG 145,058 144,822 $ 1,221 72362 KSNK 48,715 45,414 $ 383 67335 KSNT 622,818 594,604 $ 5,013 10179 KSNV 1,967,781 1,919,296 $ 16,180 72358 KSNW 791,403 791,127 $ 6,669 61956 KSPS-TV 819,101 769,852 $ 6,490 52953 KSPX-TV 7,078,228 5,275,946 $ 44,476 166546 KSQA 382,328 374,290 $ 3,155 53313 KSRE 75,181 75,181 $ 634 35843 KSTC-TV 3,843,788 3,835,674 $ 32,335 63182 KSTF 51,317 51,122 $ 431 28010 KSTP-TV 3,788,898 3,782,053 $ 31,883 60534 KSTR-DT 6,632,577 6,629,296 $ 55,885 64987 KSTS 8,363,473 7,264,852 $ 61,243 22215 KSTU 2,384,996 2,201,716 $ 18,560 23428 KSTW 4,265,956 4,186,266 $ 35,290 5243 KSVI 175,390 173,667 $ 1,464 58827 KSWB-TV 3,677,190 3,488,655 $ 29,409 60683 KSWK 79,012 78,784 $ 664 35645 KSWO-TV 483,132 458,057 $ 3,861 61350 KSYS 519,209 443,204 $ 3,736 59988 KTAB-TV 274,707 274,536 $ 2,314 999 KTAJ-TV 2,343,843 2,343,227 $ 19,753 35648 KTAL-TV 1,094,332 1,092,958 $ 9,214 12930 KTAS 471,882 464,149 $ 3,913 81458 KTAZ 4,182,503 4,160,481 $ 35,073 35649 KTBC 3,242,215 2,956,614 $ 24,924 67884 KTBN-TV 17,795,677 16,510,302 $ 139,182 67999 KTBO-TV 1,585,283 1,583,664 $ 13,350 35652 KTBS-TV 1,163,228 1,159,665 $ 9,776 28324 KTBU 6,035,927 6,035,725 $ 50,881 67950 KTBW-TV 4,202,104 4,108,031 $ 34,631 35655 KTBY 348,080 346,562 $ 2,922 68594 KTCA-TV 3,693,877 3,684,081 $ 31,057 68597 KTCI-TV 3,606,606 3,597,183 $ 30,324 35187 KTCW 103,341 89,207 $ 752 36916 KTDO 1,015,336 1,010,771 $ 8,521 2769 KTEJ 419,750 417,368 $ 3,518 83707 KTEL-TV 52,878 52,875 $ 446 35666 KTEN 602,788 599,778 $ 5,056 24514 KTFD-TV 3,210,669 3,172,543 $ 26,745 35512 KTFF-DT 2,225,169 2,203,398 $ 18,575 20871 KTFK-DT 6,969,307 5,211,719 $ 43,935 68753 KTFN 1,017,335 1,013,157 $ 8,541 35084 KTFQ-TV 1,151,433 1,117,061 $ 9,417 29232 KTGM 159,358 159,091 $ 1,341 2787 KTHV 1,275,053 1,246,348 $ 10,507 29100 KTIN 281,096 279,385 $ 2,355 66170 KTIV 751,089 746,274 $ 6,291 49397 KTKA-TV 759,369 746,370 $ 6,292 35670 KTLA 18,156,910 16,870,262 $ 142,216 62354 KTLM 1,044,526 1,044,509 $ 8,805 49153 KTLN-TV 5,381,955 4,740,894 $ 39,966 64984 KTMD 6,095,741 6,095,606 $ 51,386 14675 KTMF 187,251 168,526 $ 1,421 10177 KTMW 2,261,671 2,144,791 $ 18,081 21533 KTNC-TV 8,270,858 7,381,656 $ 62,227 47996 KTNE-TV 100,341 95,324 $ 804 60519 KTNL-TV 8,642 8,642 $ 73 74100 KTNV-TV 2,094,506 1,936,752 $ 16,327 71023 KTNW 450,926 432,398 $ 3,645 8651 KTOO-TV 31,269 31,176 $ 263 7078 KTPX-TV 1,066,196 1,063,754 $ 8,967 68541 KTRE 441,879 421,406 $ 3,552 35675 KTRK-TV 6,114,259 6,112,870 $ 51,531 28230 KTRV-TV 714,833 707,557 $ 5,965 69170 KTSC 3,124,536 2,949,795 $ 24,867 61066 KTSD-TV 83,645 82,828 $ 698 37511 KTSF 7,959,349 7,129,638 $ 60,103 67760 KTSM-TV 1,015,348 1,011,264 $ 8,525 35678 KTTC 815,213 731,919 $ 6,170 28501 KTTM 76,133 73,664 $ 621 11908 KTTU 1,324,801 1,060,613 $ 8,941 22208 KTTV 17,380,551 16,693,085 $ 140,723 28521 KTTW 329,633 326,405 $ 2,752 65355 KTTZ-TV 380,240 380,225 $ 3,205 35685 KTUL 1,416,959 1,388,183 $ 11,702 10173 KTUU-TV 380,240 379,047 $ 3,195 77480 KTUZ-TV 1,668,531 1,666,026 $ 14,045 49632 KTVA 342,517 342,300 $ 2,886 34858 KTVB 714,865 707,882 $ 5,967 31437 KTVC 137,239 100,204 $ 845 68581 KTVD 3,800,970 3,547,607 $ 29,906 35692 KTVE 641,139 640,201 $ 5,397 49621 KTVF 98,068 97,929 $ 826 5290 KTVH-DT 228,832 184,264 $ 1,553 35693 KTVI 2,995,764 2,991,513 $ 25,218 40993 KTVK 4,184,825 4,173,028 $ 35,179 22570 KTVL 419,849 369,469 $ 3,115 18066 KTVM-TV 260,105 217,694 $ 1,835 59139 KTVN 955,490 800,420 $ 6,748 21251 KTVO 227,128 226,616 $ 1,910 35694 KTVQ 179,797 173,271 $ 1,461 50592 KTVR 147,808 54,480 $ 459 23422 KTVT 6,912,366 6,908,715 $ 58,240 35703 KTVU 8,297,634 7,406,751 $ 62,439 35705 KTVW-DT 4,174,310 4,160,877 $ 35,076 68889 KTVX 2,389,392 2,200,520 $ 18,550 55907 KTVZ 201,828 198,558 $ 1,674 18286 KTWO-TV 80,426 79,905 $ 674 70938 KTWU 1,703,798 1,562,305 $ 13,170 51517 KTXA 6,915,461 6,911,822 $ 58,267 42359 KTXD-TV 6,706,651 6,704,781 $ 56,521 51569 KTXH 6,092,710 6,092,525 $ 51,360 10205 KTXL 8,306,449 5,896,320 $ 49,706 308 KTXS-TV 247,603 246,760 $ 2,080 69315 KUAC-TV 98,717 98,189 $ 828 51233 KUAM-TV 159,358 159,358 $ 1,343 2722 KUAS-TV 994,802 977,391 $ 8,239 2731 KUAT-TV 1,485,024 1,253,342 $ 10,566 60520 KUBD 14,817 13,363 $ 113 70492 KUBE-TV 6,090,970 6,090,817 $ 51,346 1136 KUCW 2,388,889 2,199,787 $ 18,544 69396 KUED 2,388,995 2,203,093 $ 18,572 69582 KUEN 2,364,481 2,184,483 $ 18,415 82576 KUES 30,925 25,978 $ 219 82585 KUEW 132,168 120,411 $ 1,015 66611 KUFM-TV 187,680 166,697 $ 1,405 169028 KUGF-TV 86,622 85,986 $ 725 68717 KUHM-TV 154,836 145,241 $ 1,224 69269 KUHT 6,080,222 6,078,866 $ 51,245 62382 KUID-TV 432,855 284,023 $ 2,394 169027 KUKL-TV 124,505 115,844 $ 977 35724 KULR-TV 177,242 170,142 $ 1,434 41429 KUMV-TV 41,607 41,224 $ 348 81447 KUNP 130,559 43,472 $ 366 4624 KUNS-TV 4,027,849 4,015,626 $ 33,852 86532 KUOK 28,974 28,945 $ 244 66589 KUON-TV 1,375,257 1,360,005 $ 11,465 86263 KUPB 318,914 318,914 $ 2,688 65535 KUPK 149,642 148,180 $ 1,249 27431 KUPT 87,602 87,602 $ 738 89714 KUPU 956,178 948,005 $ 7,992 57884 KUPX-TV 2,374,672 2,191,229 $ 18,472 23074 KUSA 3,802,407 3,560,546 $ 30,015 61072 KUSD-TV 460,480 460,277 $ 3,880 10238 KUSI-TV 3,572,818 3,435,670 $ 28,963 43567 KUSM-TV 122,678 109,830 $ 926 69694 KUTF 1,210,774 1,031,870 $ 8,699 81451 KUTH-DT 2,219,788 2,027,174 $ 17,089 68886 KUTP 4,191,015 4,176,014 $ 35,204 35823 KUTV 2,388,625 2,199,731 $ 18,544 63927 KUVE-DT 1,294,971 964,396 $ 8,130 7700 KUVI-DT 1,204,490 1,009,943 $ 8,514 35841 KUVN-DT 6,680,126 6,678,157 $ 56,297 58609 KUVS-DT 4,043,413 4,005,657 $ 33,768 49766 KVAL-TV 1,016,673 866,173 $ 7,302 32621 KVAW 76,153 76,153 $ 642 58795 KVCR-DT 18,215,524 17,467,140 $ 147,248 35846 KVCT 288,221 287,446 $ 2,423 10195 KVCW 1,967,550 1,918,809 $ 16,176 64969 KVDA 2,566,563 2,548,720 $ 21,486 19783 KVEA 17,538,249 16,335,335 $ 137,707 12523 KVEO-TV 1,244,504 1,244,504 $ 10,491 2495 KVEW 476,720 464,347 $ 3,914 35852 KVHP 747,917 747,837 $ 6,304 49832 KVIA-TV 1,015,350 1,011,266 $ 8,525 35855 KVIE 10,759,440 7,467,369 $ 62,950 40450 KVIH-TV 91,912 91,564 $ 772 40446 KVII-TV 379,042 378,218 $ 3,188 61961 KVLY-TV 350,732 350,449 $ 2,954 16729 KVMD 15,274,297 14,512,400 $ 122,340 83825 KVME-TV 26,711 22,802 $ 192 25735 KVOA 1,317,956 1,030,404 $ 8,686 35862 KVOS-TV 2,202,674 2,131,652 $ 17,970 69733 KVPT 1,744,349 1,719,318 $ 14,494 55372 KVRR 356,645 356,645 $ 3,007 166331 KVSN-DT 2,706,244 2,283,409 $ 19,249 608 KVTH-DT 303,755 299,230 $ 2,523 2784 KVTJ-DT 1,466,426 1,465,802 $ 12,357 607 KVTN-DT 936,328 925,884 $ 7,805 35867 KVUE 2,661,290 2,611,314 $ 22,013 78910 KVUI 257,964 251,872 $ 2,123 35870 KVVU-TV 2,045,255 1,935,583 $ 16,317 36170 KVYE 396,495 392,498 $ 3,309 35095 KWBA-TV 1,129,524 1,073,029 $ 9,046 78314 KWBM 657,822 639,560 $ 5,391 27425 KWBN 953,207 840,455 $ 7,085 76268 KWBQ 1,149,598 1,107,211 $ 9,334 66413 KWCH-DT 883,647 881,674 $ 7,433 71549 KWCM-TV 252,284 244,033 $ 2,057 35419 KWDK 4,194,152 4,117,852 $ 34,713 42007 KWES-TV 424,862 423,544 $ 3,570 50194 KWET 127,976 112,750 $ 950 35881 KWEX-DT 2,376,463 2,370,469 $ 19,983 35883 KWGN-TV 3,706,455 3,513,537 $ 29,619 37099 KWHB 979,393 978,719 $ 8,251 36846 KWHE 952,966 834,341 $ 7,033 26231 KWHY-TV 17,736,497 17,695,306 $ 149,171 35096 KWKB 1,121,676 1,111,629 $ 9,371 162115 KWKS 39,708 39,323 $ 331 12522 KWKT-TV 1,299,675 1,298,478 $ 10,946 21162 KWNB-TV 91,093 89,332 $ 753 67347 KWOG 512,412 505,049 $ 4,258 56852 KWPX-TV 4,220,008 4,148,577 $ 34,973 6885 KWQC-TV 1,063,507 1,054,618 $ 8,890 29121 KWSD 280,675 280,672 $ 2,366 53318 KWSE 54,471 53,400 $ 450 71024 KWSU-TV 725,554 468,295 $ 3,948 25382 KWTV-DT 1,628,106 1,627,198 $ 13,717 35903 KWTX-TV 2,071,023 1,972,365 $ 16,627 593 KWWL 1,089,498 1,078,458 $ 9,091 84410 KWWT 293,291 293,291 $ 2,472 14674 KWYB 86,495 69,598 $ 587 10032 KWYP-DT 128,874 126,992 $ 1,071 35920 KXAN-TV 2,678,666 2,624,648 $ 22,126 49330 KXAS-TV 6,774,295 6,771,827 $ 57,087 24287 KXGN-TV 14,217 13,883 $ 117 35954 KXII 2,323,974 2,264,951 $ 19,094 55083 KXLA 17,929,100 16,794,896 $ 141,581 35959 KXLF-TV 258,100 217,808 $ 1,836 53847 KXLN-DT 6,085,891 6,085,712 $ 51,303 35906 KXLT-TV 348,025 347,296 $ 2,928 61978 KXLY-TV 772,116 740,960 $ 6,246 55684 KXMA-TV 32,005 31,909 $ 269 55686 KXMB-TV 142,755 138,506 $ 1,168 55685 KXMC-TV 97,569 89,483 $ 754 55683 KXMD-TV 37,962 37,917 $ 320 47995 KXNE-TV 305,839 304,682 $ 2,568 81593 KXNW 602,168 597,747 $ 5,039 35991 KXRM-TV 1,843,363 1,500,689 $ 12,651 1255 KXTF 140,746 140,312 $ 1,183 25048 KXTV 10,759,864 7,477,140 $ 63,032 35994 KXTX-TV 6,721,578 6,718,616 $ 56,638 62293 KXVA 185,478 185,276 $ 1,562 23277 KXVO 1,404,703 1,403,380 $ 11,830 9781 KXXV 1,771,620 1,748,287 $ 14,738 31870 KYAZ 6,038,257 6,038,071 $ 50,901 29086 KYIN 581,748 574,691 $ 4,845 60384 KYLE-TV 323,330 323,225 $ 2,725 33639 KYMA-DT 396,278 391,619 $ 3,301 47974 KYNE-TV 980,094 979,887 $ 8,260 53820 KYOU-TV 651,334 640,935 $ 5,403 36003 KYTV 1,095,904 1,083,524 $ 9,134 55644 KYTX 927,327 925,550 $ 7,802 13815 KYUR 379,943 379,027 $ 3,195 5237 KYUS-TV 12,496 12,356 $ 104 33752 KYVE 301,951 259,559 $ 2,188 55762 KYVV-TV 67,201 67,201 $ 567 25453 KYW-TV 11,212,189 11,008,413 $ 92,801 69531 KZJL 6,037,458 6,037,272 $ 50,894 69571 KZJO 4,147,016 4,097,776 $ 34,544 61062 KZSD-TV 41,207 35,825 $ 302 33079 KZTV 567,635 564,464 $ 4,758 57292 WAAY-TV 1,498,006 1,428,197 $ 12,040 1328 WABC-TV 20,948,273 20,560,001 $ 173,321 4190 WABE-TV 5,308,575 5,291,523 $ 44,608 43203 WABG-TV 393,020 392,348 $ 3,307 17005 WABI-TV 530,773 510,729 $ 4,305 16820 WABM 1,772,367 1,742,240 $ 14,687 23917 WABW-TV 1,097,560 1,096,376 $ 9,242 19199 WACH 1,403,222 1,400,385 $ 11,805 189358 WACP 9,415,263 9,301,049 $ 78,408 23930 WACS-TV 786,536 783,207 $ 6,602 60018 WACX 4,292,829 4,288,149 $ 36,149 361 WACY-TV 946,580 946,071 $ 7,975 455 WADL 4,610,065 4,606,521 $ 38,833 589 WAFB 1,857,882 1,857,418 $ 15,658 591 WAFF 1,527,517 1,456,436 $ 12,278 70689 WAGA-TV 6,000,355 5,923,191 $ 49,933 48305 WAGM-TV 64,721 63,331 $ 534 37809 WAGV 1,313,257 1,159,076 $ 9,771 706 WAIQ 611,733 609,794 $ 5,141 701 WAKA 799,637 793,645 $ 6,690 4143 WALA-TV 1,320,419 1,318,127 $ 11,112 70713 WALB 773,899 772,467 $ 6,512 60536 WAMI-DT 5,449,193 5,449,193 $ 45,937 70852 WAND 1,388,118 1,386,074 $ 11,685 39270 WANE-TV 1,146,442 1,146,442 $ 9,665 52280 WAOE 2,963,253 2,907,224 $ 24,508 64546 WAOW 636,957 629,068 $ 5,303 52073 WAPA-TV2,7 3,764,742 2,794,738 $ 23,560 49712 WAPT 793,621 791,620 $ 6,673 67792 WAQP 2,135,670 2,131,399 $ 17,968 13206 WATC-DT 5,732,204 5,705,819 $ 48,100 71082 WATE-TV 1,874,433 1,638,059 $ 13,809 22819 WATL 5,882,837 5,819,099 $ 49,055 20287 WATM-TV 893,989 749,183 $ 6,316 11907 WATN-TV 1,787,595 1,784,560 $ 15,044 13989 WAVE 1,891,797 1,880,563 $ 15,853 71127 WAVY-TV 2,080,708 2,080,691 $ 17,540 54938 WAWD 579,079 579,023 $ 4,881 65247 WAWV-TV 705,790 700,361 $ 5,904 12793 WAXN-TV 2,677,951 2,669,224 $ 22,502 65696 WBAL-TV 9,743,335 9,344,875 $ 78,777 74417 WBAY-TV 1,225,928 1,225,335 $ 10,330 71085 WBBH-TV 2,017,267 2,017,267 $ 17,006 65204 WBBJ-TV 662,148 658,839 $ 5,554 9617 WBBM-TV 9,914,233 9,907,806 $ 83,523 9088 WBBZ-TV 1,269,256 1,260,686 $ 10,628 70138 WBDT 3,831,757 3,819,550 $ 32,199 51349 WBEC-TV 5,421,355 5,421,355 $ 45,702 10758 WBFF 8,523,983 8,381,042 $ 70,652 12497 WBFS-TV 5,349,613 5,349,613 $ 45,097 6568 WBGU-TV 1,343,816 1,343,816 $ 11,328 81594 WBIF 309,707 309,707 $ 2,611 84802 WBIH 718,439 706,994 $ 5,960 717 WBIQ 1,563,080 1,532,266 $ 12,917 46984 WBIR-TV 1,978,347 1,701,857 $ 14,347 67048 WBKB-TV 136,823 130,625 $ 1,101 34167 WBKI 2,104,090 2,085,393 $ 17,580 4692 WBKO 963,413 862,651 $ 7,272 76001 WBKP 55,655 55,305 $ 466 68427 WBMM 562,284 562,123 $ 4,739 73692 WBNA 1,699,683 1,666,248 $ 14,046 23337 WBNG-TV 1,435,634 1,051,932 $ 8,868 71217 WBNS-TV 2,847,721 2,784,795 $ 23,476 72958 WBNX-TV 3,639,256 3,630,531 $ 30,605 71218 WBOC-TV 813,888 813,888 $ 6,861 71220 WBOY-TV 711,302 621,367 $ 5,238 60850 WBPH-TV 10,613,847 9,474,797 $ 79,873 7692 WBPX-TV 6,833,712 6,761,949 $ 57,003 5981 WBRA-TV 1,726,408 1,677,204 $ 14,139 71221 WBRC 1,884,007 1,849,135 $ 15,588 71225 WBRE-TV 2,879,196 2,244,735 $ 18,923 38616 WBRZ-TV 2,223,336 2,222,309 $ 18,734 82627 WBSF 1,836,543 1,832,446 $ 15,448 30826 WBTV 4,433,795 4,296,893 $ 36,223 66407 WBTW 1,975,457 1,959,172 $ 16,516 16363 WBUI 981,884 981,868 $ 8,277 59281 WBUP 126,472 112,603 $ 949 60830 WBUY-TV 1,569,254 1,567,815 $ 13,217 72971 WBXX-TV 2,142,759 1,984,544 $ 16,730 25456 WBZ-TV 7,960,556 7,730,847 $ 65,171 63153 WCAU 11,269,831 11,098,540 $ 93,561 363 WCAV 1,032,270 874,886 $ 7,375 46728 WCAX-TV 784,748 665,685 $ 5,612 39659 WCBB 964,079 910,222 $ 7,673 10587 WCBD-TV 1,149,489 1,149,489 $ 9,690 12477 WCBI-TV 680,511 678,424 $ 5,719 9610 WCBS-TV 22,087,789 21,511,236 $ 181,340 49157 WCCB 3,642,232 3,574,928 $ 30,137 9629 WCCO-TV 3,837,442 3,829,714 $ 32,284 14050 WCCT-TV 5,818,471 5,307,612 $ 44,743 69544 WCCU 694,550 693,317 $ 5,845 3001 WCCV-TV 3,391,703 2,062,994 $ 17,391 23937 WCES-TV 1,098,868 1,097,706 $ 9,254 65666 WCET 3,123,290 3,110,519 $ 26,222 46755 WCFE-TV 459,417 419,756 $ 3,539 71280 WCHS-TV 1,352,824 1,274,766 $ 10,746 42124 WCIA 834,084 833,547 $ 7,027 711 WCIQ 3,186,320 3,016,907 $ 25,433 71428 WCIU-TV 10,052,136 10,049,244 $ 84,715 9015 WCIV 1,152,800 1,152,800 $ 9,718 42116 WCIX 554,002 549,911 $ 4,636 16993 WCJB-TV 977,492 977,492 $ 8,240 11125 WCLF 4,097,389 4,096,624 $ 34,535 68007 WCLJ-TV 2,305,723 2,303,534 $ 19,419 50781 WCMH-TV 2,756,260 2,712,989 $ 22,870 9917 WCML 233,439 224,255 $ 1,890 9908 WCMU-TV 707,702 699,551 $ 5,897 9922 WCMV 425,499 411,288 $ 3,467 9913 WCMW 106,975 104,859 $ 884 32326 WCNC-TV 3,883,049 3,809,706 $ 32,116 53734 WCNY-TV 1,342,821 1,279,429 $ 10,786 73642 WCOV-TV 889,102 884,417 $ 7,456 40618 WCPB 560,426 560,426 $ 4,724 59438 WCPO-TV 3,330,885 3,313,654 $ 27,934 10981 WCPX-TV 9,753,235 9,751,916 $ 82,209 71297 WCSC-TV 1,028,018 1,028,018 $ 8,666 39664 WCSH 1,755,325 1,548,824 $ 13,057 69479 WCTE 612,760 541,314 $ 4,563 18334 WCTI-TV 1,688,065 1,685,638 $ 14,210 31590 WCTV 1,065,524 1,065,464 $ 8,982 33081 WCTX 7,844,936 7,332,431 $ 61,812 65684 WCVB-TV 7,780,868 7,618,496 $ 64,224 9987 WCVE-TV 1,721,004 1,712,249 $ 14,434 83304 WCVI-TV 50,601 50,495 $ 426 34204 WCVN-TV 2,129,816 2,120,349 $ 17,875 9989 WCVW 1,505,484 1,505,330 $ 12,690 73042 WCWF 1,077,314 1,077,194 $ 9,081 35385 WCWG 3,630,551 3,299,114 $ 27,812 29712 WCWJ 1,661,270 1,661,132 $ 14,003 73264 WCWN 1,909,223 1,621,751 $ 13,671 2455 WCYB-TV 2,363,002 2,057,404 $ 17,344 11291 WDAF-TV 2,539,581 2,537,411 $ 21,390 21250 WDAM-TV 512,594 500,343 $ 4,218 22129 WDAY-TV 339,239 338,856 $ 2,857 22124 WDAZ-TV 151,720 151,659 $ 1,278 71325 WDBB 1,792,728 1,762,643 $ 14,859 71326 WDBD 940,665 939,489 $ 7,920 71329 WDBJ 1,626,017 1,435,762 $ 12,103 51567 WDCA 8,101,358 8,049,329 $ 67,856 16530 WDCQ-TV 1,269,199 1,269,199 $ 10,699 30576 WDCW 8,155,998 8,114,847 $ 68,408 54385 WDEF-TV 1,730,762 1,530,403 $ 12,901 32851 WDFX-TV 271,499 270,942 $ 2,284 43846 WDHN 452,377 451,978 $ 3,810 71338 WDIO-DT 341,506 327,469 $ 2,761 714 WDIQ 663,062 620,124 $ 5,228 53114 WDIV-TV 5,450,318 5,450,174 $ 45,945 71427 WDJT-TV 3,267,652 3,256,507 $ 27,452 39561 WDKA 658,699 658,277 $ 5,549 64017 WDKY-TV 1,204,817 1,173,579 $ 9,893 67893 WDLI-TV 4,147,298 4,114,920 $ 34,689 72335 WDPB 596,888 596,888 $ 5,032 83740 WDPM-DT 1,365,977 1,364,744 $ 11,505 1283 WDPN-TV 11,594,463 11,467,616 $ 96,672 6476 WDPX-TV 6,833,712 6,761,949 $ 57,003 28476 WDRB 2,054,813 2,037,086 $ 17,173 12171 WDSC-TV 3,389,559 3,389,559 $ 28,574 17726 WDSE 330,994 316,643 $ 2,669 71353 WDSI-TV 1,100,302 1,042,191 $ 8,786 71357 WDSU 1,649,083 1,649,083 $ 13,902 7908 WDTI 2,092,242 2,091,941 $ 17,635 65690 WDTN 3,831,757 3,819,550 $ 32,199 70592 WDTV 962,532 850,394 $ 7,169 25045 WDVM-TV 3,074,837 2,646,508 $ 22,310 4110 WDWL 2,638,361 1,977,410 $ 16,670 49421 WEAO 3,960,217 3,945,408 $ 33,260 71363 WEAR-TV 1,520,973 1,520,386 $ 12,817 7893 WEAU 1,006,393 971,050 $ 8,186 61003 WEBA-TV 641,354 632,282 $ 5,330 19561 WECN 2,886,669 2,157,288 $ 18,186 48666 WECT 1,156,807 1,156,807 $ 9,752 13602 WEDH 5,328,800 4,724,167 $ 39,825 13607 WEDN 3,451,170 2,643,344 $ 22,283 69338 WEDQ 5,379,887 5,365,612 $ 45,232 21808 WEDU 5,379,887 5,365,612 $ 45,232 13594 WEDW 5,996,408 5,544,708 $ 46,742 13595 WEDY 5,328,800 4,724,167 $ 39,825 24801 WEEK-TV 752,596 752,539 $ 6,344 6744 WEFS 3,380,743 3,380,743 $ 28,500 24215 WEHT 857,558 844,070 $ 7,116 721 WEIQ 1,055,632 1,055,193 $ 8,895 18301 WEIU-TV 458,480 458,416 $ 3,864 69271 WEKW-TV 1,263,049 773,108 $ 6,517 60825 WELF-TV 1,477,691 1,387,044 $ 11,693 26602 WELU 2,248,146 1,678,682 $ 14,151 40761 WEMT 1,726,085 1,186,706 $ 10,004 69237 WENH-TV 4,500,498 4,328,222 $ 36,487 71508 WENY-TV 656,240 517,754 $ 4,365 83946 WEPH 604,105 602,833 $ 5,082 81508 WEPX-TV 950,012 950,012 $ 8,009 25738 WESH 4,063,973 4,053,252 $ 34,169 65670 WETA-TV 8,315,499 8,258,807 $ 69,622 69944 WETK 670,087 558,842 $ 4,711 60653 WETM-TV 870,206 770,731 $ 6,497 18252 WETP-TV 2,167,383 1,888,574 $ 15,921 2709 WEUX 380,569 373,680 $ 3,150 72041 WEVV-TV 752,417 751,094 $ 6,332 59441 WEWS-TV 4,112,984 4,078,299 $ 34,380 72052 WEYI-TV 3,715,686 3,652,991 $ 30,795 72054 WFAA 6,917,502 6,907,616 $ 58,231 81669 WFBD 817,914 817,389 $ 6,891 69532 WFDC-DT 8,155,998 8,114,847 $ 68,408 10132 WFFF-TV 633,649 552,182 $ 4,655 25040 WFFT-TV 1,095,429 1,095,411 $ 9,234 11123 WFGC 3,018,351 3,018,351 $ 25,445 6554 WFGX 1,493,866 1,493,319 $ 12,589 13991 WFIE 743,079 740,909 $ 6,246 715 WFIQ 546,563 544,258 $ 4,588 64592 WFLA-TV 5,583,544 5,576,649 $ 47,011 22211 WFLD 9,957,301 9,954,828 $ 83,919 72060 WFLI-TV 1,294,209 1,189,897 $ 10,031 39736 WFLX 5,740,086 5,740,086 $ 48,389 72062 WFMJ-TV 4,328,477 3,822,691 $ 32,225 72064 WFMY-TV 4,772,783 4,746,167 $ 40,010 39884 WFMZ-TV 10,613,847 9,474,797 $ 79,873 83943 WFNA 1,391,519 1,390,447 $ 11,721 47902 WFOR-TV 5,398,266 5,398,266 $ 45,507 11909 WFOX-TV 1,603,324 1,603,324 $ 13,516 40626 WFPT 5,829,153 5,442,279 $ 45,878 21245 WFPX-TV 2,637,949 2,634,141 $ 22,206 25396 WFQX-TV 537,340 534,314 $ 4,504 9635 WFRV-TV 1,263,353 1,256,376 $ 10,591 53115 WFSB 4,752,788 4,370,519 $ 36,843 6093 WFSG 364,961 364,796 $ 3,075 21801 WFSU-TV 576,105 576,093 $ 4,856 11913 WFTC 3,787,177 3,770,207 $ 31,783 64588 WFTS-TV 5,236,379 5,236,287 $ 44,142 16788 WFTT-TV 4,523,828 4,521,879 $ 38,119 72076 WFTV 3,882,888 3,882,888 $ 32,733 70649 WFTX-TV 1,758,172 1,758,172 $ 14,821 60553 WFTY-DT 5,678,755 5,560,460 $ 46,875 25395 WFUP 234,863 234,436 $ 1,976 60555 WFUT-DT 20,362,721 19,974,644 $ 168,386 22108 WFWA 1,035,114 1,034,862 $ 8,724 9054 WFXB 1,393,865 1,393,510 $ 11,747 3228 WFXG 1,070,032 1,057,760 $ 8,917 70815 WFXL 793,637 785,106 $ 6,618 19707 WFXP 583,315 562,500 $ 4,742 24813 WFXR 1,426,061 1,286,450 $ 10,845 6463 WFXT 7,494,070 7,400,830 $ 62,389 22245 WFXU 218,273 218,273 $ 1,840 43424 WFXV 702,682 612,494 $ 5,163 25236 WFXW 274,078 270,967 $ 2,284 41397 WFYI 2,389,627 2,388,970 $ 20,139 53930 WGAL 6,287,688 5,610,833 $ 47,299 2708 WGBA-TV 1,170,375 1,170,127 $ 9,864 24314 WGBC 249,415 249,235 $ 2,101 72099 WGBH-TV 7,711,842 7,601,732 $ 64,083 12498 WGBO-DT 9,828,737 9,826,530 $ 82,838 11113 WGBP-TV 1,820,589 1,812,232 $ 15,277 72098 WGBX-TV 7,803,280 7,636,641 $ 64,377 72096 WGBY-TV 4,470,009 3,739,675 $ 31,525 72120 WGCL-TV 6,027,276 5,961,471 $ 50,255 62388 WGCU 1,510,671 1,510,671 $ 12,735 54275 WGEM-TV 361,598 356,682 $ 3,007 27387 WGEN-TV 43,037 43,037 $ 363 7727 WGFL 877,163 877,163 $ 7,394 25682 WGGB-TV 3,443,386 3,053,436 $ 25,740 11027 WGGN-TV 4,002,841 3,981,382 $ 33,563 9064 WGGS-TV 2,759,326 2,705,067 $ 22,804 72106 WGHP 4,174,964 4,123,106 $ 34,758 710 WGIQ 363,849 363,806 $ 3,067 12520 WGMB-TV 1,742,708 1,742,659 $ 14,691 25683 WGME-TV 1,495,724 1,325,465 $ 11,174 24618 WGNM 742,458 741,502 $ 6,251 72119 WGNO 1,641,765 1,641,765 $ 13,840 9762 WGNT 2,128,079 2,127,891 $ 17,938 72115 WGN-TV 9,942,959 9,941,552 $ 83,807 40619 WGPT 578,294 344,300 $ 2,902 65074 WGPX-TV 2,765,350 2,754,743 $ 23,222 64547 WGRZ 1,878,725 1,812,309 $ 15,278 63329 WGTA 1,061,654 1,030,538 $ 8,687 66285 WGTE-TV 2,210,496 2,208,927 $ 18,621 59279 WGTQ 95,618 92,019 $ 776 59280 WGTU 358,543 353,477 $ 2,980 23948 WGTV 5,989,342 5,917,966 $ 49,888 7623 WGTW-TV 807,797 807,797 $ 6,810 24783 WGVK 2,439,225 2,437,526 $ 20,548 24784 WGVU-TV 1,825,744 1,784,264 $ 15,041 21536 WGWG 986,963 986,963 $ 8,320 56642 WGWW 1,677,166 1,647,976 $ 13,892 58262 WGXA 779,955 779,087 $ 6,568 73371 WHAM-TV 1,381,564 1,334,653 $ 11,251 32327 WHAS-TV 1,955,983 1,925,901 $ 16,235 6096 WHA-TV 1,635,777 1,628,950 $ 13,732 13950 WHBF-TV 1,712,339 1,704,072 $ 14,365 12521 WHBQ-TV 1,736,335 1,708,345 $ 14,401 10894 WHBR 1,302,764 1,302,041 $ 10,976 65128 WHDF 1,553,469 1,502,852 $ 12,669 72145 WHDH 7,441,208 7,343,735 $ 61,908 83929 WHDT 5,768,239 5,768,239 $ 48,626 70041 WHEC-TV 1,322,243 1,279,606 $ 10,787 67971 WHFT-TV 5,417,409 5,417,409 $ 45,669 41458 WHIO-TV 3,877,520 3,868,597 $ 32,612 713 WHIQ 1,278,174 1,225,940 $ 10,335 61216 WHIZ-TV 911,245 840,696 $ 7,087 65919 WHKY-TV 3,358,493 3,294,261 $ 27,771 18780 WHLA-TV 554,446 515,561 $ 4,346 48668 WHLT 484,432 483,532 $ 4,076 24582 WHLV-TV 3,906,201 3,906,201 $ 32,929 37102 WHMB-TV 2,959,585 2,889,145 $ 24,355 61004 WHMC 774,921 774,921 $ 6,533 36117 WHME-TV 1,455,358 1,455,110 $ 12,267 37106 WHNO 1,499,653 1,499,653 $ 12,642 72300 WHNS 2,549,610 2,270,868 $ 19,143 48693 WHNT-TV 1,569,885 1,487,578 $ 12,540 66221 WHO-DT 1,120,480 1,099,818 $ 9,271 6866 WHOI 736,125 736,047 $ 6,205 72313 WHP-TV 4,030,693 3,538,096 $ 29,826 51980 WHPX-TV 5,579,464 5,114,336 $ 43,114 73036 WHRM-TV 535,778 532,820 $ 4,492 25932 WHRO-TV 2,169,238 2,169,237 $ 18,287 68058 WHSG-TV 5,870,314 5,808,605 $ 48,967 4688 WHSV-TV 845,013 711,912 $ 6,001 9990 WHTJ 807,960 690,381 $ 5,820 72326 WHTM-TV 2,829,585 2,367,000 $ 19,954 11117 WHTN 1,914,755 1,905,733 $ 16,065 27772 WHUT-TV 7,649,763 7,617,337 $ 64,214 18793 WHWC-TV 1,123,941 1,091,281 $ 9,199 72338 WHYY-TV 10,448,829 10,049,700 $ 84,719 5360 WIAT 1,837,072 1,802,810 $ 15,198 63160 WIBW-TV 1,234,347 1,181,009 $ 9,956 25684 WICD 1,238,332 1,237,046 $ 10,428 25686 WICS 1,149,358 1,147,264 $ 9,671 24970 WICU-TV 740,115 683,435 $ 5,761 62210 WICZ-TV 1,249,974 965,416 $ 8,138 18410 WIDP 2,559,306 1,899,768 $ 16,015 26025 WIFS 1,583,693 1,578,870 $ 13,310 720 WIIQ 353,241 347,685 $ 2,931 68939 WILL-TV 1,178,545 1,158,147 $ 9,763 6863 WILX-TV 3,378,644 3,218,221 $ 27,130 22093 WINK-TV 1,851,105 1,851,105 $ 15,605 67787 WINM 1,001,485 971,031 $ 8,186 41314 WINP-TV 2,935,057 2,883,944 $ 24,312 3646 WIPB 1,965,353 1,965,174 $ 16,566 48408 WIPL 850,656 799,165 $ 6,737 53863 WIPM-TV1 2,196,157 1,554,017 $ 2,435 53859 WIPR-TV1 3,596,802 2,811,148 $ 23,698 10253 WIPX-TV 2,305,723 2,303,534 $ 19,419 39887 WIRS12 1,091,825 757,978 $ 5,056 71336 WIRT-DT 127,001 126,300 $ 1,065 13990 WIS 2,644,715 2,600,887 $ 21,925 65143 WISC-TV 1,734,112 1,697,537 $ 14,310 13960 WISE-TV 1,070,155 1,070,155 $ 9,021 39269 WISH-TV 2,912,963 2,855,253 $ 24,070 65680 WISN-TV 3,003,636 2,997,695 $ 25,271 73083 WITF-TV 2,412,561 2,191,501 $ 18,474 73107 WITI 3,111,641 3,102,097 $ 26,151 594 WITN-TV 1,861,458 1,836,905 $ 15,485 61005 WITV 871,783 871,783 $ 7,349 7780 WIVB-TV 1,900,503 1,820,106 $ 15,343 11260 WIVT 855,138 613,934 $ 5,175 60571 WIWN 3,338,845 3,323,941 $ 28,021 62207 WIYC 639,641 637,499 $ 5,374 73120 WJAC-TV 2,219,529 1,897,986 $ 16,000 10259 WJAL 8,750,706 8,446,074 $ 71,200 50780 WJAR 7,108,180 6,976,099 $ 58,809 35576 WJAX-TV 1,630,782 1,630,782 $ 13,747 27140 WJBF 1,601,088 1,588,444 $ 13,391 73123 WJBK 5,748,623 5,711,224 $ 48,146 37174 WJCL 938,086 938,086 $ 7,908 73130 WJCT 1,618,817 1,617,292 $ 13,634 29719 WJEB-TV 1,607,603 1,607,603 $ 13,552 65749 WJET-TV 747,431 717,721 $ 6,050 7651 WJFB 2,310,517 2,302,217 $ 19,408 49699 WJFW-TV 277,530 268,295 $ 2,262 73136 WJHG-TV 864,121 859,823 $ 7,248 57826 WJHL-TV 2,034,663 1,462,129 $ 12,326 68519 WJKT 655,780 655,373 $ 5,525 1051 WJLA-TV 8,750,706 8,447,643 $ 71,214 86537 WJLP 21,384,863 21,119,366 $ 178,036 9630 WJMN-TV 160,991 154,424 $ 1,302 61008 WJPM-TV 623,939 623,787 $ 5,259 58340 WJPX6,10,12 3,254,481 2,500,195 $ 21,077 21735 WJRT-TV 2,788,684 2,543,446 $ 21,441 23918 WJSP-TV 4,225,860 4,188,428 $ 35,308 41210 WJTC 1,381,529 1,379,283 $ 11,627 48667 WJTV 987,206 980,717 $ 8,267 73150 WJW 3,977,148 3,905,325 $ 32,922 61007 WJWJ-TV 1,034,555 1,034,555 $ 8,721 58342 WJWN-TV6 2,063,156 1,461,497 $ 5,056 53116 WJXT 1,622,616 1,622,616 $ 13,679 11893 WJXX 1,618,191 1,617,272 $ 13,634 32334 WJYS 9,667,341 9,667,317 $ 81,495 25455 WJZ-TV 9,743,335 9,350,346 $ 78,823 73152 WJZY 4,432,745 4,301,117 $ 36,258 64983 WKAQ-TV3 3,697,088 2,731,588 $ 2,843 6104 WKAR-TV 1,693,373 1,689,830 $ 14,245 34171 WKAS 542,308 512,994 $ 4,325 51570 WKBD-TV 5,065,617 5,065,350 $ 42,701 73153 WKBN-TV 4,898,622 4,535,576 $ 38,235 13929 WKBS-TV 1,082,894 937,847 $ 7,906 74424 WKBT-DT 866,325 824,795 $ 6,953 54176 WKBW-TV 2,247,191 2,161,366 $ 18,220 53465 WKCF 4,241,181 4,240,354 $ 35,746 73155 WKEF 3,730,595 3,716,127 $ 31,327 34177 WKGB-TV 413,268 411,587 $ 3,470 34196 WKHA 511,281 400,721 $ 3,378 34207 WKLE 856,237 846,630 $ 7,137 34212 WKMA-TV 524,617 524,035 $ 4,418 71293 WKMG-TV 3,817,673 3,817,673 $ 32,183 34195 WKMJ-TV 1,477,906 1,470,645 $ 12,398 34202 WKMR 463,316 428,462 $ 3,612 34174 WKMU 344,430 344,050 $ 2,900 42061 WKNO 1,645,867 1,642,092 $ 13,843 83931 WKNX-TV 1,684,178 1,459,493 $ 12,304 34205 WKOH 584,645 579,258 $ 4,883 67869 WKOI-TV 3,831,757 3,819,550 $ 32,199 34211 WKON 1,080,274 1,072,320 $ 9,040 18267 WKOP-TV 1,555,654 1,382,098 $ 11,651 64545 WKOW 1,918,224 1,899,746 $ 16,015 21432 WKPC-TV 1,525,919 1,517,701 $ 12,794 65758 WKPD 283,454 282,250 $ 2,379 34200 WKPI-TV 606,666 481,220 $ 4,057 27504 WKPT-TV 1,131,213 887,806 $ 7,484 58341 WKPV10 1,132,932 731,199 $ 5,056 11289 WKRC-TV 3,281,914 3,229,223 $ 27,222 73187 WKRG-TV 1,526,600 1,526,075 $ 12,865 73188 WKRN-TV 2,409,767 2,388,588 $ 20,136 34222 WKSO-TV 658,441 642,090 $ 5,413 40902 WKTC 1,387,229 1,386,779 $ 11,691 60654 WKTV 1,573,503 1,342,387 $ 11,316 73195 WKYC 4,180,327 4,124,135 $ 34,766 24914 WKYT-TV 1,174,615 1,156,978 $ 9,753 71861 WKYU-TV 411,448 409,310 $ 3,450 34181 WKZT-TV 1,044,532 1,020,878 $ 8,606 18819 WLAE-TV 1,397,967 1,397,967 $ 11,785 36533 WLAJ 4,100,475 4,063,963 $ 34,259 2710 WLAX 469,017 447,381 $ 3,771 68542 WLBT 948,671 947,857 $ 7,990 39644 WLBZ 373,129 364,346 $ 3,071 69328 WLED-TV 332,718 174,998 $ 1,475 63046 WLEF-TV 200,517 199,188 $ 1,679 73203 WLEX-TV 969,481 964,735 $ 8,133 37806 WLFB 798,916 688,519 $ 5,804 37808 WLFG 1,614,321 1,282,063 $ 10,808 73204 WLFI-TV 2,243,009 2,221,313 $ 18,726 73205 WLFL 3,747,583 3,743,960 $ 31,562 19777 WLII-DT4,8 2,801,102 2,153,564 $ 18,155 37503 WLIO 1,067,232 1,050,170 $ 8,853 38336 WLIW 20,027,920 19,717,729 $ 166,220 27696 WLJC-TV 1,401,072 1,281,256 $ 10,801 71645 WLJT-DT 385,493 385,380 $ 3,249 53939 WLKY 1,927,997 1,919,810 $ 16,184 11033 WLLA 2,081,693 2,081,436 $ 17,547 17076 WLMB 2,754,484 2,747,490 $ 23,161 68518 WLMT 1,736,552 1,733,496 $ 14,613 22591 WLNE-TV 6,429,522 6,381,825 $ 53,799 74420 WLNS-TV 4,100,475 4,063,963 $ 34,259 73206 WLNY-TV 7,501,199 7,415,578 $ 62,513 84253 WLOO 913,960 912,674 $ 7,694 56537 WLOS 3,086,751 2,544,360 $ 21,449 37732 WLOV-TV 609,526 607,780 $ 5,124 13995 WLOX 1,182,149 1,170,659 $ 9,869 38586 WLPB-TV 1,219,624 1,219,407 $ 10,280 73189 WLPX-TV 1,066,912 1,022,543 $ 8,620 66358 WLRN-TV 5,447,399 5,447,399 $ 45,922 73226 WLS-TV 10,174,464 10,170,757 $ 85,739 73230 WLTV-DT 5,427,398 5,427,398 $ 45,753 37176 WLTX 1,580,677 1,578,645 $ 13,308 37179 WLTZ 689,521 685,358 $ 5,778 21259 WLUC-TV 92,246 85,393 $ 720 4150 WLUK-TV 1,251,563 1,247,414 $ 10,516 73238 WLVI 7,441,208 7,343,735 $ 61,908 36989 WLVT-TV 10,613,847 9,474,797 $ 79,873 3978 WLWC 3,281,532 3,150,875 $ 26,562 46979 WLWT 3,367,381 3,355,009 $ 28,283 54452 WLXI 4,184,851 4,166,318 $ 35,122 55350 WLYH 2,829,585 2,367,000 $ 19,954 43192 WMAB-TV 405,483 399,560 $ 3,368 43170 WMAE-TV 686,076 653,173 $ 5,506 43197 WMAH-TV 1,257,393 1,256,995 $ 10,596 43176 WMAO-TV 369,696 369,343 $ 3,114 47905 WMAQ-TV 9,914,395 9,913,272 $ 83,569 59442 WMAR-TV 9,198,495 9,072,076 $ 76,478 43184 WMAU-TV 642,328 636,504 $ 5,366 43193 WMAV-TV 1,008,339 1,008,208 $ 8,499 43169 WMAW-TV 726,173 715,450 $ 6,031 46991 WMAZ-TV 1,185,678 1,136,616 $ 9,582 66398 WMBB 935,027 914,607 $ 7,710 43952 WMBC-TV 18,706,132 18,458,331 $ 155,604 42121 WMBD-TV 742,729 742,660 $ 6,261 83969 WMBF-TV 445,363 445,363 $ 3,754 60829 WMCF-TV 612,942 609,635 $ 5,139 9739 WMCN-TV 10,448,829 10,049,700 $ 84,719 19184 WMC-TV 2,047,403 2,043,125 $ 17,224 189357 WMDE 6,384,827 6,257,910 $ 52,754 73255 WMDN 278,227 278,018 $ 2,344 16455 WMDT 731,868 731,868 $ 6,170 39656 WMEA-TV 902,755 853,857 $ 7,198 39648 WMEB-TV 511,761 494,574 $ 4,169 70537 WMEC 218,027 217,839 $ 1,836 39649 WMED-TV 30,488 29,577 $ 249 39662 WMEM-TV 71,700 69,981 $ 590 41893 WMFD-TV 1,561,367 1,324,244 $ 11,163 41436 WMFP 5,792,048 5,564,295 $ 46,907 61111 WMGM-TV 807,797 807,797 $ 6,810 43847 WMGT-TV 601,894 601,309 $ 5,069 73263 WMHT 1,719,949 1,550,977 $ 13,075 68545 WMLW-TV 1,843,933 1,843,663 $ 15,542 53819 WMOR-TV 5,394,541 5,394,541 $ 45,476 81503 WMOW 121,150 105,957 $ 893 65944 WMPB 7,279,563 7,190,696 $ 60,618 43168 WMPN-TV 856,237 854,089 $ 7,200 65942 WMPT 8,637,742 8,584,398 $ 72,366 60827 WMPV-TV 1,423,052 1,422,411 $ 11,991 10221 WMSN-TV 1,947,942 1,927,158 $ 16,246 2174 WMTJ11 3,143,148 2,365,308 $ 19,940 6870 WMTV 1,548,616 1,545,459 $ 13,028 73288 WMTW 1,940,292 1,658,816 $ 13,984 23935 WMUM-TV 925,814 920,835 $ 7,763 73292 WMUR-TV 5,242,334 5,057,770 $ 42,637 42663 WMVS 3,172,534 3,112,231 $ 26,236 42665 WMVT 3,172,534 3,112,231 $ 26,236 81946 WMWC-TV 946,858 916,989 $ 7,730 56548 WMYA-TV 1,650,798 1,571,594 $ 13,249 74211 WMYD 5,750,989 5,750,873 $ 48,480 20624 WMYT-TV 4,432,745 4,301,117 $ 36,258 25544 WMYV 3,901,915 3,875,210 $ 32,668 73310 WNAB 2,176,984 2,166,809 $ 18,266 73311 WNAC-TV 7,310,183 6,959,064 $ 58,665 47535 WNBC 21,952,082 21,399,204 $ 180,395 83965 WNBW-DT 1,400,631 1,396,012 $ 11,768 72307 WNCF 667,683 665,950 $ 5,614 50782 WNCN 3,795,494 3,783,131 $ 31,892 57838 WNCT-TV 1,935,414 1,887,929 $ 15,915 41674 WNDU-TV 1,863,764 1,835,398 $ 15,472 28462 WNDY-TV 2,912,963 2,855,253 $ 24,070 71928 WNED-TV 1,387,961 1,370,480 $ 11,553 60931 WNEH 1,261,482 1,255,218 $ 10,581 41221 WNEM-TV 1,475,094 1,471,908 $ 12,408 49439 WNEO 3,353,869 3,271,369 $ 27,578 73318 WNEP-TV 3,429,213 2,838,000 $ 23,924 18795 WNET 21,113,760 20,615,190 $ 173,786 51864 WNEU 7,135,190 7,067,520 $ 59,579 23942 WNGH-TV 5,744,856 5,595,366 $ 47,169 67802 WNIN 908,275 891,946 $ 7,519 41671 WNIT 1,305,447 1,305,447 $ 11,005 48457 WNJB 20,787,272 20,036,393 $ 168,907 48477 WNJN 20,787,272 20,036,393 $ 168,907 48481 WNJS 7,383,483 7,343,269 $ 61,904 48465 WNJT 7,383,483 7,343,269 $ 61,904 73333 WNJU 21,952,082 21,399,204 $ 180,395 73336 WNJX-TV2 1,628,732 1,170,083 $ 2,573 61217 WNKY 379,002 377,357 $ 3,181 71905 WNLO 1,900,503 1,820,106 $ 15,343 4318 WNMU 181,736 179,662 $ 1,515 73344 WNNE 792,551 676,539 $ 5,703 54280 WNOL-TV 1,632,389 1,632,389 $ 13,761 71676 WNPB-TV 2,130,047 1,941,707 $ 16,369 62137 WNPI-DT 167,931 161,748 $ 1,364 41398 WNPT 2,266,543 2,235,316 $ 18,844 28468 WNPX-TV 2,084,890 2,071,017 $ 17,459 61009 WNSC-TV 2,431,154 2,425,044 $ 20,443 61010 WNTV 2,419,841 2,211,019 $ 18,639 16539 WNTZ-TV 344,704 343,849 $ 2,899 7933 WNUV 9,098,694 8,906,508 $ 75,082 9999 WNVC 807,960 690,381 $ 5,820 10019 WNVT 1,721,004 1,712,249 $ 14,434 73354 WNWO-TV 2,872,428 2,872,250 $ 24,213 136751 WNYA 1,923,118 1,651,777 $ 13,924 30303 WNYB 1,785,269 1,756,096 $ 14,804 6048 WNYE-TV 19,414,613 19,180,858 $ 161,695 34329 WNYI 1,627,542 1,338,811 $ 11,286 67784 WNYO-TV 1,430,491 1,409,756 $ 11,884 73363 WNYT 1,679,494 1,516,775 $ 12,786 22206 WNYW 20,075,874 19,753,060 $ 166,518 69618 WOAI-TV 2,525,811 2,513,887 $ 21,192 66804 WOAY-TV 581,486 443,210 $ 3,736 41225 WOFL 4,048,104 4,043,672 $ 34,088 70651 WOGX 1,112,408 1,112,408 $ 9,378 8661 WOI-DT 1,173,757 1,170,432 $ 9,867 39746 WOIO 3,821,233 3,745,335 $ 31,573 71725 WOLE-DT4 1,784,094 1,312,984 $ 7,978 73375 WOLF-TV 2,990,646 2,522,858 $ 21,268 60963 WOLO-TV 2,635,715 2,594,980 $ 21,876 36838 WOOD-TV 2,507,053 2,501,084 $ 21,084 67602 WOPX-TV 3,877,863 3,877,805 $ 32,690 64865 WORA-TV3,13 3,594,115 2,762,755 $ 23,290 73901 WORO-DT 3,243,301 2,511,742 $ 21,174 60357 WOST 1,193,381 853,762 $ 7,197 66185 WOSU-TV 2,843,651 2,776,901 $ 23,409 131 WOTF-TV 3,451,383 3,451,383 $ 29,095 10212 WOTV 2,368,797 2,368,397 $ 19,966 50147 WOUB-TV 756,762 734,988 $ 6,196 50141 WOUC-TV 1,713,515 1,649,853 $ 13,908 23342 WOWK-TV 1,159,175 1,083,663 $ 9,135 65528 WOWT 1,380,979 1,377,287 $ 11,611 31570 WPAN 1,254,821 1,254,636 $ 10,577 51988 WPBF 3,190,307 3,186,405 $ 26,861 21253 WPBN-TV 442,005 430,953 $ 3,633 62136 WPBS-TV 338,448 301,692 $ 2,543 13456 WPBT 5,416,604 5,416,604 $ 45,662 13924 WPCB-TV 2,934,614 2,800,516 $ 23,608 64033 WPCH-TV 5,948,778 5,874,163 $ 49,519 4354 WPCT 195,270 194,869 $ 1,643 69880 WPCW 3,393,365 3,188,441 $ 26,879 17012 WPDE-TV 1,772,233 1,769,553 $ 14,917 52527 WPEC 5,764,571 5,764,571 $ 48,595 84088 WPFO 1,329,690 1,209,873 $ 10,199 54728 WPGA-TV 559,495 559,025 $ 4,713 60820 WPGD-TV 2,355,629 2,343,715 $ 19,758 73875 WPGH-TV 3,236,098 3,121,767 $ 26,316 2942 WPGX 425,098 422,872 $ 3,565 73879 WPHL-TV 10,421,216 10,246,856 $ 86,381 73881 WPIX 20,638,932 20,213,158 $ 170,397 53113 WPLG 5,587,129 5,587,129 $ 47,099 11906 WPMI-TV 1,468,001 1,467,594 $ 12,372 10213 WPMT 2,412,561 2,191,501 $ 18,474 18798 WPNE-TV 1,161,295 1,160,631 $ 9,784 73907 WPNT 3,172,170 3,064,423 $ 25,833 28480 WPPT 10,613,847 9,474,797 $ 79,873 51984 WPPX-TV 8,206,117 7,995,941 $ 67,406 47404 WPRI-TV 7,254,721 6,990,606 $ 58,931 51991 WPSD-TV 883,814 879,213 $ 7,412 12499 WPSG 10,798,264 10,529,460 $ 88,763 66219 WPSU-TV 1,055,133 868,013 $ 7,317 73905 WPTA 1,099,180 1,099,180 $ 9,266 25067 WPTD 3,423,417 3,411,727 $ 28,761 25065 WPTO 2,961,254 2,951,883 $ 24,884 59443 WPTV-TV 5,840,102 5,840,102 $ 49,232 57476 WPTZ 792,551 676,539 $ 5,703 8616 WPVI-TV 11,491,587 11,302,701 $ 95,282 48772 WPWR-TV 9,957,301 9,954,828 $ 83,919 51969 WPXA-TV 6,587,205 6,458,510 $ 54,445 71236 WPXC-TV 1,561,014 1,561,014 $ 13,159 5800 WPXD-TV 5,249,447 5,249,447 $ 44,253 37104 WPXE-TV 3,067,071 3,057,388 $ 25,774 48406 WPXG-TV 2,577,848 2,512,150 $ 21,177 73312 WPXH-TV 1,471,601 1,451,634 $ 12,237 73910 WPXI 3,300,896 3,197,864 $ 26,958 2325 WPXJ-TV 2,357,870 2,289,706 $ 19,302 52628 WPXK-TV 1,801,997 1,577,806 $ 13,301 21729 WPXL-TV 1,639,180 1,639,180 $ 13,818 48608 WPXM-TV 5,153,621 5,153,621 $ 43,445 73356 WPXN-TV 20,878,066 20,454,468 $ 172,431 27290 WPXP-TV 5,565,072 5,565,072 $ 46,914 50063 WPXQ-TV 3,281,532 3,150,875 $ 26,562 70251 WPXR-TV 1,375,640 1,200,331 $ 10,119 40861 WPXS 2,339,305 2,251,498 $ 18,980 53065 WPXT 1,002,128 952,535 $ 8,030 37971 WPXU-TV 700,488 700,488 $ 5,905 67077 WPXV-TV 1,919,794 1,919,794 $ 16,184 74091 WPXW-TV 8,075,268 8,024,342 $ 67,645 21726 WPXX-TV 1,562,675 1,560,834 $ 13,158 73319 WQAD-TV 1,101,012 1,089,523 $ 9,185 65130 WQCW 1,307,345 1,236,020 $ 10,420 71561 WQEC 183,969 183,690 $ 1,549 41315 WQED 3,529,305 3,426,684 $ 28,887 3255 WQHA 3,229,803 1,875,347 $ 15,809 60556 WQHS-DT 3,996,567 3,952,672 $ 33,321 53716 WQLN 602,232 577,633 $ 4,869 52075 WQMY 410,269 254,586 $ 2,146 64550 WQOW 369,066 358,576 $ 3,023 5468 WQPT-TV 941,381 933,107 $ 7,866 64690 WQPX-TV 1,644,283 1,212,587 $ 10,222 52408 WQRF-TV 1,375,774 1,354,979 $ 11,422 2175 WQTO11 2,864,201 1,598,365 $ 6,193 8688 WRAL-TV 3,852,675 3,848,801 $ 32,445 10133 WRAY-TV 4,184,851 4,166,318 $ 35,122 64611 WRAZ 3,800,594 3,797,515 $ 32,013 136749 WRBJ-TV 1,030,831 1,028,010 $ 8,666 3359 WRBL 1,493,140 1,461,459 $ 12,320 57221 WRBU 2,933,497 2,929,776 $ 24,698 54940 WRBW 4,080,267 4,077,341 $ 34,372 59137 WRCB 1,587,742 1,363,582 $ 11,495 47904 WRC-TV 8,188,601 8,146,696 $ 68,677 54963 WRDC 3,972,477 3,966,864 $ 33,441 55454 WRDQ 3,930,315 3,930,315 $ 33,133 73937 WRDW-TV 1,564,584 1,533,682 $ 12,929 66174 WREG-TV 1,642,307 1,638,585 $ 13,813 61011 WRET-TV 2,419,841 2,211,019 $ 18,639 73940 WREX 2,303,027 2,047,951 $ 17,264 54443 WRFB13 2,674,527 1,975,375 $ 2,843 73942 WRGB 1,757,575 1,645,483 $ 13,871 411 WRGT-TV 3,451,036 3,416,078 $ 28,798 74416 WRIC-TV 2,059,152 1,996,075 $ 16,827 61012 WRJA-TV 1,204,291 1,201,900 $ 10,132 412 WRLH-TV 2,017,508 1,959,111 $ 16,515 61013 WRLK-TV 1,229,094 1,228,616 $ 10,357 43870 WRLM 3,960,217 3,945,408 $ 33,260 74156 WRNN-TV 19,853,836 19,615,370 $ 165,358 73964 WROC-TV 1,203,412 1,185,203 $ 9,991 159007 WRPT 110,009 109,937 $ 927 20590 WRPX-TV 2,637,949 2,634,141 $ 22,206 62009 WRSP-TV 1,156,134 1,154,040 $ 9,729 40877 WRTV 2,919,683 2,895,164 $ 24,406 15320 WRUA 2,905,193 2,121,362 $ 17,883 71580 WRXY-TV 1,784,000 1,784,000 $ 15,039 48662 WSAV-TV 1,000,315 1,000,309 $ 8,433 6867 WSAW-TV 652,442 646,386 $ 5,449 36912 WSAZ-TV 1,239,187 1,168,954 $ 9,854 56092 WSBE-TV 7,535,710 7,266,304 $ 61,255 73982 WSBK-TV 7,290,901 7,225,463 $ 60,911 72053 WSBS-TV 42,952 42,952 $ 362 73983 WSBT-TV 1,763,215 1,752,698 $ 14,775 23960 WSB-TV 5,897,425 5,828,269 $ 49,132 69446 WSCG 867,516 867,490 $ 7,313 64971 WSCV 5,465,435 5,465,435 $ 46,074 70536 WSEC 538,090 536,891 $ 4,526 49711 WSEE-TV 613,176 595,476 $ 5,020 21258 WSES 1,829,499 1,796,561 $ 15,145 73988 WSET-TV 1,575,886 1,340,273 $ 11,299 13993 WSFA 1,166,744 1,132,826 $ 9,550 11118 WSFJ-TV 1,675,987 1,667,150 $ 14,054 10203 WSFL-TV 5,344,129 5,344,129 $ 45,051 72871 WSFX-TV 970,833 970,833 $ 8,184 73999 WSIL-TV 672,560 669,176 $ 5,641 4297 WSIU-TV 1,019,939 937,070 $ 7,900 74007 WSJV 1,651,178 1,644,683 $ 13,865 78908 WSKA 546,588 431,354 $ 3,636 74034 WSKG-TV 892,402 633,163 $ 5,338 76324 WSKY-TV 1,934,585 1,934,519 $ 16,308 57840 WSLS-TV 1,447,286 1,277,753 $ 10,771 21737 WSMH 2,339,224 2,327,660 $ 19,622 41232 WSMV-TV 2,447,769 2,404,766 $ 20,272 70119 WSNS-TV 9,914,395 9,913,272 $ 83,569 74070 WSOC-TV 3,706,808 3,638,832 $ 30,675 66391 WSPA-TV 3,388,945 3,227,025 $ 27,204 64352 WSPX-TV 1,298,295 1,174,763 $ 9,903 17611 WSRE 1,354,495 1,353,634 $ 11,411 63867 WSST-TV 331,907 331,601 $ 2,795 60341 WSTE-DT 3,723,967 3,033,272 $ 25,570 21252 WSTM-TV 1,455,586 1,379,393 $ 11,628 11204 WSTR-TV 3,297,280 3,286,795 $ 27,708 19776 WSUR-DT8 3,714,790 3,015,529 $ 7,978 2370 WSVI 50,601 50,601 $ 427 63840 WSVN 5,588,748 5,588,748 $ 47,113 73374 WSWB 1,530,002 1,102,316 $ 9,293 28155 WSWG 381,004 380,910 $ 3,211 71680 WSWP-TV 902,592 694,697 $ 5,856 74094 WSYM-TV 1,498,905 1,498,671 $ 12,634 73113 WSYR-TV 1,329,977 1,243,098 $ 10,479 40758 WSYT 1,970,721 1,739,071 $ 14,660 56549 WSYX 2,635,937 2,592,420 $ 21,854 65681 WTAE-TV 2,995,755 2,860,979 $ 24,118 23341 WTAJ-TV 1,187,718 948,598 $ 7,997 4685 WTAP-TV 512,358 494,914 $ 4,172 416 WTAT-TV 1,111,476 1,111,476 $ 9,370 67993 WTBY-TV 15,858,470 15,766,438 $ 132,911 29715 WTCE-TV 2,620,599 2,620,599 $ 22,092 65667 WTCI 1,216,209 1,104,698 $ 9,313 67786 WTCT 608,457 607,620 $ 5,122 28954 WTCV5,9 3,254,481 2,500,195 $ 21,077 74422 WTEN 1,902,431 1,613,747 $ 13,604 9881 WTGL 3,707,507 3,707,507 $ 31,254 27245 WTGS 966,519 966,357 $ 8,146 70655 WTHI-TV 928,934 886,846 $ 7,476 70162 WTHR 2,949,339 2,901,633 $ 24,461 147 WTIC-TV 5,318,753 4,707,697 $ 39,686 26681 WTIN-TV7 3,714,547 2,898,224 $ 2,573 66536 WTIU 1,570,257 1,569,135 $ 13,228 1002 WTJP-TV 1,947,743 1,907,300 $ 16,079 4593 WTJR 334,527 334,221 $ 2,817 70287 WTJX-TV 135,017 121,498 $ 1,024 47401 WTKR 2,149,376 2,149,375 $ 18,119 82735 WTLF 349,696 349,691 $ 2,948 23486 WTLH 1,065,127 1,065,105 $ 8,979 67781 WTLJ 1,622,365 1,621,227 $ 13,667 65046 WTLV 1,757,600 1,739,021 $ 14,660 1222 WTLW 1,646,714 1,644,206 $ 13,861 74098 WTMJ-TV 3,096,406 3,085,983 $ 26,015 74109 WTNH 7,845,782 7,332,431 $ 61,812 19200 WTNZ 1,699,427 1,513,754 $ 12,761 590 WTOC-TV 993,098 992,658 $ 8,368 74112 WTOG 5,268,364 5,267,177 $ 44,402 4686 WTOK-TV 417,919 412,276 $ 3,475 13992 WTOL 4,184,020 4,174,198 $ 35,188 21254 WTOM-TV 120,369 117,121 $ 987 74122 WTOV-TV 3,892,886 3,619,899 $ 30,516 82574 WTPC-TV 2,049,246 2,042,851 $ 17,221 86496 WTPX-TV 255,972 255,791 $ 2,156 6869 WTRF-TV 2,941,511 2,565,375 $ 21,626 67798 WTSF 922,441 851,465 $ 7,178 11290 WTSP 5,506,869 5,489,954 $ 46,280 4108 WTTA 5,583,544 5,576,649 $ 47,011 74137 WTTE 2,690,341 2,650,354 $ 22,342 22207 WTTG 8,101,358 8,049,329 $ 67,856 56526 WTTK 2,844,384 2,825,807 $ 23,822 74138 WTTO 1,877,570 1,844,214 $ 15,547 56523 WTTV 2,522,077 2,518,133 $ 21,228 10802 WTTW 9,729,982 9,729,634 $ 82,021 74148 WTVA 823,492 810,123 $ 6,829 22590 WTVC 1,579,628 1,366,976 $ 11,524 8617 WTVD 3,790,354 3,775,757 $ 31,830 55305 WTVE 5,156,905 5,152,997 $ 43,440 36504 WTVF 2,384,622 2,367,601 $ 19,959 74150 WTVG 4,405,350 4,397,113 $ 37,068 74151 WTVH 1,390,502 1,327,319 $ 11,189 10645 WTVI 2,856,703 2,829,960 $ 23,857 63154 WTVJ 5,458,451 5,458,451 $ 46,015 595 WTVM 1,498,667 1,405,957 $ 11,852 72945 WTVO 1,409,708 1,398,825 $ 11,792 28311 WTVP 678,884 678,539 $ 5,720 51597 WTVQ-DT 989,786 983,552 $ 8,291 57832 WTVR-TV 1,816,197 1,809,035 $ 15,250 16817 WTVS 5,511,091 5,510,837 $ 46,456 68569 WTVT 5,473,148 5,460,179 $ 46,029 3661 WTVW 839,003 834,187 $ 7,032 35575 WTVX 3,157,609 3,157,609 $ 26,619 4152 WTVY 974,532 971,173 $ 8,187 40759 WTVZ-TV 2,156,534 2,156,346 $ 18,178 66908 WTWC-TV 1,061,101 1,061,079 $ 8,945 20426 WTWO 737,341 731,294 $ 6,165 81692 WTWV 1,527,511 1,526,625 $ 12,869 51568 WTXF-TV 10,784,256 10,492,549 $ 88,452 41065 WTXL-TV 1,054,514 1,054,322 $ 8,888 8532 WUAB 3,821,233 3,745,335 $ 31,573 12855 WUCF-TV 3,707,507 3,707,507 $ 31,254 36395 WUCW 3,664,480 3,657,236 $ 30,830 69440 WUFT 1,372,142 1,372,142 $ 11,567 413 WUHF 1,152,580 1,147,972 $ 9,677 8156 WUJA 2,638,361 1,977,410 $ 16,670 69080 WUNC-TV 4,184,851 4,166,318 $ 35,122 69292 WUND-TV 1,504,532 1,504,532 $ 12,683 69114 WUNE-TV 3,146,865 2,625,942 $ 22,137 69300 WUNF-TV 2,625,583 2,331,723 $ 19,656 69124 WUNG-TV 3,605,143 3,588,220 $ 30,249 60551 WUNI 7,209,571 7,084,349 $ 59,721 69332 WUNJ-TV 1,116,458 1,116,458 $ 9,412 69149 WUNK-TV 1,991,039 1,985,696 $ 16,739 69360 WUNL-TV 3,055,263 2,834,274 $ 23,893 69444 WUNM-TV 1,357,346 1,357,346 $ 11,442 69397 WUNP-TV 1,402,186 1,393,524 $ 11,747 69416 WUNU 1,202,495 1,201,481 $ 10,128 83822 WUNW 1,109,237 570,072 $ 4,806 6900 WUPA 5,966,454 5,888,379 $ 49,639 13938 WUPL 1,721,320 1,721,320 $ 14,511 10897 WUPV 1,933,664 1,914,643 $ 16,140 19190 WUPW 2,100,914 2,099,572 $ 17,699 23128 WUPX-TV 1,102,435 1,089,118 $ 9,181 65593 WUSA 8,750,706 8,446,074 $ 71,200 4301 WUSI-TV 339,507 339,507 $ 2,862 60552 WUTB 8,523,983 8,381,042 $ 70,652 30577 WUTF-TV 7,918,927 7,709,189 $ 64,988 57837 WUTR 526,114 481,957 $ 4,063 415 WUTV 1,589,376 1,557,474 $ 13,130 16517 WUVC-DT 3,768,817 3,748,841 $ 31,603 48813 WUVG-DT 6,029,495 5,965,975 $ 50,293 3072 WUVN 1,233,568 1,157,140 $ 9,755 60560 WUVP-DT 10,421,216 10,246,856 $ 86,381 9971 WUXP-TV 2,316,872 2,305,293 $ 19,434 417 WVAH-TV 1,373,555 1,295,383 $ 10,920 23947 WVAN-TV 1,026,862 1,025,950 $ 8,649 65387 WVBT 1,885,169 1,885,169 $ 15,892 72342 WVCY-TV 3,111,641 3,102,097 $ 26,151 60559 WVEA-TV 4,553,004 4,552,113 $ 38,374 74167 WVEC 2,098,679 2,092,868 $ 17,643 5802 WVEN-TV 3,921,016 3,919,361 $ 33,040 61573 WVEO5 1,091,825 757,978 $ 5,056 69946 WVER 888,756 758,441 $ 6,394 10976 WVFX 731,193 609,763 $ 5,140 47929 WVIA-TV 3,429,213 2,838,000 $ 23,924 3667 WVII-TV 368,022 346,874 $ 2,924 70309 WVIR-TV 1,945,637 1,908,395 $ 16,088 74170 WVIT 5,846,093 5,357,639 $ 45,165 18753 WVIZ 3,695,223 3,689,173 $ 31,100 70021 WVLA-TV 1,897,179 1,897,007 $ 15,992 81750 WVLR 1,412,728 1,300,554 $ 10,964 35908 WVLT-TV 1,888,607 1,633,633 $ 13,772 74169 WVNS-TV 916,451 588,963 $ 4,965 11259 WVNY 742,579 659,270 $ 5,558 29000 WVOZ-TV9 1,132,932 731,199 $ 5,056 71657 WVPB-TV 992,798 959,526 $ 8,089 60111 WVPT 767,268 642,173 $ 5,414 70491 WVPX-TV 4,147,298 4,114,920 $ 34,689 66378 WVPY 756,696 632,649 $ 5,333 67190 WVSN 2,948,832 2,137,333 $ 18,018 69943 WVTA 888,756 758,441 $ 6,394 69940 WVTB 455,880 257,445 $ 2,170 74173 WVTM-TV 2,009,346 1,940,153 $ 16,355 74174 WVTV 3,091,132 3,083,108 $ 25,991 77496 WVUA 2,209,921 2,160,101 $ 18,210 4149 WVUE-DT 1,658,125 1,658,125 $ 13,978 4329 WVUT 273,293 273,215 $ 2,303 74176 WVVA 1,037,632 722,666 $ 6,092 3113 WVXF 85,191 78,556 $ 662 12033 WWAY 1,208,625 1,208,625 $ 10,189 30833 WWBT 1,924,502 1,892,842 $ 15,957 20295 WWCP-TV 2,811,278 2,548,691 $ 21,485 24812 WWCW 1,390,985 1,212,308 $ 10,220 23671 WWDP 5,792,048 5,564,295 $ 46,907 21158 WWHO 2,762,344 2,721,504 $ 22,942 14682 WWJE-DT 7,209,571 7,084,349 $ 59,721 72123 WWJ-TV 5,562,031 5,561,777 $ 46,886 166512 WWJX 518,866 518,846 $ 4,374 6868 WWLP 3,838,272 3,077,800 $ 25,946 74192 WWL-TV 1,788,624 1,788,624 $ 15,078 3133 WWMB 1,547,974 1,544,778 $ 13,022 74195 WWMT 2,538,485 2,531,309 $ 21,339 68851 WWNY-TV 375,600 346,623 $ 2,922 74197 WWOR-TV 19,853,836 19,615,370 $ 165,358 65943 WWPB 3,197,858 2,775,966 $ 23,401 23264 WWPX-TV 2,299,441 2,231,612 $ 18,812 68547 WWRS-TV 2,324,155 2,321,066 $ 19,567 61251 WWSB 3,340,133 3,340,133 $ 28,157 23142 WWSI 11,269,831 11,098,540 $ 93,561 16747 WWTI 196,531 190,097 $ 1,603 998 WWTO-TV 5,613,737 5,613,737 $ 47,324 26994 WWTV 1,034,174 1,022,322 $ 8,618 84214 WWTW 1,527,511 1,526,625 $ 12,869 26993 WWUP-TV 116,638 110,592 $ 932 23338 WXBU 4,030,693 3,538,096 $ 29,826 61504 WXCW 1,749,847 1,749,847 $ 14,751 61084 WXEL-TV 5,416,604 5,416,604 $ 45,662 60539 WXFT-DT 10,174,464 10,170,757 $ 85,739 23929 WXGA-TV 608,494 606,849 $ 5,116 51163 WXIA-TV 6,179,680 6,035,625 $ 50,880 53921 WXII-TV 3,630,551 3,299,114 $ 27,812 146 WXIN 2,836,532 2,814,815 $ 23,729 39738 WXIX-TV 2,911,054 2,900,875 $ 24,454 414 WXLV-TV 4,364,244 4,334,365 $ 36,539 68433 WXMI 1,988,970 1,988,589 $ 16,764 64549 WXOW 425,378 413,264 $ 3,484 6601 WXPX-TV 4,594,588 4,592,639 $ 38,716 74215 WXTV-DT 20,362,721 19,974,644 $ 168,386 12472 WXTX 699,095 694,837 $ 5,857 11970 WXXA-TV 1,680,670 1,537,868 $ 12,964 57274 WXXI-TV 1,184,860 1,168,696 $ 9,852 53517 WXXV-TV 1,191,123 1,189,584 $ 10,028 10267 WXYZ-TV 5,622,543 5,622,140 $ 47,395 12279 WYCC 9,729,982 9,729,634 $ 82,021 77515 WYCI 35,873 26,508 $ 223 70149 WYCW 3,388,945 3,227,025 $ 27,204 62219 WYDC 560,266 449,486 $ 3,789 18783 WYDN 2,577,848 2,512,150 $ 21,177 35582 WYDO 1,330,728 1,330,728 $ 11,218 25090 WYES-TV 1,872,245 1,872,059 $ 15,781 53905 WYFF 2,626,363 2,416,551 $ 20,372 49803 WYIN 6,956,141 6,956,141 $ 58,640 24915 WYMT-TV 1,180,276 863,881 $ 7,283 17010 WYOU 2,879,196 2,226,883 $ 18,773 77789 WYOW 91,839 91,311 $ 770 13933 WYPX-TV 1,529,500 1,413,583 $ 11,917 4693 WYTV 4,898,622 4,535,576 $ 38,235 5875 WYZZ-TV 1,042,140 1,036,721 $ 8,740 15507 WZBJ 1,626,017 1,435,762 $ 12,103 28119 WZDX 1,596,771 1,514,654 $ 12,769 70493 WZME 5,996,408 5,544,708 $ 46,742 81448 WZMQ 73,423 72,945 $ 615 71871 WZPX-TV 2,039,157 2,039,157 $ 17,190 136750 WZRB 952,279 951,693 $ 8,023 418 WZTV 2,312,658 2,301,187 $ 19,399 83270 WZVI 76,992 75,863 $ 640 19183 WZVN-TV 1,981,488 1,981,488 $ 16,704 49713 WZZM 1,574,546 1,548,835 $ 13,057 1 Call signs WIPM and WIPR are stations in Puerto Rico that are linked together with a total fee of $26,133. 2 Call signs WNJX and WAPA are stations in Puerto Rico that are linked together with a total fee of $26,133. 3 Call signs WKAQ and WORA are stations in Puerto Rico that are linked together with a total fee of $26,133. 4 Call signs WOLE and WLII are stations in Puerto Rico that are linked together with a total fee of $26,133. 5 Call signs WVEO and WTCV are stations in Puerto Rico that are linked together with a total fee of $26,133. 6 Call signs WJPX and WJWN are stations in Puerto Rico that are linked together with a total fee of $26,133. 7 Call signs WAPA and WTIN are stations in Puerto Rico that are linked together with a total fee of $26,133. 8 Call signs WSUR and WLII are stations in Puerto Rico that are linked together with a total fee of $26,133. 9 Call signs WVOZ and WTCV are stations in Puerto Rico that are linked together with a total fee of $26,133. 10 Call signs WJPX and WKPV are stations in Puerto Rico that are linked together with a total fee of $26,133. 11 Call signs WMTJ and WQTO are stations in Puerto Rico that are linked together with a total fee of $26,133. 12 Call signs WIRS and WJPX are stations in Puerto Rico that are linked together with a total fee of $26,133. 13 Call signs WRFB and WORA are stations in Puerto Rico that are linked together with a total fee of $26,133. APPENDIX H FY 2021 Schedule of 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) (Includes Non-Geographic telephone numbers) .15 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) 605 605 AM Radio Construction Permits 610 FM Radio Construction Permits 1,070 AM and FM Broadcast Radio Station Fees See Table Below Digital TV (47 CFR part 73) VHF and UHF Commercial Fee Factor $.007793 See Appendix G for fee amounts due, also available at https://www.fcc.gov/licensing-databases/fees/regulatory-fees Digital TV Construction Permits 5,100 Low Power TV, Class A TV, TV/FM Translators & FM Boosters (47 CFR part 74) 320 CARS (47 CFR part 78) 1,555 Cable Television Systems (per subscriber) (47 CFR part 76), Including IPTV (per subscriber) and Direct Broadcast Satellite (DBS) (per subscriber) .98 Interstate Telecommunication Service Providers (per revenue dollar) .00400 Toll Free (per toll free subscriber) (47 CFR section 52.101 (f) of the rules) .12 Earth Stations (47 CFR part 25) 595 Space Stations (per operational station in geostationary orbit) (47 CFR part 25) also includes DBS Service (per operational station) (47 CFR part 100) 116,855 Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25) (Other) 343,555 Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25) (Less Complex) 122,695 International Bearer Circuits - Terrestrial/Satellites (per Gbps circuit) $43 Submarine Cable Landing Licenses Fee (per cable system) See Table Below FY 2021 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 $975 $700 $610 $670 $1,070 $1,220 25,001 – 75,000 $1,465 $1,050 $915 $1,000 $1,605 $1,830 75,001 – 150,000 $2,195 $1,575 $1,375 $1,510 $2,410 $2,745 150,001 – 500,000 $3,295 $2,365 $2,060 $2,265 $3,615 $4,125 500,001 – 1,200,000 $4,935 $3,540 $3,085 $3,390 $5,415 $6,175 1,200,001 – 3,000,000 $7,410 $5,320 $4,635 $5,090 $8,130 $9,270 3,000,001 – 6,000,000 $11,105 $7,975 $6,950 $7,630 $12,185 $13,895 >6,000,000 $16,665 $11,965 $10,425 $11,450 $18,285 $20,850 FY 2021 International Bearer Circuits - Submarine Cable Systems Submarine Cable Systems (capacity as of December 31, 2020) Fee Ratio FY 2021 Regulatory Fees Less than 50 Gbps .0625 Units $9,495 50 Gbps or greater, but less than 250 Gbps .125 Units $18,990 250 Gbps or greater, but less than 1,500 Gbps .25 Units $37,980 1,500 Gbps or greater, but less than 3,500 Gbps .5 Units $75,955 3,500 Gbps or greater, but less than 6,500 Gbps 1.0 Unit $151,910 6,500 Gbps or greater 2.0 Units $303,820 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 Notice of Proposed Rulemaking for fiscal year (FY) 2022 (FY 2022 NPRM) released in June 2022. Assessment and Collection of Regulatory Fees for Fiscal Year 2022, Assessment and Collection of Regulatory Fees for Fiscal Year 2021, MD Docket Nos. 21-190, 22-223, Report and Order and Notice of Proposed Rulemaking, 2022 WL 2045858 (June 2, 2022) (FY 2022 NPRM). The Commission sought written public comment on the proposals in the FY 2022 NPRM, including comment on the IRFA. No comments were filed addressing the IRFA. This present Final Regulatory Flexibility Analysis (FRFA) conforms to the RFA. 5 U.S.C. § 604. A. Need for, and Objectives of, the Report and Order 2. In the Report and Order, we adopt a regulatory fee schedule to collect $381,950,000 in congressionally mandated regulatory fees for FY 2022. Consolidated Appropriations Act, 2022, Public Law No. 117-103 (Mar. 15, 2022) (FY 2022 Consolidated Appropriations Act). Under section 9 of the Communications Act of 1934, as amended, (Act or Communications Act), 47 U.S.C. § 159. regulatory fees are mandated by Congress and collected to recover the regulatory costs associated with the Commission’s oversight and regulatory activities in an amount that can be reasonably expected to equal the amount of the Commission’s annual appropriation. 47 U.S.C. § 159(a). The objective in adopting the regulatory fee schedule is to comply with the Congressional mandate to recover the total amount of the Commission’s annual appropriation, from the various industries for which the Commission provides oversight and/or regulation, with a fair, administrable and sustainable fee framework based on the number of full-time equivalents (FTEs) involved in such oversight and regulation in the licensing bureaus. 3. In the FY 2022 NPRM, See FY 2022 NPRM, generally. we sought comment on the methodology for assessing regulatory fees and the FY 2022 regulatory fee schedule, as well as on other issues related to the collection of regulatory fees including: (i) space station regulatory fees, including new regulatory fees for small satellites; (ii) continuing to use our methodology for calculating television broadcaster regulatory fees based on population; (iii) calculating the cost of collection of regulatory fees in establishing the annual de minimis threshold; (iv) reclassification of certain FTEs; (v) adopting new regulatory fee categories and (vi) how our proposals may promote or inhibit advances in diversity, equity, inclusion, and accessibility. For FY 2022, we adopt the regulatory fee schedule set forth in Appendices B and C to the Report and Order. Id., Appendices B and C. B. Summary of the Significant Issues Raised by the Public Comments in Response to the IRFA 4. None. C. Response to Comments by the Chief Counsel for Advocacy of the Small Business Administration 5. No comments were filed by the Chief Counsel for Advocacy of the Small Business Administration. D. Description and Estimate of the Number of Small Entities to Which the Rules Will Apply 6. 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 rules adopted herein. See 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.” See id. § 601(6). In addition, the term “small business” has the same meaning as the term “small-business concern” under the Small Business Act. See id. § 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. See 15 U.S.C. § 632. 7. 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, there are industry-specific size standards for small businesses that are used in the regulatory context. These types of small businesses represent 99.9% of all businesses in the United States, which translates to flexibility analysis, according to data from the Small Business Administration’s (SBA) 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, “What is a small business?,” https://cdn.advocacy.sba.gov/wp-content/uploads/2021/11/03093005/Small-Business-FAQ-2021.pdf. (Nov 2021). There are 32.5 million such businesses. Id. 8. 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). The Internal Revenue Service (IRS) uses a revenue benchmark of $50,000 or less to delineate its annual electronic filing requirements for small exempt organizations. The IRS benchmark is similar to the population of less than 50,000 benchmark in 5 U.S.C § 601(5) that is used to define a small governmental jurisdiction. Therefore, the IRS benchmark has been used to estimate the number of small organizations in this small entity description. See Annual Electronic Filing Requirement for Small Exempt Organizations — Form 990-N (e-Postcard), “Who must file,” https://www.irs.gov/charities-non-profits/annual-electronic-filing-requirement-for-small-exempt-organizations-form-990-n-e-postcard. We note that the IRS data does not provide information on whether a small exempt organization is independently owned and operated or dominant in its field. Nationwide, for tax year 2020, there were approximately 447,689small exempt organizations in the U.S. reporting revenues of $50,000 or less according to the registration and tax data for exempt organizations available from the IRS. See Exempt Organizations Business Master File Extract (EO BMF), “CSV Files by Region,” https://www.irs.gov/charities-non-profits/exempt-organizations-business-master-file-extract-eo-bmf. The IRS Exempt Organization Business Master File (EO BMF) Extract provides information on all registered tax-exempt/non-profit organizations. The data utilized for purposes of this description was extracted from the IRS EO BMF data for businesses for the tax year 2020 with revenue less than or equal to $50,000, for Region 1-Northeast Area (58,577), Region 2-Mid-Atlantic and Great Lakes Areas (175,272), and Region 3-Gulf Coast and Pacific Coast Areas (213,840) which includes the continental U.S., Alaska, and Hawaii. This data does not include information for Puerto Rico. 9. 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 2017 Census of Governments See 13 U.S.C. § 161. The Census of Governments survey is conducted every five years, compiling data for years ending with “2” and “7.” See also Census of Governments, https://www.census.gov/programs-surveys/cog/about.html. indicate that there were 90,075 local governmental jurisdictions consisting of general purpose governments and special purpose governments in the United States. See U.S. Census Bureau, 2017 Census of Governments – Organization Table 2. Local Governments by Type and State: 2017 [CG1700ORG02]. https://www.census.gov/data/tables/2017/econ/gus/2017-governments.html. Local governmental jurisdictions are made up of general purpose governments (county, municipal, and town or township) and special purpose governments (special districts and independent school districts). See also Table 2. CG1700ORG02 Table Notes Local Governments by Type and State_2017. Of this number there were 36,931 general purpose governments (county, See id. at Table 5. County Governments by Population-Size Group and State: 2017 [CG1700ORG05]. https://www.census.gov/data/tables/2017/econ/gus/2017-governments.html. There were 2,105 county governments with populations less than 50,000. This category does not include subcounty (municipal and township) governments. municipal, and town or township See id. at Table 6. Subcounty General-Purpose Governments by Population-Size Group and State: 2017 [CG1700ORG06]. https://www.census.gov/data/tables/2017/econ/gus/2017-governments.html. There were 18,729 municipal and 16,097 town and township governments with populations less than 50,000. ) with populations of less than 50,000 and 12,040 special purpose governments - independent school districts See id. at Table 10. Elementary and Secondary School Systems by Enrollment-Size Group and State: 2017 [CG1700ORG10]. https://www.census.gov/data/tables/2017/econ/gus/2017-governments.html. There were 12,040 independent school districts with enrollment populations less than 50,000. See also Table 4. Special-Purpose Local Governments by State Census Years 1942 to 2017 [CG1700ORG04], CG1700ORG04 Table Notes Special Purpose Local Governments by State Census Years 1942 to 2017. with enrollment populations of less than 50,000. While the special purpose governments category also includes local special district governments, the 2017 Census of Governments data does not provide data aggregated based on population size for the special purpose governments category. Therefore, only data from independent school districts is included in the special purpose governments category. Accordingly, based on the 2017 U.S. Census of Governments data, we estimate that at least 48,971 entities fall into the category of “small governmental jurisdictions.” This total is derived from the sum of the number of general purpose governments (county, municipal, and town or township) with populations of less than 50,000 (36,931) and the number of special purpose governments - independent school districts with enrollment populations of less than 50,000 (12,040), from the 2017 Census of Governments - Organizations Tables 5, 6, and 10. 10. Incumbent Local Exchange Carriers (Incumbent LECs). Neither the Commission nor the SBA have developed a small business size standard specifically for incumbent local exchange carriers. Wired Telecommunications Carriers See U.S. Census Bureau, 2017 NAICS Definition, “517311 Wired Telecommunications Carriers,” https://www.census.gov/naics/?input=517311&year=2017&details=517311. is the closest industry with a SBA small business size standard. See 13 CFR § 121.201, NAICS Code 517311. The SBA small business size standard for Wired Telecommunications Carriers classifies firms having 1,500 or fewer employees as small. Id. U.S. Census Bureau data for 2017 show that there were 3,054 firms in this industry that operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517311, https://data.census.gov/cedsci/table?y=2017&n=517311&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,964 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 1,227 providers that reported they were incumbent local exchange service providers. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/public/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that 929 providers have 1,500 or fewer employees. Id. Consequently, using the SBA’s small business size standard, the Commission estimates that the majority of incumbent local exchange carriers can be considered small entities. 11. 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. See U.S. Census Bureau, 2017 NAICS Definition, “517311 Wired Telecommunications Carriers,” https://www.census.gov/naics/?input=517311&year=2017&details=517311. 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. Id. By exception, establishments providing satellite television distribution services using facilities and infrastructure that they operate are included in this industry. Id. Wired Telecommunications Carriers are also referred to as wireline carriers or fixed local service providers. Fixed Local Service Providers include the following types of providers: Incumbent Local Exchange Carriers (ILECs), Competitive Access Providers (CAPs) and Competitive Local Exchange Carriers (CLECs), Cable/Coax CLECs, Interconnected VOIP Providers, Non-Interconnected VOIP Providers, Shared-Tenant Service Providers, Audio Bridge Service Providers, and Other Local Service Providers. Local Resellers fall into another U.S. Census Bureau industry group and therefore data for these providers is not included in this industry. 12. The SBA small business size standard for Wired Telecommunications Carriers classifies firms having 1,500 or fewer employees as small. See 13 CFR § 121.201, NAICS Code 517311. U.S. Census Bureau data for 2017 show that there were 3,054 firms that operated in this industry for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517311, https://data.census.gov/cedsci/table?y=2017&n=517311&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,964 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 5,183 providers that reported they were engaged in the provision of fixed local services. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/pubId.lic/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that 4,737 providers have 1,500 or fewer employees. Id. Consequently, using the SBA’s small business size standard, most of these providers can be considered small entities. 13. Competitive Local Exchange Carriers (LECs). Neither the Commission nor the SBA has developed a size standard for small businesses specifically applicable to local exchange services. Providers of these services include several types of competitive local exchange service providers. Competitive Local Exchange Service Providers include the following types of providers: Competitive Access Providers (CAPs) and Competitive Local Exchange Carriers (CLECs), Cable/Coax CLECs, Interconnected VOIP Providers, Non-Interconnected VOIP Providers, Shared-Tenant Service Providers, Audio Bridge Service Providers, Local Resellers, and Other Local Service Providers. Wired Telecommunications Carriers See U.S. Census Bureau, 2017 NAICS Definition, “517311 Wired Telecommunications Carriers,” https://www.census.gov/naics/?input=517311&year=2017&details=517311. is the closest industry with a SBA small business size standard. The SBA small business size standard for Wired Telecommunications Carriers classifies firms having 1,500 or fewer employees as small. See 13 CFR § 121.201, NAICS Code 517311. U.S. Census Bureau data for 2017 show that there were 3,054 firms that operated in this industry for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517311, https://data.census.gov/cedsci/table?y=2017&n=517311&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,964 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 3,956 providers that reported they were competitive local exchange service providers. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/pubId.lic/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that 3,808 providers have 1,500 or fewer employees. Id. Consequently, using the SBA’s small business size standard, most of these providers can be considered small entities. 14. Interexchange Carriers (IXCs). Neither the Commission nor the SBA have developed a small business size standard specifically for Interexchange Carriers. Wired Telecommunications Carriers See U.S. Census Bureau, 2017 NAICS Definition, “517311 Wired Telecommunications Carriers,” https://www.census.gov/naics/?input=517311&year=2017&details=517311. is the closest industry with a SBA small business size standard. See 13 CFR § 121.201, NAICS Code 517311. The SBA small business size standard for Wired Telecommunications Carriers classifies firms having 1,500 or fewer employees as small. Id. U.S. Census Bureau data for 2017 show that there were 3,054 firms that operated in this industry for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517311, https://data.census.gov/cedsci/table?y=2017&n=517311&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,964 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 151 providers that reported they were engaged in the provision of interexchange services. Of these providers, the Commission estimates that 131 providers have 1,500 or fewer employees. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/public/attachments/DOC-379181A1.pdf. Consequently, using the SBA’s small business size standard, the Commission estimates that the majority of providers in this industry can be considered small entities. 15. Operator Service Providers (“OSPs”). Neither the Commission nor the SBA has developed a small business size standard specifically for operator service providers. The closest applicable industry with a SBA small business size standard is Wired Telecommunications Carriers. See U.S. Census Bureau, 2017 NAICS Definition, “517311 Wired Telecommunications Carriers,” https://www.census.gov/naics/?input=517311&year=2017&details=517311. The SBA small business size standard classifies a business as small if it has 1,500 or fewer employees. See 13 CFR § 121.201, NAICS Code 517311. U.S. Census Bureau data for 2017 show that there were 3,054 firms in this industry that operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517311, https://data.census.gov/cedsci/table?y=2017&n=517311&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,964 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 32 providers that reported they were engaged in the provision of operator services. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/pubId.lic/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that all 32 providers have 1,500 or fewer employees. Id. Consequently, using the SBA’s small business size standard, all of these providers can be considered small entities. 16. Local Resellers. Neither the Commission nor the SBA have developed a small business size standard specifically for Local Resellers. Telecommunications Resellers is the closest industry with a SBA small business size standard. See U.S. Census Bureau, 2017 NAICS Definition, “517911 Telecommunications Resellers,” https://www.census.gov/naics/?input=517911&year=2017&details=517911. 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. Id. Establishments in this industry resell telecommunications; they do not operate transmission facilities and infrastructure. Id. Mobile virtual network operators (MVNOs) are included in this industry. Id. The SBA small business size standard for Telecommunications Resellers classifies a business as small if it has 1,500 or fewer employees. See 13 CFR § 121.201, NAICS Code 517911. U.S. Census Bureau data for 2017 show that 1,386 firms in this industry provided resale services for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517911, https://data.census.gov/cedsci/table?y=2017&n=517911&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of that number, 1,375 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 293 providers that reported they were engaged in the provision of local resale services. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/pubId.lic/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that 289 providers have 1,500 or fewer employees. Id. Consequently, using the SBA’s small business size standard, most of these providers can be considered small entities. 17. Toll Resellers. Neither the Commission nor the SBA have developed a small business size standard specifically for Toll Resellers. Telecommunications Resellers See U.S. Census Bureau, 2017 NAICS Definition, “517911 Telecommunications Resellers,” https://www.census.gov/naics/?input=517911&year=2017&details=517911. is the closest industry with a SBA small business size standard. 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. Id. Mobile virtual network operators (MVNOs) are included in this industry. Id. The SBA small business size standard for Telecommunications Resellers classifies a business as small if it has 1,500 or fewer employees. See 13 CFR § 121.201, NAICS Code 517911. U.S. Census Bureau data for 2017 show that 1,386 firms in this industry provided resale services for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517911, https://data.census.gov/cedsci/table?y=2017&n=517911&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of that number, 1,375 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 518 providers that reported they were engaged in the provision of toll services. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/pubId.lic/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that 495 providers have 1,500 or fewer employees. Id. Consequently, using the SBA’s small business size standard, most of these providers can be considered small entities. 18. Wireless Telecommunications Carriers (except Satellite). This industry comprises establishments engaged in operating and maintaining switching and transmission facilities to provide communications via the airwaves. See U.S. Census Bureau, 2017 NAICS Definition, “517312 Wireless Telecommunications Carriers (except Satellite),” https://www.census.gov/naics/?input=517312&year=2017&details=517312. 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. Id. The SBA size standard for this industry classifies a business as small if it has 1,500 or fewer employees. See 13 CFR § 121.201, NAICS Code 517312. U.S. Census Bureau data for 2017 show that there were 2,893 firms in this industry that operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517312, https://data.census.gov/cedsci/table?y=2017&n=517312&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of that number, 2,837 firms employed fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 797 providers that reported they were engaged in the provision of wireless services. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/pubId.lic/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that 715 providers have 1,500 or fewer employees. Id. Consequently, using the SBA’s small business size standard, most of these providers can be considered small entities. 19. Satellite Telecommunications. This industry comprises firms “primarily engaged in providing telecommunications services to other establishments in the telecommunications and broadcasting industries by forwarding and receiving communications signals via a system of satellites or reselling satellite telecommunications.” See U.S. Census Bureau, 2017 NAICS Definition, “517410 Satellite Telecommunications,” https://www.census.gov/naics/?input=517410&year=2017&details=517410. Satellite telecommunications service providers include satellite and earth station operators. The SBA small business size standard for this industry classifies a business with $35 million or less in annual receipts as small. See 13 CFR § 121.201, NAICS Code 517410. U.S. Census Bureau data for 2017 show that 275 firms in this industry operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 517410, https://data.census.gov/cedsci/table?y=2017&n=517410&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePreview=false. Of this number, 242 firms had revenue of less than $25 million. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. We also note that according to the U.S. Census Bureau glossary, the terms receipts and revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices. Additionally, based on Commission data in the 2021 Universal Service Monitoring Report, as of December 31, 2020, there were 71 providers that reported they were engaged in the provision of satellite telecommunications services. Federal-State Joint Board on Universal Service, Universal Service Monitoring Report at 26, Table 1.12 (2021), https://docs.fcc.gov/pubId.lic/attachments/DOC-379181A1.pdf. Of these providers, the Commission estimates that approximately 48 providers have 1,500 or fewer employees. Id. Consequently using the SBA’s small business size standard, a little more than of these providers can be considered small entities. 20. All Other Telecommunications. This industry 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 Definition, “517919 All Other Telecommunications,” https://www.census.gov/naics/?input=517919&year=2017&details=517919. 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. Providers of Internet services (e.g. dial-up ISPs) or voice over Internet protocol (VoIP) services, via client-supplied telecommunications connections are also included in this industry. Id. The SBA small business size standard for this industry classifies firms with annual receipts of $35 million or less as small. See 13 CFR § 121.201, NAICS Code 517919. U.S. Census Bureau data for 2017 show that there were 1,079 firms in this industry that operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 517919, https://data.census.gov/cedsci/table?y=2017&n=517919&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePreview=false. Of those firms, 1,039 had revenue of less than $25 million. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. We also note that according to the U.S. Census Bureau glossary, the terms receipts and revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices. Based on this data, the Commission estimates that the majority of “All Other Telecommunications” firms can be considered small. 21. Television Broadcasting. This industry is comprised of “establishments primarily engaged in broadcasting images together with sound.” See U.S. Census Bureau, 2017 NAICS Definition, “515120 Television Broadcasting,” https://www.census.gov/naics/?input=515120&year=2017&details=515120. 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 small business size standard for this industry classifies businesses having $41.5 million or less in annual receipts as small. See 13 CFR § 121.201, NAICS Code 515120. 2017 U.S. Census Bureau data indicate that 744 firms in this industry operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 515120, https://data.census.gov/cedsci/table?y=2017&n=515120&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePreview=false. Of that number, 657 firms had revenue of less than $25,000,000. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. We also note that according to the U.S. Census Bureau glossary, the terms receipts and revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices. Based on this data we estimate that the majority of television broadcasters are small entities under the SBA small business size standard. 22. The Commission estimates that as of March 31, 2022, there were 1,373 licensed commercial television stations. Broadcast Station Totals as of March 31, 2022, Public Notice, DA 22-365 (rel. April 5, 2022) (March 2022 Broadcast Station Totals PN), https://www.fcc.gov/document/broadcast-station-totals-march-31-2022. Of this total, 1,280 stations (or 93.2%) had revenues of $41.5 million or less in 2021, according to Commission staff review of the BIA Kelsey Inc. Media Access Pro Television Database (BIA) on June 1, 2022, and therefore these licensees qualify as small entities under the SBA definition. In addition, the Commission estimates as of March 31, 2022, there were 384 licensed noncommercial educational (NCE) television stations, 383 Class A TV stations, 1,840 LPTV stations and 3,231 TV translator stations. Id. The Commission however does not compile, and otherwise does not have access to financial information for these television broadcast stations that would permit it to determine how many of these stations qualify as small entities under the SBA small business size standard. Nevertheless, given the SBA’s large annual receipts threshold for this industry and the nature of these television station licensees, we presume that all of these entities qualify as small entities under the above SBA small business size standard. 23. Radio Stations. This industry is comprised of “establishments primarily engaged in broadcasting aural programs by radio to the public.” See U.S. Census Bureau, 2017 NAICS Definition, “515112 Radio Stations,” https://www.census.gov/naics/?input=515112&year=2017&details=515112. Programming may originate in their own studio, from an affiliated network, or from external sources. Id. The SBA small business size standard for this industry classifies firms having $41.5 million or less in annual receipts as small. See 13 CFR § 121.201, NAICS Code 515112. U.S. Census Bureau data for 2017 show that 2,963 firms operated in this industry during that year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 515112, https://data.census.gov/cedsci/table?y=2017&n=515112&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePreview=false. We note that the US Census Bureau withheld publication of the number of firms that operated for the entire year. Of this number, 1,879 firms operated with revenue of less than $25 million per year. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. We note that the U.S. Census Bureau withheld publication of the number of firms that operated with sales/value of shipments/revenue in the individual categories for less than $100,000, and $100,000 to $249,999 to avoid disclosing data for individual companies (see Cell Notes for the sales/value of shipments/revenue in these categories). Therefore, the number of firms with revenue that meet the SBA size standard would be higher that noted herein. We also note that according to the U.S. Census Bureau glossary, the terms receipts and revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices. Based on this data and the SBA’s small business size standard, we estimate a majority of such entities are small entities. 24. The Commission estimates that as of March 2022, there were 4,508 licensed commercial AM radio stations and 6,763 licensed commercial FM radio stations, for a combined total of 11,271 commercial radio stations. Broadcast Station Totals as of March 31, 2022, Public Notice, DA 22-365 (rel. April 5, 2022) (March 2022 Broadcast Station Totals PN), https://www.fcc.gov/document/broadcast-station-totals-march-31-2022. Of this total, 11,269 stations (or 99.98 %) had revenues of $41.5 million or less in 2021, according to Commission staff review of the BIA Kelsey Inc. Media Access Pro Database (BIA) on June 1, 2022, and therefore these licensees qualify as small entities under the SBA definition. In addition, the Commission estimates that as of March 31, 2022, there were 4,119 licensed noncommercial (NCE) FM radio stations, 2,049 low power FM (LPFM) stations, and 8,919 FM translators and boosters. Id. The Commission however does not compile, and otherwise does not have access to financial information for these radio stations that would permit it to determine how many of these stations qualify as small entities under the SBA small business size standard. Nevertheless, given the SBA’s large annual receipts threshold for this industry and the nature of these radio station licensees, we presume that all of these entities qualify as small entities under the above SBA small business size standard. 25. Cable Companies and Systems (Rate Regulation). The Commission has developed its own small business size standard 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(d). Based on industry data, there are about 420 cable companies in the U.S. S&P Global Market Intelligence, S&P Capital IQ Pro, U.S. MediaCensus, Operator Subscribers by Geography (last visited May 26, 2022). Of these, only five have more than 400,000 subscribers. S&P Global Market Intelligence, S&P Capital IQ Pro, Top Cable MSOs 12/21Q (last visited May 26, 2022); S&P Global Market Intelligence, Multichannel Video Subscriptions, Top 10 (April 2022). In addition, under the Commission’s rules, a “small system” is a cable system serving 15,000 or fewer subscribers. 47 CFR § 76.901(c). Based on industry data, there are about 4,139 cable systems (headends) in the U.S. S&P Global Market Intelligence, S&P Capital IQ Pro, U.S. MediaCensus, Operator Subscribers by Geography (last visited May 26, 2022). Of these, about 639 have more than 15,000 subscribers. S&P Global Market Intelligence, S&P Capital IQ Pro, Top Cable MSOs 12/21Q (last visited May 26, 2022); S&P Global Market Intelligence, Multichannel Video Subscriptions, Top 10 (April 2022). Accordingly, the Commission estimates that the majority of cable companies and cable systems are small. 26. Cable System Operators (Telecom Act Standard). The Communications Act of 1934, as amended, contains a size standard for a “small cable operator,” 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 U.S.C. § 543(m)(2). For purposes of the Telecom Act Standard, the Commission determined that a cable system operator that serves fewer than 677,000 subscribers, either directly or through affiliates, will meet the definition of a small cable operator based on the cable subscriber count established in a 2001 Public Notice. FCC Announces New Subscriber Count for the Definition of Small Cable Operator, Public Notice, 16 FCC Rcd 2225 (CSB 2001) (2001 Subscriber Count PN). In this Public Notice, the Commission determined that there were approximately 67.7 million cable subscribers in the United States at that time using the most reliable source publicly available. Id. We recognize that the number of cable subscribers changed since then and that the Commission has recently estimated the number of cable subscribers to be approximately 48.6 million. See Communications Marketplace Report, GN Docket No. 20-60, 2020 Communications Marketplace Report, 36 FCC Rcd 2945, 3049, para. 156 (2020) (2020 Communications Marketplace Report). However, because the Commission has not issued a public notice subsequent to the 2001 Subscriber Count PN, the Commission still relies on the subscriber count threshold established by the 2001 Subscriber Count PN for purposes of this rule. See 47 CFR § 76.901(e)(1). Based on industry data, only four cable system operators have more than 677,000 subscribers. S&P Global Market Intelligence, S&P Capital IQ Pro, Top Cable MSOs 12/21Q (last visited May 26, 2022). Accordingly, the Commission estimates that the majority of cable system operators are small under this size standard. We note however, 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 does receive 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 § 76.901(e) of the Commission’s rules. See 47 CFR § 76.910(b). 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. 27. 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 the Wired Telecommunications Carriers industry which 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. See U.S. Census Bureau, 2017 NAICS Definition, “517311 Wired Telecommunications Carriers,” https://www.census.gov/naics/?input=517311&year=2017&details=517311. Transmission facilities may be based on a single technology or combination of technologies. Id. 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. Included in this industry are: broadband Internet service providers (e.g., cable, DSL); local telephone carriers (wired); cable television distribution services; long-distance telephone carriers (wired); closed-circuit television (CCTV) services; VoIP service providers, using own operated wired telecommunications infrastructure; direct-to-home satellite system (DTH) services; telecommunications carriers (wired); satellite television distribution systems; and multichannel multipoint distribution services (MMDS). By exception, establishments providing satellite television distribution services using facilities and infrastructure that they operate are included in this industry. Id. 28. The SBA small business size standard for Wired Telecommunications Carriers classifies firms having 1,500 or fewer employees as small. See 13 CFR § 121.201, NAICS Code 517311. U.S. Census Bureau data for 2017 show that 3,054 firms operated in this industry for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517311, https://data.census.gov/cedsci/table?y=2017&n=517311&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,964 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Based on this data, the majority of firms in this industry can be considered small under the SBA small business size standard. According to Commission data however, only two entities provide DBS service - DIRECTV (owned by AT&T) and DISH Network, which require a great deal of capital for operation. 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 both exceed the SBA size standard for classification as a small business. Therefore, we must conclude based on internally developed Commission data, in general DBS service is provided only by large firms. 29. All Other Telecommunications. This industry 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 Definition, “517919 All Other Telecommunications,” https://www.census.gov/naics/?input=517919&year=2017&details=517919. 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. Providers of Internet services (e.g. dial-up ISPs) or voice over Internet protocol (VoIP) services, via client-supplied telecommunications connections are also included in this industry. Id. The SBA small business size standard for this industry classifies firms with annual receipts of $35 million or less as small. See 13 CFR § 121.201, NAICS Code 517919. U.S. Census Bureau data for 2017 show that there were 1,079 firms in this industry that operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 517919, https://data.census.gov/cedsci/table?y=2017&n=517919&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePreview=false. Of those firms, 1,039 had revenue of less than $25 million. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. We also note that according to the U.S. Census Bureau glossary, the terms receipts and revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices. Based on this data, the Commission estimates that the majority of “All Other Telecommunications” firms can be considered small. 30. RespOrgs. Responsible Organizations, or RespOrgs (also referred to as Toll-Free Number (TFN) providers), 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). Based on information on the website of SOMOS, the entity that maintains a registry of Toll-Free Number providers (SMS/800 TFN Registry) for the more than 42 million Toll-Free numbers in North America, and the TSS Registry, a centralized registry for the use of Toll-Free Numbers in text messaging and multimedia services, there were approximately 446 registered RespOrgs/Toll-Free Number providers in July 2021. See www.somos.com, “Find a Toll-Free Service Provider,” https://www.somos.com/find-toll-free-number?searchType=provider&alpha=true&certified=false&services=&serviceName=&keyword=&_page=1. SOMOS serves as the North American Numbering Plan Administrator (NANPA) for more than 800 million local and wireless telephone numbers and as the Reassigned Number Database Administrator. See also 2020 NANPA Annual Report at 97. https://nationalnanpa.com/reports/2020_NANPA_Annual_Report.pdf. RespOrgs are often wireline carriers, however they can be include non-carrier entities. Accordingly, the description below for RespOrgs include both Carrier RespOrgs and Non-Carrier RespOrgs. 31. Carrier RespOrgs. Neither the Commission nor the SBA have developed a small business size standard for Carrier RespOrgs. Wired Telecommunications Carriers, See U.S. Census Bureau, 2017 NAICS Definition, “517311 Wired Telecommunications Carriers,” https://www.census.gov/naics/?input=517311&year=2017&details=517311. and Wireless Telecommunications Carriers (except Satellite) See U.S. Census Bureau, 2017 NAICS Definition, “517312 Wireless Telecommunications Carriers (except Satellite),” https://www.census.gov/naics/?input=517312&year=2017&details=517312. are the closest industries with a SBA small business size applicable to Carrier RespOrgs. The industry descriptions selected for Carrier and Non-Carrier RespOrgs were selected because as a group they refer generically and comprehensively to all RespOrgs. 32. Wired Telecommunications Carriers are 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. Id. The SBA small business size standard for this industry classifies a business as small if it has 1,500 or fewer employees. See 13 CFR § 121.201, NAICS Code 517311. U.S. Census Bureau data for 2017 show that there were 3,054 firms that operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517311, https://data.census.gov/cedsci/table?y=2017&n=517311&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,964 firms operated with fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Based on that data, we conclude that the majority of Carrier RespOrgs that operated with wireline-based technology are small. 33. Wireless Telecommunications Carriers (except Satellite) engage 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. The SBA small business size standard for this industry classifies a business as small if it has 1,500 or fewer employees. See 13 CFR § 121.201, NAICS Code 517312. For this industry, U.S. Census Bureau data for 2017 show that there were 2,893 firms that operated for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Employment Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEEMPFIRM, NAICS Code 517312, https://data.census.gov/cedsci/table?y=2017&n=517312&tid=ECNSIZE2017.EC1700SIZEEMPFIRM&hidePreview=false. Of this number, 2,837 firms employed fewer than 250 employees. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. Based on this data, we conclude that the majority of Carrier RespOrgs that operated with wireless-based technology are small. 34. Non-Carrier RespOrgs. Neither the Commission, nor the SBA have developed a small business size standard Non-Carrier RespOrgs. Other Services Related to Advertising See U.S. Census Bureau, 2017 NAICS Definition, “541890 Other Services Related to Advertising,” https://www.census.gov/naics/?input=541890&year=2017&details=541890. and Other Management Consulting Services” See U.S. Census Bureau, 2017 NAICS Definition, “541618 Other Management Consulting Services,” https://www.census.gov/naics/?input=541618&year=2017&details=541618. are the closest industries with a SBA small business size applicable to Non-Carrier RespOrgs. The industry descriptions selected for Carrier and Non-Carrier RespOrgs were selected because as a group they refer generically and comprehensively to all RespOrgs. 35. The Other Services Related to Advertising industry contains 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). See supra n.148. The SBA small business size standard for this industry classifies a business as small that has annual receipts of $16.5 million or less. See 13 CFR § 121.201, NAICS Code 541890. U.S. Census Bureau data for 2017 show that 5,650 firms operated in this industry for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 541890, https://data.census.gov/cedsci/table?y=2017&n=541890&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePreview=false. Of that number, 3,693 firms operated with revenue of less than $10 million. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. We note that the U.S. Census Bureau withheld publication of the number of firms that operated with sales/value of shipments/revenue in the individual categories for less than $100,000, and $100,000 to $249,999, to avoid disclosing data for individual companies (see Cell Notes for the sales/value of shipments/revenue in these categories). Therefore, the number of firms with revenue that meet the SBA size standard would be higher than noted herein. We further note that according to the U.S. Census Bureau glossary, the terms receipts and revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices. Based on this data, we conclude that a majority of non-carrier RespOrgs who provide TFN-related management consulting services are small. 36. Other Management Consulting Services. This industry comprises establishments primarily engaged in providing operating advice and assistance to businesses and other organizations on marketing issues, such as developing marketing objectives and policies, sales forecasting, new product developing and pricing, licensing and franchise planning, and marketing planning and strategy. See U.S. Census Bureau, 2017 NAICS Definition, “541618 Other Management Consulting Services,” https://www.census.gov/naics/?input=541618&year=2017&details=541618. The SBA small business size standard for this industry classifies firms with annual receipts of $16.5 million or less as small. See 13 CFR § 121.201, NAICS Code 541618. U.S. Census Bureau data for 2017 show that 4,696 firms operated in this industry for the entire year. See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 541618, https://data.census.gov/cedsci/table?y=2017&n=541618&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePreview=false. Of this number, 3,700 firms had revenue of less than $10 million. Id. The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that meet the SBA size standard. We note that the U.S. Census Bureau withheld publication of the number of firms that operated with sales/value of shipments/revenue less than $100,000, to avoid disclosing data for individual companies (see Cell Notes for the sales/value of shipments/revenue for this category). Therefore, the number of firms with revenue that meet the SBA size standard would be higher than noted herein. We also note that according to the U.S. Census Bureau glossary, the terms receipts and revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices. Based on this data, we conclude that a majority of firms that operate in this industry are small. E. Description of Projected Reporting, Recordkeeping and Other Compliance Requirements 37. The Report and Order does not adopt any new reporting, recordkeeping, or other compliance requirements. Small and other regulated entities are required to pay regulatory fees on an annual basis. The cost of compliance with the annual regulatory fee assessment for small entities is the amount assessed for their the regulatory fee category and should not require small entities to hire professionals in order to comply. Small entities that qualify can take advantage of the exemption from payment of regulatory fees allowed under the de minimis threshold discussed below in Section F. Small entities can also reduce their cost of compliance by availing themselves of the flexibility options for regulatory payees that the Commission made available in FYs 2020 and 2021 as a result of the COVID-19 pandemic. Pursuant to those options, small entities may request a waiver, reduction, deferral and/or installment payment of their FY 2022 regulatory fees. F. Steps Taken to Minimize the Significant Economic Impact on Small Entities, and Significant Alternatives Considered 38. The RFA requires an agency to provide, “a description of the steps the agency has taken to minimize the significant economic impact on small entities…including a statement of the factual, policy, and legal reasons for selecting the alternative adopted in the final rule and why each one of the other significant alternatives to the rule considered by the agency which affect the impact on small entities was rejected. 5 U.S.C. §604(a)(6). 39. The Report and Order for FY 2022 maintains several approaches from the FY 2021 regulatory fee framework which will minimize the significant economic impact for some small entities. Specifically, the FY 2022 regulatory fee framework maintains: (1) the methodology adopted using the population-based calculations for TV broadcasters that was initially adopted because it is a fairer methodology for smaller broadcasters; and (2) the flexibility for regulatory payees to request a waiver, reduction, deferral and/or installment payments of their regulatory fees adopted for FYs 2020 and 2021 as a result of the financial hardships produced by the COVID-19 pandemic. The waiver process is an easier filing process for smaller entities that may not be familiar with our procedural filing rules and (3) the application of the Commission’s de minimis threshold rule adopted pursuant to section 9(e)(2) of the Act, 47 U.S.C. § 159(e)(2). Section 9(e)(2) of the Act permits the Commission to exempt a party from paying regulatory fees if “in the judgment of the Commission, the cost of collecting a regulatory fee established under this section from a party would exceed the amount collected from such party.” which exempts a regulatee from paying regulatory fees if the sum total of all of its annual regulatory fee liabilities is $1,000 or less for the fiscal year. The de minimis threshold applies only to filers of annual regulatory fees and provides relief to small and other entities with lower annual regulatory fees. 40. There were alternative proposals on various elements of the methodology for assessing regulatory fees and the FY 2022 regulatory fee schedule that the Commission proposed in the FY 2022 NPRM, as well as other issues related to the collection of regulatory fees. Below we discuss a number of these proposals and why they were not adopted. 41. Allocating Full-time Equivalents. Several commenters questioned the Commission’s allocation methodology, NAB Comments at 8; Joint Broadcasters Reply at 3; Satellite Coalition Reply at 7. including proposing that we create an additional allocation category for the apportionment of regulatory fees. State Broadcasters Associations Comments at 15-16. In the Report and Order, we decline to modify the allocation methodology explaining that the Commission’s regulatory fees must cover the entire appropriation, including those FTEs who may work on issues for which we do not have regulatory fee categories. As a result, we continue to find that, consistent with section 9 of the Act, regulatory fees are not based on a precise allocation of specific employees with certain work assignments each fiscal year and instead are based on a higher-level approach. 42. Space Station and Submarine Cable Regulatory Fees. Fee modification alternatives involved three areas for this category - Non-Geostationary Orbit System (NGSO) Regulatory Fees, Spacecraft Performing On-Orbit Servicing (OOS) and Rendezvous and Proximity Operations (RPO) and Submarine Cable Regulatory Fees. We decline to make any fee modifications or to create additional regulatory fee categories for FY 2022 and adopt fee rates for NGSO space stations for FY 2022 for the reasons discussed below. 43. NGSO Space Station Regulatory Fees. We adopt the fee rates for NGSO space stations for FY 2022. We decline to change the methodology for calculating the regulatory fee for small satellites and small spacecraft (together, small satellites) that we adopted in the Report and Order attached to the FY 2022 NPRM. We also decline to create additional regulatory fee categories for FY 2022. The NGSO fee allocation maintained was adopted to ensure that regulatory fees more closely reflected the FTE oversight and regulation for each space station category, and no new arguments have been raised to warrant changes to the NSGO fee categories. Satellite Coalition Comments at 8-10. We further decline to modify the definition of “small satellites” for the purposes of regulatory fee assessment. OSK Comments at 1-4. Only space stations licensed pursuant to the streamlined small satellite licensing process under sections 25.122 and 25.123 of our rules are eligible to be assessed the small satellite regulatory fee. As the Commission noted in the FY 2022 NPRM, the streamlined small satellite rules are designed to lower the regulatory burden and reduce staff resources required for licensing, but the rules also restrict the benefits received by these licensees. FY 2022 NPRM at *8, para. 24. 44. OOS and RPO. In the FY 2022 NPRM, we sought comment on adopting regulatory fee categories for spacecraft performing OOS and RPO. FY 2022 NPRM at *15-*16, paras. 45-46. Proposals from commenters included creating a new fee category and how to define services in the new category, Spaceflight Comments at 3,7; Spaceflight Reply at 2; Turion Reply at 6.; Astroscale Reply at 1-2. and having an interim regulatory fee that is the same amount as the small satellite fee. Spaceflight Comments at 3-4; Turion Reply at 3-4. Commenters recognize, however, that in-space servicing is a relatively new industry. SIA Comments at 6; Spaceflight Comments at 6; Spaceflight Reply at 2; Astroscale Reply at 3. We decline to adopt a new regulatory fee for both OOS and RPO, and more generally for in-space servicing operations for FY 2022, because the Commission is required to notify Congress at least 90 days prior to creating such a change to the regulatory fee schedule. Section 9(c)(1)(B) of the Communications Act contemplates such changes to the fee schedule necessary to result in the collection of the amount required by subsection 159(b). 47 U.S.C. § 159(c)(1)(B). Changes under section 9(c) of the Communications Act fall under the section 9A(b)(1) Congressional notification requirements. 47 U.S.C. §§159A(b)(1), 159(c). Further, even absent the notice requirement, we find that the record does not support such action at this time. We do not currently have the experience or the robust record needed to establish definitions and methodologies for a new fee category for these operations that would fairly recover any costs that might be associated with such services. See FY 2022 NPRM, at *16, para. 46, n.137. A review of the licensing and regulatory fee history of small satellites shows that adopting a fair, sustainable and administrable fee system is generally only possible after the service is established and well defined with operational rules. In that instance, the first service rule took effect on August 19, 2020, and we are only in the position to assess fees on such systems for FY 2021. See Federal Communications Commission, Streamlining Licensing Procedures for Small Satellites, 85 Fed. Reg. 43711 (July 20, 2020). Similarly, in light of the Commission’s lack of experience and information, we decline to adopt an interim regulatory fee. We will gain a better understanding how to recover any regulatory costs and benefits that might be associated with these operations as we gain more experience in oversight and regulation of this industry. In addition, the Commission expects to gain more insight into this industry through the record associated with its Notice of Inquiry regarding commercial and other non-governmental In-space Servicing, Assembly, and Manufacturing (ISAM) activities. See generally Space Innovation; Facilitating Capabilities for In-space Servicing, Assembly, and Manufacturing, IB Docket No. 22-271, IB Docket No. 22-272, Notice of Inquiry, FCC-CIRC2208-03. 45. Submarine Cable Regulatory Fees. We reject a request to revise its regulatory fee methodology for submarine cable operators. The request contended that the “regulatory fee structure based upon cable system capacity is contrary to the mandate of the Communications Act, is overly burdensome, and is disconnected from the Commission’s responsibilities for regulatory oversight of the submarine cable industry” and our methodology “fails to take into consideration that the size of a system is not tied to the number of customers, nor the amount of revenue that it will generate.” Submarine Cable Coalition Comments at 3 (citing Submarine Cable Coalition Comments, MD Docket 20-105, at 3-8 (filed June 12, 2020); Submarine Cable Coalition Comments, MD Docket 21-190, at 3-4 (filed June 3, 2021)). We are not persuaded that our assessment of these regulatory fees based on capacity is contrary to the Act and is not reasonably related to the benefits provided. Submarine Cable Coalition Comments at 3-5. The Submarine Cable Coalition consists of Cable & Wireless Networks; GlobeNet Cabos Submarinos America, Inc.; GU Holdings Inc. (an indirect, wholly-owned subsidiary of Google LLC); Hawaiki Submarine Cable USA LLC; SETAR; and Tata Communications (Americas), Inc. Id. at 1-2. Additionally, the arguments proffered in this proceeding were the same arguments rejected by the Commission in the FY 2020 and FY 2021 proceedings. Submarine Cable Coalition at 3-5; see, e.g., FY 2020 Report and Order, 36 FCC Rcd at 1754, para. 58; FY 2021 Report and Order, 36 FCC Rcd at 13011-12, paras. 43-45. 46. Broadcaster Regulatory Fees for FY 2022. The Commission received proposals to reduce broadcasters regulatory fees associated with the Broadband DATA Act, UHF/VHF Stations and the Methodology for Full-Service TV Regulatory Fees. We decline to adopt any of the alternative proposals for the reasons discussed below. 47. Broadband DATA Act. In the FY 2022 NPRM, broadcasters’ regulatory fees are not exempt from the costs associated with work done by the Commission relating to broadband as they had been in FY 2021. Commenters contended that they should continue to be exempt from Commission work associated with broadband. NAB Reply at 7. We disagree. In FY 2021, the Commission adjusted its regulatory fees assessment approach for broadcasters FY 2021 Report and Order, 36 FCC Rcd 12995-999, paras. 11-16. to account for the unusual circumstances associated with the Broadband DATA Act. Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, Div. E, Title V, Federal Communications Commission, 134 Stat. 1182 (2020) (Consolidated Appropriations Act, 2021) (appropriating $374,000,000 to the Commission for salaries and expenses and directing the Commission to collect $374,000,000 in offsetting collections for FY 2021). Of the $374,000,000 appropriation, Congress directed that “$33,000,000 shall be made available until expended for implementing Title VIII of the Communications Act of 1934 (47 U.S.C. 641 et seq.), as added by the Broadband DATA Act (Public Law 116–130).” Id. The Broadband Deployment Accuracy and Technological Availability Act, Pub. L. No. 116-130, 134 Stat. 228 (2020) (codified at 47 U.S.C. §§ 641-646) (Broadband DATA Act) contemplated that a future appropriation for implementations costs might be partially offset by regulatory fees. Section 805 of the Broadband DATA Act provides that the Commission “may not use funds from the universal service programs” to pay for any costs associated with the Broadband DATA Act, but the Commission “may recover costs associated with this title under section 9 to the extent provided for in an appropriation Act, as required under subsection (a) of that section.” The Broadband DATA Act is available at https://www.congress.gov/116/plaws/publ130/PLAW-116publ130.pdf (last visited Aug. 12, 2022). Separately, Congress appropriated an additional $65 million for Broadband DATA Act implementation, which is not recovered through regulatory fees. Consolidated Appropriations Act, 2021, Division N, Title IX, § 906. Broadcasters or “Media Services” licensees were excluded from part of their share of indirect costs as a result of the one-time nature and magnitude of the earmark, the statutory text, the legislative history, and the record in the proceeding. FY 2021 Report and Order, 36 FCC Rcd at 12998-999, para. 16. In doing so, all other regulatory fee payors within the core bureaus, including cable, direct broadcast satellite (DBS), and Internet Protocol television (IPTV) providers regulated by the Media Bureau, had to absorb these indirect costs to ensure that the Commission collected the full annual appropriation as required by law. Id. (The Commission stated: “In doing so, we recognize that all other fee payors within the core bureaus, including cable, DBS and IPTV providers regulated by the Media Bureau, will need to absorb these indirect costs because we are required by Congress to collection the full annual appropriation.”) We decline to continue to exempt broadcasters because the Congressional mandate which was the impetus for the methodology change in FY 2021 is not present for FY 2022. See FY 2022 Consolidated Appropriations Act. In FY 2022, Congress did not provide an earmark for a particular purpose, and the accompanying direction regarding use of staff resources. 48. UHF/VHF Stations. Modification of the FY 2022 regulatory fees for VHF stations was proposed based on the contention that UHF stations should be assessed greater regulatory fees than VHF stations because of the ability of UHF stations to offer a wider array of services and thereby obtain greater revenues while VHF stations that cannot. NJBA Comments at 3-4. As the Commission did in FY 2020, we decline to categorically lower FY 2022 regulatory fees for VHF stations to account for signal limitations. Assessment and Collection of Regulatory Fees for Fiscal Year 2020, MD Docket No. 20-205, Report and Order and Further Notice of Proposed Rulemaking, 36 FCC Rcd 1731, 1739, para. 22 (2020) (FY 2020 Report and Order); FY 2020 NPRM, 35 FCC Rcd at 4997, para. 52. 49. Methodology for Full-Service TV Regulatory Fees. In the FY 2022 NPRM, the Commission rejected a request to revise the population-based methodology used for regulatory fee assessments for full-service television broadcasters proposed. NJAB Comments at 4. Finding a population-based methodology to be more equitable, the Commission completed the transition to a population-based full-power broadcast television regulatory fee in FY 2020. FY 2020 Report and Order, 36 FCC Rcd at 1738, para 19. 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). See Assessment and Collection of Regulatory Fees for Fiscal Year 2018, MD Docket 18-175, Report and Order and Notice of Proposed Rulemaking, 33 FCC Rcd 5091, 5101-102, at para. 27 (2018) (FY 2018 NPRM). In the FY 2018 NPRM, the Commission 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, the Commission adopted the new methodology and determined that we would fully transition to the methodology by FY 2020, and in the interim, for FY 2019, 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 8501-8502, para. 14. In the FY 2022 NPRM, we addressed this specific issue stating that it we are not reopening the FY 2020 decision to use the population-based methodology to determine these regulatory fees. FY 2022 NPRM at *16, para. 48. We recognize that the population-based methodology increases fees for some licensees and reduces fees for others, but in the end the population-based metric better conforms with the actual service authorized here—broadcasting television to the American people. FY 2020 Report and Order, 36 FCC Rcd at 1738, para. 19. Small and other entities can seek a waiver, reduction, or deferment of the fee, interest charge, or penalty on a case-by-case basis, “in any specific instance for good cause shown, where such action would promote the public interest.” 47 U.S.C. § 159A(d). Where financial hardship is the asserted basis for a waiver, the Commission has consistently interpreted that to require a showing that the requesting party “lacks sufficient funds to pay the regulatory fees and to maintain its service to the public.” FY 2019 Report and Order, 34 FCC Rcd at 8207, para. 50. 50. De Minimis Threshold. The Commission previously retained the de minimis threshold amount of $1,000 for determining whether a party is exempt from paying regulatory fees because the average cost for the Commission to collect regulatory fees did not exceed $1,000. In the Report and Order, we decline to increase this threshold or redefine the “cost of collection” to provide relief to small broadcasters, as proposed by some commenters. NAB Comments at 32-33; SIA Comments at 6-7; State Broadcasters Associations Comments at 18-19; Richards at 2. We acknowledge that the de minimis threshold has the collateral effect of providing financial relief to some regulatory fee payors, however, we do not interpret the language of section 9(e)(2) of the Act to allow providing relief for financial hardship as a factor that can be considered in setting this threshold. Moreover, nothing in the text of the statute supports using policy factors outside of the cost of collection in establishing the de minimis threshold. Further, we determine that raising the threshold on such a basis would result in exempting classes or categories of fee payors in a manner contrary to the limited waiver provisions for regulatory fees. 47 U.S.C. § 159A(d). 51. Nevertheless, we conducted a review of the de minimis threshold and calculated the average cost of collecting FY 2021 regulatory fees and included the cost of collecting payor fee data and the cost of processing waiver and installment plan requests, as suggested by some commenters. NAB Comments at 33; State Broadcasters Associations Comments at 18-19. In the final analysis, the inclusion of these costs did not increase the Commission’s average cost of collection above the $1,000 de minimis threshold. Therefore, we determined that the current costs for the Commission to collect regulatory fees including the costs of collecting payor fee data and processing waiver and installment requests, does not justify an increase to the existing $1,000 de minimis threshold. 52. Regarding the definition of the “cost of collection,” we do not agree that the cost of collecting a regulatory fee should be expanded to include all of the Commission’s costs to administer the regulatory fee program each year. State Broadcasters Associations Comments at 18; NAB Comments at 33. In support of its expansive definition of collection costs, NAB cites to a statutory provision defining the cost of the collection of a fee assessed by the U.S. Coast Guard to include “the reasonable administrative, accounting, personnel, contract, equipment, supply, training and travel expenses of calculation, assessing, collection, enforcing, reviewing, adjusting, and reporting” the fee. NAB Comments at 33 & n.98 (citing 14 U.S.C. § 946(h). We think NAB’s reliance on 14 U.S.C. § 946(h) is misplaced, for the simple reason that had Congress intended to define cost of collection in section 9 of the Act as expansively as it did in 14 U.S.C. § 946(h), it would have done so. Rather, we believe a sensible interpretation of the language of section 9(e)(2) of the Act includes only those costs incurred by the Commission once the Commission has established the annual fees. This occurs when the Commission’s regulatory fee report and order is released. Our belief in part, relies on the Debt Collection Improvement Act of 1996, as amended, 31 U.S.C. § 3701 et seq. (DCIA), which governs the federal administrative debt collection process for most federal agencies, including the Commission, and indicates that the collection of debt begins after an agency has determined that the debt is due. See 31 U.S.C. § 3701(b)(1) (defining “debt” or “claim” to mean an amount of funds or property, including a fee, that an appropriate agency official has determined is owed) and 31 U.S.C. § 3711(a) (directing agencies to collect debts owed to them). 53. Reclassification of FTEs from Direct to Indirect. In the FY 2022 NPRM, the Commission sought comment generally on whether prior reclassifications of FTEs from direct to indirect produce a more accurate regulatory fee assessment. FY 2022 NPRM at *14, para. 52. Comments relating to the 38 FTEs in the Wireline Competition Bureau who work on non-high-cost programs of the Universal Service Fund that were allocated as indirect FTEs for regulatory fee purposes by the Commission in 2017, FY 2017 Report and Order, 32 FCC Rcd at 7061-64, paras. 10-15. and the Commission’s 2019 reassignment of 95 FTEs (of which 64 were not auctions-funded) as indirect FTEs when the Commission created the Office of Economics and Analytics (OEA), contended that such allocations severely departed from the statutory requirement that regulatory fees be adjusted to reflect the benefits received by the payor by the Commission’s activities, NAB Comments at 12-13; Letter from the National Association of Broadcasters to Marlene H. Dortch, Secretary, FCC, MD Docket No. 22-223 (filed July 27, 2022); NAB Reply at 5. and should not be apportioned to regulatory payees that do not benefit from work by the FTEs. SIA Comments at 5. Based on these contentions, commenters request that Commission make changes associated with these allocations. 54. As we explain in the Report and Order, indirect FTEs work on a variety of issues and their time in many instances does not directly address oversight and regulation of a particular regulated entity or regulatory fee category. Moreover, pursuant to section 9 of the Act, 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). However, while we continue to find that the Commission was supported in its decision in 2017 to reassign the 38 FTEs in the Wireline Competition Bureau who work on non-high cost programs of the Universal Service Fund as indirect, we agree with broadcast commenters that the method for calculating the fees associated with these indirect FTEs should be corrected given the record in this proceeding, as well as the Commission’s prior findings. Therefore, we exclude “Media Services” licensees from recovery of the funds associated with the 38 indirect FTEs who work on non-high cost Universal Service Fund issues. While we acknowledge that other commenters have raised arguments about the Commission’s allocation of indirect FTEs more generally, we find that the record currently before us is not sufficiently developed to support affording similar relief to other regulatory fee payors based upon indirect FTE areas of work at this time. We believe that these issues would benefit from additional comment, as set forth in the accompanying Notice of Inquiry. 55. We are not persuaded that changes are required for the OEA FTE allocation, at this time, and expressly rejected the changes proposed in comments. SIA Comments at 5. First, an FTE is a full-time equivalent, not an employee, and is based on the hours of work devoted to the regulation and oversight of the fee categories and not a particular job title. See Procedures for Assessment and Collection of Regulatory Fees for Fiscal Year 2012, Notice of Proposed Rulemaking, 27 FCC Rcd 8458, 8460, para. 5 & n.5 (2012) (FY 2012 Regulatory Fee Reform NPRM); Procedures for Assessment and Collection of Regulatory Fees for Fiscal Year 2012, Report and Order, 27 FCC Rcd 8390, 8392 paras. 3-5 (2012) (FY 2012 Report and Order). The Commission, typically assesses the allocation of FTEs by first determining the number of direct FTEs, those non-auctions FTEs whose work is focused on the industry segment in each in each core bureau (i.e., the Wireless Telecommunications Bureau, the Media Bureau, the Wireline Competition Bureau, and the International Bureau), and then attributing all other non-auction FTEs as indirect. Second, FTE time working on auctions issues is not included in the Commission’s regulatory fee calculations and is funded separately. Also, OEA FTE numbers attributed to non-auction work stem from FTE levels in OEA’s Data Division, Economic Analysis Division, Industry Analysis Division, and its Front Office. The OEA staff participates in the review of all Commission-level items, from all of the Commission’s bureaus and offices, and provides economic and other data analysis to the Commission. 56. Proposals for New Regulatory Fee Categories. The Commission previously requested comments in the FY 2021 proceeding on adopting new regulatory fee categories and on ways to improve its regulatory fee process for any and all categories of service. FY 2021 Report and Order, 36 FCC Rcd at 13026, paras. 73-74 In response to our request for additional comments on these issues in the FY 2022 NPRM, we received new regulatory fee category proposals for: Holders of Experimental Licenses, Satellite Coalition Comments at 3; SIA Comments at 3; SIA Reply at 3-4. Broadband Internet Access Service, NAB Comments at 15-23. Holders of Equipment Authorizations, Satellite Coalition Comments at 4. Operators of Databases of Spectrum Used on an Unlicensed Basis, Id. and Users of Spectrum on an Unlicensed Basis. NAB Reply at 10-15; Satellite Coalition Comments at 3-4. We decline to adopt any new regulatory fee categories in the Report and Order because, at this time, there is not a sufficient basis to warrant adding the new proposed regulatory fees. Further, there is a lack of evidence and information in the record which would allow us to create these new fee categories and establish a fair, administrable and sustainable system for assessing the fees. G. Report to Congress 57. The Commission will send a copy of the Report and Order and Notice of Inquiry, including this FRFA, in a report to Congress pursuant to the Congressional Review Act. See 5 U.S.C. § 801(a)(1)(A). In addition, the Commission will send a copy of the Report and Order and Notice of Inquiry, including this FRFA, to the Chief Counsel for Advocacy of the SBA. A copy of the Report and Order and Notice of Inquiry, and FRFA (or summaries thereof) will also be published in the Federal Register. See 5 U.S.C. § 604(b). APPENDIX J Rule Changes Part 1 of Title 47 of the Code of Federal Regulations is amended to read as follows: PART 1 – PRACTICE AND PROCEDURE The authority citation for part 1 continues to read as follows: Authority: [TO BE INSERTED PRIOR FEDERAL REGISTER PUBLICATION] 1. Section 1.1151 of the Commission’s rules is revised to read as follows: §1.1151 Authority to prescribe and collect regulatory fees. Authority to impose and collect regulatory fees is contained in section 9 of the Communications Act, as amended by sections 101-103 of title I of the Consolidated Appropriations Act of 2018 (Pub. L 115-141, 132 Stat. 1084), 47 U.S.C. 159, which directs the Commission to prescribe and collect annual regulatory fees to recover the cost of carrying out the functions of the Commission. 2. Section 1.1152 is revised to read as follows: § 1.1152 Schedule of annual regulatory fees for wireless radio services. Exclusive use services (per license) Fee Amount Note that “small fees” are collected in advance for the entire license term. Therefore, the annual fee amount shown in this table that is a small fee (categories 1 through 5) must be multiplied by a 10-year license term, as appropriate, to arrive at the total amount of regulatory fees owed. Also, application fees may apply as detailed in § 1.1102 of this chapter. 1. Land Mobile (Above 470 MHz and 220 MHz Local, Base Station & SMRS) (47 CFR part 90) a)New, Renew/Mod $25.00 (FCC 601 & 159) b) New, Renew/Mod $25.00 (Electronic Filing) (FCC 601 & 159) c)Renewal Only $25.00 (FCC 601 & 159) d)Renewal Only $25.00 (Electronic Filing) (FCC 601 & 159) 220 MHz Nationwide $25.00 a)New, Renew/Mod (FCC 601 & 159) b)New, Renew/Mod $25.00 (Electronic Filing) (FCC 601 & 159) c)Renewal Only $25.00 (FCC 601 & 159) d)Renewal Only $25.00 (Electronic Filing) (FCC 601 & 159) 2. Microwave (47 CFR Pt. 101) (Private) a)New, Renew/Mod $25.00 (FCC 601 & 159) b)New, Renew/Mod $25.00 (Electronic Filing) (FCC 601 & 159) c)Renewal Only $25.00 (FCC 601 & 159) d)Renewal Only $25.00 (Electronic Filing) (FCC 601 & 159) 3. Shared Use Services Land Mobile (Frequencies Below 470 MHz – except 220 MHz) a)New, Renew/Mod $10.00 (FCC 601 & 159) b) New, Renew/Mod $10.00 (Electronic Filing) (FCC 601 & 159) c)Renewal Only $10.00 (FCC 601 & 159) d)Renewal Only $10.00 (Electronic Filing) (FCC 601 & 159) Rural Radio (Part 22) a)New, Additional Facility, $10.00 Major Renew/Mod (Electronic Filing) (FCC 601 & 159) b)Renewal, Minor Renew/Mod $10.00 (Electronic Filing) (FCC 601 & 159) Marine Coast a)New Renewal/Mod $40.00 (FCC 601 & 159) b)New, Renewal/Mod $40.00 (Electronic Filing) (FCC 601 & 159) c)Renewal Only $40.00 (FCC 601 & 159) d)Renewal Only $40.00 (Electronic Filing) (FCC 601 & 159) Aviation Ground a)New, Renewal/Mod $20.00 (FCC 601 & 159) b)New, Renewal/Mod $20.00 (Electronic Filing) (FCC 601 & 159) c)Renewal Only $20.00 (FCC 601 & 159) d)Renewal Only $20.00 (Electronic Only) (FCC 601 & 159) Marine Ship a)New, Renewal/Mod $15.00 (FCC 605 & 159) b)New, Renewal/Mod $15.00 (Electronic Filing) (FCC 605 & 159) c)Renewal Only $15.00 (FCC 605 & 159) d)Renewal Only $15.00 (Electronic Filing) (FCC 605 & 159) Aviation Aircraft a)New, Renew/Mod $10.00 (FCC 605 & 159) b)New, Renew/Mod $10.00 (Electronic Filing) (FCC 605 & 159) c)Renewal Only $10.00 (FCC 605 & 159) d)Renewal Only $10.00 (Electronic Filing) (FCC 605 & 159) 4. CMRS Cellular/Mobile Services $ .14 These are standard fees that are to be paid in accordance with § 1.1157(b) of this chapter. (per unit) (FCC 159) 5. CMRS Messaging Services $ .08 These are standard fees that are to be paid in accordance with § 1.1157(b) of this chapter. (per unit) (FCC 159) 6. Broadband Radio Service $ 590 (formerly MMDS and MDS) 7. Local Multipoint Distribution Service $ 590 3. Section 1.1153 is revised to read as follows: § 1.1153 Schedule of annual regulatory fees and filing locations for mass media services. Radio [AM and FM] (47 CFR part 73) Fee Amount 1. AM Class A <=25,000 population $1,050 25,001-75,000 population $1,575 75,001-150,000 population $2,365 150,001-500,000 population $3,550 500,001-1,200,000 population $5,315 1,200,001-3,000,000 population $7,980 3,000,001-6,000,000 population $11,960 >6,000,000 population $17,945 2. AM Class B <=25,000 population $755 25,001-75,000 population $1,135 75,001-150,000 population $1,700 150,001-500,000 population $2,550 500,001-1,200,000 population $3,820 1,200,001-3,000,000 population $5,740 3,000,001-6,000,000 population $8,600 >6,000,000 population $12,905 3. AM Class C <=25,000 population $655 25,001-75,000 population $985 75,001-150,000 population $1,475 150,001-500,000 population $2,215 500,001-1,200,000 population $3,315 1,200,001-3,000,000 population $4,980 3,000,001-6,000,000 population $7,460 >6,000,000 population $11,195 4. AM Class D <=25,000 population $720 25,001-75,000 population $1,080 75,001-150,000 population $1,620 150,001-500,000 population $2,435 500,001-1,200,000 population $3,645 1,200,001-3,000,000 population $5,470 3,000,001-6,000,000 population $8,200 >6,000,000 population $12,305 5. AM Construction Permit $655 6. FM Classes A, B1 and C3 <=25,000 population $1,145 25,001-75,000 population $1,720 75,001-150,000 population $2,575 150,001-500,000 population $3,870 500,001-1,200,000 population $5,795 1,200,001-3,000,000 population $8,700 3,000,001-6,000,000 population $13,040 >6,000,000 population $19,570 7. FM Classes B, C, C0, C1 and C2 <=25,000 population $1,310 25,001-75,000 population $1,965 75,001-150,000 population $2,950 150,001-500,000 population $4,430 500,001-1,200,000 population $6,630 1,200,001-3,000,000 population $9,955 3,000,001-6,000,000 population $14,920 >6,000,000 population $22,390 8. FM Construction Permits $1,145 TV (47 CFR, part 73) Digital TV (UHF and VHF Commercial Stations) 1. Digital TV Construction Permits $5,200 2. Television Fee Factor $.008430 per population count Low Power TV, Class A TV, TV/FM $ 330 Translator, & FM Booster (47 CFR part 74) 4. Section 1.1154 is revised to read as follows: § 1.1154 Schedule of annual regulatory charges for common carrier services. Radio Facilities Fee Amount 1. Microwave (Domestic Public Fixed) $25.00 (Electronic Filing) (FCC Form 601 & 159) Carriers 1. Interstate Telephone Service Providers $ .00452 (per interstate and international end-user revenues (see FCC Form 499-A) 2. Toll Free Number Fee $.12 per Toll Free Number 5. Section 1.1155 is revised to read as follows: § 1.1155 Schedule of regulatory fees for cable television services. Fee Amount 1. Cable Television Relay Service $1,715 2. Cable TV System, Including IPTV $ 1.16 per subscriber and DBS (per subscriber) 3. Direct Broadcast Satellite (DBS) $1.16 per subscriber 6. Section 1.1156 is revised to read as follows: § 1.1156 Schedule of regulatory fees for international services. a.         The following schedule applies for the listed services: Fee Category Fee Amount Space Stations (per operational station in geostationary orbit) (47 CFR part 25) also includes DBS Service (per operational station) (47 CFR part 100) $124,060 Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25) (Other) $340,005 Space Stations (per operational system in non-geostationary orbit) (47 CFR part 25) (Less Complex) $141,670 Space Stations (per license/call sign in non-geostationary orbit) (47 CFR part 25) (Small Satellite) $12,215 Earth Stations:  Transmit/Receive & Transmit only (per authorization  or registration) $620 b.         International Terrestrial and Satellite.  Regulatory fees for International Bearer Circuits are to be paid by facilities-based common carriers that have active (used or leased) international bearer circuits as of December 31 of the prior year in any terrestrial or satellite transmission facility for the provision of service to an end user or resale carrier, which includes active circuits to themselves or to their affiliates.   In addition, non-common carrier terrestrial and satellite operators must pay a fee for each circuit sold or leased to any customer, including themselves or their affiliates, other than an international common carrier authorized by the Commission to provide U.S. international common carrier services.  “Active circuits” for these purposes include backup and redundant circuits.  In addition, whether circuits are used specifically for voice or data is not relevant in determining that they are active circuits. The fee amount, per active Gbps circuit will be determined for each fiscal year. International Terrestrial and Satellite (capacity as of December 31, 2021) Fee Amount Terrestrial Common Carrier and Non Common Carrier Satellite Common Carrier and Non-Common Carrier $39 per Gbps circuit c.         Submarine cable:  Regulatory fees for submarine cable systems will be paid annually, per cable landing license, for all submarine cable systems operating as of December 31 of the prior year.  The fee amount will be determined by the Commission for each fiscal year.  FY 2022 International Bearer Circuits - Submarine Cable Systems Submarine Cable Systems (capacity as of December 31, 2021) Fee Ratio FY 2021 Regulatory Fees Less than 50 Gbps .0625 Units $8,610 50 Gbps or greater, but less than 250 Gbps .125 Units $17,215 250 Gbps or greater, but less than 1,500 Gbps .25 Units $34,430 1,500 Gbps or greater, but less than 3,500 Gbps .5 Units $68,860 3,500 Gbps or greater, but less than 6,500 Gbps 1.0 Unit $137,715 6,500 Gbps or greater 2.0 Units $275,430 2