Reply comments filed last week in response to the FCC’s plan to reform the agency’s regulatory fee process highlighted the concerns of satellite industry players, who warned that the proposed revisions will bring about significant fee increases that do not reflect the cost and amount of regulation applied to earth and space station licensees. In a rulemaking noticeissued in July, the FCC sought comment on proposals to update the agency’s regulatory fee regime by allocating all fulltime FCC employees (FTEs) in the core wireless, media, wireline and international bureaus as “direct” FTEs and to treat FTEs in other support bureaus as “indirect.” Declaring it “completely impractical” for the FCC to evaluate the activities of FTEs in each of the core bureaus and to allocate the time spent by those FTEs across all companies that benefit from their regulatory efforts, the National Cable & Telecommunications Association applauded the FCC’s proposed blanket approach as “both fair and administrable.” To ensure equitable treatment of all multichannel video program distributors (MVPDs), the American Cable Association further advised the FCC to reform its fee categories to ensure that all MVPDs, including direct broadcast satellite providers, “pay their fair share.” (Under the FCC’s current regulatory fee system, only cable operators and licensees of cable antenna relay systems are required to pay fees that are derived from the Media Bureau’s costs.) Although the FCC’s proposals were also endorsed by Verizon Communications, Verizon Wireless and USTelecom, among others, the Satellite Industry Association (SIA) emphasized that only FTEs of the International Bureau Satellite Division “can be considered direct costs for satellite regulatory fee players.” As such, SIA argued that the imposition of costs associated with the work of other core bureau FTEs on satellite operators “is demonstrably unfair and inconsistent with the statutory purpose.” Complaining that regulatory fees paid by satellite licensees already exceed the actual FCC resources allocated to such licensees, Sirius XM argued that the FCC’s proposal “further exacerbates this inequity and must be rejected.” Along similar lines, Intelsat observed that satellite licensees “continue to pay increasingly high . . . fees, even as the commission has streamlined licensing processes and requirements for space and earth stations.” Globalstar, meanwhile, voiced concerns that the proposed rule revisions “could result in a significant and unjustified increase in the fees paid by satellite operators.”