An FCC proposal to overhaul the agency’s regulatory fee structure by adjusting the levels of full time employees (FTEs) in the four “core” bureaus of the FCC has arisen as a key point of contention among providers of international calling services, who claim the plan will significantly increase the regulatory fees they must pay. This week, the FCC received feedback on its regulatory fee proposals in comments filed by providers of international services and their representatives, such as America Movil (AM), the International Carrier Coalition (ICC) and the North American Submarine Cable Association (NASCA), major domestic carriers such as AT&T and Verizon, the U.S. Telecom Association (USTA), the Satellite Industry Association, and the National Association of Broadcasters. Under the approach proposed by the FCC, the agency would update data based on the number of FTEs in its four core bureaus—Media, Wireline Competition, Wireless Telecommunications and International—and allocate FTEs proportionally from other “support” bureaus and offices to the four core bureaus. Complaining that the allocation plan would raise the percentage of fees allocated to submarine cable providers and other International Bureau licensees from 6.7% to 22%, AM advised the FCC: “while no increase in regulatory fees for submarine cable licensees would be appropriate based on . . . declining regulation, at a minimum the Commission must recognize that a significant number of the FTEs of the International Bureau are engaged in activities that benefit licensees regulated by other bureaus.” The FCC’s rulemaking notice, added NASCA, “fails to explain why changes in Commission regulation or workload might justify . . . the tripling of regulatory fees paid by submarine cable operators and other International Bureau licensees.” Similarly, the ICC said that one proposal envisioning a “straight head count” of FTEs in the applicable agency bureaus “makes no adjustment at all to reflect the benefits provided to the payer of the fee” and would thereby violate applicable statutory provisions. Declaring, however, that providers of domestic interstate telecommunications services “have been over-assessed for more than a decade, and thus other categories of fee payers have been under-assessed for that same period,” USTA quipped: “it has been obvious to all FCC regulatory fee payers . . . that substantial adjustments to the fee system are long overdue, and therefore such payers should be prepared to adjust.”