When it comes to paying the piper for regulatory fees, the National Association of Broadcasters believes that the scales are still unbalanced against radio and TV license holders.
In its filing to the Federal Communications Commission after its preliminary assessment of regulatory fees for Fiscal Year 2026, NAB explained that it appreciates the FCC’s efforts to improve the collection process.
As far as this year’s proposal is concerned, NAB is on board with the FCC’s contour-based methodology for calculating TV regulatory fees, for example.
Commercial radio stations in the U.S. would see their fees go up around 5% under the planned schedule, as we reported in April. Typically, the exact fees are announced by the FCC at the start of September and are then due to be paid at the end of the current fiscal year. This time around, it ends Sept. 30.
But prior to the reveal of the FY 2026 fees, NAB offered a number of suggestions it feels would make the proposal more reasonable for broadcasters.
The association is worried about a large rate hike for transmit-capable earth stations and also said the de minimis threshold for fee payors needs to be above $1,000.
At the heart of the matter, though, is what NAB has believed to be true for a long while: Broadband and large technology companies need to pay new regulatory fees to help pay for the work of the commission’s full-time employees.
Last year, NAB and Telesat asked the FCC to create five new regulatory categories. The commission rejected that proposal. But NAB hasn’t given up.
“The current regulatory fee process disproportionately burdens a limited group of legacy industries, despite that a larger set of entities benefit from the commission’s work,” NAB wrote in its May 28 filing. “It is neither fair nor sustainable for a small group of payors to retain the responsibility for funding the commission’s broad and growing portfolio of activities,” it continued.
NAB also argued that the commission needs to be more transparent to account for work conducted by full-time employees in non-core bureaus.
“Without knowing why certain FTEs have been reallocated, NAB and other commenters are unable to provide a ‘thorough analysis showing a sufficient basis’ for a proposed change or modification to the commission’s reallocation decisions,” it wrote in the filing.
(Read the NAB’s review of the FCC’s assessment and collection of regulatory fees for FY 2026.)
The information gap
The FCC’s FY 2026 proposed rulemaking sought comments regarding “ways that the commission can improve the regulatory fee process.”
NAB’s response was rather straightforward: “The commission can improve the process by expanding its base of regulatory fee payors to include all entities that benefit directly from the commission’s activities.”
While the FCC has previously rejected such proposals for new categories by citing a “lack of specificity” from commenters, NAB argued that outside groups suffer from an “information asymmetry” that prevents them from providing deeper data.
“Only the commission has access to internal FTE data,” it wrote.
Under the current fee structure, the costs of non-core bureaus are supposed to be “proportionally allocated” across core bureaus like the Media Bureau.
However, NAB argued that the commission’s analysis improperly excludes staff in certain non-core offices simply because they happen to work on matters pertaining to non-fee payors — like Big Tech.
Similarly, while NAB acknowledged that broadcasters are technically exempt from the indirect costs associated with Universal Service Fund staff within the Wireline Competition Bureau, it argues these FTEs should be reclassified as direct costs.
Because the USF benefits specific telecom payors and not broadcasters, NAB contended that leaving them in the general overhead pool forces radio and TV stations to unfairly subsidize them.
NAB applied this same logic to broadband data mapping under the Broadband DATA Act, noting that “broadcasters simply do not benefit from this work.”
Doubly-burdened
NAB is also concerned over a proposed hike in fees transmit-capable earth stations face, used by radio and TV stations for satellite-based uplinks.
Under the FCC’s FY 2026 proposal, regulatory fees for earth stations are set to increase by 46% to $3,010 in FY 2026.
It pointed out that broadcaster-operated earth stations are fixed facilities that “do not move or change operating parameters,” resulting in what NAB views as minimal FCC oversight.
Radio and TV stations, NAB said, pay earth station regulatory fees in addition to the fees for their own licenses, which “unfairly compounds” the burden on broadcasters, who it emphasized “provide their services to the public for free.”
At the same time, NAB said that the proposed hike comes with a reduction of FTEs in the Space Bureau from 51 to 48.
It acknowledged that the number of earth stations decreased from 4,000 in 2025 to 3,250 this year, and because the revenue requirement for those stations went up approximately 18%, the fee for licensees “must inevitably rise.”
But NAB contended that the bulk of the Space Bureau’s recent work goes to the oversight and regulation of non-geostationary orbit satellites.
Non-GSO, large constellation satellites only saw an approximately 15% increase under the proposal, NAB said.
There are 19,415 regulated non-GSO satellites, including from SpaceX, Kuiper and WorldVu constellations, compared to 152 U.S.-regulated GSO satellites, according to NAB.
Those non-GSO stations are charged per system, it explained, and the entire Starlink constellation of 11,908 satellites has a proposed assessment of approximately $2.27 million, which amounts to $191 per satellite.
Conversely, each GSO satellite, NAB said, will be charged a fee of $178,700.
Raising the bar
NAB also desired the de minimis threshold to be increased above $1,000.
Under the Communications Act of 1934, the FCC can exempt fee payors if the cost of collecting such a fee would exceed the amount the party would contribute.
The rise in a salary of a Step 1 commission employee alone, from $106,000 in 2022 to approximately $121,000 today, warrants review of whether the threshold remains justified, NAB said.
To prove its point, NAB contrasted the proposed fee increases against last year’s rates for several radio license classes.
Under the new proposal, FM Classes A, B1 and C3 — covering populations between 10,001 and 25,000 — will see fees rise to $1,050 — pushing them just past the current $1,000 exemption line. Similarly, AM Class B stations — populations between 25,001 and 75,000 — will see fees rise to $1,035.
Last year, both of these groups fell just under the $1,000 threshold — $1,000 and $985 respectively — and were exempt.
These smaller radio stations are suddenly facing new bills, NAB said.
To rectify this, NAB recommends raising the de minimis threshold to $1,200, so that radio broadcasters who fell under the exemption last year can do so again in FY 2026.
Reply comments for the FCC’s assessment and collection of FY 2026 regulatory fees are due by June 12 via Docket No. 26-94.
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