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The record so far demonstrates that FCC proposals to subject wireless carriers to a regulatory fee for interstate telecommunications service providers (ITSPs) and to reallocate some full-time equivalent employees (FTEs) are “ill-advised and, if not rejected outright, at the very least should be subject to further scrutiny and greater transparency,” CTIA said in reply comments on a May NPRM on regulatory fee reform (CD June 24 p5). “Commenters have expressed grave concerns and have identified significant flaws in the proposal to include wireless regulatees in the ITSP regulatory fee category,” CTIA said (http://bit.ly/153bJki). “In particular, industry growth is not a basis for setting regulatory fees under Section 9 of the Communications Act. Moreover, as CTIA demonstrated in its initial comments, claims that wireline regulatees are paying more than their fair share of regulatory fees fail to account for the fact that wireless regulatees contribute more to the Commission’s overall budget than ITSPs or any other group of regulatees.” CTIA said the NPRM’s proposal “to reallocate the FTEs in certain core bureaus creates a tremendous amount of complexity and uncertainty regarding the calculation of regulatory fees across all bureaus.”