Historically, the FCC has charged VHF TV stations significantly higher fees than those assessed their UHF counterparts. I haven't seen a justification for this, but it’s likely due to the VHF analog stations having been the dominant stations in a market prior to the June 2009 digital transition. In some cases, this laid them open to renewal challenges which required more FCC resources.
After the 2009 transition, many of the dominant network-owned and network-affiliated stations wound up transmitting on UHF channels and thus subject to a much lower regulatory fee. Unlucky stations that moved to a VHF channel after formerly operating in UHF spectrum saw a huge jump in their regulatory fees. The FCC recognized the problem, but was more concerned about the impact on smaller stations transmitting on UHF channels. It would be hard to explain why TV stations transmitting on VHF were being charged more when the incentive auction would pay stations to move to those channels.
A Notice of Proposed Rulemaking, Second Further Notice of Proposed Rulemaking, and Order, released on Friday, June 13 may change this. In the NPRM, the FCC proposed that UHF/VHF regulatory fees be combined into a single digital television category.
Under the proposed FY2014 fees, a top-10 market VHF station that paid $86,075 last year will pay only $44,875 this year—the same as a top-10 market U. Last year, that UHF station paid $38,000. Top-10 VHF stations will pay 47.9 percent less, with comparable market UHF stations paying 18.1 percent more.
In U.S. television markets 51-100, the proposed combined VHF/UHF fee is $15,675, compared to last year's fees of $22,475 for VHFs and $13.700 for UHFs. This represents approximately a 30 percent drop for a V and a 14 percent increase for a commercial U.
Proposed FY2014 regulatory fees for LPTV, TV/FM translators, boosters and Class A TV stations would remain unchanged at $410, as would broadcast auxiliary licenses at $10. Fees for Earth stations, which includes Ku-band uplinks used for SNG, are supposed to drop from $275 to $240.
Fees for AM and FM radio stations are unchanged in all markets, but the AM stations operating in the expanded band would no longer be exempt from FCC regulatory fees.