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Consultants Presented FCC With Range of Field

Office Options
Leslie Stimson,04/23/2015

More details are emerging about the FCCs proposal to

close many of its Enforcement Bureau field offices.
In a document prepared by Oceaneast Associates and
Censeo Consulting Group that was shared (by a broadcast source) with me in Las Vegas
last week, they lay out options for modernizing the bureaus field offices and redeploying
resources, taking into account the FCCs changing needs.
In the cover letter that accompanied the report to Oregon Republican Greg Walden,
chairman of the House Subcommittee on Communications and Technology, FCC
Chairman Tom Wheeler states the review began last October. He reiterates the costs: our
licensees pay over $20 million a year to support 24 field sites and the average
administrative overhead cost level to maintain just one field location is $400,000. Overall
support costs per full-time equivalent employee for field staff are more than double that
of headquarters staff, according to Wheeler.
The field offices cost some $21 million annually, according to the material, much of that is
labor and $3.7 million is office-related. The new expenditures would be between $9 million
to $10 million annually, under the current proposal.
The consultants estimate that 108 personnel work in the field offices for a total of $12
million annually in wages and an additional $3 million in benefits.
The team working on the report consulted with 160+ stakeholders, including CTIA, NTIA,
NAB, FAA, wireless carriers, former Enforcement Bureau leadership, the Army, equipment
manufacturers and others.
Some 40% of field time addresses RF spectrum enforcement: 8% is spent on public
safety interference, 7% on cellular/LTE interference and another 7% on pirate radio,
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according to the document. Lower priority activities, like tower inspections, which have a
high rate of compliance, take up significant (as in 8% of) time, and agents spend about
25% of their time on administrative activities.
The agency should focus on developing and using more portable direction-finding
equipment, concludes the consultants, quoting sources about the vehicles as saying:
Were not as dependent on our cars for direction-finding as we used to be, and We only
need undercover vehicle 1520% of the time. The 74 direction-finding vehicles consume
some $90,000 to $115,000 each.
Enforcement Bureau Chief Travis LeBlanc told attendees at the NAB Show last week that
agents morale was low when he came to the commission a year ago. The document
backs this up, noting morale and retention issues that are likely driven by excessive
management layers, [a] perceived lack of feedback and unclear linkage to the mission.
Two quotes to that effect are: We rarely hear what happens after a case is submitted,
which is demoralizing and makes us feel like our work is not valued. Another is: I have
no idea what HQ defines as success.
A range of total field offices was considered, from having none to 11. The consultants
recommended the agency go with eight, and thats what weve reported the current plan
is. And the plan assumes the Tiger Teams that would deploy to help any of the offices
would be able to fly within three hours or less to the nearest field offices.
To say that broadcasters are skeptical that the Tiger team concept will work is an
understatement. The DOE for a radio group said the field office closure plan sickens me
and fears pirates will become even more of an issue to licensed broadcasters. Chairman
Wheeler pledged to put more agents on the ground in Miami and New York specifically to
combat pirates, however broadcasters remain skeptical of the plan.
One broadcast attorney deemed the Tiger team concept crazy and doubts there will be
much of a travel budget in the new plan. To find any source of RF interference, especially
if its intermittent, agents need to know the local geography and have local contacts,
numerous sources have told me.
Broadcast engineers at the show asked me whether telework had been considered;
indeed, it was under the various office deployment scenarios, but that option offered
limited equipment and case prioritization flexibility, concluded the consultants.
Im curious about this option, because the federal government and the private sector have
been encouraging telework in the last few years, both to save money and get better work
out of their employees who are not worn down by a long commute. A former field office
director tells me telecommuting has been done in a limited fashion for years, and hes
incredulous the consultants dismissed that option.
He termed case prioritization a nebulous term. Havent these people ever heard of
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email to assign or discuss case prioritization? Or maybe they could use the phone! We
wouldn't have these telecommuters locked up in some isolated room somewhere without
any means to interact would we?
As far as moving or storing the equipment, assuming the consultants refer to directionfinding cars and spectrum analyzers, this source suggests renting a secure storage space
or making storage arrangements with another government agency: The agent would drive
to the nearby location, pick-up the stuff they needed for that particular case and be on
their way.
The latter might work under the consultants scenario, since the document refers to
increased collaboration with other bureaus, agencies and organizations as a future goal.
Depending on how the commission chooses to proceed, a variety of one-time
expenditures are related to implementing the current proposal, such as potential
personnel exit costs, and outlays related to exiting space leases, shipping equipment,
new construction costs estimated to comprise a total of between $2 million to $4
million.
NAB and the FCC are still talking about the closure plan, which, hopefully, is a good sign
and I hear other industries are involved in similar talks.

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