Further on the subject of FCC enforcement per David Woolweaver's timely note the other day, here is an article in the new Radio World broadcast engineering publication on the subject. Also, Riley Hollingsworth reports to us from his meeting yesterday with Laura Smith that there are further FCC field office closings in January. On the good news side, Laura, back in her role as Special Counsel for Amateur Radio Enforcement, has been given essentially full autonomy in that role by her current boss, Bruce Jacobs. 73, Chris W3KD *WASHINGTON —* The Federal Communications Commission is moving ahead with its plan to shed field staff and close many offices. Meanwhile, few details have been made public about the creation of emergency “Tiger Teams” to handle special enforcement situations; some observers are skeptical that the approach will be effective. *FROM THE EDITOR* *Randy Stine writes here to update us on the closure of FCC field offices. When Randy started work on this assignment, there had been little to no new information from the commission since the hullaballoo over the closures last year, so we thought this story was going to be “FCC mum, Tiger Teams delayed.” But shortly thereafter came word that the closures are in fact pending come the New Year. Let us know what you hear in the trenches.* *— Paul McLane* The commission in January will close field offices in Buffalo, Detroit, Houston, Kansas City, Norfolk, Philadelphia, San Diego, Seattle and Tampa. Industry watchers expect these moves will put additional pressure on remaining staff. Meanwhile, delays in forming the rapid response teams could allow holes in the enforcement fence to develop. The on-call Tiger Teams are supposed to be based in Columbia, Md., and Denver to supplement enforcement efforts of other field offices and, when necessary, to support high-priority enforcement actions nationwide. Chairman Tom Wheeler testified before the House Subcommittee on Communications and Technology in 2015 that the teams would be deployed within 24 hours of an interference crisis. Equipment was to be “prepositioned” at about a half dozen sites across the country. iStockphoto/Sylvie BouchardLittle information had emerged from the commission since then about the status of the Tiger Team effort, but in August an FCC spokesperson told Radio World the commission expects to have the special on-call positions filled by January. “Field office staff will also have the resources and flexibility needed to travel in order to address issues outside of their region,” the spokesperson said. Broadcasters and some on Capitol Hill complained about the field office cuts; the National Association of Broadcasters and the Society of Broadcast Engineers worried that the moves will limit the FCC’s ability to mitigate interference complaints. Before the plan could be implemented the FCC had to reach an agreement over projected job losses with the union representing Enforcement Bureau field employees. The National Treasury Employees Union had been a vocal critic of the overhaul, questioning the commission’s ability to safeguard radio spectrum in the future. A FCC spokesperson told Radio World that displaced agents will have the opportunity to apply for vacancies in the remaining field offices, if a vacancy exists. Field offices will remain open in Atlanta, Boston, Chicago, Columbia, Md., Dallas, Denver, Honolulu, Los Angeles, Miami, New Orleans, New York, Portland, Ore., and San Francisco. *ON-CALL* In July 2015, the commission decided to close nine field offices and eliminate at least 44 jobs; this was said to be the first reorganization of FCC field operations in 20 years. The moves, led by Chairman Wheeler, were designed to eliminate redundancies and realize cost savings, according to an FCC report. The field office closings are expected to save millions of dollars per year. Data provided by the FCC in 2015 showed the average administrative overhead cost level to maintain one field location came in at $400,000 per year. An earlier plan had called for the closure of even more offices; it would have left only eight remaining but came under criticism and was later scaled back. The revised plan was a compromise with the House Subcommittee on Communications and Technology; it keeps 15 regional offices open. To help smooth the transition to a smaller field staff, last fall, the FCC appointed Charles Cooper as its first Enforcement Bureau field director. Cooper, who is expected to be based in Los Angeles, worked prior with the broadcast engineering consulting firm du Treil, Lundin & Rackley. *PIRATES* While the field office transition moves ahead, the FCC has been under pressure to put renewed focus on illegal radio operations. Wheeler told the House Subcommittee on Communications and Technology in July that 91 actions had been taken this year against pirate radio stations compared to 130 actions all of last year. A recent engineering survey by the New York State Broadcasters Association found 76 illegal radio signals in New York City and northern New Jersey, concentrated in the Bronx, Brooklyn, Newark and Paterson. The association has been vocal in its call for the FCC to crack down. Some observers believe the move to reduce field offices and staff numbers will hurt the agency’s ability to mitigate interference. An aide for the House Subcommittee on Communications and Technology, who asked to not be identified, said its chairman, Rep. Greg Walden, R-Ore., is monitoring the situation but isn’t sure how things are working out so far. Walden is a former broadcaster. “We hear complaints about interference in the broadcast radio band continue to come into the FCC but are unsure how the new plans are affecting enforcement efforts, good or bad,” the aide said. “We still have concerns that as the FCC is reducing field staff that they still be able to perform the function of which the agency was founded, which is resolving interference concerns.” The subcommittee aide said Wheeler is “acutely aware” of Walden’s interest in the matter. “We want to see the Tiger Teams set up. We certainly expect the FCC to follow through on its plans.” *CONCEPT “FAILED”?* The Society of Broadcast Engineers remains concerned about the effects of the office closures, said Chris Imlay, its general counsel. “Morale in the Spectrum Enforcement Division at the commission is at a very low ebb; skilled, experienced and tenured field office staff have been retired,” Imlay said this summer. “The promised two Tiger Teams that were to have been dispatched to areas where there is no field office presence to respond to interference cases have not been staffed, and that entire concept appears to have failed.” Imlay said the SBE has learned that positions for the Tiger Teams were posted by the FCC but went unfilled “because the job involved, by definition, 100 percent travel time.” The SBE did not favor the compromise between the House subcommittee and Wheeler last year. It believes the plan is unworkable and an unjustified departure from the commission’s statutory mandate. Walter Gernon, a former FCC district director for the states of Louisiana, Mississippi and Arkansas, is critical of the FCC’s plans. He said the long-term result would be degraded communications for licensees and the general public. “The folks I talk to in the field are demoralized and discouraged. It’s a very delicate situation with a lot of people in limbo for the past year,” he said. “Honestly, the FCC is hemorrhaging technical staff right now because of retirements and the new requirements.” As part of its modernization, the commission also has said it will require all field agents to be electrical engineers. That shift was expected eventually to cost a half-dozen compliance specialists their jobs. “This plan will result in the loss of an astounding amount of institutional knowledge in the field that can’t be replaced,” Gernon said. “I think this plan endangers the communications infrastructure of this country.” Gernon, who spent 30 years with the FCC, doubts the effectiveness of Tiger Teams to deal with emergency interference problems once they are assembled. “FCC field agents at one time were allowed to be proactive and to anticipate problems. They knew all the broadcasters. To think that you could just drop an agent or two into a market without knowledge of that specific market and be successful is unreasonable.” *Comment on this or any story to *radioworld@nbmedia.com. - See more at: http://www.radioworld.com/article/update-fcc-field-offices-to-close-in-janua... -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG