Life Member Jim, K9SE is particularly well qualified to comment on the FCC field reorganization. Dave K1ZZ From: James M. Roop [mailto:k9se@comcast.net] Sent: Tuesday, July 14, 2015 12:00 PM To: Sumner, Dave, K1ZZ Cc: Henderson, Dan N1ND Subject: RE: "It Seems to Us - The 50% Solution", August 2015 QST Dave, Feel free to share with the Board. If I can be of any further service, please feel free to contact me. Jim From: Sumner, Dave, K1ZZ [mailto:dsumner@arrl.org] Sent: Tuesday, July 14, 2015 10:12 AM To: 'James M. Roop' Cc: Henderson, Dan N1ND Subject: RE: "It Seems to Us - The 50% Solution", August 2015 QST Jim, thank you very much for your observations. May I share them with the ARRL Board? We really miss the expertise of you and your retired colleagues and are greatly concerned for those who remain. Dave From: James M. Roop [mailto:k9se@comcast.net] Sent: Tuesday, July 14, 2015 11:03 AM To: Sumner, Dave, K1ZZ Cc: Henderson, Dan N1ND Subject: "It Seems to Us - The 50% Solution", August 2015 QST David, The League should continue its skepticism of the ability of the FCCs field offices to police the radio spectrum irrespective of the revised plan that will close (only) half of the field offices instead of two-thirds of the offices. The FCC Enforcement Bureau ("EB") senior management has yet to share the details of their grand plan with the field staff. The field staff remains in the dark with regards to their futures. The lack of enforcement action in the Woodinville, Washington grow light ballast radio frequency interference complaint is emblematic of the EB senior management team. The EB management team lacks an institutional knowledge of the historic roles and activities of the field with respect to spectrum management as well as a lack of technical aptitude especially as it applies to the radio services regulated by the Commission. Commissioner Michael O'Rielly in his speech to the Federal Communications Bar Association (June 11, 2015) asserts that "the Commission seems more intent on obtaining newspaper headlines trumpeting accusations and eye-popping fines." Commissioner O'Rielly iterates the point that this "self-aggrandizing fanfare is a major objective and often appears to be more important than case foundation, correcting the violation or establishing a reasonable deterrent." In light of Commissioner O'Rielly's observations, it is not difficult to see how the Woodinville, Washington enforcement action would not be able to gain any traction within the EB's front office. I am not optimistic that the reorganized field will be sustainable as an effective spectrum management tool. As a former district director, I was acutely aware of the administrative overhead required for equipment maintenance, staff professional development and other ancillary enforcement activities. These activities will require a greater percentage of time by the remaining field staff. This will impact the amount of time available for on-scene investigative work. I share your skepticism. I was fortunate to have been able to retire last year from the FCC as the Chicago district director and not be directly involved with this folly. Jim, K9SE