According to an internal FCC Enforcement Bureau (EB) memorandum, the Bureau plans to ask the full Commission to cut two-thirds of its field offices and eliminate nearly one-half of its field agents. At the same time, the Bureau would develop a so-called “Tiger Team” of field agents as a flexible strike force it could deploy as needed. In the March 10 memorandum to Enforcement Bureau field staff — obtained by ARRL and others — EB Chief Travis LeBlanc and FCC Managing Director Jon Wilkins cited the need to take “a fresh look” at the Bureau’s 20-year-old operating model in light of technology changes and tighter budgets. ARRL CEO David Sumner, K1ZZ, expressed dismay at the proposals.

“The ARRL is concerned that there is already no sense of urgency in the FCC’s enforcement activities targeting spectrum polluters, such as utilities with noisy power lines, or the few violators in our own ranks,” Sumner said. “It is troubling to see recommendations for such drastic reductions in the Commission’s geographic footprint and the number of field agents at a time when the Field staff is facing ever-increasing challenges.”

The EB and the Office of the Managing Director initiated an effort last fall to modernize the Bureau’s field operations, the memorandum said.

“This project sought to ensure that the Field’s structure, operations, expenses, and equipment were properly aligned with the Commission’s overall mission and resources,” LeBlanc and Wilkins said. The Commission hired outside consultants to analyze the EB’s current “operating model,” gathering input from employees, outside experts, and internal and external stakeholders.

Under its “Phase I” field modernization scheme, the Bureau will recommend to the full Commission that it adjust the primary focus of its reduced field office complement to RF spectrum enforcement. The EB also will recommend “adjusting” the number of field agents from 63 to 33. To compensate, part of that field staff complement would include what the EB called a “Tiger Team” of agents “flexible enough to support other high-priority initiatives.” Under the plan, all field agents would have to have electrical engineering backgrounds “to support the primary focus on RF spectrum enforcement.” The Bureau also will propose standardizing its investigatory and sanctioning processes.

Management would not be spared. Under the recommendations, the EB field organization chart would shrink from 21 to 5 director positions, and from 10 to 3 administrative support positions.

Under the proposals, the field office would reduce its “geographic footprint,” from 24 sites to 8 sites and would “pre-position” equipment in several other strategic locations. Offices slated to stay under the plan would be New York City; Columbia, Maryland — the site of the Bureau’s HF Direction-Finding Center; Chicago; Atlanta; Miami; Dallas; Los Angeles, and San Francisco. The EB would deploy equipment in or near several other cities, initially to include Kansas City, Salt Lake City, Phoenix, Seattle, San Juan, Anchorage, Honolulu, and Billings, Montana.

Part of the plan calls for the EB to establish “beneficial partnerships between the Field and other organizations that may support increasing our effectiveness.”

During a March 4 US House Subcommittee on Communications and Technology Committee hearing on the FCC’s FY2016 budget, Rep Michael Pompeo (R-KS) pressed Wilkins on whether the FCC intended to close any field offices and eliminate any personnel. Wilkins attempted to dodge offering a direct answer and hedged on whether any cuts were planned. He also said the Bureau had not yet received a final report from the outside consultant it had worked with. US Rep Greg Walden, W7EQI (R-OR), chairs the subcommittee.

A copy of the memorandum was sent to National Treasury Employees Union (NTEU) Local 209 President Ana Curtis. The NTEU represents many FCC staff members.