Tiger Teams and the FCC Enforcement Bureau

By Mark E. Crosby, President and CEO, EWA

We remain dumbfounded that the FCC leadership continues to extol the virtues of its plans to significantly shrink the Enforcement Bureau, reducing the number of its employees by perhaps as much as 60%, and the number of its field offices by nearly 50%. Apparently saved from the chopping block will be New York City, Atlanta, Miami, Los Angeles, San Francisco, Chicago, Dallas, and Columbia, Md., bureau offices. Not so lucky may be the offices in Seattle, Denver, Boston, Philadelphia, and Houston.

According to one Commission official, “Interference resolution is and will remain the field’s top priority, our methods and organization need to evolve with changes in the industry such as spectrum sharing, improvements in remote detection, and self-regulation. The proposals under consideration would adequately equip the field to meet the enforcement needs of the commission.”

Emerging plans call for concentrating staff in Washington, D.C., and even the formation of mobile “Tiger Teams” that will be launched from Columbia, Maryland on a moment’s notice to address critical enforcement matters around the country. We have also heard that there will be no reduction in enforcement effectiveness, as Enforcement Bureau personnel will be better trained, investments will be made in improved technology, and the travel budget will be increased.

I would like to believe these commitments and promises of better wireless days ahead resulting from these reorganization plans, but I am having difficulty drinking the Kool Aid. The Enforcement Bureau is full of very dedicated government employees, although one might assume that those fortunate enough to still have a job might be concerned about their future prospects. It also remains to be seen whether the Bureau is keeping its already well-trained staff or planning to train its less experienced personnel.

The Bureau’s critical role has been underfunded and underappreciated for decades. Not that long ago, its field staff too often had to say “we can’t go investigate this interference matter, as we do not have the budget to put gas in our vehicles.” Yet now the Commission is going to invest in new interference-mitigation technology, remote-monitoring capabilities, agent training, airline tickets, and rental cars for the Tiger Teams?

By the way, expect the Tiger Teams to come home to Columbia only a few days each year as they will remain in perpetual motion out in America’s wireless world chasing down unlicensed operators, purposeful interference to mission-critical communication, pirate broadcasters, unbalanced folks who have fun interfering with aeronautical functions, citizens-band users who like to add amplifiers to their systems, and those nasty enough to impede ubiquitous access to the internet, thus prohibiting the opportunity of all citizens to download past episodes of the Game of Thrones.

The Bureau has its idiosyncrasies, such as differences in effort from one office to another and forfeitures that increasingly appear to be based on the operator’s apparent ability to pay rather than on the severity of the crime, but we can work with these issues. At a time when the number of devices is exploding across all wireless markets, at a time when the economy is growing ever so more dependent on private wireless systems and national broadband networks, and at a time when new sources of shared spectrum will be forthcoming from the federal government, the Enforcement Bureau has never been needed so much. One hopes that the FCC leadership will revisit these plans to consolidate the Enforcement Bureau, and choose instead to broaden its presence and reach with a meaningful expansion of resources in staff and equipment. Tiger Teams are a good solution best deployed in the armed forces.