FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON
OFFICE OF
TH E CHAI RMAN
May 29, 2015
The Honorable Jeff Merkley
United States Senate
107 Russell Senate Office Building
Washington, D.C. 20510
Dear Senator Merkley:
Thank you for your letter dated April 24, 2015 concerning the Vancouver, Washington (Portland)
field office of the FCC's Enforcement Bureau (Bureau). The proposal to modernize the Bureau's field
activities comes nearly 20 years after the field offices' last major reorganization and is part of a broader
effort to improve the management and efficiencies of the Commission's operations. The Bureau and the
Office of the Managing Director engaged outside, independent consultants to assess the field offices'
activities, personnel, office space and equipment and make recommendations to ensure the alignment of
those areas with the agency's overall mission and priorities. The consultants found numerous issues that
make it clear that the Bureau's field operations can do more with less:
• Administrative overhead costs to support each field office averaged $400,000 - more than
double that of FCC headquarters.
• The ratio of managers to staff is severely askew - on average one field manager for just four
employees while FCC headquarters operates with an average of seven employees per
manager.
• The Commission is paying for excessive office space in nearly all field locations, which
range between 4,000 and 381 square feet per employee. By comparison, FCC headquarters
operates with 272 square feet per employee, and plans to reduce that figure to 180 after
FY2017.
• We have more mobile direction-finding (MDF) vehicles than field agents. Each MDF
vehicle has a value of approximately $100,000 in equipment and labor costs. Some offices,
however, have two or more MDF vehicles for each agent.
• Our employees and stakeholders agree that radiofrequency interference complaints should be
the field offices' top priority. Yet many field offices only receive one such complaint per
agent every month. Indeed, less than half of the field offices' total personnel time is spent on
spectrum enforcement activity, and a much smaller percentage is spent on critical spectrum
enforcement work like public safety interference.
Based on thorough data analysis, the Commission's proposed plan to modernize the field offices
includes right-sizing our geographic footprint so field agents may continue to respond to all public safety
interference complaints within one day, and to the vast majority ofthe country within 4-6 hours;
increasing the number of electrical engineers at all remaining field offices; and expanding our deployment
of staged MDF vehicles throughout the country.
Regarding our recommendation to close the Portland field office, although the office has kept
busy with outreach and routine compliance work, it has relatively little radio frequency complaint
Page 2-The Honorable Jeff Merkley
resolution activity. The field office costs approximately $276,000 each year to maintain. Yet the
Portland office received the third fewest radiofrequency-related complaints in the entire field - only 18
matters all year, or about 1.5 per month. That is more than $15,000 in taxpayer funds per complaint.
Although the Portland staff has provided valuable assistance to local broadcasters and public
safety representatives over the years, these matters generally do not require a residence by an FCC agent.
We will respond to complaints and requests in the Pacific Northwest from the closest field office (San
Francisco). If that office is unable to provide a sufficient response, staff from a dedicated "tiger team"
will provide additional support. In addition, we plan to take measures to sustain and enhance the
relationships between field personnel and local stakeholders.
Our field offices do an excellent job in resolving radiofrequency issues throughout the country on
behalf of numerous private and public stakeholders. Our proposed plan will not change this - the
Commission will continue to be well positioned to quickly respond to and resolve spectrum interference
complaints, and will do so in ways aligned with establishing a model field organization for the 21 st
Century.
Thank you for your interest in this matter. If you require additional information or assistance,
please contact the Commission's Office of Legislative Affairs at (202) 418-1900.
Sincerely,
Tom Wheeler
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON
OFFICE OF
THE CHAIRMAN
May 29, 2015
The Honorable Ron Wyden
United States Senate
223 Dirksen Senate Office Building
Washington, D.C. 20510
Dear Senator Wyden:
Thank you for your letter dated April 24, 2015 concerning the Vancouver, Washington (Portland)
field office of the FCC's Enforcement Bureau (Bureau). The proposal to modernize the Bureau's field
activities comes nearly 20 years after the field offices' last major reorganization and is part of a broader
effort to improve the management and efficiencies ofthe Commission's operations. The Bureau and the
Office of the Managing Director engaged outside, independent consultants to assess the field offices'
activities, personnel, office space and equipment and make recommendations to ensure the alignment of
those areas with the agency's overall mission and priorities. The consultants found numerous issues that
make it clear that the Bureau's field operations can do more with less:
• Administrative overhead costs to support each field office averaged $400,000 - more than
double that of FCC headquarters.
• The ratio of managers to staff is severely askew - on average one field manager for just four
employees while FCC headquarters operates with an average of seven employees per
manager.
• The Commission is paying for excessive office space in nearly all field locations, which
range between 4,000 and 381 square feet per employee. By comparison, FCC headquarters
operates with 272 square feet per employee, and plans to reduce that figure to 180 after
FY20l7.
• We have more mobile direction-finding (MDF) vehicles than field agents. Each MDF
vehicle has a value of approximately $100,000 in equipment and labor costs. Some offices,
however, have two or more MDF vehicles for each agent.
• Our employees and stakeholders agree that radiofrequency interference complaints should be
the field offices' top priority. Yet many field offices only receive one such complaint per
agent every month. Indeed, less than half of the field offices' total personnel time is spent on
spectrum enforcement activity, and a much smaller percentage is spent on critical spectrum
enforcement work like public safety interference.
Based on thorough data analysis, the Commission's proposed plan to modernize the field offices
includes right-sizing our geographic footprint so field agents may continue to respond to all public safety
interference complaints within one day, and to the vast majority of the country within 4-6 hours;
increasing the number of electrical engineers at all remaining field offices; and expanding our deployment
of staged MDF vehicles throughout the country.
Regarding our recommendation to close the Portland field office, although the office has kept
busy with outreach and routine compliance work, it has relatively little radiofrequency complaint
Page 2-The Honorable Ron Wyden
resolution activity. The field office costs approximately $276,000 each year to maintain. Yet the
Portland office received the third fewest radiofrequency-related complaints in the entire field - only 18
matters all year, or about 1.5 per month. That is more than $15,000 in taxpayer funds per complaint.
Although the Portland staff has provided valuable assistance to local broadcasters and public
safety representatives over the years, these matters generally do not require a residence by an FCC agent.
We will respond to complaints and requests in the Pacific Northwest from the closest field office (San
Francisco). If that office is unable to provide a sufficient response, staff from a dedicated "tiger team"
will provide additional support. In addition, we plan to take measures to sustain and enhance the
relationships between field personnel and local stakeholders.
Our field offices do an excellent job in resolving radiofrequency issues throughout the country on
behalf of numerous private and public stakeholders. Our proposed plan will not change this - the
Commission will continue to be well positioned to quickly respond to and resolve spectrum interference
complaints, and will do so in ways aligned with establishing a model field organization for the 21 st
Century.
Thank you for your interest in this matter. If you require additional information or assistance,
please contact the Commission's Office of Legislative Affairs at (202) 418-1900.
;:it?J-
Tom Wheeler