Federal Communications Commission FCC 15-81
CONCURRING STATEMENT OF
COMMISSIONER AJIT PAI
Re: Reorganization of the Enforcement Bureau’s Field Operations.
The Enforcement Bureau’s field agents perform essential work.  They resolve interference that 
threatens public safety communications.  They ferret out pirate radio operators.  And they play a critical 
role in ensuring that everyone complies with the Commission’s rules.  One statistic helps to highlight the 
importance of their duties.  During the October 2013 government shutdown, over 25% of FCC employees 
who remained on the job were field personnel, even though they represented less than 7% of the 
Commission’s workforce.
Unfortunately, the process leading to today’s vote has not treated our field agents with the respect 
they deserve.  The original field office reorganization plan was developed without adequate input from 
either field personnel or key outside stakeholders.  Many have told me that they believe the FCC’s 
leadership commissioned a report in order to figure out how to justify a predetermined outcome.
The end result, of course, was a plan that provoked widespread opposition.  Wireless carriers, 
broadcasters, and public safety officials, along with Democrats and Republicans on Capitol Hill, all spoke 
out against it.  And I agreed that the original plan was badly flawed.  To point out just one of its many 
problems, it would have left us without any FCC field presence in either the Rocky Mountain or Great 
Plains regions, a void which would have made it impossible to respond in a timely manner to an 
emergency in a vast swath of our nation.
I am therefore grateful to the leadership of the House Energy and Commerce Committee for 
stepping up to the plate.  The Committee’s intervention yielded real improvements.  In particular, because 
we are now maintaining a field presence in the Pacific Northwest, the Rocky Mountains, the Gulf Coast, 
New England, Alaska, Hawaii, and Puerto Rico, the FCC will be able to address incidents in those areas 
more quickly than would have been possible under the original plan.
To be sure, were it solely up to me, this plan would look substantially different.  For example, the 
size of the Enforcement Bureau’s front office here in Washington, DC has more than doubled since 2008.  
I believe that it is a mistake to continue to grow the Bureau’s front office while substantially cutting the 
number of field agents.  I worry that it is a sign of a greater interest in newspaper headlines than bread-
and-butter enforcement work—work that is less glamorous but nonetheless critical.
Notwithstanding my reservations, I will vote to concur on this item.  Thanks to the House Energy 
and Commerce Committee’s involvement, as well as input from stakeholders including the National 
Association of Broadcasters and CTIA, we have made tangible progress in improving this plan, and my 
vote today is a vote to support that progress.
As we move forward in implementing this plan, there are challenges ahead.  Most notably, the 
relationship between the Enforcement Bureau’s front office and its field agents has become badly frayed.  
In recent months, I have received many e-mails from field personnel, and the message was clear.  They do 
not believe that their work is valued.  They do not believe that there is adequate communication between 
FCC headquarters and the field.  And they do not believe that the FCC’s field operations are well 
managed.  In the months ahead, we must do what we can to repair this breach and give field agents the 
support that they need to carry out their important mission.