The author is a former FCC district director for the states of Louisiana, Mississippi and Arkansas.
Walter Gernon The Federal Communications Commission has proposed to reduce the number of its field offices from 24 to eight, and the field staff from 63 to 33, to better deploy its assets and save money. If this proposal is implemented, the long-term result will be degraded communications for licensees and the general public.
The planned Tiger Team, composed of agents dispatched from a distant location, in most cases, will be unfamiliar with the unique geographic features and RF intangibles of the area of interference and will not be able to resolve interference in a timely manner. Unresolved interference to safety of life communications, i.e., marine, aviation and public safety communications, could result in disastrous events not only for licensees but also the general population.
An FCC agent is the only entity that has the authority to enforce compliance and require operators to cease harmful transmissions. Under this proposed staffing, disruptions in cellular service, use of jamming devices, pirate radio transmissions, transmitter malfunctions and cable leakage may continue for days.
A top priority for the commission has always been interference-free safety of life communications. Vessel Traffic Service offices and similar entities, which direct traffic on our waterways, depend on interference-free communications. Marine communications in lakes, rivers and coastal waters by the U.S. Coast Guard, Navy, commercial operators and the boating public are currently served by 16 FCC Field Offices: Chicago, Detroit, Buffalo, N.Y., Boston, New York, Philadelphia, Norfolk, Va., Miami, Tampa, Fla., New Orleans, Houston, San Diego, Los Angeles, San Francisco, Portland, Ore., and Seattle.
An FCC field office investigated this pirate radio station in an abandoned building in Lake Charles, La., about seven years ago.MARINE, AVIATION USERS
Under the proposed plan, Chicago, New York, Miami, Los Angeles and San Francisco will serve the needs of all marine radio users.
Commercial shipping on the Mississippi River, the port of New Orleans (busiest in the U.S.), the Gulf Coast, the Houston Ship Channel, intercoastal waterways and large naval installations such as the one in Norfolk, Va., will all be vastly underserved.
Aviation radios, both land-based and those in aircraft, can and do receive interference from a variety of sources, including cable leakage, wireless devices, electrical systems, malfunctioning radios, Emergency Locator Transmitters and intentional jammers. FCC field agents have a working relationship with area Federal Aviation Administration personnel that enables them to recognize, locate and resolve interference issues promptly.
A proactive function of FCC field agents is to drive cable television systems with vehicles equipped to detect signal leakage. Cable companies are required to check their system continually for leaks, because some CATV frequencies are shared with the aviation service.
The random inspection of CATV systems by FCC field agents for leaks is an important oversight function that cannot be ignored. When interference to aviation frequencies occurs, commission field agents have the equipment, expertise, knowledge of CATV personnel and equipment to locate the leaks, and more importantly the authority to require CATV systems to fix the leaks.
Cell phone service is ubiquitous. The public expects perfect reception. During the past few years, cheaply-made, easily-obtainable cell phone jamming devices have become common.
These devices produce a broadband signal rendering cellular phones, public safety radios and GPS devices and other wireless devices useless in a given area. Without real-time interference resolution, employers, criminals, terrorists or pranksters could use jamming devices to profoundly affect all types of wireless communications.
EAS, HAMS, PIRATES
The Emergency Alert System tone, that noisy buzz we hear weekly on all broadcast stations, is effective because FCC field agents actively assisted in the implementation phase, and ensure continued compliance by routine inspections. Advocates for the proposed reduction of commission agents will argue that the Alternative Broadcast Inspection Program will ensure that EAS continues to function; but less than half of the broadcasters participate in ABIP, a voluntary, private program that charges broadcast stations for an inspection.
Most broadcasters are responsible and comply with EAS requirements, but if several neglect their duties, the entire system is put at risk and the public will not receive weather information and disaster alerts from city, state and national officials. In addition to ensuring compliance to EAS, commission field agents ensure stations comply with the parameters of their license and assist broadcasters by locating interference to a station’s STLs, RPUs and wireless microphones.
Good local contacts enabled the FCC field staff in New Orleans to fly with the Louisiana Air National Guard to locate interference to the FAA approach at the Baton Rouge Airport in 2012. According to Gernon, shown here, the Guard flew FCC field staff and their direction-finding equipment along the path of the interference in a Blackhawk helicopter. The interference was coming from faulty power lines that were right under the flight path. Pirate broadcasting is a growing problem for licensed broadcasters as well as the general public. Unlicensed transmitters are easy to obtain and often drift off frequency or produce spurious emissions in the aviation band, which could have a disastrous result.
Amateur radio, in addition to being a hobby for many, plays an important role in disaster communications. FCC agents assist in resolving interference to ham radios from sources as diverse as broadband over power lines to remote-controlled devices. If a ham operator causes interference to neighboring home electronic devices, commission agents mitigate the dispute and ensure compliance with FCC rules.
Agency personnel in the FCC field offices also have a working relationship with electrical utility companies. They assist these companies by pinpointing electrical interference to consumer products.
FCC Field Offices had a drastic reduction in force in 1996. In the ensuing years, they were left to twist in the wind under a policy of benign neglect. This occurred during a time of unprecedented growth in wireless communications. FCC staff should have been maintained or increased to keep pace with this growth, but field engineering staff dwindled. Their important oversight, compliance, interference resolution and expertise to police, fire and other public safety agencies were curtailed.
The interference resolution expertise of commission field agents is unique, unmatched in the industry. Whoever is responsible for this proposal has no concept of the difficulty of direction-finding in a marine environment with metal wharves and numerous vessels; or in mountainous regions with canyon walls reflecting the signal; or among skyscrapers on busy streets.
In addition, interference is often sporadic, caused by an unstable transmitter. This type of signal is difficult for experienced agents to locate. By taking FCC field agents out of this equation and sending Tiger Teams to resolve interference is applying a one-size fits all mentality.
Depending on a Tiger Team to assemble, deploy and mitigate an interference problem within a reasonable amount of time is delusional and unreasonable. Pirate radio stations are often sporadic in nature, operating only a few hours a day or a week. Locating these transmitters, a routine Field Office function, would pose a logistics nightmare for a Tiger Team. What priority would be given to the myriad consumer interference issues that are dealt with on a daily basis by FCC field offices? With less technical staff in the future located throughout the county, problems will be ignored with the hope that they will go away; a major disservice to the general public.
EFFECTS OF FCC DOWNSIZING
Walter Gernon lists the following as reasons not to close field offices and reduce the number of field agents:
• Loss of FCC presence nationwide
• Only three offices west of the Mississippi
• Slow response to all radio interference
• No local direction finding experts
• Reduced enforcement compliance with FCC rules
• Increase in pirate radio transmissions
• Interruption of radio communications by jammers in all services
• No oversight of cable leaks that can disrupt aviation communications
• Marine communications lost due to interference from faulty transmitters
• No other entity equipped, skilled or authorized to resolve wireline and wireless communication problems
The plan fails to mention that most district directors actively work cases and perform the duties of field agents because of a lack of staff. In the last 20 years, more attorneys than technical staff have been hired by the FCC’s Enforcement Bureau. This is not an efficient use of resources in regard to interference resolution, on-site investigations, consumer education and compliance with the Communications Act.
Proponents of this proposal argue the FCC field staff doesn’t need to perform these functions. But commission management should not ignore the fact that the field staff historically has performed these duties, and with the proliferation of radio devices, the field staff is more important than ever.
The FCC has a fiduciary responsibility to the American public to ensure that the best communications infrastructure in the world remains just that: the best. Katrina, 9/11 and other disasters taught us that interference-free, reliable communications are critical. Anyone who flies in an aircraft, uses a marine radio, talks on a cellular phone, depends on the EAS system, listens to radio, watches TV or runs a business with a stake in uninterrupted, reliable communications must question how this proposal will serve their needs.
Walter D. Gernon began his 30-year career with the commission as a license examiner in the New Orleans Field Office and was the district director for Louisiana, Mississippi and Arkansas for the last four years of his FCC career.His wife Rebecca Willman Gernon was a field agent for 15 years.
