Executive Summary of the FCC's Million Dollar Consulting Report

"There are too many people doing too few things in the current field structure and it costs four times what a centralized structure would cost. With our current budgetary environment we need to find efficiencies. We need to do more with less." - Chairman Tom Wheeler

Expensive floorspace and salaries

The field enjoys much more space than the employees at HQ and the space is more expensive. Salaries and benefits combined with overhead costs too much for the perceived return on investment.

A lack of understanding

Aside from public safety matters, there is a lack of shared understanding around the mission of the Field or how activities support the broader EB and FCC missions. Time and resources are allocated to Field activities, which the value of and alignment to mission are not immediately clear to EB and FCC management. FCC and EB have other mission-critical priorities that require resources. Mission Surplus and potentially unnecessary Field management, office space, vehicles, and network infrastructure tie up resources that could be used elsewhere. 

A lack of standard processes

There is a lack of standard processes and outputs across the Field offices and regions that results in suboptimal resource utilization. The Field could do more with less if resource and equipment pooling and sharing processes were in place. There are unrealized benefits and cost savings of consolidating and centralizing the processes and functions devoted to equipment acquisition and R&D.

A failure to communicate

Resource utilization - The Field could perform more optimally with a more streamlined management structure that incorporates more formal ties with the HQ. A perceived lack of communication with the Field regarding changing priorities and shifts in mission is driving low morale. Despite performing similar work, there is a lack of standardization in the requirements and grades between field agents, compliance specialists, and resident agents. 

A lack of skill and proper training

The Field may not have the right skill sets for the enforcement challenges created by present day or near future communications and there is perceived lack of training resources that could prepare and retool the Field.

Overall perceptions

Bad morale, low level of training, poor management, misaligned priorities, enforcement activities not optimally aligned with Commission's evolving priorities. Current locations, management, skillsets, processes, equipment, and systems are not fully effective. Overall budgetary pressures and other high priority initiatives are competing for resources. Imperative to standardize matter prioritization, investigation and inspection procedures, and sanction delivery and develop trainings to increase efficiency. 

Ineffective organizational structure

The field does not believe the current structure is effective:
• 40% of Field Agents believe the current organizational structure inhibits achievement of goals.
• 60% of the Field thinks the management structure is not effective, well understood or consistent.

Field Agents explain in their own words, why sanctions are arbitrary and capricious, blatantly misrepresented, and/or completely erroneous:

• Sanction policy changes too often
• "Every bureau chief creates their own sanctions policy." –Field Agent
• Lack of templates, consistency, and guidance; could be processed like traffic tickets
• "There should be a simple, consistent template for writing and preparing sanctions." –Field Agent
• "We have three different regions, each with a lawyer, and different lawyers do things differently." –Field Agent
• "We used to have guidelines for what sanctions to issue based on what evidence we have, but they got rid of this about six months ago." –Field Agent
• Too much focus on legal concerns from HQ and Regional Counsels
• "Attorneys have taken over the FCC" -Field Agent
• "We have gotten into the mindset that every time we write even the most trivial sanction, it's treated with the most painstaking effort, as though every sanction will turn into a gigantic legal battle." –Field Agent [Clearly, the agent failed to understand that each sanction might lead to a legal battle]
• There is work that a technical engineer shouldn't be doing
• "In a perfect world, I don't touch the sanctions. Why are we the paralegals?" - Field Agent 
• Should have portable deployable monitoring equipment
• "We sometimes spend weeks or even months trying to locate an intermittent interference, and sometimes don't end up finding it at all." –Field Agent

Issues with bad complaints

•  "CGB is bad at discriminating illegitimate complaints and collecting basic info." –Field Agent
• "Some complaints are anonymous or don't include a phone number and can be difficult to get background information on." -Field agent

Issues with staff interactions

• "Some agents have very strong feelings that they don't need to come into an office, because they can do all their work from home." – Field Agent
• "Because of personality issues in the office, we telework a lot." – Field Employee

Issues with unreliable direction finding vehicles and stationary DF equipment

• "The EDG has made the vehicles very powerful, but they've added a lot of complexity and they aren't as reliable as they used to be." –Field Agent
• "When something goes wrong with a stationed vehicle, we only get to maintain it when we're sent to a case near the site." –Field Agent
• Field agents indicate the equipment is becoming increasingly insufficient.
• The Field indicated that the existing DF vehicle inventory was becoming less effective in handling casework
• Barely 50% of Field Agents feel their equipment is currently state of the art.
• More than 4 out of 5 Field Agents (>80%+) feel an increasing need for new equipment today.
• "We have old equipment that often needs to be calibrated." - Field Agent
• "We are unprepared for spectrum sharing, we need digital analyzers." - Deputy Director
• Older equipment needs more and more frequent repairs
• Agents spend up to 18% of their total time maintaining equipment
• Ex: Two agents in an office with more than 100 pieces of equipment
• The field identified several deficiencies with the current Mobile Direction Finding Vehicle
• May become more problematic as the matter types evolve
• "Stationary equipment has been a challenge for a long time, need droppable DF, stuff that works remotely." - Deputy Director
• "We want portable deployable monitoring equipment that they could set up at a location that would just sit and log activity." - Deputy Director
• "We need portable equipment that we can control remotely." - Field Agent
• "Droppable DF would be the most useful." - Field Agent
• "Drop, set, and forget type system is the future." - Field Agent
• Decoding digital signals Need software that can read information coded within digital signals and need technicians who can understand the software.

Obtaining a job in the field is not recommended

• 59% of managers and 43% of field agents would NOT recommend the FCC field as a place to work.

Lack of clarity and inconsistency in developing sanctions

• "Sometimes it has to move through layers before they even decide what kind of sanction to write up" -Field Agents
• "When you have too many managers for the number of workers… they start to meddle" 
-Field Agent
• "The main thing that we first have to know is what our job is... What is the mission we are aligning to" -Field Agent
• "Policy, enforcement policy, sanctions selection, etc. should be one unified voice, not local or regional decisions. This should come from the EB chief and the field" -Field Agent
• "Each new HQ personnel creates their own policy and prioritization. We need more clarity of the changes" -Field Agent

More than half of the Field is unsure how success is measured; interviews suggested even more confusion

• "We don't know how to measure success; I know you can't measure it based on number of matters…I just don't know how I would measure it" -Field Agent
• "I have no idea what HQ defines as success." -Field Agent
• "I would love for HQ to tell me how to define success and then I would make sure our team is successful". -Field Management
• "Defining success is difficult because we hope to achieve deterrence which can't be measured" -HQ leadership
• "I'm not sure how you can measure success; but I know there are certain things you cant stop and others you don't want to ignore" -HQ leadership

Lack of training

• "Even though we're EEs, the training for new technology is non-existent… If you want to learn about new technology you have to do it on your own and there is no incentive currently to do that" -Field Agent
• "We are going to need a lot of training, if we're moving into more advanced technology in the future" -Field Agent
• "There's a serious lack of training and I believe that's an issue for both the Field and Equip Devel Group" -EDG Engineer
• "Hiring directly out of college only works if we have a robust training" -Field Agent

Source: Field Survey 2014 and Field Survey responses.
Note: Agents includes EEs, CSs, and Compliance Assistants; Management includes RDs, DRDs, DDs, and Regional Counsels.
Note: Page 46/253: Amateur Radio is perceived as 3rd from the bottom in order of importance. Implication: Few cases were pursued in the past; there will be fewer in the future.