On the heels of some Congressional inquiry into the the FCC’s plan to radically cut its field enforcement resources, the National Association of Broadcasters finally chimed in. In a post titled “Defanging a Paper Tiger” (hm, where have I heard that term before?), NAB VP of Spectrum Policy Bob Weller gave the idea two big thumbs down.

Weller, who joined NAB last year after several years with the FCC working spectrum policy/enforcement issues, says the new proposal effectively undoes a service-cushion implemented by the agency when it last downsized its enforcement resources some 20 years ago: “In 1995, the FCC automated its monitoring station operations, resulting in the closure of more than a dozen field offices with a commensurate reduction in staffing. Some of the remaining offices were converted to ‘Resident Agencies,’ a euphemism for a one- or two-person office with no support staff. At that time, the FCC offered early retirement and a humane personnel relocation program. Increased training, improved technology and a reasonable travel budget were offered as assurances that no reduction in enforcement effectiveness would result.”

Since then, enforcement staff has continued to shrink, primarily as agents have retired over the last decade and qualified replacements are hard to come by. Weller also notes that even if one were to give credence to the “tiger team” that will backstop the 33 agents who would remain deployed in the field, “the proposed staffing numbers just don’t add up. People take leave, training takes time, on-scene investigations mean in-office paperwork. So, the actual number of field agents available for assignment on a typical day might be half the total, or 16. Sixteen pairs of boots on the ground, doing field investigations for the FCC for the entire country. Think about that.”

What about the FCC’s notion that it might rely on private-sector outsourcing of particular enforcement duties? We already know the broadcast engineering and amateur radio communities have their fair share of zealots who fox-hunt pirates for fun and would just love to take ’em down. Not so fast, says Weller: “Even if the affected user is able to identify the source of the problem, there is no right of private action in the Communications Act that could force the source [to] shut down. State and local law enforcement are reluctant to take on interference or unauthorized transmitter cases due, understandably, to lack of expertise. FCC field staff possess the expertise and have sole authority to investigate and enforce laws relating to radio.”

The planned downsizing is also causing a bit of a stink among rank-and-file FCC field staff, one of whom tells Radio World that the agency’s guarantee of a 4-6 hour response-time using its tiger-team approach is “a BS statistic.” In simple terms, there’s a big difference between acknowledging an interference problem exists and doing something concrete to stop it.

I can see the NAB’s well-oiled lobbying machine gearing up to combat this plan on two fronts: putting Congressional pressure on the FCC to abandon or dilute its planned cutback, and working with state broadcasters’ associations to get more anti-pirate radio laws on the books.