• Number of people affected: The present staffing level is 98 and the new one is 54 for a net loss of 44 positions. The 98 number includes no vacancies so this is a loss of 44 FCC employees, most of whom are long time employees.

• Three "bargaining unit" staffers will be downgraded/demoted from GS-14 to GS-13: 2 in Miami and 1 in LA. "Save pay" provisions will limit the salary impact but the salary impact will be real and negative for these 3 individuals.

• A few supervisors will also be downgraded/demoted but the details were not part of the notification to the union and are more difficult to deduce at this point.

• A new GS-15 Enforcement Bureau Field Director office is created with a GS-15 EE as "Field Director" and 3 lawyers as ""Field Counsel". Two of these lawyers are named and do not presently work in DC so it is unclear where these positions will be. The Field Director will be an awfully lonely position if his/her nearest colleagues are in Columbia MD.

• The Equipment Development Group in Powder Springs, GA shrinks from 10 positions to 7. This is the part of EB that develops new equipment and built special equipment. In the long term with a decrease in overall staff and number of offices there may be less equipment to build. But the only way to increase the productivity of field staff is to give them the right equipment to make them more productive as the consultant's report says. Various statements have been made about keep some of the savings from the staff cuts within the field to buy equipment, but the downsizing of EDG raises the question of whether this is credible.

• Equipment acquisition in EB (as well as in OET) has always been limited by the late availability of funds every fiscal year and excessive procurement bureaucracy. As a result usually only off-the-shelf equipment is bought, usually "riding" a DoD contract so the model options are limited. In order to get specialized equipment more procurement flexibility is needed and that generally means earlier availability of funding something that does not appear to be of interest at present to the FCC's Managing Director.

• t is unclear if FCC will pay relocation costs of any of the 44+ employees who are affected by these changes who qualifies for a position elsewhere in FCC. FCC since the Reagan era FCC has not budgeted for staff relocations even though it has staff "outside the Beltway". Indeed, former Managing Director Minkel (1980s) would cancel personnel postings if the person selected was legally entitled to relocation at FCC expense! Great way to help morale!

• Despite the promises to NAB to increase suppression of pirate radio stations there is not evidence this will happen or be sustainable. Pirates are generally not limited to the usual 40 hour work week and suppression needs availability of both overtime funding and travel funding - for those not conveniently near any of the remaining offices. In addition, since the creation of PSHSB aft 9/11 the entire 24/7 operation of FCC moved from EB to PSHSB and is only interested in off hour contacts dealing with safety-related issues not pirate broadcasters. Who you gonna call on weekend/evenings about a private station? Ghost Busters?

Tags: enforcement, FCC personnel policy