FCC Enforcement: On the Wane?

Just got the Enforcement Action Database caught up for the year, and the numbers show that FCC field activity is running at the lowest level it’s been since 2005. Just 173 enforcement actions to date, as opposed to ~260 at this time last year.
There was a similar dip in the years afer the FCC first proposed the creation of LPFM, and with LPFM’s second wave in the works it’s enticing to see a correlation, but this time around I’m more inclined to believe it has to do with changing political priorities regarding enforcement policy (pirates take a back seat to cell-phone jammers, for example) coupled with the effects of austerity on federal government services more broadly.
eadbymonthConsidering that the level of enforcement activity varies over the year (see right), with October being the traditional month of last hurrah, barring some holiday surprise this could be the quietest year in nearly a decade. The vast majority of the FCC’s work remains administrative, with visits and warning letters now constituting a full 85% of all enforcement activity. There have been just six Notices of Apparent Liability and six monetary forfeitures issued in 2014; the only fine issued in the last 4+ months went to a pirate broadcaster in Florida whose first contact with the FCC dates back to 2009.
Perhaps the biggest news is that New York is now officially the #1 pirate radio hot-spot in the United States, eclipsing Florida in the total number of enforcement actions logged over the last 17 years. New York enforcement activity has actually outpaced Florida by a 3-to-1 margin since 2013. Interestingly, both states have their own anti-pirate radio laws on the books, but neither seem to be generating much of a return, and even less of a deterrent. This year, pirates have been pinged in a total of 19 states and Puerto Rico.