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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

April 2008: 

Digital Television Transition: 

Majority of Broadcasters Are Prepared for the DTV Transition, but Some 
Technical and Coordination Issues Remain: 

Issues Surrounding the DTV Transition: 

GAO-08-510: 

GAO Highlights: 

Highlights of GAO-08-510, a report to congressional requesters. 

Why GAO Did This Study: 

The Digital Television Transition and Public Safety Act of 2005, 
requires all full-power television stations in the United States to 
cease analog broadcasting by February 17, 2009, known as the digital 
television (DTV) transition. Prior to the transition date, the 
television broadcast industry must take a series of actions to ensure 
that over-the-air programming will continue to be available to 
television households once the transition is complete. For example, 
broadcast stations must obtain, install, and test the necessary 
equipment needed to finalize their digital facilities, and some 
stations will need to coordinate the movement of channels on the day 
the analog signal ceases transmission. This requested report examines 
(1) the status of broadcast stations in transitioning to digital, (2) 
the extent to which broadcast stations are encountering issues, and (3) 
the actions the Federal Communications Commission (FCC) has taken to 
guide broadcasters in the digital transition. To address these issues, 
GAO conducted a Web-based survey of full-power television broadcast 
stations. GAO surveyed 1,682 stations and obtained completed 
questionnaires from 1,122 stations, for a response rate of 66.7 
percent. GAO also reviewed legal, agency, and industry documents and 
interviewed public, private, and other stakeholders. 

We provided FCC with a draft of this report, and FCC provided technical 
comments that we incorporated where appropriate. 

What GAO Found: 

Television broadcast stations have made substantial progress in 
transitioning to digital television, with the vast majority already 
transmitting a digital signal. Approximately 91 percent of the 1,122 
full-power stations responding to our survey are currently transmitting 
a digital signal, with approximately 68 percent of survey respondents 
transmitting their digital signal at full strength and 68 percent 
transmitting their digital signal on the channel from which they will 
broadcast after the transition date. However, some stations still need 
to complete construction of their final digital facilities, and others 
need to relocate their digital channel to complete the transition. For 
example, 23 percent of survey respondents indicated they will be moving 
their digital channel to their analog channel. In addition, other 
stations need to move to a completely new channel. While almost all 
full-power stations are already broadcasting a digital signal, 9 
percent of stations responding to our survey indicated that they are 
not currently broadcasting digitally. Almost all of these stations, 
however, indicated that they plan to have their digital signal 
operational by February 17, 2009. 

Some stations, including those already broadcasting a digital signal, 
need to resolve various technical, coordination, or other issues before 
their transition to digital is complete. For example, over 13 percent 
of stations responding to our survey reported that they need to install 
or relocate their digital or analog antennas. Some of these stations 
still need to order equipment, such as antennas, to build their final 
digital facilities. Furthermore, stations may have coordination issues 
to address to complete their final digital facilities. In particular, 
some stations are awaiting agreements with the Canadian and Mexican 
governments regarding their signals crossing the borders of these 
respective countries before they can complete their digital facilities. 
Stations also need to coordinate with cable providers and satellite 
companies to ensure that cable and satellite facilities receive digital 
signals when the analog signals are turned off. Lastly, the 
construction of broadcast towers or financial constraints might affect 
some stations during their transition. 

FCC’s actions have provided guidance to broadcasters throughout the 
digital transition, but at the time we completed our survey, some 
broadcasters were awaiting FCC decisions. Since 1987, FCC has directed 
broadcasters with a series of rulemakings and orders, including 
assigning digital broadcast channels and developing timelines for the 
construction of digital facilities. Furthermore, FCC has conducted 
periodic reviews of the transition and released a ruling on its third 
periodic review on December 31, 2007, in which FCC addressed a number 
of important DTV issues. However, some stations responded to our survey 
that they needed decisions from FCC, such as approval for a 
construction permit or for changes to their final digital channel. 
According to FCC, it will address remaining issues quickly and with the 
release of an order in March 2008, FCC stated that it believes 
broadcasters have everything they need from the commission to proceed 
with construction of their final digital facilities. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-510]. To view the 
results of GAO’s survey, click on GAO-08-528SP. For more information, 
contact Mark L. Goldstein at (202) 512-2834 or goldsteinm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Broadcast Stations Have Made Substantial Progress in Transitioning to 
Digital Television, and the Vast Majority Are Already Transmitting a 
Digital Signal: 

Some Broadcast Stations Face a Range of Technical, Coordination, or 
Other Issues in Completing Their Transition to Digital Television: 

FCC Has Taken Numerous Actions to Guide Broadcast Stations through the 
Digital Transition: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: FCC Key Actions in Support of Broadcasters' Transition to 
Digital: 

Figures: 

Figure 1: Operating Status of Broadcast Stations Transmitting a Digital 
Signal, as of February 8, 2008: 

Figure 2: Survey Respondents' Location of Digital Channels Once the 
Transition Is Complete: 

Figure 3: Number of Broadcast Stations with Additional Steps Needed to 
Locate Their Digital Antenna: 

Figure 4: Survey Respondents' Status Regarding U.S. Government 
Coordination with the Mexican and Canadian Governments: 

Figure 5: Survey Respondents' Status in Coordinating with Cable 
Providers and Satellite Companies: 

Figure 6: Example of a Broadcast Station's Digital Signal Coverage 
Compared with Analog Signal Coverage: 

Abbreviations: 

DTV: digital television: 

FCC: Federal Communications Commission: 

MHz: megahertz: 

United States Government Accountability Office: 

Washington, DC 20548: 

April 30, 2008: 

Congressional Requesters: 

The Digital Television Transition and Public Safety Act of 
2005[Footnote 1] requires all full-power television stations in the 
United States to cease analog broadcasting by February 17, 2009. After 
that time, such television stations may only broadcast digital 
transmissions. This change is often referred to as the digital 
television (DTV) transition. Prior to the transition date, the 
television broadcast industry must take a series of actions. For 
example, broadcast stations must obtain, install, and test the 
necessary equipment needed for their final digital facilities, and some 
stations will need to coordinate the movement of channels on the day 
that they cease analog signal transmission. Most television 
broadcasters are already transmitting both an analog and a digital over-
the-air signal to television households. However, prior to or on the 
final transition date, broadcasters will be vacating portions of the 
spectrum, and 108 megahertz (MHz) of spectrum will be reclaimed by the 
federal government.[Footnote 2] The Federal Communications Commission 
(FCC), which is the federal entity responsible for guiding the 
transition, has reallocated 24 MHz of the spectrum for public safety 
purposes. In January 2008, FCC began auctioning the remaining spectrum 
for commercial purposes. 

You asked us to provide information on technical issues surrounding the 
DTV transition. We reviewed (1) the status of broadcast stations in 
transitioning to digital, (2) the extent to which broadcast stations 
are encountering issues during the DTV transition and how these issues 
impact the broadcast community, and (3) the actions FCC has taken to 
guide broadcasters in the DTV transition and how those actions have 
affected the broadcast community. In November 2007, we reported on the 
status of consumer issues related to the DTV transition.[Footnote 3] We 
are continuing to review consumer issues related to the DTV transition 
and will provide an update on those issues later in 2008. 

To obtain information on the status of the broadcast industry in 
transitioning to digital and the issues broadcasters were encountering, 
we conducted a Web-based survey of the full-power commercial and 
noncommercial television broadcast stations (such as network broadcast 
stations and public television stations) in the 50 states and the 
District of Columbia. Among other things, we asked the broadcasters 
questions related to their digital facilities, construction plans, and 
issues affecting the digital transition. We obtained the list of full- 
power stations from FCC in June 2007. Since FCC did not maintain e-mail 
addresses for all of the licensed broadcasters at that time, we needed 
to obtain contact information on the broadcasters through alternate 
sources. Of the 1,747 stations on FCC's list, we surveyed 
1,682[Footnote 4] stations located in the 50 states and the District of 
Columbia for which we could obtain contact information. We conducted 
our survey from December 2007 through February 2008 and obtained 
completed questionnaires from 1,122 stations, for a response rate of 
66.7 percent. Of those completed questionnaires, 72 percent were from 
commercial stations and 28 percent were from noncommercial stations. 
This report does not contain all of the results from the survey. The 
survey and a more complete tabulation of the results can be viewed by 
accessing the following link: [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-528SP]. Furthermore, we reviewed relevant law, public 
comments, FCC proposed and final rules, and various industry and 
private sector documents. We interviewed FCC officials as well as a 
wide variety of industry and other private sector stakeholders with an 
interest in the transition, such as broadcasters, manufacturers, and 
industry advocacy groups. Appendix I contains a more detailed 
discussion of our objectives, scope, and methodology. We conducted this 
performance audit from April 2007 through April 2008 in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe that the evidence 
obtained provides a reasonable basis for our findings and conclusions 
based on our audit objectives. 

Results in Brief: 

Broadcast stations have made substantial progress in transitioning to 
DTV, with the vast majority already transmitting a digital signal. 
Information obtained from our survey of broadcast stations indicates 
that approximately 91 percent of full-power stations are currently 
transmitting a digital signal. Our survey further indicated that 
approximately 68 percent of respondents are transmitting their digital 
signal at full strength. In addition, 68 percent of survey respondents 
are currently transmitting their digital signal on the channel from 
which they will broadcast after the transition date. Twenty-three 
percent of stations that responded to our survey indicated they will be 
moving their digital signal to their analog channel. In addition, other 
stations need to move to a completely new channel. While almost all 
full-power stations are already broadcasting a digital signal, 97 
stations, or 9 percent of stations responding to our survey, are not 
currently broadcasting digitally. Almost all of these stations, 
however, indicated that they plan to have their digital signal 
operational by February 17, 2009. 

Some stations, including those already broadcasting a digital signal, 
still have technical, coordination, or other issues that need to be 
resolved before completing their transition. For example, over 13 
percent of stations responding to our survey indicated that they have 
to install or relocate their digital or analog antennas in 
transitioning to digital. Some stations still needed to order 
equipment, such as antennas, to build their final digital facilities. 
According to an antenna manufacturer we contacted, it can take from 6 
weeks to 9 months to design, order, and install an antenna, depending 
on the antenna's complexity. This manufacturer told us that stations 
need to have their orders placed by the second quarter of 2008 to be 
assured of having the equipment installed prior to the transition date. 
Furthermore, stations may have coordination issues to address in 
completing their final digital facilities. For example, some stations 
are awaiting agreements with the Canadian and Mexican governments 
regarding their signals crossing the borders of these respective 
countries before the stations can complete their digital facilities. 
Stations will also need to coordinate with cable providers and 
satellite companies to ensure that cable and satellite facilities can 
receive digital signals when the analog signals are turned off; most of 
those responding to our survey indicated that they are coordinating 
with or are planning to coordinate with cable providers and satellite 
companies. Lastly, stations that have to construct broadcast towers or 
have financial constraints might be affected during their transition. 
According to our survey, 47 stations indicated that they need to 
construct a broadcast tower or reinforce an existing tower to build 
their digital facilities. Another 69 stations responding to our survey 
indicated that they have not started construction on their final 
digital facilities, or that they have not begun broadcasting a digital 
signal due to financial constraints. 

FCC's actions have provided guidance to broadcasters throughout the 
transition process, but at the time we completed our survey, some 
broadcasters were waiting for FCC decisions before they could finalize 
their transition plans. Since 1987, FCC has been working on the DTV 
transition, and its rulemakings and orders have provided guidance for 
broadcasters. For example, in 1996, FCC adopted a rulemaking on a final 
digital standard for broadcasters. Since then, FCC rulemakings and 
orders have directed the broadcasters through the transition process, 
including the assignment of digital broadcast channels and the 
development of timelines for broadcasters to complete their digital 
facilities. In 2002, FCC established rules to ensure that all new 
television and television-related equipment would have a digital tuner 
capable of receiving digital over-the-air signals. Furthermore, FCC has 
conducted periodic reviews of the DTV transition and released its third 
periodic review on December 31, 2007. In its report, FCC addressed 
several issues important to broadcasters' completion of the digital 
transition.[Footnote 5] For example, stations that meet specific 
requirements can now reduce or cease service on their analog or paired 
digital channel prior to the final transition date. FCC also required 
all stations to submit information by February 19, 2008, detailing each 
station's current transition status, the steps that are necessary to 
complete the transition, and the timeline to complete these steps. 
According to our survey of broadcast stations, a few broadcasters had 
issues that required FCC decisions--such as approval for a construction 
permit or for changes to their final digital channel. FCC officials 
said they would address the remaining issues quickly and with the 
release of an order in March 2008, FCC noted that it believes 
broadcasters have everything they need from the commission to proceed 
with construction of their final digital facilities. 

We provided a draft of this report to FCC for review and comment. In 
response, FCC noted that since our survey results of broadcast stations 
were based on information received between December 2007 and February 
2008, the percentages we cite do not necessarily match information FCC 
would derive from its records. FCC also provided technical comments 
that we incorporated in this report where appropriate. 

Background: 

The DTV transition has been in progress for over two decades. With a 
firm date established in law, all full-power television broadcasters 
will cease broadcasting their analog signal by February 17, 2009. There 
are numerous benefits to transitioning to digital-only broadcast 
signals, such as enabling better quality television picture and sound 
reception and using the radiofrequency spectrum more efficiently than 
analog transmission. With traditional analog technology, pictures and 
sounds are converted into "waveform" electrical signals for 
transmission through the radiofrequency spectrum, while digital 
technology converts these pictures and sounds into a stream of digits 
consisting of zeros and ones for transmission. While the digital signal 
disperses over distances, a digital receiver can adjust and recreate 
the missing zeros and ones from the digital transmission, thus making 
the digital picture and sound near perfect until significant fading 
occurs, at which point no picture can be seen.[Footnote 6] 

To facilitate the digital transition, Congress and FCC temporarily 
provided each eligible full-power television station (both commercial 
and noncommercial educational stations, including public stations) with 
additional spectrum so they could begin broadcasting a digital signal. 
This companion, or paired, digital channel simulcasts the analog 
program content in digital format. Assignment of the paired digital 
channel began in 1997 with the hopes that operating this digital 
channel would help stations learn about broadcasting a digital signal, 
in addition to raising consumer interest and understanding about the 
digital transition. The paired digital channel was intended to be used 
for a limited period until all stations were assigned a final digital 
broadcast station and were able to broadcast on their final digital 
channel. FCC completed the digital channel assignment for most stations 
in August 2007. A station's final digital channel could be (1) the same 
channel as its paired digital channel, (2) the same channel that its 
analog signal uses to broadcast, or (3) an entirely new 
channel.[Footnote 7] 

The Digital Television Transition and Public Safety Act of 2005 
addresses the responsibilities of FCC related to the DTV transition. 
The act directs FCC to require full-power television stations to cease 
analog broadcasting after February 17, 2009.[Footnote 8] Stations are 
responsible for meeting this requirement and being prepared to commence 
digital broadcasting by this date; stations not ready to commence 
digital broadcasting risk losing interference protection and operating 
authority. The capability to provide a digital broadcast signal often 
involves a large outlay of capital and effort by broadcast stations. 
Sometimes a new broadcast tower or significant modifications to an 
existing tower is required. While a new antenna could cost a station 
several hundred thousand dollars, an industry association stated that 
stations could spend as much as $2 million to purchase and install a 
new broadcast tower, antenna, and equipment. If new towers or antennas 
are not required, stations may still need to alter or upgrade existing 
towers. Alterations may include moving the digital antenna from a side- 
mounted antenna to the top of the tower to increase the coverage of the 
digital signal. Upgrades to an existing tower may include strengthening 
a tower before additional antennas can be added. For stations building 
new towers, installing new antennas, or making changes to existing 
structures, the stations must plan in advance to order the proper 
equipment and schedule construction crews. 

In September 2007, FCC adopted an order designed to ensure that all 
cable subscribers, including those with analog television sets, can 
view digital broadcasts after the transition.[Footnote 9] FCC stated 
that all cable operators must make all broadcast signals viewable to 
all subscribers and cannot degrade any signal so that a difference in 
the cable signal and the broadcast signal would be perceptible to a 
viewer. According to the order, cable operators can meet this 
requirement in one of two ways, either (1) carry the signals of 
commercial and noncommercial must-carry stations in analog format to 
all analog cable subscribers or (2) for all-digital systems, carry 
those signals in a digital-only format, provided all subscribers with 
analog television sets have the proper equipment to view the digital 
signals. This requirement ensures that subscribers will have the 
ability to view a digital signal or an analog signal, depending on 
which best suits their equipment. While this ruling did not address 
satellite companies, FCC is considering how to apply the content and 
degradation requirements to satellite carriage of digital broadcast 
signals, and the commission expects to complete this ruling before the 
transition. Satellite companies already transmit digital signals to 
subscribers by digitizing broadcasters' analog signals. 

Broadcast Stations Have Made Substantial Progress in Transitioning to 
Digital Television, and the Vast Majority Are Already Transmitting a 
Digital Signal: 

Most broadcasters have made significant progress in preparing their 
stations for the transition to digital, with 91 percent of survey 
respondents reporting that they were already transmitting a digital 
signal. Of the broadcasters already transmitting a digital signal and 
responding to our survey, 68 percent indicated that they are 
broadcasting their digital signal at full strength. In addition, 68 
percent of survey respondents are broadcasting their digital signal on 
the channel from which they will be broadcasting after the transition. 
A small number of stations responding to our survey (9 percent) have 
yet to begin broadcasting a digital signal, but almost all of those 
stations expect to be broadcasting digitally by February 17, 2009. 

Almost All Stations Are Broadcasting a Digital Signal, and the Majority 
Are Operating at Full Power: 

Our survey of broadcast television stations found that almost all 
stations (91 percent of respondents) are transmitting a digital 
signal.[Footnote 10] Of those stations transmitting a digital signal, 
the operating status of these survey respondents, as of February 8, 
2008, is shown in figure 1. 

Figure 1: Operating Status of Broadcast Stations Transmitting a Digital 
Signal, as of February 8, 2008: 

This figure is a pie chart showing operating status of broadcast 
stations transmitting a digital signal, as of February 8, 2008. 

Operating at full power: 68%; 
Not operating at full power, but has capability: 19%; 
Not currently capable of full power: 9%; 
Not operating at full power, but has capability: 4%. 

Source: GAO survey of full-power broadcast television stations. 

[See PDF for image] 

[A] Broadcast stations responding to the survey that indicated their 
operating status as "other" provided various comments on the readiness 
of their digital facilities, to include, among other things, those 
stations operating at full power, but moving channels on February 17, 
2009; those stations operating only a digital signal; and those 
stations operating at full power, but needing to move their antennas. 

[End of figure] 

As figure 2 shows, 68 percent of stations that responded to our survey 
said that their digital channel will not move after the 
transition.[Footnote 11] However, about one third of stations are 
currently operating on a temporary digital channel and will move to 
another channel to complete their transition to digital. Twenty-three 
percent of survey respondents said they will abandon their current 
digital channel to begin broadcasting digitally at the channel location 
currently occupied by their analog channel. Approximately 9 percent of 
survey respondents will have to move to a completely new channel once 
the transition is complete. 

Figure 2: Survey Respondents' Location of Digital Channels Once the 
Transition Is Complete: 

This figure is vertical bar graph showing a survey respondents' 
location of digital channels once the transition is complete. The X 
axis represents the station response, and the Y axis represents 
percentage. 

Remaining on current digital channel: 68; 
Moving from digital channel to current analog channel: 23; 
Moving from digital channel to new channel: 9. 

[See PDF for image] 

Source: GAO survey of full-power broadcast television stations. 

[End of figure] 

Nine Percent of Stations Responding to the Survey Are Not Broadcasting 
Digitally, but Almost All Stations Plan to Have a Digital Signal by 
February 17, 2009: 

Our survey of broadcast stations found that 97 stations, or 9 percent, 
are not broadcasting a digital signal. On the basis of the information 
provided by survey respondents, these stations serve a smaller number 
of households, on average, compared with those stations broadcasting a 
digital signal. In particular, survey respondents that are not 
broadcasting digitally transmit their analog signal to approximately 
350,000 households, on average, compared with the average of nearly 
775,000 households from stations responding to our survey that are 
already broadcasting digitally. Almost all of these stations that are 
not yet broadcasting digitally noted that they plan to have their 
digital signal operational by February 17, 2009. Three stations 
responded that they were not planning to broadcast a digital signal by 
February 17, 2009. 

According to FCC, stations that are not currently transmitting a 
digital signal either (1) were granted a license to operate a digital 
signal along with their analog signal but have yet to begin 
broadcasting digitally or (2) were not given a digital license and plan 
to turn off their analog signal at the same time that they turn on 
their digital signal--known as "flash cutting."[Footnote 12] According 
to our survey, 5 percent (61 stations) of the stations indicated that 
they plan to flash cut to a digital-only broadcast. According to FCC, 
flash cutting may present challenges, since it will involve stations' 
ending their analog television operations and beginning their digital 
television operations on their current analog channel or, in some 
cases, will require that a station change to a new channel to be fully 
operational. Of those stations responding to our survey that plan to 
flash cut, only 21 percent had begun constructing final digital 
facilities at the time of our survey. Furthermore, 64 percent of the 
flash cutters responding to our survey noted that they need to order 
equipment to complete their digital facilities. 

Some Broadcast Stations Face a Range of Technical, Coordination, or 
Other Issues in Completing Their Transition to Digital Television: 

Before the transition to digital can be finalized, some stations still 
have to resolve technical, coordination, or other issues. According to 
stations responding to our survey, a major technical task for over 13 
percent of the stations is the relocation of their digital or analog 
antenna. Other stations responding to our survey indicated that they 
have coordination issues to resolve prior to completing the transition, 
such as the U.S. government reaching agreements with the Canadian and 
Mexican governments and coordinating with cable providers and satellite 
companies. Our survey also found that other issues, such as the 
construction of broadcast towers or financial constraints, have 
affected some stations' ability to finalize their digital facilities. 

Some Broadcast Stations Need to Address Technical Issues in Building 
Their Digital Facilities: 

Broadcast stations and industry representatives have stated that 
technical issues might affect television stations' ability to finalize 
digital operations. Technical issues that some stations need to address 
include (1) antenna and equipment replacement or relocation and (2) 
channel relocation. 

Issues with Antenna and Equipment Replacement or Relocation: 

One of the major tasks that many television stations have to complete 
to build their digital facilities is to install a digital antenna on 
the top of the broadcast tower, where the analog antenna 
resides.[Footnote 13] According to a broadcast industry representative, 
many stations need to have their digital antenna at the top of the 
tower to fully replicate the area that their analog service covers. The 
broadcast industry representative stated that stations have two options 
in placing their digital antenna at the top of the broadcast tower: (1) 
move the digital antenna to the top now, and buy a new side-mounted 
analog antenna, which would ensure that the analog signal continues 
until it is switched off and that the digital signal would be at full 
power, or (2) keep the analog antenna at the top of the tower until it 
is turned off on February 17, 2009, and then install the digital 
antenna at the top of the tower. The industry representative stated 
that both options, however, present problems for broadcast stations. 
For the first option, stations may have to purchase a new analog 
antenna, which will only be used for a few months. Also, as a result of 
the analog antenna being side mounted, stations' analog broadcast 
coverage area would be reduced by a range from 2 to 9 percent of the 
viewing market. Stations agreed that they might have to reduce their 
analog service prior to the transition date. For example, the owner of 
a station in Minnesota commented that it may not be possible to 
complete the construction of its digital facilities without 
significantly disrupting its analog operations as well as its digital 
operations. The owner said the power of its analog signal would have to 
be significantly reduced before February 17, 2009, which would affect a 
large number of its viewers. 

Several survey respondents that were already broadcasting a digital 
signal reported that they needed to take additional steps to complete 
their digital facilities. According to our survey results, 151 stations 
(13 percent) indicated that they needed to relocate their digital or 
analog antenna on a current tower, reinforce an existing tower to allow 
for additional antennas, or coordinate antenna placement on another 
tower. Figure 3 shows the number of stations that need to complete 
these various steps, with some stations reporting that they have to 
complete multiple steps. 

Figure 3: Number of Broadcast Stations with Additional Steps Needed to 
Locate Their Digital Antenna: 

This figure is a vertical bar graph showing number of broadcast 
stations with additional steps needed to locate their digital antenna. 
The X axis represents additional steps needed, and the Y axis 
represents broadcast stations. 

Relocate digital antenna on current tower: 138; 
Relocate analog antenna on current tower: 66; 
Reinforce existing tower to allow for additional antennas: 63; 
Coordinate antenna placement on another broadcast tower: 31. 

[See PDF for image] 

Source: GAO survey of full-power broadcast television stations. 

Note: Some of the 151 stations indicated that they have to complete 
multiple steps. 

[End of figure] 

FCC recognizes that there are many technical issues associated with 
antenna and equipment replacement or relocation that might force 
stations to terminate analog signals prior to the transition date. For 
example, FCC noted that there are 49 stations that have documented 
problems with side-mounted analog antennas. These stations will have to 
relocate their analog antenna to another location on their tower and 
operate with reduced analog facilities as they complete the transition. 
Other stations may have a tower at capacity, preventing the 
installation of an additional antenna on the tower. According to FCC, 
these stations will have to terminate analog operations prior to the 
end of the transition to mount their digital antenna. In addition, 
stations with an antenna that is located on a shared tower may need to 
reduce or terminate analog signals as the stations coordinate the 
configuration of their final digital facilities. Still other stations 
have equipment currently in use with their analog operations that they 
plan to use with their digital operations. Such a situation will force 
stations to terminate their analog signals prior to the transition so 
that the equipment can be reconfigured for the final digital 
facilities. Although FCC established February 17, 2009, as the new 
construction deadline for stations facing unique technical challenges, 
FCC will also consider stations' requests to operate their digital 
facilities at less then full power until August 18, 2009--provided the 
stations continue to serve at least 85 percent of their viewers. 

According to an antenna manufacturer with whom we spoke, stations will 
need to place orders for their antenna by the second quarter of 2008 
for the stations to be prepared for the February 17, 2009, deadline. 
According to this manufacturer, the amount of time needed to design, 
order, and install an antenna can range from 6 weeks and 9 months, 
depending on its complexity. This manufacturer said a typical antenna 
serving one station requires about 4 or 5 months, from design to 
installation. In its third periodic review and order on the DTV 
transition, FCC noted that absent extraordinary circumstances, it would 
no longer consider a lack of equipment as a valid reason for granting 
an extension of time to construct facilities.[Footnote 14] FCC also 
said that stations demonstrating that they placed equipment orders well 
in advance will be considered eligible for an extension on these 
grounds. 

Antenna work and replacement could be hampered by weather conditions 
for towers located in northern climates and on higher elevations. 
According to an antenna manufacturer with whom we spoke, although 
antenna work can be done during the winter months, it can be much more 
difficult, take longer, and entail additional costs. According to this 
manufacturer, winds over 10 miles an hour can be problematic for 
installing equipment. Installation crews need several days of limited 
wind speed to complete antenna work. In addition, ice and snow can 
present safety issues when installing antennas on towers. FCC 
recognizes that for some stations, work cannot be completed because of 
weather conditions, and that those stations facing legitimate delays 
will be considered for construction extensions. For example, if a 
station has a side-mounted digital antenna and can demonstrate that 
weather considerations would force it to reduce or terminate its analog 
signal well before the transition date to complete building of their 
final facility, it might qualify for an early reduction or termination 
of analog service prior to February 17, 2009. FCC states that in such 
situations, it could be preferable to accept a limited loss of analog 
service for a short time prior to the transition date to ensure the 
station is able to complete its transition to digital. 

Issues with Channel Relocation: 

FCC notes that the stations facing the most significant amount of 
construction to finalize their facilities are those that are moving to 
a different channel. According to FCC, 643 stations will move to a 
different channel to complete the transition. FCC states that 514 of 
these stations will relocate their current digital channel to their 
analog channel. Stations might prefer to relocate their digital channel 
to the analog channel because it is the channel that viewers recognize. 
For example, one station we visited has its digital signal on channel 
16 but plans to relocate the digital signal to channel 9, which is the 
station's current analog channel and the channel number people 
recognize for that station. In addition, stations currently located on 
channels 52 through 69 need to relocate their channel because these 
channel frequencies will be used for public safety and new wireless 
services after the transition.[Footnote 15] According to FCC, 129 
stations will move to a completely new channel once the transition is 
complete. Such moves entail additional challenges for these stations 
because they may need to address such issues as (1) can the stations 
use any of their current analog or digital equipment, (2) will their 
viewers be impacted during construction of their digital facilities, 
and (3) will the stations have to coordinate with other stations 
because the channel they are moving to will be occupied by another 
station until the transition date. 

Because of the issues associated with channel relocation, FCC is 
allowing stations moving to a different digital channel to cease 
operations on their pretransition digital channels and begin operating 
digitally on their new channels before the transition date. Stations 
can operate on their new channel before the transition date provided 
(1) the early transitioning stations will not cause impermissible 
interference to another station and (2) the early transitioning 
stations continue to serve their existing viewers for the remainder of 
the transition, and commence their full-power, authorized 
posttransition operations upon expiration of the February 17, 2009, 
transition deadline. In addition, stations that are moving to a 
different digital channel for posttransition operations may temporarily 
remain on their pretransition channel while they complete construction 
of their final digital facilities. Stations can remain on their 
pretransition channel provided (1) they build facilities serving at 
least the same population that receives their current analog television 
and digital services so that over the air viewers will not lose service 
and (2) they do not cause impermissible interference to other stations 
or prevent other stations from making their transition. 

Coordination between Broadcast Stations and Various Public and Private 
Entities May Be Necessary to Support a Smooth Transition: 

Coordination issues might affect television broadcast stations' ability 
to finalize their digital operations, according to stations that 
responded to our survey and our discussions with broadcast stations and 
industry representatives. Coordination issues that some stations face 
include (1) U.S. government coordination with Canadian or Mexican 
governments, (2) coordination with cable providers and satellite 
companies, and (3) coordination with other broadcast stations. 

Coordination with Canadian and Mexican Governments: 

For some stations located along the northern and southern borders of 
the United States, agreements must be reached with the Canadian and 
Mexican governments regarding the coverage of the stations' digital 
signals that transmit across the borders.[Footnote 16] According to FCC 
officials, there are 139 and 43 U.S. stations that operate along the 
Canadian and Mexican borders, respectively. FCC officials stated that 
agreements are in place for most of these stations, and FCC expects 
agreements to be reached for all of the remaining stations. In 
responding to our survey, the stations that require coordination with a 
foreign government noted that different levels of coordination had 
taken place, as illustrated in figure 4. 

Figure 4: Survey Respondents' Status Regarding U.S. Government 
Coordination with the Mexican and Canadian Governments: 

This figure is a vertical bar graph showing survey respondents' status 
regarding U.S. Government coordination with Mexican and Canadian 
government. The X axis represents the international coordination, and 
the Y axis represents the broadcast antenna. 

Has already occurred: 49; 
Is taking place: 26; 
Has not taken place: 20. 

[See PDF for image] 

Source: GAO survey of full-power broadcast television stations. 

[End of figure] 

However, in responding to our survey, most stations with a signal that 
penetrates into Canada or Mexico were not concerned about analog 
interference. In particular, 81 percent of respondents operating along 
the Mexican border were not concerned about interference, while 86 
percent along the Canadian border were not concerned about such 
interference. 

In responding to our survey question regarding coordination with the 
Mexican and Canadian governments, one station commented that the lack 
of concurrence from the Mexican government has created significant 
concern about the station's ability to transition to its final digital 
operations, and that an agreement is needed as soon as possible. 
Another survey respondent stated that objection by the Canadian 
government to its final channel assignment was very late in the process 
and will seriously jeopardize its ability to build its digital 
facilities by the transition date. Another station that responded to 
our survey expressed concern about Canadian coordination being 
completed by the 2009 deadline. In its third periodic review and order, 
FCC stated that it will consider extensions of construction deadlines 
for stations encountering delays in cases where resolution of issues 
related to international coordination is truly beyond the control of 
the station. FCC also stated that if agreements cannot be reached, 
stations might be required to construct facilities with a smaller area 
of signal coverage. At the time of this report, there was a set of 
companion bills in the Senate and House known as the DTV Border Fix 
Act, which, if enacted, would authorize FCC to allow full- power 
television stations serving communities located within 50 miles of the 
U.S.-Mexican border to continue operating an analog signal until 
February 17, 2014. Among other requirements, stations seeking an 
extension would have to satisfy FCC that continued analog operation 
would be in the public interest. 

Coordination with Cable Providers and Satellite Companies: 

As part of finalizing the transition to DTV, cable providers and 
satellite companies will need to make sure that their facilities 
receive digital signals from television stations when the analog 
signals terminate. In its third periodic review and order, FCC made no 
rules concerning the coordination between broadcast stations, cable 
providers, and satellite companies. However, FCC reiterated that 
broadcasters must work with cable providers and satellite companies to 
ensure a successful transition. 

Many broadcast stations are currently coordinating with cable providers 
and satellite companies. As shown in figure 5, 55 percent of the 
stations responding to our survey indicated that they are currently 
coordinating with cable providers, and 50 percent of the stations 
responding to our survey indicated that they are currently coordinating 
with satellite companies. In addition, nearly 35 percent of stations 
responding to our survey indicated that they plan to coordinate with 
cable providers, and 36 percent of stations indicated that they plan to 
coordinate with satellite companies. One percent of stations responding 
to our survey indicated that they were not coordinating with and were 
not planning to coordinate with cable providers, and 5 percent 
indicated that they were not coordinating with and were not planning to 
coordinate with satellite companies. 

Figure 5: Survey Respondents' Status in Coordinating with Cable 
Providers and Satellite Companies: 

This figure is a combination vertical bar graph showing survey 
respondents' status in coordinating with cable providers and satellite 
companies. The X axis represents the station results, and the Y axis 
represents the percentage. 

Cable providers; 
Currently coordinating: 55; 
Planning to coordinate: 35; 
Not currently or planning to coordinate: 1; 
Do not know: 1. 

Satellite companies; 
Currently coordinating: 50; 
Planning to coordinate: 36; 
Not currently or planning to coordinate: 5; 
Do not know: 2. 

[See PDF for image] 

Source: GAO survey of full-power broadcast televisions stations. 

[End of figure] 

With some stations moving to a new channel or changing the coverage 
area of their broadcast signal, cable providers told us there is 
uncertainty about whether their cable head-ends will continue to 
receive the broadcast signals.[Footnote 17] For example, if a 
broadcaster's digital coverage area differs from its analog coverage 
area, there is a possibility the cable head-end will no longer be able 
to receive that signal. Approximately 32 percent of survey respondents 
that are carried by cable, satellite, or both indicated that they are 
concerned their digital signal may not reach one or more cable 
providers' or satellite companies' facilities once the transition has 
occurred. One cable provider told us this issue could be particularly 
problematic in smaller markets where head-ends rely on over-the-air 
broadcasts to pull in the broadcast signals. 

A cable provider and satellite company also told us that they need 
broadcast stations to inform them of their coverage areas, or signal 
contours, as soon as possible to help them identify areas where the 
digital signal may not reach cable head-ends or satellite receiver 
facilities. This information is important because even when stations do 
have their digital facilities fully operational, they may not broadcast 
their digital signal to the exact coverage area that their analog 
signal covered. As shown in figure 6, the digital signal coverage of a 
station can differ from its analog signal coverage. 

Figure 6: Example of a Broadcast Station's Digital Signal Coverage 
Compared with Analog Signal Coverage: 

This figure is an illustration of a broadcast station's digital signal 
coverage compared with analog signal coverage. 

[See PDF for image] 

Source: FCC. 

[End of figure] 

Officials with one cable provider with whom we spoke indicated that on 
the basis of potential changing signal coverage areas, the provider 
might need to reposition its antenna or otherwise update its head-ends 
so that it can continue to receive the broadcast signals. The officials 
went on to say that since their company has hundreds of head-ends, it 
could be time-consuming to update them. Officials of a satellite 
company told us that any change in the signal coverage area could 
seriously affect the company's ability to retransmit broadcast signals 
and might require it to build new facilities in the altered coverage 
area. 

Information from our survey indicates that some stations will have a 
different digital signal coverage area compared with their analog 
signal coverage area. Of our survey respondents, 24 percent reported 
that their digital signal coverage area will vary from their analog 
coverage area. While some of these stations' digital coverage area 
could be increasing compared with the analog coverage area, some 
stations' digital coverage area will be smaller, at least in some parts 
of the coverage area, compared with their analog coverage area. This is 
evident by 11 percent of the stations responding to our survey 
reporting that they anticipate losing over-the-air viewers after the 
transition to digital. On average, those stations anticipating 
decreased coverage areas expect to lose 23,000 viewers. 

Stations Coordinating with Each Other: 

According to our survey, 101 stations (9 percent) that have to relocate 
their current digital channel are moving to another channel that might 
be occupied by another station. Of these 101 stations, 13 survey 
respondents indicated that they are working with the other station to 
resolve coordination issues. According to a broadcast industry 
representative, the movement of channels will require television 
stations to closely coordinate with each other to minimize interference 
issues. The industry representative stated that the movement of 
channels could cause interference for neighboring channels if they move 
too early or if the neighboring channels move too late. The industry 
representative further stated that compounding this challenge is the 
fact that analog signals will be turned off on February 17, 2009. 

Other Issues, Such as Construction Scheduling and Financial 
Constraints, Might Affect Some Stations during Their Transition: 

The construction of broadcast towers or financial constraints might 
affect some stations during their transition. Stations that must change 
their DTV tower locations might face considerable challenges, 
especially if the station must construct a new tower. Nineteen stations 
responding to our survey indicated that they needed to construct a 
broadcast tower to build their digital facilities. In addition, 62 
stations responding to our survey indicated that they needed to 
reinforce an existing broadcast tower to finalize their facilities. A 
major television broadcast network stated that equipment manufacturing 
constraints and the limited number of tower crews and other key 
equipment installation resources available between now and the 
transition date will impede stations' movement to final digital 
channels by February 17, 2009. A representative with a major tower 
construction company told us that the company is already booked 6 
months into 2008, and that other construction crews also have full 
schedules. The company representative stated he believes that there are 
a significant number of stations that will wait until early 2008 to 
start making inquiries about work needing to be done on broadcast 
towers. 

According to FCC, stations constructing a new tower should consider 
whether there are any existing towers that can be used or if a new 
tower must be constructed. FCC states that because of the lead times 
involved in purchasing or leasing land with the appropriate federal 
government clearances, local and state zoning requirements, and varying 
timelines for designing and constructing the new tower, stations must 
begin planning as soon as possible to have all of the work completed by 
the deadline. 

Similar to weather conditions affecting work on antennas, winter 
weather could hamper tower construction in northern climates and on 
higher elevations. Television stations commented that working on towers 
in the winter months can be problematic, if not impossible. For 
example, a major broadcast network commented that many station 
transmitting sites are not readily accessible during the winter, 
especially to cranes and other heavy equipment necessary for tower 
rigging and equipment installation. In fact, the broadcaster commented 
that snow and ice make one of its stations accessible only by a special 
vehicle from October until March. Another station commented that it has 
been difficult to perform heavy construction at a remote and high- 
altitude transmitter site, and that the short weather window, difficult 
access, and complex work make the transition date hard to attain. A 
representative of a major tower construction company stated that 
weather is always a factor when determining the amount of time a 
project takes. The company representative stated that subzero 
conditions and ice are not conducive for tower work, and, although the 
work can be done, it is very dangerous and takes a much longer time to 
complete. 

Stations encountering financial constraints may also have difficulties 
in completing the digital transition. According to our survey, 38 
stations noted that financial constraints had been an issue during the 
process of constructing their final digital facilities. In addition, 39 
stations that are broadcasting a digital signal, but have yet to begin 
building their final digital facilities, indicated that financial 
constraints were a reason they had not yet started construction. 
Furthermore, another 33 stations, or 42 percent of stations not yet 
broadcasting a digital signal, indicated that financial constraints 
contributed to delays in building their final digital facilities. One 
station commented that the digital transition has been a financial 
drain on small-market television stations. This station noted that the 
cost for the equipment is the same whether the station serves a small 
or large market, but large-market stations have a much higher financial 
base to pay for the equipment. 

In its third periodic review, FCC acknowledged that some stations face 
financial obstacles to completing construction, but stated that it is 
imperative that stations devise and implement a plan to complete their 
final digital facilities. FCC established criteria for extensions of 
construction on final digital facilities due to financial 
hardship.[Footnote 18] To obtain an extension on the grounds of 
financial hardship, FCC requires a station to demonstrate that it (1) 
is the subject of a bankruptcy or receivership proceeding or (2) has 
experienced a negative cash flow for the past 3 years. FCC stated that 
while adopting the tighter financial hardship standard, it recognizes 
that some stations, including some noncommercial educational stations 
and some smaller stations, face extraordinary financial circumstances 
that do not fit within the new financial hardship criteria but may 
warrant an extension of time to finalize construction. Two stations 
that responded to our survey stated that they would qualify under FCC's 
new criteria of financial hardship. One station commented that it was 
in the process of filing bankruptcy after 3 years of negative cash 
flow. Another station commented that it would qualify for financial 
hardship due to costs associated with locating its analog antenna and 
operating with a digital-only signal for a period of time, which 
resulted in a 30 percent drop in viewers and a negative cash flow from 
the reduction of viewers. 

FCC Has Taken Numerous Actions to Guide Broadcast Stations through the 
Digital Transition: 

FCC's actions have provided guidance to broadcast stations throughout 
the transition process. A recent FCC ruling addressed many issues 
important to broadcasters and provided increased flexibility for 
broadcasters in completing DTV transition tasks. At the time we 
completed our survey, however, some broadcasters were waiting for FCC 
decisions before they could finalize their transition plans. 

FCC Rulemakings and Orders Have Directed Broadcast Stations' 
Preparation for the Digital Transition: 

For many years, FCC has orchestrated the DTV transition using its 
rulemakings process to guide broadcast stations through important 
milestones. FCC determined that establishing a digital standard for 
broadcasters was critical to begin the transition to digital broadcast; 
the establishment of a digital standard was completed with the adoption 
of an order in 1996.[Footnote 19] Since then, FCC has taken additional 
actions to continue moving broadcasters toward the digital transition, 
as shown in table 1. For example, FCC assigned paired digital channels 
for stations that would be broadcasting both a digital and an analog 
signal prior to the digital transition. These paired digital channels 
were important to allow broadcasters time to gain experience in 
operating a digital service, stimulate interest in the DTV transition, 
and encourage consumers to begin purchasing digital equipment. 

Table 1: FCC Key Actions in Support of Broadcasters' Transition to 
Digital: 

FCC key action: Adopted a digital broadcast technical standard; 
Description: * Identified the development of a digital standard as 
critical to move the digital transition ahead; 
* Collaborated with the industry in the development of this standard by 
appointing the Advisory Committee on Advanced Television Service; 
* Charged the advisory committee with providing recommendations on 
technical, economic, and policy issues related to the introduction of 
DTV service. Subsequently, the advisory committee conducted an open 
competition to define a DTV standard, determined that a high-definition 
television system was possible, and recommended a set of DTV protocols. 

FCC key action: Assigned broadcasters a paired digital broadcast 
channel; 
Description: * Defined criteria to determine which stations would be 
allowed a paired digital channel to simultaneously broadcast a digital 
and an analog broadcast signal prior to the transition; 
* Adopted simulcast requirement for the paired digital channels and by 
what time all broadcast content must be simulcast on the paired digital 
channel; 
* Established deadlines for stations to maximize the signal of their 
paired digital channel or lose interference protection on this channel. 

FCC key action: Assigned broadcasters final digital broadcast channel; 
Description: * Created a multistep channel election process that 
allowed broadcasters to express their final digital channel preference; 
* Designated construction deadlines for final digital broadcast channel 
that stations must meet or face potential loss of interference 
protection; 
* Updated construction deadlines for final digital broadcast channel 
and created tighter standards for stations requesting any extension 
beyond the final transition date. 

FCC key action: Established time frame for all new television equipment 
in the United States to have a digital tuner; 
Description: * Required that all new television equipment in the United 
States be capable of receiving a digital signal; 
* Created a phased approach for the digital tuner requirement based on 
the size of television sets, beginning in July 2004 and ending in March 
2007, when all sizes of television sets and all television equipment 
must be equipped with a digital tuner.[A]. 

Source: FCC. 

[A] The original end date for all sizes of new television sets and 
television equipment to be equipped with a digital tuner was July 1, 
2007. However, in 2005, FCC moved the date to March 1, 2007. 

[End of table] 

In its December 2007 third periodic review and order, FCC finalized a 
number of actions to facilitate broadcasters' completion of the DTV 
transition. For example, the third periodic review and order addressed, 
among other things, (1) time frames for television stations to complete 
construction of their digital facilities; (2) information all full- 
power television stations must provide to FCC by February 19, 2008, 
detailing the station's current transition status, any additional steps 
needed to commence its full, digital operations, and its timeline to 
meet the February 17, 2009, transition deadline;[Footnote 20] (3) when 
and for how long stations will be permitted to reduce or cease service 
on their analog or paired digital channel;[Footnote 21] and (4) 
guidelines for rapid approval of minor expansion of authorized service 
areas for stations that are moving their digital channel for 
posttransition operations to allow these stations additional 
flexibility to use their existing analog antenna. 

Some Broadcast Stations Required FCC Decisions Prior to Finalizing 
Their Digital Facilities: 

In our survey of broadcast stations, 128 respondents indicated they 
were "awaiting action from FCC" to complete building their final 
digital facilities. In following up with these stations after they had 
responded to our survey, our analysis suggested that the actions many 
stations were awaiting were addressed in FCC's third periodic review 
and order. However, at that time, a few broadcasters still had issues 
that required FCC decisions--such as approval for a construction 
permit, petitions to alter their signal power, or FCC reconsideration 
of their final digital channel assignment. According to FCC, 
approximately 100 petitions for reconsideration of final DTV channel 
assignments were filed by broadcasters. FCC said these petitions needed 
engineering analysis performed to determine the feasibility and impact 
on other stations. FCC told us that the analysis had been completed, 
and released its decisions regarding the petitions in early March 
2008.[Footnote 22] FCC noted that it believes broadcasters have 
everything they need from the commission to proceed with construction 
of their final digital facilities. 

Agency Comments: 

We provided a draft of this report to FCC for its review and comment. 
In response, FCC noted that since our survey results of broadcast 
stations were based on information received between December 2007 and 
February 2008, the percentages we cite do not necessarily match 
information FCC would derive from its records. FCC also provided 
technical comments that we incorporated in this report where 
appropriate. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of the report 
to interested congressional committees and the Chairman of the Federal 
Communications Commission. We will make copies available to others upon 
request. In addition, the report will be available at no charge on 
GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions concerning this report, please 
contact me on (202) 512-2834 or at goldsteinm@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. Key contributors to this report 
are listed in appendix II. 

Signed by: 

Mark L. Goldstein: 

Director, Physical Infrastructure Issues: 

List of Requesters: 

The Honorable Edward J. Markey: 
Chairman: 
The Honorable Cliff Stearns: 
Ranking Member: 
Subcommittee on Telecommunications and the Internet: 
Committee on Energy and Commerce: 
House of Representatives: 

The Honorable Herb Kohl Chairman: 
Special Committee on Aging: 
United States Senate: 

The Honorable Daniel K. Inouye: 
Chairman: 
Committee on Commerce, Science, and Transportation: 
United States Senate: 

The Honorable Joe Barton: 
Ranking Member: 
Committee on Energy and Commerce: 
House of Representatives: 

The Honorable Fred Upton: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The objectives of this report are to provide information on technical 
issues surrounding the digital television (DTV) transition, 
specifically, (1) the status of broadcast stations in transitioning to 
digital, (2) the extent to which broadcast stations are encountering 
issues during the DTV transition and how these issues impact the 
broadcast community, and (3) the actions the Federal Communications 
Commission (FCC) has taken to guide broadcasters in the DTV transition 
and how those actions have affected the broadcast community. 

To obtain information on the status of the television broadcast 
industry in transitioning to digital and the issues broadcasters were 
encountering, we developed and administered a Web-based survey. Our 
intent was to survey all full-power commercial and noncommercial 
broadcast television stations in the 50 states and the District of 
Columbia. We asked the broadcast stations questions related to their 
(1) digital facilities and plans, (2) issues affecting the digital 
conversion, (3) antenna locations, (4) DTV information advertisements 
and public service announcements, (5) digital signal contour and 
coordination with cable and satellite, (6) relocation of digital 
channels, (7) digital and analog signal coverage, (8) international 
issues, and (9) translator stations. The initial sample frame for the 
study was all FCC licensed full-powered television stations as of June 
2007--a total of 1,747 stations. Since FCC did not maintain e-mail 
addresses for the licensed broadcasters at that time, we needed to 
obtain contact information on the broadcasters through alternate 
sources. We requested and received contact information from the 
following sources: the Association of Public Television Stations, ABC, 
CBS, NBC, CW, FOX, and Telemundo. In total, we received contact 
information for 1,058 stations. For the remaining 625 stations, the 
engagement team spent 1 week compiling a list of contact information. 
Of the 1,747 broadcasters on FCC's list, we surveyed 1,682 stations 
located in the 50 states and the District of Columbia for which we 
could obtain contact information.[Footnote 23] In several instances, we 
identified stations that were not on FCC's list of full-power broadcast 
stations, or stations for which we did not initially have contact 
information and subsequently sent the survey to these stations. From 
September 27, 2007, through October 16, 2007, we conducted a series of 
pretests with general managers of broadcast television stations to help 
further refine our questions, clarify any ambiguous portions of the 
survey, and identify any potentially biased questions. Upon completion 
of the pretests and development of the final survey questions and 
format, we sent an announcement of the upcoming survey to 1,682 
broadcast television stations on November 30, 2007. These stations were 
notified that the survey was available online on December 7, 2007. We 
sent follow-up e-mail messages to nonrespondents on December 14, 2007, 
December 21, 2007, January 8, 2008, and January 9, 2008, and then 
attempted to contact by telephone those stations that had not completed 
the survey. 

The survey was available online until February 8, 2008. Of the 1,682 
broadcast stations that were asked to complete the survey, we received 
1,122 completed surveys, for an overall response rate of 66.7 percent. 
Of those completed questionnaires, 72 percent were from commercial 
stations and 28 percent were from noncommercial stations. The practical 
difficulties of conducting surveys may introduce errors commonly 
referred to as "nonsampling errors." For example, questions may be 
misinterpreted and the respondents' answers may differ from broadcast 
stations that did not respond to the survey. To minimize nonsampling 
errors, we pretested the survey and conducted numerous follow-up 
contacts with nonrespondents. In addition, steps were taken during data 
analysis to further minimize errors, such as performing computer 
analyses to identify inconsistencies and completing a review of data 
analysis by an independent reviewer. We also conducted a nonresponse 
bias analysis, comparing our survey estimates with estimates obtained 
from FCC records, and found small, but statistically significant 
differences. Because of the differences identified through the bias 
analysis, we decided to provide estimates only for respondents and not 
to project our results to the population. The survey results were 
reliable enough for our purpose because the bias does not appear to be 
more than a few percentage points. A difference of 5 percentage points 
in any of our estimates would not affect our findings. To view the 
survey and a more complete tabulation of the results, go to [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-528SP]. 

Furthermore, we reviewed relevant law, public comments, proposed rules, 
and other industry and private sector documents. We interviewed 
officials with FCC as well as a wide variety of industry and other 
private sector stakeholders with an interest in the DTV transition, 
such as commercial and noncommercial broadcasters; antenna and 
equipment manufacturers; tower construction companies; and industry 
advocacy groups, such as the National Association of Broadcasters and 
the Association for Maximum Service Television. We conducted this 
performance audit from April 2007 through April 2008 in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe that the evidence 
obtained provides a reasonable basis for our findings and conclusions 
based on our audit objectives. 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, other key contributors to 
this report were Sally Moino, Assistant Director; Andy Clinton; Colin 
Fallon; Simon Galed; Eric Hudson; Bert Japikse; Aaron Kaminsky; and 
Andrew Stavisky. 

[End of section] 

Related GAO Products: 

Digital Television Transition: Increased Federal Planning and Risk 
Management Could Further Facilitate the DTV Transition. GAO-08-43. 
Washington, D.C.: November 19, 2007. 

Digital Television Transition: Preliminary Information on Progress of 
the DTV Transition. GAO-08-191T. Washington, D.C.: October 17, 2007. 

Digital Television Transition: Preliminary Information on Initial 
Consumer Education Efforts. GAO-07-1248T. Washington, D.C.: September 
19, 2007. 

Digital Television Transition: Issues Related to an Information 
Campaign Regarding the Transition. GAO-05-940R. Washington, D.C.: 
September 6, 2005. 

Digital Television Transition: Questions on Administrative Costs of an 
Equipment Subsidy Program. GAO-05-837R. Washington, D.C.: June 20, 
2005. 

Digital Broadcast Television Transition: Several Challenges Could Arise 
in Administering a Subsidy Program for DTV Equipment. GAO-05-623T. 
Washington, D.C.: May 26, 2005. 

Digital Broadcast Television Transition: Estimated Cost of Supporting 
Set-Top Boxes to Help Advance the DTV Transition. GAO-05-258T. 
Washington, D.C.: February 17, 2005. 

Telecommunications: German DTV Transition Differs from U.S. Transition 
in Many Respects, but Certain Key Challenges Are Similar. GAO-04-926T. 
Washington, D.C.: July 21, 2004. 

Telecommunications: Additional Federal Efforts Could Help Advance 
Digital Television Transition. GAO-03-7. Washington, D.C.: November 8, 
2002. 

Telecommunications: Many Broadcasters Will Not Meet May 2002 Digital 
Television Deadline. GAO-02-466. Washington, D.C.: April 23, 2002. 

[End of section] 

Footnotes: 

[1] Deficit Reduction Act of 2005, Pub. L. No. 109-171, title III. 

[2] The radiofrequency spectrum is the part of the natural spectrum of 
electromagnetic radiation lying below 300 gigahertz. The spectrum is 
the medium that makes possible wireless communications, including 
cellular and paging services, radio and television broadcasting, radar, 
and satellite-based services. 

[3] GAO, Digital Television Transition: Increased Federal Planning and 
Risk Management Could Further Facilitate the DTV Transition, GAO-08-43 
(Washington, D.C.: Nov. 19, 2007). 

[4] We did not survey 30 broadcasters for which we could not obtain 
contact information or 35 stations located in the territories of Puerto 
Rico, Guam, and the Virgin Islands. 

[5] Federal Communications Commission, Third Periodic Review of the 
Commission's Rules and Policies Affecting the Conversion to Digital 
Television, MB Docket No. 07-91, Report and Order (2007). The third 
periodic review and report and order was published in the Federal 
Register on January 30, 2008, putting into effect the rules, forms, and 
procedures outlined therein. 

[6] This is known as the "cliff effect"--a viewer either gets a clear 
picture or no picture at all. 

[7] Some stations were not assigned a paired digital channel. 

[8] Low-power broadcast and translator stations are not required to 
cease broadcasting in analog as of February 17, 2009. Although some of 
these stations already have or plan to independently transition to 
digital-only broadcasting, many will continue to broadcast in analog 
after the conclusion of the full-power transition. Thus, these 
stations' consumers might receive some programming in digital and some 
programming in analog after the transition date. 

[9] Federal Communications Commission, Carriage of Digital Television 
Broadcast Signals: Amendment to Part 76 of the Commission's Rules, CS 
Docket No. 98-120, Third Report and Order and Third Further Notice of 
Proposed Rulemaking, 22 FCC Rcd. 21064 (2007). 

[10] Several stations are not broadcasting an analog signal and are 
solely transmitting a digital signal. For example, 17 stations that 
responded to our survey indicated that they were only broadcasting a 
digital signal. 

[11] FCC has identified 1,034 stations that have finished building 
digital facilities and are ready to cease analog broadcasts and 
broadcast solely in digital. 

[12] According to FCC, "flash cut" refers to the situation where a 
station simultaneously gives up its pretransition digital channel and 
begins digital service using its analog channel or a newly allotted 
channel. 

[13] We use the term "digital antenna" to refer to an antenna that is 
to be used to transmit a digital signal; the term "analog antenna" 
refers to an antenna used to transmit an analog signal. 

[14] A broadcaster may apply for an extension to the construction 
deadline defined by FCC as part of the broadcaster's construction 
permit or in the third periodic review. The deadline defines when 
construction must be complete and when the digital broadcast signal is 
operational. 

[15] The Digital Television Transition and Public Safety Act of 2005 
requires that no full-power stations remain on out-of-core channels 
after the February 17, 2009, transition date. 

[16] Mexico and Canada use the same spectrum for television broadcasts 
as the United States. 

[17] Cable providers receive the local broadcast signals to their 
"head- ends." Head-ends are the facilities where cable providers 
originate and distribute cable service in a geographic area. Cable 
providers receive and package television signals from a variety of 
television stations and networks and distribute the signals over 
coaxial or fiber-optic cable emanating from the head-end and 
terminating at subscribers' residences. These signals can be received 
by the providers either over the air, across fiber, by microwave 
antenna, or by other means. Over- the-air signals could be lost 
completely on the basis of changes to the broadcast stations' antenna 
placement or structure. Fiber and other means of receiving the 
broadcast signal may require changes in equipment. 

[18] FCC previously had permitted consideration of circumstances where 
the cost of meeting build-out requirements exceeded the station's 
financial resources. 

[19] Federal Communications Commission, Advanced Television Systems and 
Their Impact Upon the Existing Television Broadcast Service, MM Docket 
No. 87-268, Fourth Report and Order, 11 FCC Rcd. 17771 (1996). 

[20] Stations will also be required to update this information, as 
necessary, until construction of fully authorized digital facilities is 
completed and the station has begun operating its full posttransition 
facility. FCC intends to use this information to identify stations that 
are not communicating their progress and may contact stations directly 
to assess and discuss the stations' transition status. In addition, FCC 
is planning to prepare a comprehensive summary report of the 
information provided by stations no later than August 18, 2008, to 
assess the progress toward completing the transition. FCC will also 
require stations that have not completed construction of their final 
digital facilities to update their status by October 20, 2008. 

[21] Stations can now reduce or terminate their analog and paired 
digital broadcasts prior to the transition for a period longer than 30 
days, if the station meets certain requirements. If approved for early 
reduction or termination, stations are required to notify their 
viewers. The third periodic review and order specifies what must appear 
in the notification, and that the notification must be broadcast at 
least 4 times a day for 60 days prior to the change in service for 
stations reducing service for longer than 30 days. 

[22] Federal Communications Commission, Advanced Television Systems and 
Their Impact Upon the Existing Television Broadcast Service, MB Docket 
No. 87-268, Memorandum Opinion and Order on Reconsideration of the 
Seventh Report and Order and Eighth Report and Order (2008). 

[23] We did not survey 30 broadcast stations for which we could not 
obtain contact information or 35 stations located in the territories of 
Puerto Rico, Guam, and the Virgin Islands. 

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