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Testimony: 

Before the House Subcommittee on Telecommunications and the Internet: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 9:30 a.m. EDT: 

Wednesday, October 17, 2007: 

Digital Television Transition: 

Preliminary Information on Progress of the DTV Transition: 

Statement of Mark L. Goldstein, Director: 

Physical Infrastructure: 

DTV Transition: 

GAO-08-191T: 

GAO Highlights: 

Highlights of GAO-08-191T, a testimony before the House Subcommittee on 
Telecommunications and the Internet. 

Why GAO Did This Study: 

On February 17, 2009, federal law requires all full-power television 
stations in the United States to cease analog broadcasting, enabling 
the government to reclaim valuable spectrum that the broadcasters 
currently use for analog broadcasts. This change, often referred to as 
the digital television (DTV) transition, requires action by 
broadcasters and consumers to ensure broadcast television signals are 
still available and viewable. The National Telecommunications and 
Information Administration (NTIA) created a program to subsidize 
consumers’ purchases of digital-to-analog converter boxes. This 
testimony provides preliminary information on (1) the progress made by 
federal entities, and others, to facilitate the transition, (2) the 
progress in the education of consumers about the transition, (3) the 
progress made in implementing the converter box subsidy program, (4) 
technical issues of the transition, and (5) future GAO work on the 
progress of the DTV transition. GAO interviewed officials with the 
Federal Communications Commission (FCC) and NTIA. Further, GAO 
interviewed a wide variety of industry and other stakeholders involved 
with the transition, including members of the DTV Transition 
Coalition—a group of public and private stakeholders, and experts on 
strategic communications. GAO discussed this testimony with FCC and 
NTIA officials and incorporated their comments. 

What GAO Found: 

FCC and NTIA, in conjunction with other stakeholders, have taken steps 
to facilitate the DTV transition. For example, FCC has conducted 
periodic reviews to report on transition progress, and NTIA has issued 
a contract for administering the converter box subsidy program. In 
addition, private sector industries have also begun preparing for the 
transition. Despite public-private sector interaction designed to help 
facilitate the transition, we found that no comprehensive plan exists 
for the DTV transition. Without such a plan, meaningful guidance for 
coordinating responsibilities and measuring progress might not be 
available to the private or public sector. 

Several federal and private stakeholders have begun consumer education 
campaigns. FCC and NTIA have developed informational materials and 
begun direct outreach to consumer groups. In addition, private industry 
stakeholders created the DTV Transition Coalition and are voluntarily 
conducting outreach efforts. However, these efforts are in the planning 
stages and challenges remain. An expert panel that GAO convened 
identified potential challenges and key practices for a consumer 
education campaign. 

NTIA has made progress in implementing the converter box subsidy 
program, but the program’s outcome depends on the voluntary 
participation of retailers and manufacturers. Retailers we contacted 
expressed concerns about the possibility of a redemption system that 
would affect their point-of-sale systems and stated they would need 
more information on IBM’s technical solution before they could assess 
the impact on their systems and whether it would affect their 
participation. With limited or delayed retailer participation, 
consumers might face difficulties in redeeming their coupons for 
eligible converter boxes. 

Most television stations already transmit a digital signal, but 
technical and coordination issues, such as antenna replacement and 
tower construction, may present challenges for broadcasters. In 
addition, cable and satellite television providers must coordinate with 
broadcasters to ensure that they can continue to receive and transmit 
the digital broadcast signals. Further, certain stations that 
retransmit the television signals, known as translator stations, are 
not required to cease analog broadcasting. These stations may choose to 
retransmit a digital signal, or they may convert the digital signal to 
analog and continue to broadcast in analog after February 2009. 

We plan on reporting on the progress of the DTV transition, including 
the status of consumer education and awareness about the DTV 
transition, IBM and NTIA’s administration of the converter box subsidy 
program, and industry technical preparations throughout the upcoming 
transition period. We will continue to monitor government and industry 
consumer education efforts and plan to analyze the efforts compared 
with key practices for consumer outreach. In addition, we plan to 
survey broadcasters on the technical issues that must be addressed 
prior to the DTV transition date. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://GAO-08-191T]. For more information, contact Mark L. 
Goldstein at (202) 512-2834 or goldsteinm@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to report on our work on the progress 
made in the nation's transition to digital television (DTV). We have a 
detailed report on public and private sector efforts underway to 
implement the transition that will be issued in November 2007. The 
findings that I am reporting to the Subcommittee today are based on our 
draft report and are therefore preliminary. 

A primary goal of the DTV transition is for the federal government to 
reclaim spectrum[Footnote 1] that broadcasters currently use to provide 
analog television signals. The spectrum that the federal government 
will reclaim at the end of the transition is considered highly valuable 
because of its particular technical properties. In all, the DTV 
transition will free up 108 megahertz (MHz) of spectrum. The Federal 
Communications Commission (FCC) has reallocated 24 MHz of the spectrum 
that will be recovered for public safety purposes, which became a 
higher priority following the terrorist attacks of September 11, 2001. 
FCC will auction the remaining spectrum for commercial purposes, with 
the resulting proceeds allocated for, among other things, reducing the 
federal deficit. 

The Digital Television Transition and Public Safety Act of 2005 
mandates the cessation of analog television broadcast signals on 
February 17, 2009. After that date, households who view television on 
analog sets solely through the reception of over-the-air signals must 
take action to ensure that they have the necessary equipment, such as a 
digital-to-analog converter box, or subscription video service to be 
able to view the digital broadcast signals. If they do not take such 
action, they will lose the ability to view the digital signals on their 
analog sets; i.e., they will not be able to watch television programs. 
The act also directed the National Telecommunications and Information 
Administration (NTIA) to establish a $1.5 billion program through which 
households can obtain coupons for the purchase of digital-to-analog 
converter boxes. NTIA issued a final rule that adopted regulations to 
implement the converter box subsidy program, and in August 2007, 
selected IBM Corporation (IBM) to administer the program. Beginning 
January 1, 2008, households can request up to two $40 coupons toward 
the purchase of eligible[Footnote 2] digital-to-analog converter boxes. 

Although it is unclear what percentage of households who rely 
exclusively on over-the-air broadcasts have analog sets, potentially 
millions of those households stand to be left without any television 
service unless they take action. To help the public understand the DTV 
transition and the various options they have, consumer education and 
awareness programs are underway and additional programs are being 
planned. 

My testimony today will focus on progress made in the DTV transition. 
In particular, I will discuss (1) the progress made by federal 
entities, in conjunction with other stakeholders, in facilitating the 
transition, (2) the progress made in educating consumers about the 
transition and any related challenges, (3) the progress made in 
implementing a subsidy program for converter boxes and any related 
challenges, (4) the technical issues facing the broadcast industry in 
meeting the transition, and (5) future work on the progress of the DTV 
transition that we will undertake. 

To meet these objectives, we reviewed government documents and 
interviewed officials with FCC and NTIA, the steering committee members 
of the Digital Television Transition Coalition, as well as a wide 
variety of industry and other private stakeholders, such as 
broadcasters, satellite television providers, cable companies, 
manufacturers, retailers, industry associations, and consumer advocacy 
groups. Further, we consulted strategic communications experts 
representing public, private, and academic organizations to identify 
potential challenges that might obstruct consumer education efforts, as 
well as key practices for consumer outreach campaigns. We reviewed FCC 
and NTIA rules and proposed rule-makings related to the digital 
television transition, and the comments they received in response to 
the proposed rule-makings. Finally, we reviewed NTIA's request for 
proposals for administering the converter box subsidy program, and 
related contract documents. We performed our review from January 2007 
through October 2007 in accordance with generally accepted government 
auditing standards. We discussed this testimony with FCC and NTIA 
officials to obtain their comments. FCC and NTIA provided additional 
information that we incorporated where appropriate. 

In summary: 

* FCC and NTIA, in conjunction with other stakeholders, have taken 
steps to facilitate the DTV transition. For example, FCC has conducted 
periodic reviews to report on transition progress, and NTIA has issued 
a contract for administering the converter box subsidy program. In 
addition, private sector industries have also begun preparing for the 
transition. Despite public-private sector interaction designed to help 
facilitate the transition, we found that no comprehensive plan exists 
for the DTV transition. Without such a plan, meaningful guidance for 
coordinating responsibilities and measuring progress might not be 
available to the private or public sector. 

* Several federal and private stakeholders have begun consumer 
education campaigns, with both independent and coordinated efforts 
underway. FCC and NTIA have developed informational materials and begun 
direct outreach to consumer groups. In addition, private industry 
stakeholders created the DTV Transition Coalition and are voluntarily 
conducting outreach efforts. However, these efforts are in the planning 
stages, and challenges remain. An expert panel that we convened 
identified potential challenges and key practices for a consumer 
education campaign, such as defining goals and objectives and 
establishing metrics to measure success. 

* NTIA has made progress in implementing the converter box subsidy 
program, but the program's outcome depends on the voluntary 
participation of retailers and manufacturers. Retailers we contacted 
expressed concerns about the possibility of a redemption system that 
would affect their point-of-sale systems and stated they would need 
more information on IBM's technical solution before they could assess 
the impact on their systems and whether it would affect their 
participation. With limited or delayed retailer participation, 
consumers might face difficulties in redeeming their coupons for 
eligible converter boxes. 

* Although most television stations already transmit a digital signal, 
technical and coordination issues, such as antenna replacement and 
tower construction, may present challenges for broadcasters in 
preparing for the DTV transition. In addition, cable and satellite 
television providers must coordinate with broadcasters to ensure that 
they can continue to receive and transmit the digital broadcast signals 
after the transition. Further, select stations that retransmit 
television signals, known as translator stations, are not required to 
cease analog broadcasting. These stations may choose to retransmit a 
digital signal, or they may convert the digital signal to analog and 
continue to broadcast in analog after February 2009. 

* We plan on reporting on the progress of the DTV transition, including 
public and private efforts in facilitating the transition, the status 
of consumer education and awareness about the DTV transition, IBM and 
NTIA's administration of the converter box subsidy program, and 
industry technical preparations throughout the upcoming transition 
period. For example, we will continue to monitor consumer education 
programs and plan to conduct a series of consumer surveys throughout 
the year prior to the transition date. The surveys we conduct will be 
aimed at determining the population that will be affected by the DTV 
transition and the public awareness of the transition. Throughout the 
transition process, we will continue to monitor government and industry 
consumer education efforts and analyze the efforts compared with key 
practices for consumer outreach. In addition, we plan to survey 
broadcasters on the technical issues that must be addressed prior to 
the DTV transition date. 

Background: 

The DTV transition will enable the government to allocate valuable 
spectrum from analog broadcast to public safety and other purposes. 
Further, digital transmission of television signals provides several 
advantages compared to analog transmission, such as enabling better 
quality picture and sound reception as well as 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. 

The Digital Television Transition and Public Safety Act of 2005 
addresses the responsibilities of two federal agencies--FCC and NTIA-- 
related to the DTV transition. The act directs FCC to require full- 
power television stations to cease analog broadcasting on February 17, 
2009. While full-power television stations are required to terminate 
their analog signals, this deadline does not apply to translator 
television stations. Translator stations receive a signal from a 
television station and simultaneously retransmit the signal on another 
channel. These stations are intended to provide service to areas where 
direct reception of full-service broadcast stations is unsatisfactory 
because of distance or terrain obstructions, such as in mountainous 
regions. 

As we have previously reported, households with analog televisions that 
rely solely on over-the-air television signals received through a 
rooftop antenna or indoor antenna must take action to be able to view 
digital broadcast signals after the termination of analog broadcasts. 
Options available to these households include (1) purchasing a digital 
television set that includes a tuner capable of receiving, processing, 
and displaying a digital signal; (2) purchasing a digital-to-analog 
converter box, which converts the digital broadcast signals to analog 
so they can be viewed on an existing analog set; or (3) subscribing to 
a cable, satellite, or other service to eliminate the need to acquire a 
digital-to-analog converter box. The act also directed NTIA to 
establish a $1.5 billion subsidy program through which households can 
obtain coupons toward the purchase of digital-to-analog converter 
boxes. The last day for consumers to request coupons is March 31, 2009, 
and coupons will be redeemed through July 9, 2009. As required by law, 
all coupons expire 90 days after issuance. Consumers can redeem their 
coupons at participating retailers (both "brick and mortar" and online) 
for eligible converter boxes. 

To help inform consumers about the transition, in February 2007, eight 
private sector organizations launched the Digital Television Transition 
Coalition. These eight organizations are the Association for Maximum 
Service Television, Association of Public Television Stations, Consumer 
Electronics Association, Consumer Electronic Retailers Coalition, 
Leadership Conference on Civil Rights, LG Electronics, National 
Association of Broadcasters, and the National Cable and 
Telecommunications Association. These founding organizations comprise 
the Coalition's steering committee and make decisions on behalf of the 
Coalition. To better represent the interests of at risk or underserved 
populations--such as the elderly--AARP later joined the steering 
committee. The Coalition's mission is to ensure that no consumer is 
left without broadcast television due to a lack of information about 
the transition. Currently, the Coalition has over 160 member 
organizations comprised of business, trade and industry groups, as well 
as FCC.[Footnote 3] 

Recent surveys conducted by industry trade associations indicate that 
consumer awareness of the digital transition is low. The Association 
for Public Television Stations reported in January 2007 that 61 percent 
of participants surveyed had "no idea" that the transition was taking 
place. Another study conducted by the National Association of 
Broadcasters focused on households that primarily receive their analog 
television signals over-the-air--and will therefore be most affected by 
the transition--and reported that 57 percent of those surveyed were not 
aware of the transition. Both surveys found that almost all people with 
some awareness of the transition had limited awareness of the date the 
transition will take place. 

Federal Entities and Other Stakeholders are Facilitating the 
Transition, but Comprehensive Planning and Risk Management is Limited: 

FCC and NTIA, in conjunction with other stakeholders, have taken steps 
to facilitate the DTV transition. FCC has primary responsibility to 
regulate the television broadcast industry for the federal government 
and has taken a number of actions regarding the transition. For 
example, FCC has proposed and set deadlines to upgrade station 
equipment to send digital signals. In addition, FCC has conducted 
periodic reviews to report on transition progress and held a workshop 
for interested parties to discuss transition challenges and issues. 
NTIA has statutory responsibility for the converter box subsidy 
program, and it has issued a contract in preparation for that program's 
development. Private sector industries, including broadcasters, 
manufacturers, and retailers have also begun preparing for the 
transition. Despite public-private sector interaction designed to help 
facilitate the transition, we found that no comprehensive plan exists 
for the DTV transition. Among other things, a comprehensive plan can 
detail milestones and key goals, which provide meaningful guidance for 
assigning and coordinating responsibilities and deadlines and measuring 
progress. Such planning also includes assessing, managing, and 
mitigating risks, which can help organizations to identify potential 
problems before they occur and target limited resources. We have 
previously reported on the benefits of managing risks, including 
assisting other organizations involved in high stakes efforts similar 
to the DTV transition. For example, we credited one federal agency's 
success in weathering the potential for critical computer system 
failures during the Year 2000 Computer Conversion (Y2K), in part, due 
to reducing risks to facilities, systems, programs, and services during 
the critical rollover period. 

Progress in Consumer Education on the DTV Transition Has Been Made, But 
Widespread Implementation Is Not Yet Underway: 

FCC and NTIA, along with industry and other private stakeholders, have 
made progress in educating consumers about the DTV transition. For 
example, FCC and NTIA have developed informational materials on the 
transition and begun outreaching directly to consumer and stakeholder 
groups. Both agencies are also involved with the Digital Television 
Transition Coalition, a group representing over 160 business, trade, 
grass roots, and other organizations whose purpose is to provide 
consumers with information about the transition. Private industry 
stakeholders are voluntarily taking the lead on planning public service 
announcements, developing Web sites, and garnering media coverage on 
the transition. While federal and private stakeholders have taken these 
initial steps, the initiative is still largely in the planning stages 
and widespread efforts have yet to be implemented. Further, because of 
the number of public and private sector entities involved in consumer 
education efforts for the transition and the timing, coordination and 
content of the messages they produce, consumers might become confused 
over what steps, if any, are necessary to avoid disruptions to their 
television viewing after the transition date. 

To identify the difficulties and challenges to consumer education and 
outreach, we convened an expert panel to discuss consumer education 
issues applicable to the DTV transition, including potential challenges 
that may obstruct efforts and the key planning components of a consumer 
education campaign that will help to overcome some of those challenges. 
Expert panel members as well as other private and public sector 
officials highlighted several challenges, as follows: 

Prioritizing limited resources. With limited time and financial 
resources, it is likely to be a challenge for stakeholders to determine 
how best to allocate those resources within the campaign--for example, 
whether to target a smaller audience over a set period of time, versus 
targeting a broader audience over a shorter period of time. 

Educating consumers who do not necessarily need to take action. Many of 
the outreach efforts will be focused on educating consumers on what to 
do to keep their television sets from going dark after the termination 
of analog broadcasts. However, a large proportion of U.S. households 
will not need to do anything--for example, because they have cable or 
satellite television service that will enable their analog set to 
continue to display programming. Because many messages focus on the 
actions that households that rely on over-the-air analog broadcasting 
need to take, consumers unaffected by the transition may become 
confused and purchase equipment they do not need. In our past work 
looking at a similar digital transition in Germany, we have described 
this potential confusion to cable and satellite households as a 
challenge of educating consumers about the transition.[Footnote 4] 

Reaching underserved populations. Conveying the message to underserved 
populations--for example, senior citizens, disabled, those residing in 
rural areas, or non-English speaking households will provide an added 
challenge. For example, many groups outreaching to consumers about the 
transition are doing so on Web sites, which may not be available to 
people who lack Internet access or are less technically savvy. Another 
challenge is providing information in a wide variety of formats, such 
as in different languages for non-English speaking consumers and in 
text, video, voice, and Braille for the disabled. Overall, a challenge 
of consumer education is that those households in need of taking action 
may be the least likely to be aware of the transition. 

Aligning stakeholders. Panel members and other industry representatives 
also noted the challenge of aligning stakeholders--some who are natural 
competitors--to work together. In our past work, we have reported that 
federal agencies engaged in collaborative efforts--such as the 
transition--need to create the means to monitor and evaluate their 
efforts to enable them to identify areas for improvement. Reporting on 
these activities can help key decision makers within the agencies, as 
well as clients and stakeholders, to obtain feedback for improving both 
policy and operational effectiveness.[Footnote 5] 

In addition to highlighting potential challenges, the expert panelists 
identified the following key practices as important to planning a 
consumer education campaign that will motivate consumers to take the 
steps needed to avoid television viewing disruptions, as well as help 
to alleviate identified challenges along the way: 

Table 1: Key Practices for Consumer Education Planning: 

Key Practice: Define Goals and Objectives; 
Description: Define the goals of the communications campaign, e.g., to 
increase awareness or motivate a change in behavior. Define the 
objectives that will help the campaign meet those goals. 

Key Practice: Analyze the Situation; 
Description: Analyze the situation, including any competing voices or 
messages, related market conditions, and key dates or timing 
constraints. Review relevant past experiences and examples to identify 
applicable "lessons learned" that may help to guide efforts. 

Key Practice: Identify Stakeholders; 
Description: Identify and engage all the key stakeholders who will be 
involved in communications efforts. Clarify the roles and 
responsibilities of each stakeholder, including which entity or 
entities will lead overall efforts. 

Key Practice: Identify Resources; 
Description: Identify available short-and long-term budgetary and other 
resources. 

Key Practice: Research Target Audiences; 
Description: Conduct audience research, such as dividing the audience 
into smaller groups of people who have relevant needs, preferences and 
characteristics, as well as measuring audience awareness, beliefs, 
competing behaviors, and motivators. Also, identify any potential 
audience-specific obstacles, such as access to information. 

Key Practice: Develop Consistent, Clear Messages; 
Description: Determine what messages to develop based on budget, goals, 
and audience research findings. Develop clear and consistent audience 
messages; test and refine them. 

Key Practice: Identify Credible Messenger(s); 
Description: Identify who will be delivering the messages and ensure 
that the source is credible with audiences. 

Key Practice: Design Media Mix; 
Description: Plan the media mix to optimize earned media (such as news 
stories or opinion editorials) and paid media (such as broadcast, 
print, or Internet advertising). Identify through which methods (e.g., 
advertising in newsprint ads), how often (e.g., weekly or monthly) and 
over what duration (e.g., 1 year) messages will reach audiences. 

Key Practice: Establish Metrics to Measure Success; 
Description: Establish both process and outcome metrics to measure 
success in achieving objectives of the outreach campaign. Process 
metrics assure the quality, quantity, and timeliness of the 
contractor's work. Outcome metrics evaluate how well the campaign 
influenced the attitudes and behaviors of the target audience(s) that 
it set out to influence. 

Source: GAO analysis of expert panel discussion: 

[End of table] 

While still too early to evaluate the Coalition's consumer education 
efforts, the Coalition has employed strategies consistent with the key 
practices identified by the expert panel. For example, the Coalition 
has identified stakeholders and conducted focus groups to test and 
refine its consumer messages. However, at the time of our report, it 
remains unclear whether public-private sector interaction can ensure a 
consistent message to prevent confusion or unnecessary purchases on the 
part of consumers. Moreover, the absence of comprehensive planning to 
assess and mitigate risks associated with the transition, including 
outreach efforts, may increase the potential for at risk populations 
not adequately preparing for the transition. 

NTIA Has Taken Steps to Implement a Subsidy Program for Converter 
Boxes, but Challenges Remain: 

NTIA has made progress in implementing the converter box subsidy 
program, including soliciting stakeholder comments, meeting with 
industry participants, and selecting IBM in August 2007 to administer 
the program. The subsidy program's outcomes depend on the coordination 
and participation of NTIA, IBM, converter box manufacturers, retailers, 
and consumers. Manufacturers and retailers are voluntarily 
participating in the program, as NTIA does not have the authority to 
require their participation. IBM will develop the technical solution 
for the program, which includes determining how consumers will request, 
receive, and redeem coupons, and how this will affect retailers' 
current point-of-sale systems.[Footnote 6] NTIA and IBM will also be 
conducting consumer outreach specific to the program. Figure 1 depicts 
the necessary, interrelated actions for the subsidy program. 

Figure 1: Coordination of Groups Involved in the Subsidy Program: 

[See PDF for image] 

Source: GAO. 

[End of figure] 

As shown in figure 2, consumers can begin applying for converter box 
coupons starting January 1, 2008, with NTIA requiring full distribution 
of coupons to begin by April 1, 2008. Consequently, some consumers that 
request coupons in January might have to wait months to receive their 
coupons. Complicating matters is uncertainty regarding retailer 
participation and readiness. At the time of our review, several 
retailers we contacted expressed concerns about the possibility of a 
redemption system that would affect their point-of-sale systems, noting 
that modifying these systems can be time-consuming, resource-intensive, 
and expensive, and can affect their other financial systems. Retailer 
representatives told us they will need more information about the 
contractor's technical solution before they could assess the impact on 
their systems and whether it would affect their participation. Further, 
they said that March or April of 2008--3 to 4 months after consumers 
can begin requesting coupons--is a more likely time frame for retailers 
to be ready to participate in the program. The extent to which point- 
of-sale system modifications will be necessary and the potential impact 
on retailers will remain unknown until IBM presents its technical 
solution. With limited or delayed retailer participation, consumers 
might face difficulties in redeeming their coupons for eligible 
converter boxes during the designated time period. Some manufacturer, 
advocacy, and retailer representatives we contacted expressed concern 
about consumers' ability to find participating retailers that are able 
to redeem coupons and have converter boxes in stock. The final rule 
does not require remedies if certain geographic areas lack 
participating retailers and NTIA does not have the explicit authority 
to require that participating retailers maintain a certain level of 
inventory. Thus, it is uncertain whether consumers with coupons will be 
able to locate a participating retailer with converter boxes in stock. 

Figure 2: Time Line of Converter Box Subsidy Program: 

[See PDF for image] 

Source: GAO analysis of NTIA data. 

[A] Manufacturer converter box certification has no specified end date. 

[End of figure] 

While Most Television Stations Are Transmitting a Digital Signal, 
Numerous Technical and Coordination Issues Remain: 

The vast majority of broadcast television stations already broadcast a 
digital signal with many of these stations prepared to turn off their 
analog signal on February 17, 2009. However, a number of technical and 
coordination issues remain, such as antenna replacement and tower 
construction. In addition, cable and satellite television providers 
must coordinate with broadcasters to ensure that they can continue to 
receive and transmit the digital broadcast signals after the 
transition. While not required to cease analog broadcasting, some 
translator stations may choose to retransmit a digital signal but 
others will convert the digital signal to analog and continue to 
broadcast in analog after February 2009. 

Broadcasters Face Technical and Coordination Issues: 

According to FCC, as of April 2007, approximately 93 percent of 
television broadcast stations were transmitting a digital signal. 
[Footnote 7] FCC reports that nearly 1,200 of these stations already 
transmitting a digital signal have been authorized to continue to 
operate on their current digital channel after February 17, 2009. FCC 
states that these stations will have a relatively simple transition to 
their final post-transition digital operation. Additionally, FCC states 
that approximately 750 of these stations may now already be or are very 
close to being ready for their post-transition operations and will 
simply have to turn off their analog signal. For example, managers 
representing six television broadcast stations that we interviewed said 
that they face no major transition issues between by February 17, 2009, 
and will only have to turn off their analog signal. 

However, as discussed below, stations may encounter challenges in 
completing their digital transition such as, (1) antenna and equipment 
replacement or relocation, (2) tower construction, (3) channel 
relocation, and (4) coordination with Canadian and Mexican governments. 

Issues with antenna and equipment replacement or relocation. One of the 
major tasks that many television stations have to complete to build out 
their post-transition digital facilities is to install a digital 
antenna on the top of the broadcast tower, where the analog antenna 
resides. According to a broadcast industry official, many stations need 
to have their digital antenna at the top of the tower in order to fully 
replicate the area that their analog service covers. The broadcast 
industry official 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, then install the digital antenna at the top 
of the tower. The industry official 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, and as a result of the analog antenna being side mounted, 
stations' analog broadcast coverage area would be reduced by 2 percent 
to 9 percent of the viewing market. Stations agreed that they could 
potentially 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 operation 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, 
affecting a large number of its viewers. For the second option, 
problems include the digital signal not being at full power until later 
in the year, and getting the necessary authority to do this from FCC. 
Further, broadcast stations have commented that the design, 
manufacture, and installation of new antennas can take months to 
complete. For example, a company that owns five television stations 
commented that it can take up to 6 months to design, order, receive and 
install a new antenna. 

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. For example, representatives from a 
commercial television station told us that in order for the stations to 
replicate its analog service contour, it had to reduce coverage for 
part of its digital contour. As a result, the station representatives 
said that the digital signal will reach 15,000 fewer people and that 
while many of these homes will have cable and satellite to still 
receive the station's signal, some will not. As shown in figure 3, the 
digital signal coverage of a station can differ from its analog signal 
coverage. Consequently, homes residing in the light shaded areas 
relying on over-the-air signals might not be able to receive the 
digital broadcast signals. 

Figure 3: Example of a Station's Digital Signal Coverage Compared to 
Analog Signal Coverage: 

[See PDF for image] 

Source: FCC. 

[End of figure] 

FCC has acknowledged that a reduction or termination of analog service 
may be necessary if maintaining full analog coverage hinders the 
construction and operation of digital facilities. FCC officials told us 
that some loss of analog service is part of a tradeoff needed to ensure 
the entire transition is as smooth as possible. FCC officials also said 
it is difficult to replicate an existing signal contour, and is almost 
impossible to exactly replicate a pattern. FCC stated that it is not 
always in the best interest of the public to have a digital signal 
fully replicate the analog signal because a digital signal can cause 
serious interference to nearby stations. Further, FCC said that, in 
some instances, while contour shifting may result in some viewers 
losing a station's signal, other homes might gain the signal of a 
station. For example, FCC said contour shifting might disenfranchise 
500 people in one area, but cover a new area with 10,000 people. 

Issues with tower construction. According to FCC, a station that must 
change its DTV tower locations may face considerable challenges, 
especially if the station must construct a new tower. FCC states that 
such stations must 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 
appropriate federal government clearances, local and state zoning 
requirements, and varying timelines for designing the new tower, 
ordering equipment, delivery of equipment, and construction-related 
issues, stations must begin planning as soon as possible in order to 
transition by the deadline. According to a major television broadcast 
network, 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. Additionally, any work on 
towers could be hampered by weather conditions for towers located 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 
and another of its sites can only be reached by special vehicle until 
April. 

Issues with channel relocation. According to FCC, approximately 600 
stations will have to move to a different channel once the transition 
is complete. Some of these stations are broadcasting on a temporary 
digital channel and plan to relocate this digital channel back to their 
current analog channel. 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. Other stations will 
have to move to a completely new channel once the transition is 
complete. According to a broadcast industry association representative, 
television stations moving to another channel will face some technical 
challenges. For example, the broadcast representative stated that 
stations moving to another channel could cause interference for their 
neighboring channels if they move too early or if the neighboring 
channel moves too late. He estimated that there could be interference 
issues for up to 300 stations and stressed the need for coordination to 
minimize interference issues. Additionally, some stations broadcasting 
an analog signal do not have a paired digital channel and plan to 
"flash cut" to their digital channel by February 17, 2009.[Footnote 8] 
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 and, in some cases, will require that a station change to a new 
channel to be fully operational. 

Coordination issues with Canadian and Mexican governments. Another 
challenge for some stations located along the northern and southern 
borders of the United States is reaching agreements with Canadian and 
Mexican governments on the coverage of their digital signals that cross 
the border. According to FCC, some stations may still have unresolved 
coordination issues with Canadian and Mexican governments. Stations 
have commented that coordination issues with Canadian and Mexican 
governments might affect their ability to finalize their digital 
operations. For example, a company that operates several stations near 
the Canadian border commented that uncertainty about the stations' 
final digital signal coverage are preventing it from ordering 
equipment, scheduling tower crews and making necessary changes to its 
transmitter buildings. The company stated that if coordination issues 
cannot be resolved, the stations would face significant additional 
costs in constructing their digital facilities and could result in two 
of its stations discontinuing operations as full power stations and 
rather, operate as low power stations. Another station located near the 
Mexican border commented that the station's digital channel allotment 
could result in the Mexican government delaying or denying any request 
for coordination due to concerns about interference with a station on 
the Mexican side of the border. The station comments that any delay in 
coordination will result in the station not having sufficient time to 
construct its digital facilities. FCC officials told us that they are 
in discussions with Canadian and Mexican governments to resolve any 
coordination issues and expect to the discussions to be completed by 
January 2008. However, FCC has commented that if there are situations 
where international coordination cannot be obtained, stations may have 
to broadcast to a smaller coverage area. 

Cable and Satellite Television Providers Must Coordinate with 
Broadcasters to Ensure They Continue to Receive Broadcast Signals: 

Cable and satellite television providers face fewer challenges than 
broadcasters with the DTV transition, however, there are technical 
issues that need to be resolved to ensure they can provide digital 
broadcast signals to their subscribers. For cable, FCC recently 
indicated its intent to require cable to either carry both a digital 
and analog signal, often referred to as a "dual carriage" requirement, 
or carry only the digital signal provided all subscribers can view the 
signal.[Footnote 9] FCC further indicated its intent to require that 
high definition broadcast signals continue to be carried in high 
definition format. According to FCC, this will ensure all cable 
subscribers are able to view broadcast signals on their current 
televisions -whether analog or digital. We heard from cable providers 
that there are key technical challenges needing to be resolved prior to 
the transition. As previously noted, the technical and coordination 
issues facing the broadcasters can vary from station to station, with 
some stations moving to a new channel or changing the coverage area of 
their broadcast signal. As a result, cable providers told us there is 
uncertainty whether its cable head-ends will continue to receive the 
broadcast signals.[Footnote 10] 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. One cable provider told us this could be particularly 
problematic in smaller markets where head-ends rely on over-the-air 
broadcast to pull in the broadcast signals. Cable providers will have 
to coordinate with local broadcasters to ensure cable continues to 
receive local broadcast feeds. In particular, we heard that cable 
providers need the coverage areas, or signal contour maps, from 
broadcast stations as soon as possible to help them identify problem 
areas. One cable provider we spoke with indicated based on potential 
changing signal coverage areas, it might need to reposition its 
antennas or otherwise update its head-ends so that they can continue to 
receive the broadcast signals. Since the cable provider has hundreds of 
head-ends, it could be time consuming to update them. Furthermore, this 
cable provider emphasized concerns with clearing enough bandwidth for 
the "dual carriage" requirements. While this should not be a major 
issue in the bigger markets, it could be problematic in many of the 
smaller markets where there is no viable technological solution for 
dealing with these requirements on bandwidth. 

The satellite television providers we talked to anticipate no technical 
issues that will impact their subscribers' viewable broadcast signals 
following the transition date. However, similar to cable, satellite 
providers have concerns about broadcasters' coverage area changing such 
that the satellite receiving stations will fall out of the coverage 
area resulting in a lost or poorly received broadcast signal. Since 
satellite television operates on a national platform, the satellite 
providers will have to coordinate with all broadcast stations carried 
nationally.[Footnote 11] To better coordinate and be better prepared 
for the DTV transition, both cable and satellite providers support 
broadcast stations making their transition plans public. Cable and 
satellite providers indicated advanced planning will allow them 
adequate time to make technical modifications to their systems, such as 
updating their receiving equipment and testing signal strength and 
reception. 

Owners of Translator Stations Will Need to Take Action in Order for 
Viewers to Continue to Receive Translator Signals: 

Unlike full power broadcast television stations, the February 17, 2009 
deadline to cease analog broadcasting does not apply to translator 
stations.[Footnote 12] However, since translator stations retransmit 
signals from full power broadcast stations, owners of these stations 
will need to take action to ensure broadcast signals continue to reach 
viewers. Translator stations can either transition to digital or take 
the digital signal and convert it to analog before transmitting it to 
their viewers. Those stations transitioning to digital have two 
options; they can cease analog transmission and begin operation of new 
digital transmitting equipment on the same date, or they can operate a 
digital companion channel allowing them to deliver both analog and 
digital signals. According to a broadcast industry association, there 
are currently several hundred companion digital channels operating, and 
FCC is not presently allowing these stations to cease analog operation 
even though they are transmitting a digital signal. However, many 
translator stations will continue to transmit an analog signal beyond 
the full-power analog shutdown date. One broadcast industry association 
representative told us that although many translators will likely have 
obtained the hardware to operate with the digital input signal by the 
transition date, some stations will not have the necessary equipment. 

If a translator station decides to convert the digital signal to analog 
and retransmit the signal, there is a possibility they will not reach 
those viewers who have purchased set-top converter boxes. According to 
a broadcast industry association, there are some instances where 
translator stations serve communities that receive at least one full- 
power television station, which would necessitate those over-the-air 
viewers to obtain a converter box. Since these areas will continue 
receiving both digital and analog signals, there is concern that those 
people who buy a set-top converter box that does not have analog pass 
through will have to turn them off or have an external bypass 
arrangement to allow for over-the-air signals to pass through their 
analog sets. 

Our Future Work Will Focus on the Progress of the DTV Transition: 

We have work planned to assess the progress of the DTV transition. To 
accomplish this, we will continue to monitor public and private sector 
efforts related to the transition, including consumer outreach, the 
converter box subsidy program, and technical issues. Specifically, we 
will review consumer education programs and plan to conduct a series of 
consumer surveys throughout the year prior to the transition date. The 
surveys we conduct will be aimed at determining the population that 
will be affected by the DTV transition and the public awareness of the 
transition. In determining the affected population, we will look at the 
percent of the population relying on over-the-air broadcasts for their 
primary television, as well as the percent of the population with non- 
primary televisions being used to watch over-the-air television. 
Additionally, we will review the demographic characteristics of the 
affected population to determine what groups might be most disrupted by 
the transition. We will survey for public awareness of the DTV 
transition, and specific knowledge of the transition, such as when the 
transition will take place. We will seek to determine the level of 
public awareness of those who will be affected by the transition and 
awareness of the converter box subsidy program and other options for 
viewing digital signals after the transition. We plan to report on 
changes in consumer awareness over time by conducting surveys 
throughout the transition process. Furthermore, we will continue to 
monitor government and industry consumer education efforts and will 
analyze the efforts compared with key practices for consumer outreach. 
We will also monitor the outcome of FCC's notices of proposed 
rulemaking regarding the transition and collect details on IBM's 
consumer education plan as they become available. To monitor the 
implementation of the converter box subsidy program, we plan to 
continue reviewing the steps taken by NTIA and IBM in administering the 
subsidy program. In addition, we plan to survey broadcasters to obtain 
their perspectives on the technical issues that must be addressed prior 
to the DTV transition date. 

Mr. Chairman, this concludes my prepared statement. I would be happy to 
respond to any questions you or other Members of the Committee may have 
at this time. 

Contacts and Acknowledgements: 

For questions regarding this testimony, please contact Mark L. 
Goldstein on (202) 512-2834 or goldsteinm@gao.gov. Individuals making 
key contributions to this testimony included Matthew Cail, Andy 
Clinton, Simon Galed, Eric Hudson, Bert Japikse, Crystal Jones, Aaron 
Kaminsky, Sally Moino, Andrew Stavisky, and Margaret Vo. 

[End of section] 

Footnotes: 

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

[2] NTIA established technical and performance specifications that 
converter boxes must meet to be eligible for the coupon program. 

[3] While NTIA is not an official Coalition member, the agency has been 
participating in Coalition activities since its inception. The 
Coalition, as well as FCC and NTIA, have created Web sites providing 
information on the DTV transition and converter box subsidy program. 
These Web sites are available for viewing at the following addresses: 
[hyperlink, http://www.dtvtransition.org] and [hyperlink, 
http://www.dtv.gov] and [hyperlink, 
http://www.ntia.doc.gov/otiahome/dtv/]. 

[4] GAO, 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). 

[5] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, GAO-06-15 
(Washington, D.C.: October 21, 2005). 

[6] Point of sale systems record purchases, payments, returns, and 
exchanges, as well as send the individual transactions to the company's 
internal inventory and accounting systems. They can also include an 
external component of 'in real time' communication with financial 
institutions, merchant banks, or other sources to identify the validity 
of the method of payment and authorize utilization of that method 
(credit card, debit card, gift card, check, etc). 

[7] As of April 2, 2007, 1,603 of the approximate 1,722 licensed 
television stations broadcast a digital signal. Of the stations 
broadcasting a digital signal, 1,136 represent commercial licensed 
stations. 

[8] According to FCC, "flash-cut" refers to the situation where a 
station gives up its pre-transition digital channel and transitions to 
digital service using its analog channel or a newly allotted channel. 

[9] The FCC rules were adopted on September 11, 2007, but as of October 
11, 2007, the final ruling had yet to be published. 

[10] Cable providers receive the local broadcast signals to their head- 
ends, while satellite providers receive the local broadcast signals at 
local receive facilities. This signal can be received by the providers 
either over-the-air, across fiber, by microwave antenna, or other 
means. Over-the-air signals could be lost completely based on changes 
to the broadcast stations antenna placement or structure, but fiber and 
other means of receiving the broadcast signal may require changes in 
equipment. 

[11] The two satellite television providers, EchoStar and DIRECTV, 
retransmit 1,500 local broadcast signals and 1,200 local broadcast 
signals, respectively. 

[12] Most of the approximately 5,000 translator stations operate in the 
mountainous western regions of the country and are often used to 
deliver the only off-air television service available in rural 
communities. Although some translator stations are owned by full-power 
stations, many are either owned or rely on support from a local 
government.

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