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entitled 'Digital Television Transition: Increased Federal Planning and
Risk Management Could Further Facilitate the DTV Transition' which was
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
November 2007:
Digital Television Transition:
Increased Federal Planning and Risk Management Could Further Facilitate
the DTV Transition:
Consumer Issues Surrounding the DTV Transition:
GAO-08-43:
GAO Highlights:
Highlights of GAO-08-43, 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 to cease analog
broadcasting by February 17, 2009. Following this digital television
transition, consumers who receive over-the-air television signals on
analog sets will need to take action to be able to view digital
broadcasts. The act also requires the National Telecommunications and
Information Administration (NTIA) to create a program that subsidizes
consumers’ purchases of digital-to-analog converter boxes. This
requested report examines progress made (1) by federal entities and
others in facilitating the transition, (2) in educating consumers on
the transition, and (3) in implementing the converter box subsidy
program. GAO reviewed legal, agency, and industry documents;
interviewed public, private, and other stakeholders; and convened an
expert panel focused on consumer outreach.
What GAO Found:
The Federal Communications Commission (FCC) and NTIA, in conjunction
with other stakeholders, have taken actions to facilitate the digital
television (DTV) transition. FCC has primary responsibility to regulate
the broadcast television industry and, as such, has set deadlines for
broadcasters to upgrade station equipment and conducted periodic
reviews related to the transition. NTIA has issued a contract for
services related to its converter box subsidy program. Industry
stakeholders, including broadcasters, have begun to prepare for the
transition. Despite these efforts, GAO found no comprehensive plan or
strategy to measure progress and results. Such planning includes
managing and mitigating risks, which can help organizations identify
potential problems before they occur and target limited resources. GAO
has reported on the benefits of risk management in helping
organizations involved in high stakes efforts similar to the DTV
transition.
FCC, NTIA, industry, and other private sector stakeholders have made
progress in educating consumers about the DTV transition, but these
efforts are mostly in the planning phase, and challenges remain. Both
FCC and NTIA have developed informational materials on the transition
and begun reaching out to consumer and stakeholder groups. Private
sector stakeholders are leading consumer outreach efforts on a
voluntary basis. This includes developing a coalition of over 160
business, trade, and other organizations committed to providing
consumers with information about the transition; planning public
service announcements; developing Web sites; and encouraging media
coverage. An expert panel GAO convened identified key practices for
consumer education planning, including coordinating among stakeholders,
constructing consistent messages, researching target audiences, and
establishing metrics to measure success. The expert panel also noted
that potential challenges for consumer outreach include prioritizing
limited resources, educating consumers who do not necessarily need to
take action, and reaching underserved populations. It remains unclear
whether public-private sector interaction can ensure a consistent
message to prevent consumer confusion.
NTIA has made progress in implementing a subsidy program for converter
boxes, but the program faces challenges. The current program allows
households to request up to two $40 coupons toward the purchase of
eligible converter boxes. While the program’s outcome depends on the
ability of NTIA and its contractor to encourage and coordinate the
voluntary participation of retailers and manufacturers, NTIA remains
ultimately responsible for the program. There is also uncertainty
regarding retailer readiness and participation in the program, as well
as potential challenges related to inventory planning. If retailers’
participation is limited or delayed, consumers might face difficulties
in redeeming their coupons for converter boxes, without which some
might lose access to television programming.
What GAO Recommends:
GAO recommends that FCC, in conjunction with public and private
stakeholders, develop a comprehensive plan for the various aspects of
the DTV transition. In commenting on this report, FCC and the
Department of Commerce (which contains NTIA) noted the steps they had
taken to facilitate the transition, but neither indicated whether they
agreed or disagreed with the recommendation. A more detailed discussion
of their comments is in our report.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-43]. For more information, contact Mark
L. Goldstein at (202) 512-2834 or goldsteinm@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Federal Entities and Other Stakeholders Are Facilitating the
Transition, but Comprehensive Planning and Risk Management Is Limited:
Progress in Consumer Education on the DTV Transition Has Been Made, but
Widespread Implementation Is Not Yet Under Way:
NTIA Has Taken Steps to Implement a Subsidy Program for Converter
Boxes, but Challenges Remain:
Conclusions:
Recommendation for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Key Planning Components, Implementation Challenges, and
Evaluation Elements of Public Education Outreach:
Appendix III: Federal Communications Commission Response:
Appendix IV: Comments from the Department of Commerce:
Appendix V: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Converter Box Subsidy Program Funding:
Table 2: Key Practices for Consumer Education Planning:
Figures:
Figure 1: Time Line of Converter Box Subsidy Program:
Figure 2: Options for Viewing Digital Signals after the DTV Transition:
Figure 3: Examples of Consumer Outreach Materials about the DTV
Transition:
Figure 4: Risk Management Framework:
Figure 5: Consumer Advisory Alerts for Analog Televisions:
Figure 6: Coordination of Groups Involved in the Subsidy Program:
Abbreviations:
ATSC: Advanced Television Systems Committee:
CEA: Consumer Electronics Association:
DOC: Department of Commerce:
DTV: digital television:
FCC: Federal Communications Commission:
GAGAS: generally accepted government auditing standards:
IBM: International Business Machines Corporation:
MHz: megahertz:
NOAA: National Oceanic and Atmospheric Administration:
NTIA: National Telecommunications and Information Administration:
NTSC: National Television Systems Committee:
Y2K: Year 2000 Computer Conversion:
United States Government Accountability Office:
Washington, DC 20548:
November 19, 2007:
Congressional Requesters:
By February 17, 2009, federal law requires all full-power television
stations in the United States to cease analog broadcasting and
broadcast digital-only transmissions, often referred to as the digital
television (DTV) transition. 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 because digital transmissions require less
spectrum than analog transmissions. The Federal Communications
Commission (FCC) has reallocated 24 MHz of the spectrum 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, the proceeds of which, Congress had
determined, will in part be allocated toward reducing the federal
deficit.[Footnote 2]
After the DTV transition, consumers who rely exclusively on over-the-
air television signals viewed on analog sets[Footnote 3] will not be
able to view broadcast programming, possibly including important news
information or emergency alerts, unless they take action. In
particular, these consumers could (1) purchase a television capable of
processing digital signals;[Footnote 4] (2) purchase a digital-to-
analog converter box that converts the digital signals to analog
signals and enables their display on an analog set; or (3) subscribe to
cable, satellite, or other service that already converts digital
signals into a format an analog receiver can process or will provide a
remedy for their viewers. A number of governmental and private sector
stakeholders are currently planning outreach efforts to educate
consumers about this important transition to digital television.
Furthermore, as required by the Digital Television Transition and
Public Safety Act of 2005,[Footnote 5] the National Telecommunications
and Information Administration (NTIA), an agency of the U.S. Department
of Commerce, created a digital-to-analog converter box subsidy program
establishing that beginning January 1, 2008, households can request up
to two $40 coupons toward the purchase of such converter boxes. In
August 2007, NTIA contracted with International Business Machines
Corporation (IBM) to provide services for the subsidy program. The
implementation of this program, in addition to a widespread consumer
education campaign, will require the coordination of government
agencies, manufacturers, retailers, broadcasters, and public advocacy
groups.
You asked us to provide information on the progress of the DTV
transition. We reviewed the progress made (1) by federal entities, in
conjunction with other stakeholders, in facilitating the transition;
(2) in educating consumers about the transition and any related
challenges; and (3) in implementing a subsidy program for converter
boxes and any related challenges. We are also reviewing technical
issues related to the DTV transition and will report on progress and
challenges in these areas in the near future.
To meet these objectives, we reviewed relevant laws and regulations,
agency strategic plans, budgets, time lines, public comments, proposed
reporting requirements, and the NTIA contract for the converter box
subsidy program to determine the nation's progress toward digital
television. We interviewed officials with FCC and NTIA, as well as a
wide variety of industry and other private sector stakeholders with an
interest in the transition, such as broadcasters, retailers,
manufacturers, and advocacy groups. We discussed their roles in the
transition and obtained information on their involvement with consumer
education efforts and the NTIA converter box subsidy program. Further,
we convened a panel of 14 experts representing public, private, and
academic organizations to identify key practices for conducting
consumer education. A more detailed discussion of our objectives,
scope, and methodology is provided in appendix I. We performed our
review from January 2007 through August 2007 in accordance with
generally accepted government auditing standards.
Results in Brief:
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 for certain services related to
that program's operation. Private sector stakeholders, 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.
FCC and NTIA, along with industry and other private sector
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 outreach directly to consumer and
stakeholder groups. Both agencies are also involved with the Digital
Television Transition Coalition, a group representing over 160
business, trade, grassroots, and other organizations whose purpose is
to provide consumers with information about the transition. Private
sector 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 DTV transition as well
as 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. During an expert panel we convened, communications experts
identified challenges to consumer outreach, such as prioritizing
limited resources and ensuring that certain at-risk populations receive
the information they need. In addition, the panel identified the key
components of a consumer education campaign, such as the need to
clarify the roles and responsibilities of all stakeholders and the
importance of developing a consistent, clear message. At the time of
our report, it remains unclear whether there will be sufficient public-
private sector interaction to ensure a consistent message to prevent
confusion or unnecessary purchases on the part of consumers.
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 provide
services for the program. Despite NTIA's progress in implementing the
subsidy program, the program still faces certain challenges. In
particular, the program's outcome depends upon the coordination of
multiple groups and necessitates the voluntary participation of
retailers and manufacturers. As shown in figure 1, consumers can begin
applying for converter box coupons starting January 1, 2008, with NTIA
requiring full distribution of coupons to begin no later than 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
and potential challenges related to inventory planning. With limited or
delayed retailer participation, consumers might face difficulties in
redeeming their coupons for eligible converter boxes during the
designated time period.
Figure 1: 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]
To help facilitate the DTV transition through comprehensive planning
and risk management, we are recommending that the Chairman, FCC, in
conjunction with public and private stakeholders, develop and
communicate a comprehensive plan, including the attendant mitigation of
risk, for the various aspects of the DTV transition, encompassing
technical, policy, consumer outreach, and other critical elements.
We provided a draft of this report to FCC and the Department of
Commerce (which contains NTIA) for comment. FCC did not directly
indicate whether they agreed or disagreed with our recommendation. The
Chairman of the FCC provided us with oral comments indicating he
appreciated the role that we played in reviewing government programs.
The Chairman also provided us with a draft document that he said
represented the commission's actions over a number of years to meet the
DTV transition. Regarding our recommendation, the Chairman said FCC
does not have a formal plan in place that is publicly available, but
that the various orders contained in FCC dockets amount to a plan. The
Chairman also said that FCC staff working on the DTV transition do not
believe our report gives them adequate credit for all the tasks they
have accomplished related to the transition, which was the reason the
Chairman indicated he provided us with the draft document. Similar to
the elements we recommended FCC develop in a comprehensive plan, this
draft document compiles FCC actions and other activities related to the
transition and includes four main sections--technical goals, policy
goals, consumer outreach goals, and other critical elements. This
document appears to be the first step toward developing and
communicating a comprehensive plan for various aspects of the
transition, per our recommendation. The draft document describes a
variety of actions related to DTV. However, the document neither meets
the requirements for a strategic plan, nor is it sufficiently
transparent to guide stakeholders to meeting the DTV goals or in
serving as a road map to facilitate effective collaboration between the
various stakeholders to ensure the intent of the DTV transition.
Because the draft document does not directly address our
recommendation, is relatively long (96 single-spaced pages), and
includes FCC's actions related to technical matters not discussed in
this report but which we will discuss in a subsequent report, we have
chosen to characterize the document rather than include it in its
entirety. We did not make any changes to our report based on the draft
document we received from FCC. However, since interested parties might
find the information provided by FCC useful, we are providing a Web
link to the draft document, which is located at FCC draft document (or
at [hyperlink, http://www.gao.gov/fccdraft.pdf]. Upon learning that we
would not include the draft document in this report, the FCC Chairman
submitted a letter, which we do include (see app. III), stating that
generally accepted government auditing standards (GAGAS) requires us to
publish FCC's draft document. The Chairman also stated that he had
significant reservations and concerns with the report's approach and
conclusions. However, he did not indicate whether he agreed or
disagreed with our recommendation. We note that GAGAS does not require
us to print in its entirety responses submitted by an agency in
connection with our reports and allows us to characterize responses
where suitable and to include or not include them as appropriate. Also,
we are unable to evaluate the Chairman's statement that he had
reservations and concerns about our approach and conclusions, as
neither his letter nor the draft document indicate the basis for his
reservations and concerns. FCC's response is reprinted in appendix III.
In commenting on the draft of this report, the Department of Commerce
(DOC) acknowledged the risks associated with the voluntary nature of
industry participation in the converter box subsidy program and
consumer outreach campaign, but stated that the solution is not the
establishment of a digital transition czar or a single, government-
mandated message. We did not recommend establishing a digital
transition czar or a single, government-mandated message. DOC did not
comment on our recommendation. Written comments from DOC are reprinted
in appendix IV.
Background:
The United States is currently undergoing a transition from analog to
digital broadcast television, often referred to as the DTV transition.
The transition will enable the government to reallocate valuable
spectrum from analog broadcast to public safety and other purposes.
Digital transmission of television signals provides several advantages
compared with 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 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 after February 17, 2009. The DTV
transition also involves preparation on the part of American
households. This preparation will require citizens' understanding of
the transition and the actions that some might have to take to maintain
television service. The specific equipment needs for each household to
transition to DTV--that is, to be able to view broadcast digital
signals--depends on certain key factors. As shown in figure 2, the
method through which a household watches television, and whether it has
already upgraded its television equipment to be compatible with digital
television, will factor into the equipment needs of the household.
While many households may need to take specific actions to ensure that
they continue to receive television signals, others may not need to
take any action. 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 broadcasting. 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 that provides
the necessary signal to eliminate the need to acquire a digital-to-
analog converter box.
Figure 2: Options for Viewing Digital Signals after the DTV Transition:
This figure is a chart of pictures of options for viewing digital
signals after the DTV transition.
TV type: Analog;
Signal source: Over the air;
Equipment needed: Digital-to-analog converter box.
TV type: Analog;
Signal source: Cable or satellite;
Equipment needed: Provider will address.
TV type: Digital;
Signal source: Over-the-air;
Equipment needed: Nothing.
TV type: Digital;
Signal source: Cable or satellite;
Equipment needed: Provider will address.
[See PDF for image]
Source: GAO analysis of NTIA data.
[End of figure]
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 September 2007 that 51
percent of participants surveyed were unaware that the transition was
taking place. Another study conducted by the National Association of
Broadcasters focused on households that primarily receive their
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. We are also in the process of conducting
our own survey gauging, among other things, consumer awareness of the
transition. We will discuss the results of our survey in a subsequent
report.
To help inform consumers about the transition, in February 2007, eight
private sector stakeholders launched the Digital Television Transition
Coalition. These eight stakeholders 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 grassroots and membership organizations, and FCC.[Footnote 6]
See figure 3 for examples of consumer outreach materials.
Figure 3: Examples of Consumer Outreach Materials about the DTV
Transition:
This figure is a combination of photos showing outreach materials for
consumers for the DTV transition.
[See PDF for image]
Source: DTV Transition Coalition, CEA, FCC, NTIA, and RadioShack. These
materials represent printed and online sources.
[End of figure]
The Digital Television Transition and Public Safety Act directed NTIA
to establish a $1.5 billion subsidy program through which households
can obtain coupons for the purchase of digital-to-analog converter
boxes. In March 2007, NTIA issued a final rule that adopted regulations
to implement the converter box subsidy program and, in August 2007,
selected IBM to provide certain services for the program. NTIA, in
accordance with the act, established that beginning January 1, 2008,
households can request up to two $40 coupons toward the purchase of
eligible[Footnote 7] digital-to-analog converter boxes. Households
requesting coupons must submit the name of the person requesting the
coupon and a valid United States Postal Service address. A post office
box will not be considered a valid address except in the cases of
residents of American Indian reservations, Alaskan native villages, and
other rural areas without home postal delivery.[Footnote 8] Initially,
any household is eligible to request and receive the coupons, but once
$890 million worth of coupons have been redeemed, and issued but not
expired, NTIA must certify to Congress that the program's initial
allocation of funds is insufficient to fulfill coupon requests. NTIA
will then receive $510 million in additional program funds, but any
households requesting coupons during this second phase must certify
that they do not receive cable, satellite, or other pay television
service.[Footnote 9] As shown in table 1, total possible program
funding, which includes coupons redeemed, and issued but not expired,
is $1.5 billion.
Table 1: Converter Box Subsidy Program Funding:
Dollars in millions: Initial allocation;
Funds available for coupons: $890;
Funds available for administrative costs: $100;
Total: $990.
Dollars in millions: Additional allocation;
Funds available for coupons: $450;
Funds available for administrative costs: $60;
Total: $510.
Dollars in millions: Grand total;
Funds available for coupons: $1,340;
Funds available for administrative costs: $160;
Total: $1,500.
Source: GAO analysis of NTIA data.
[End of table]
The last day for consumers to request coupons is March 31, 2009, and
coupons can be redeemed through July 9, 2009. As required by law, all
coupons expire 90 days after issuance. The fully funded program could
provide 33.5 million coupons.[Footnote 10] After participants apply for
a coupon, IBM will send the coupons to their address via United States
Postal Service delivery. Consumers can redeem their coupons at
participating retailers (both "brick and mortar" and online) for
eligible converter boxes. Consumers can neither combine two $40 coupons
for the purchase of one converter box, nor can they return converter
boxes for a cash refund of the coupon amount, or exchange the converter
box for another product, except another coupon-eligible converter box.
In order to participate in the program, retailers must apply and meet
certain standards, such as being a consumer electronics retailer for at
least 1 year and having systems and procedures that can be easily
audited. NTIA and IBM are responsible for certifying retailers. NTIA
also established technical standards that included permitted, required,
and disqualifying features that converter boxes must comply with in
order to be coupon eligible. Manufacturers wishing to certify their
converter boxes as coupon eligible must submit a notice of intent to
NTIA 3 months prior to submitting their test results and sample models
of their converter boxes. Then, manufacturers must submit test results
demonstrating that the converter boxes meet the performance
specifications and features established by NTIA, as well as two sample
models of the converter box. NTIA will review the test results and
sample models and will approve or disapprove of a converter box based
on consultations with FCC.[Footnote 11]
Federal Entities and Other Stakeholders Are Facilitating the
Transition, but Comprehensive Planning and Risk Management Is Limited:
FCC and NTIA have taken numerous steps intended to facilitate the
transition. Likewise, the private sector has begun efforts related to
advancing the transition. However, despite these public and private
sector efforts, we found that no comprehensive plan or strategy exists
with which to track transition efforts and measure progress. Such
planning includes managing and mitigating risks, which we have
previously reported as assisting organizations involved in other high
stakes efforts similar to the DTV transition.
FCC and NTIA Have Taken Steps to Facilitate the Transition:
FCC has primary responsibility under the Communications Act of 1934, as
amended, to regulate the television broadcast industry. As such, FCC is
required to periodically review the progress of the nation's transition
to digital television, as well as to generally encourage the use of
television in the public interest. The Digital Television Transition
and Public Safety Act defines the specific responsibilities of FCC and
other government agencies in the transition but does not specifically
include overall responsibility to ensure the success of transition
efforts. The act directs FCC to start auctioning the licenses for
spectrum recovered in the digital transition no later than January 28,
2008, and to deposit auction proceeds in the U.S. Treasury by June 30,
2008.
FCC has taken steps to facilitate the DTV transition. FCC proposed and
set deadlines and other requirements for broadcast stations upgrading
their equipment to send digital signals. In addition, FCC conducts
periodic reviews to report on progress in the DTV transition, including
analyzing and proposing procedures and rule changes necessary to
complete the transition. The most recent review released in May 2007
included a number of proposals and requests for comments from
stakeholders. For example, the review proposed construction deadlines
for preparing for the transition, as well as requested comments on what
FCC can do to facilitate broadcasters' meeting the DTV transition
deadline and whether coordination is needed between broadcasters and
cable/satellite companies to ensure a smooth transition. FCC also
worked to coordinate with outside stakeholders on the transition, such
as holding a September 2007 workshop to provide an opportunity for
interested parties to jointly discuss transition challenges and related
issues. Additionally, FCC mandated the inclusion of digital
tuners[Footnote 12] in television receivers. Originally issued in 2002,
FCC revised this mandate in 2005 to require that all televisions
imported into the United States or shipped in interstate commerce after
March 1, 2007, include a digital tuner. As we have previously reported,
this action will help increase the number of households with the
equipment to receive over-the-air digital signals.[Footnote 13] FCC has
proposed further steps to facilitate the transition. For example, in
its recent review of the DTV transition, FCC proposed requiring all
full-power television stations to file a form, detailing the station's
current transition status, additional steps necessary in order to be
prepared for digital-only operations after the transition, and a time
line to accomplish those steps. If adopted, this would provide a
comprehensive, national snapshot of stations' efforts to prepare for
the transition.
FCC has also taken a number of actions focused on the technical aspects
of the transition, such as determining channel assignments for
broadcast stations following the transition, and tracking stations'
readiness to broadcast digitally. We are conducting related work on the
technical aspects and challenges of the transition and will issue a
separate report on this work in 2008.
The Digital Television Transition and Public Safety Act also assigned
responsibility to NTIA for the related converter box subsidy program.
NTIA has taken steps to implement the subsidy program, such as issuing
a contract to IBM to implement the program. We discuss the other steps
NTIA has taken to implement the subsidy program later in this report.
Industry Stakeholders Have Also Begun Preparing for the DTV Transition:
Industry stakeholders, including broadcasters, manufacturers, and
retailers have begun efforts to prepare for the transition. For
example, the broadcasters have been overhauling and replacing their
transmission facilities, such as transmission lines, antennas, and
digital transmitters and encoders to enable them to broadcast
digitally.[Footnote 14] Depending on each broadcaster's situation, the
transition might require new towers or upgrades to existing towers.
Most television stations (approximately 90 percent) throughout the
country are now providing a digital broadcast signal in addition to
their analog signal. In other efforts, manufacturers have designed, and
retailers carry, a wide array of televisions that can receive digital
signals. The Consumer Electronics Association estimated that for 2007
estimated wholesale revenues for digital televisions would be $26
billion. Manufacturers have also designed digital-to-analog converter
boxes in order for analog televisions to receive and display digital
signals. Manufacturers, broadcasters, and other private sector
stakeholders are also assisting with consumer outreach efforts for the
transition, which we will describe further later in this report.
Comprehensive Federal Planning and Risk Management for the Transition
Is Limited:
Despite efforts by the public and private sectors and ongoing
coordination, we found that no comprehensive plan for the transition
exists. FCC has included the DTV transition in its strategic plan for
2006 through 2011, as well as related annual performance reports.
However, this particular plan is a high-level, agencywide plan, and FCC
did not intend it to serve as a comprehensive plan or strategy for the
overall transition. FCC officials were aware of planning information
located in both its own and other organizations' documents. However,
this information had not been coordinated in a comprehensive manner and
was not accessible through any centralized planning document, rather it
was scattered in parts of other documents across different
organizations. We have previously reported on the benefits of having a
comprehensive, centralized plan to facilitate program management and
accountability.
Among other things, a comprehensive plan or strategy can detail
milestones and key goals, which provide meaningful guidance for
planning and measuring progress. Such plans can also establish
deadlines for achieving objectives and assigning responsibility for
program implementation. In recent months, there has been disagreement
over federal agencies' roles and responsibilities for the transition.
For example, officials at NTIA and FCC have different views on
responsibilities related to the transition. In addition, FCC
commissioners have expressed varying views to a congressional committee
on the adequacy of the commission's activities and related
responsibilities for the transition. We have previously reported on the
importance of collaboration for issues cutting across more than one
agency and in addressing complicated challenges like the DTV
transition. Specifically, we identified agreeing on roles and
responsibilities as a key practice of collaboration. We found no
comprehensive plans for the overall transition that included these
elements.
One aspect of comprehensive planning absent from transition efforts is
assessing, managing, and mitigating risks. Several organizations we
interviewed described potential risks to the transition. For example,
one public broadcaster association said that one risk or "red flag" for
transition efforts is whether various forms of media provide consumers
with consistent and accurate information on the transition. Potential
misinformation could create confusion among citizens, as well as in
those organizations involved in the transition. Other risks cited
included failing to reach certain consumers and existing funding
proving inadequate for transition needs. Yet we found no examples of a
formal risk assessment documenting these or other concerns, as well as
potential solutions to mitigate them. FCC has risk assessment tools
that it uses for internal activities. Assessing risks is also an
element of FCC's annual performance report, and FCC told us it could
explore applying risk assessment tools to ongoing transition efforts.
NTIA has included risk management tools relevant to the transition,
although this is only for its management of the converter box subsidy
program. For example, NTIA required IBM to submit a risk management
plan with its contract proposal, indicating how risks will be
continually identified, documented, assessed, and communicated to
project stakeholders and the criteria for risk management planning.
According to NTIA, it requires IBM to identify and assess risks
associated with their ability to meet program objectives and to develop
risk mitigation plans for high probability or high impact risks. NTIA
said these risks are reviewed with IBM on a monthly basis In addition,
NTIA said it has established an internal risk management process to
identify and assess other program risks and to develop risk mitigation
plans for those risks considered to be high probability or high impact.
Managing risks can help target limited resources and ensure critical
dates are met, an important benefit given the transition's 2009
deadline. We have previously described the purpose of risk management
as identifying potential problems before they occur to mitigate adverse
impacts. Figure 4 depicts a risk management cycle representing a series
of analytical and managerial steps, which are sequential, that can be
used to assess risk, assess alternatives for reducing risks, choose
among those alternatives, implement the alternatives, monitor their
implementation, and continually use new information to adjust and
revise the assessments and actions, as needed. The approach is dynamic
and can be applied at various organizational levels. A viable risk
management approach can also affect outcomes beyond the public sector
in achieving national goals, which also has applicability to the DTV
transition and the involvement of public and private stakeholders.
Figure 4: Risk Management Framework:
This figure is a circular flow chart with arrows pointing left to
right.
Management selection;
Implementation and monitoring;
Strategic goals, objectives, and constraints;
Risk assessment;
Alternative evaluation.
[See PDF for image]
Source: GAO.
[End of figure]
We have previously reported on the benefits of risk management in other
high stakes efforts with similarities to the DTV transition. For
example, like the DTV transition, Y2K involved a deadline when certain
technology--computer systems--would face potential operational
problems. In preparing the nation's computer systems for Y2K,[Footnote
15] we provided a guide that included risk assessments, oversight, and
the common thread of accountability at all levels.[Footnote 16] We
credited one federal agency's success in weathering Y2K, in part, due
to reducing risks to facilities, systems, programs, and services during
the critical rollover. Further, we have recently reported on the
benefits of risk management in relation to the 2010 census,
specifically in managing and overseeing contracts that are key to
conducting a successful census.[Footnote 17] Like the DTV transition,
private organizations are involved in carrying out important public
goals, in this case, the next census. Finally, we have reported on the
advantages of managing risks for homeland security programs, namely to
target federal funding for homeland security to maximize results and
mitigate risks within available resource levels.[Footnote 18]
Effectively targeting resources is important to the DTV transition
since funding appears limited.
Progress in Consumer Education on the DTV Transition Has Been Made, but
Widespread Implementation Is Not Yet Under Way:
Federal and private stakeholders are making progress in educating
consumers about the DTV transition, with both independent and
coordinated efforts under way. Some private sector stakeholders are
taking the lead on outreach efforts on a voluntary basis. Overall, at
the time of our report, many consumer education efforts were still in
the planning stages and had not been widely implemented. Industry,
government, and academic experts participating in our expert panel
identified potential challenges and key components in launching a
consumer education campaign.
Federal Stakeholders Have Begun Consumer Education Efforts:
FCC and NTIA are both involved in consumer education about the DTV
transition. For example, FCC has launched a Web site [hyperlink,
http://wwww.DTV.gov] which, among other things, provides background
information on the DTV transition and answers common consumer
questions. In addition, FCC has met with some industry groups, consumer
groups, and other government agencies and participated in public events
intended to educate audiences about the transition. FCC also joined the
DTV Transition Coalition, whose goal is to provide consumers with
information about the transition. Moreover, in April 2007, FCC adopted
a rule requiring all sellers of television-receiving equipment that
does not include a digital tuner to prominently display a consumer
alert that such devices will require a converter box to receive over-
the-air broadcast television after February 17, 2009 (see fig. 5).
Figure 5: Consumer Advisory Alerts for Analog Televisions:
This figure is a picture of a television with an enlarged warning
sticker with the label:
Consumer Alert:
This television receiver has only an analog broadcast tuner and will
require a converter box after February 17, 2009, to receive over-the-
air broadcasts with an antenna because of the Nation’s transition to
digital broadcasting. Analog-only TVs should continue to work as before
with cable and satellite TV services, gaming consoles, VCRs, DVD
layers, and similar products. For more information, call the Federal
Communications Commission at 1-888-225-5322 (TTY:1-888-835-5322) or
visit the Commission’s digital television website at: [hyperlink,
http://www.dtv.gov].
[See PDF for image]
Source: FCC.
[End of figure]
To ensure that retailers are in compliance, FCC staff have inspected
over 1,000 retail stores and Web sites and issued over 250 citations
with potential fines exceeding $3 million. In addition, FCC has issued
notices to television manufacturers with potential fines over $2.5
million for importing televisions without digital tuners. In June 2007,
FCC announced that it had rechartered an intergovernmental advisory
committee comprising 15 representatives from local, state, and tribal
governments to help it address, among other things, consumer education
about the DTV transition. Similarly, it rechartered a consumer advisory
committee that will also make recommendations to FCC about the
transition on behalf of consumers, with specific representation for
people with disabilities and other underserved or at-risk populations.
Finally, in August 2007, in response to a letter containing proposals
on advancing consumer education submitted by members of
Congress,[Footnote 19] FCC released a notice of proposed rulemaking
soliciting public comments on the proposals listed in the letter. These
proposals include requiring television broadcasters to conduct on-air
consumer education efforts and regularly report on the status of these
efforts, requiring cable and satellite providers to insert periodic
notices in customers' bills about the transition and their future
viewing options, and requiring manufacturers to include information on
the transition with any television set or related device they import or
distribute in the United States. Each of the requirements mentions
civil penalties for noncompliance. Another proposal on which FCC sought
comment would have FCC work with NTIA to require that retailers
participating in the converter box subsidy program detail their
employee training and consumer information plans, as well as having FCC
staff spot check the retailers for compliance. Also, FCC sought
comments on a proposal requiring partners identified on FCC's
[hyperlink, http://www.DTV.gov] Web site to report their specific
consumer outreach efforts. The comment period on the notice of proposed
rulemaking closed on September 17, 2007; the period to file any
rebuttal closed October 1, 2007.
NTIA has also taken initial steps toward educating consumers about the
transition. NTIA has statutory responsibility for the converter box
subsidy program, for which Congress appropriated up to $5 million for
education efforts. According to NTIA, its education efforts are focused
on the subsidy program and within that on five groups most likely to
lose all television service as a result of the transition: (1) senior
citizens, (2) the economically disadvantaged, (3) rural residents, (4)
people with disabilities, and (5) minorities. NTIA has begun outreach
to these groups through partnerships with private organizations, as
well as other federal agencies. In addition, it has created
"information sheets" for consumers, retailers, and manufacturers that
outline the subsidy program and are available on its Web site. NTIA
said it has provided informational brochures in English and Spanish to
the public and provided a copy to every member of Congress and federal
agencies that serve some of the populations noted above. The agency
also created a consumer hotline[Footnote 20] that provides information
about the transition in English and Spanish, as well as TTY numbers
that provide information in English[Footnote 21] and Spanish[Footnote
22] to the hearing impaired. In addition, in August 2007, NTIA
contracted with IBM to implement a broad consumer education component
about the program, and a draft of this consumer education plan was
submitted to NTIA on September 15, 2007.
While public sector entities are planning and, in some cases, launching
consumer education efforts, widespread and comprehensive efforts have
yet to be implemented. FCC officials told us that its efforts to
educate consumers about the transition are limited, in large part
because it does not currently have specific funds directed at consumer
education. In a July 2007 testimony to Congress, the FCC Chairman
stated that the agency is "working, consistent with its statutory
authority and budgetary capacity to ensure that no American is left
behind in this part of the digital revolution." In FCC's fiscal year
2008 budget request, it has requested $1.5 million for digital
television consumer outreach specifically. FCC's outreach initiative
would primarily use the media, Internet, publications, and
participation in forums, public events, and community education
programs to disseminate information. In addition, to maximize DTV
outreach effectiveness and efficiency, it intends to coordinate
programs with NTIA and other government agencies with DTV transition
involvement. NTIA also has not fully implemented education efforts
about its subsidy program in large part because it is contracting out
the consumer education component of its program and, as mentioned
previously, the contract was only recently awarded, and plans were in
the development stage at the time of our review.
Private Sector Stakeholders Are Taking the Lead on Consumer Education
Efforts, but Actions Are Voluntary and Widespread Implementation Is
Limited:
On a voluntary basis, some private sector stakeholders have begun
planning and, in some cases, implementing measures to inform consumers
about the DTV transition. One such private sector led effort is the DTV
Transition Coalition, which encompasses over 160 organizations.
According to the coalition, it has developed and consumer tested
various messages about the transition, using surveys and focus groups
of the affected consumers--the general population, senior citizens,
minority groups, and over-the-air analog television households--to
understand what messages are most effective in informing them about the
transition. Subsequently, the coalition said it agreed upon one concise
message that includes information about the transition itself, the
rationale for the transition, and the ways consumers can effectively
switch to DTV. In particular, the coalition suggests consumers can
prepare for the transition by purchasing a DTV converter box,
purchasing a new television set with a built in digital tuner, or
subscribing to a pay television service such as cable, satellite, or
telephone company video service provider. The coalition said its member
organizations will distribute this information to their constituents,
including senior citizens, the disabled, and minority groups. The
coalition message will also be delivered to media outlets.
In addition to coordinated efforts within the coalition, private sector
stakeholders also have independent education efforts under way. For
example, a number of industry associations host Web sites that inform
consumers of, among other things, common consumer questions about the
transition, how to check if the television they own is digital-ready,
and how to dispose of analog television sets. The Consumer Electronics
Association (CEA) has launched a number of Web sites, one of which
provides online education for retailers and their sales associates.
Another CEA Web site informs consumers how to connect their television
equipment, and CEA officials told us it will include guidance on how to
connect a converter box to a television. One national retailer told us
that it added a feature to its registers so that when a consumer
purchases an analog television, a message about the DTV transition is
printed on the bottom of the receipt. The National Cable and
Telecommunications Association has created public service announcements
about the transition in both Spanish and English, which are being aired
by cable operators and networks in markets throughout the country. The
National Association of Broadcasters also has plans to launch a public
service announcement campaign related to the transition by the end of
2007, which will air on its local television broadcasting affiliates,
independent stations, and broadcast networks.
Despite ongoing education efforts, since these actions are voluntary,
the government cannot be assured of the extent of private sector
efforts. For example, in a 2004 review, FCC deferred requiring
retailers to label analog-only television equipment with information
about the transition, leaving retailers and manufacturers to educate
consumers voluntarily. Later, FCC determined that retailer and
manufacturer efforts did not adequately inform consumers how analog-
only television equipment would be affected by the transition and in
2007 implemented a labeling requirement. Moreover, given the different
interests represented by industry stakeholders, messages directed at
consumers vary and might lead to confusion. For example, in addition to
providing information about why the transition is occurring, industry
stakeholders also have incentives to provide consumers with information
on a wide host of technology equipment or services that consumers could
purchase, at varying costs. Advocates for the elderly, disabled, and
non-English speaking households told us that they are concerned that
their members will become confused by the options and end up purchasing
equipment they do not need or more expensive equipment than necessary
to maintain their television viewing.
Similar to progress made by public sector entities, widespread and
comprehensive efforts have yet to be implemented by the private sector.
Representatives from private sector organizations have told us there
are several reasons why they are waiting to fully launch their consumer
education campaigns. For example, they do not want to start too early
and possibly lose the attention of consumers later on. Another reason
is that they are awaiting key events to be finalized, such as when
converter boxes will be available for purchase, so that education
efforts can be complete. A number of nonprofit organizations told us
that a lack of dedicated funding hampers their ability to educate and
provide outreach to their constituents.
Expert Panelists Identified Potential Challenges and Key Components in
Launching a Consumer Education Campaign:
We convened an expert panel to discuss consumer education issues
applicable to the DTV transition. These issues included 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. One expert
noted, "There is a necessity of focus when you have limited resources.
Rather than try to do too much and dilute your campaign, tighten it in
and take your best shot."
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 23]
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.
Furthermore, representatives from organizations representing
underserved groups that we contacted relayed consumer education
challenges that their members could face. A broad concern is that
television sets will go dark on the transition date without adequate
education about the transition and, for people in these groups, their
televisions may be their sole source for receiving emergency and other
local information. However, we heard these populations may be hard to
locate and, therefore, expensive to reach. While representatives from a
number of these organizations noted that they are in the best position
to provide outreach to these groups, they also noted that they do not
have the budget to target them comprehensively. AARP representatives
expressed concern that retailers will downplay the various options--
such as cable and satellite service and converter boxes--and try to
convince consumers to purchase digital televisions. According to
representatives from AARP and the Association for Public Television
Stations, Americans over the age of 65 are more likely to receive their
television programming through over-the-air analog broadcasting than
those under 65. Regarding consumer education related to the converter
box subsidy program, representatives from multiple organizations noted
that education about the availability of coupons is especially
important for underserved households for whom a television is an
essential item, not a luxury item. Insofar as the subsidy will be
administered on a first-come, first-served basis, there is a concern
that these populations will be the last to hear about the program,
putting them at a disadvantage for obtaining a coupon before the fund
is depleted.
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 DTV
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 24]
In addition to highlighting potential challenges, the expert panelists
identified the key practices that are 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 (see table 2).
Table 2: 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 and concerns, and
selecting IBM in August 2007 to provide services for the program.
However, the program faces challenges. In particular, the program's
outcome depends on the coordination of several groups, and necessitates
the voluntary participation of retailers and manufacturers. Moreover,
uncertainty about retailers' participation, as well as readiness and
potential challenges related to inventory planning, could hinder
consumers' access to subsidy-eligible converter boxes.
NTIA Has Selected IBM to Implement the Converter Box Subsidy Program,
but NTIA Remains Ultimately Responsible for the Program:
NTIA completed several tasks related to the converter box subsidy
program before it awarded the contract to IBM. In July 2006, NTIA
issued a notice of proposed rulemaking inviting public comments on
converter box manufacturing standards, the coupon application and
redemption process, household eligibility, and ways of minimizing
waste, fraud, and abuse. NTIA received 113 comments, including comments
from manufacturers, retailers, media companies, advocacy groups, and
professional services firms. As part of this process, NTIA also met
with and received presentations from industry stakeholders. In
addition, in July 2006, NTIA issued a request for information to
conduct market research on the implementation of the converter box
subsidy program. Specifically, NTIA asked vendors to comment on NTIA's
proposed project objectives, time frames, corporate capability;
proposed products, services, and solutions; and experience and cost
estimates. NTIA released the final rule on the converter box subsidy
program and issued a request for proposals for services related to the
subsidy program in March 2007. A contract was awarded on schedule to
IBM on August 15, 2007.
Although NTIA contracted with IBM to provide services for the converter
box subsidy program, NTIA remains ultimately responsible for meeting
the program's objectives. The contract is performance-based, which
means that while NTIA requires IBM to meet certain outcomes and
objectives, IBM is responsible for determining the specific means for
doing so, including developing performance metrics.[Footnote 25] NTIA
remains responsible for ensuring that IBM meets the program objectives
by determining that the performance metrics tie to the program
objectives and by overseeing IBM's performance. The Office of
Management and Budget's Office of Federal Procurement Policy identified
managing the contractor's performance as the final step of its "Seven
Steps to Performance-Based Acquisition," and this included adjusting
staff roles and responsibility, assigning accountability for managing
the contractor's performance, and regularly reviewing the contractor's
performance in a working group. In addition, we have previously
reported that agencies using performance-based contracting for complex,
unique, and risky services need to maintain strong government
involvement to mitigate risks.[Footnote 26] We have found that
effective contractor management and oversight includes having adequate
resources and properly trained personnel, conducting ongoing
surveillance throughout the performance period of the contract, and
creating an official record of the contractor's performance.[Footnote
27] To assist the agency in the implementation and oversight of the
program, NTIA designated existing staff and is hiring new staff for
contract management activities, and has required IBM to submit a
quality assurance and surveillance plan for measuring its performance.
Also, NTIA requested that IBM develop a Web-based electronic
"dashboard" that provides real-time access to program status and
performance measures, such as consumer coupon requests, retailer
participation, and program financials. In addition, the National
Oceanic and Atmospheric Administration (NOAA) is providing acquisition
support to NTIA, which includes acting as the contracting officer, and
temporarily locating NOAA acquisition staff in NTIA offices to provide
acquisition expertise and assist NTIA personnel in managing the
contract. IBM submitted a draft project management plan with its
proposal. While IBM will determine the specifics of the consumer
outreach plan and the technical solution for distributing and redeeming
coupons, NTIA remains ultimately responsible for managing IBM's
performance to ensure the program's successful completion.
Program Outcomes Depend on the Careful Coordination and Voluntary
Participation of Several Groups, Some of Which May Face Challenges:
The subsidy program's outcomes depend on the coordination and
participation of NTIA, IBM, converter box manufacturers, retailers, and
consumers. Figure 6 depicts the necessary, interrelated actions for the
subsidy program. Manufacturers and retailers are voluntarily
participating in the program, as NTIA does not have the authority to
require their participation. According to NTIA, IBM has developed the
technical solution for the program, which covers determining how
consumers will request, receive, and redeem coupons, and how this will
affect retailers' current point-of-sale systems.[Footnote 28] In
addition, manufacturers are creating converter boxes and submitting
them to NTIA, which, in consultation with FCC, will review the results
and determine whether the converter box meets the technical standards
required of coupon-eligible converter boxes. In addition, IBM will
certify eligible retailers where consumers can use their coupon for
eligible converter boxes. NTIA and IBM will test IBM's solution for
distributing and redeeming coupons. According to NTIA, one part of this
testing will occur in December 2007, and includes processing a limited
number of coupon requests, distributing a limited number of coupons to
consumers, and having the coupons redeemed for eligible converter boxes
by participating retailers.[Footnote 29] NTIA and IBM will also be
conducting consumer outreach specific to the program.
Figure 6: Coordination of Groups Involved in the Subsidy Program:
This figure is a flowchart showing coordination of groups involved in
the subsidy program.
[See PDF for image]
Source: GAO.
[End of figure]
Retailers could face challenges that might limit or delay their
participation in the subsidy program. 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 and 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. In addition, retailers have pointed out that participating in
the converter box subsidy program could require a considerable amount
of effort for a one-time program with a product that has a limited
shelf life[Footnote 30] and low profit margin. 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.
In addition, the unique nature of the converter box program and the
limited time between the emergence and the depletion of demand for the
converter boxes may present challenges for retailers and manufacturers
in predicting demand and planning inventory accordingly. For example,
retailer and manufacturer representatives noted that it is possible
that demand could rapidly increase just before the transition and may
then suddenly drop after February 17, 2009. This uncertain demand, as
well as uncertainty about the extent of retailers' participation in the
program, could affect the number of converter boxes that manufacturers
produce and the corresponding availability of coupon-eligible converter
boxes in stores. While a manufacturer and a consumer group we contacted
expressed concern that retailers are not required to carry a certain
level of inventory in their stores, a retailer trade association told
us that requiring retailers to have a certain level of converter boxes
in stock would be a large disincentive to participate in the program.
However, manufacturers we contacted noted that their production of
converter boxes would depend on receiving orders from retailers. These
manufacturers could not tell us how many boxes they would produce or
the expected retail cost of the boxes.
Challenges to Private Sector Participation Might Affect Consumers'
Access to Converter Boxes:
Uncertain retailer participation and converter box availability might
affect consumers' access to converter boxes. Specifically, whether and
when retailers participate may be affected by IBM's technical solution
for accepting and redeeming coupons and the corresponding impact on
retailers' point-of-sale systems. As previously noted, some retailer
representatives have stated that they are more likely to be prepared to
participate in the program in March or April 2008.
In accordance with the Digital Television Transition and Public Safety
Act, consumers can begin applying for coupons starting January 1, 2008.
In addition, NTIA requires full distribution of coupons to begin by
April 1, 2008. Although IBM plans to distribute a limited number of
coupons from January through March 31, 2008, unless they receive a
coupon as part of the test solution, some consumers that request
coupons in January may have to wait months to receive coupons. NTIA has
stated that IBM will determine how to inform consumers requesting
coupons in January 2008 when they will be able to redeem their coupons.
In addition, since retailers' participation in the subsidy program is
voluntary, and currently uncertain, 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. Although the final
rule does not require remedies if certain geographic areas lack
participating retailers, NTIA requires IBM to measure retailers'
participation by geographic area and intends to investigate areas with
unusual participation patterns. In other words, if there is a large
number of coupon requests from a small rural city, but no participating
retailers in that area, NTIA may investigate the issue, but it does not
have the authority to require retailers to participate. In addition,
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. Some retailer and advocacy
groups we contacted have pointed out that this could pose a challenge
to certain groups, such as rural residents with limited access to
retail outlets, or elderly and low-income populations for whom multiple
trips to a store could be burdensome. Furthermore, some tribal groups
have noted that tribal members living far from retailers will need to
be able to purchase a coupon-eligible converter box online or direct
from retailers and have it shipped to their homes. An advocacy group
and a retailer we contacted noted that while online ordering could help
address this issue, it might not be a viable option for some vulnerable
groups. In addition, an online retailer told us they would need to
assess the extent to which IBM's technical solution will affect their
existing systems before deciding whether to participate.
Conclusions:
The federal government has an interest in a smooth DTV transition since
a primary goal of the transition is for the government to reclaim the
spectrum that broadcasters currently use to provide analog television
signals. The government is expected to be afforded billions of dollars
in revenues from the spectrum auction. Moreover, the return of the
spectrum will ease the spectrum scarcity facing public safety first
responders and engender economic growth and consumer value from
spectrum redeployed to wireless services. The approaching deadline for
the DTV transition has heightened efforts among public and private
organizations to ensure that the United States achieves a smooth
transition to digital television by February 17, 2009. FCC, NTIA, and
private sector organizations have begun important efforts toward this
end, including policy and technical decisions and outreach to consumers
on the options that they can take to maintain access to their
television programming. These efforts are ongoing, and the involvement
of multiple organizations in assisting with the transition is a
positive demonstration of the commitment of public and private
stakeholders to meet the 2009 deadline.
In an undertaking as complicated as the DTV transition, careful
planning--including managing and mitigating risks--is needed to help
organizations track and complete their transition efforts. Managing and
mitigating risks is especially important as the transition's success
will rely on participation by both the public and the private sectors,
effective collaboration among these groups, targeting resources to
reach citizens of various demographics across the country, and meeting
critical dates to achieve results before the legislatively set deadline
to turn off analog signals. Current public and private sector efforts
might be adequate to ensure a smooth transition, free of consumer
disruptions. However, not having a comprehensive plan for the DTV
transition limits the government's ability to measure efforts against
planned goals, set milestones, and assess risks. This raises
uncertainty, including whether consumers, particularly underserved and
otherwise vulnerable populations, will have the information necessary
to respond to the transition and to maintain their access to television
programming. Furthermore, a comprehensive plan could help identify gaps
or other areas for improvement that further planning and risk
management could address. Voluntary transition efforts combined with
the absence of responsibility for facilitating the overall DTV
transition means that accountability for a successful transition cannot
be assured. Since FCC has the broadest telecommunications
responsibilities in the federal government, it is in the best position
to increase assurance of a successful transition through increased
attention to high-level comprehensive planning, performance
measurement, and risk mitigation efforts.
Recommendation for Executive Action:
To help facilitate the DTV transition through comprehensive planning
and risk management, in consultation with public and private
stakeholders, we recommend that the Chairman, FCC, develop and
communicate a comprehensive plan for the various aspects of the DTV
transition, encompassing technical, policy, consumer outreach, and
other critical elements. The plan should include (1) detailed goals,
milestones, and time frames that can be used to gauge performance and
progress, identify gaps, and determine areas for improvement; (2)
strategies for collaboration between public and private sector
stakeholders to agree on roles and responsibilities; (3) a description
of reporting requirements to track stakeholder efforts against planned
goals; and (4) strategies for managing and mitigating risks to avoid
potential problems and target federal resources.
Agency Comments and Our Evaluation:
We provided a draft of this report to FCC and the Department of
Commerce (which contains NTIA) for comment. FCC did not directly
indicate whether they agreed or disagreed with our recommendation. The
Chairman of the FCC provided us with oral comments indicating he
appreciated the role that we played in reviewing government programs.
The Chairman also provided us with a draft document that he said
represented the commission's actions over a number of years to meet the
DTV transition. Regarding our recommendation, the Chairman said FCC
does not have a formal plan in place that is publicly available, but
that the various orders contained in FCC dockets amount to a plan. The
Chairman also said that FCC staff working on the DTV transition do not
believe our report gives them adequate credit for all the tasks they
have accomplished related to the transition, which was the reason FCC
provided the draft document. Similar to the elements we recommended FCC
develop in a comprehensive plan, this draft document compiles FCC
actions and other activities related to the transition and includes
four main sections--technical goals, policy goals, consumer outreach
goals, and other critical elements. For these sections, the document
includes items such as goals, progress and performance, milestones,
time frames and steps, reporting requirements, and risks and related
mitigation strategies. This document appears to be the first step
toward developing and communicating a comprehensive plan for various
aspects of the transition, per our recommendation. However, because the
draft document does not directly address our recommendation, is
relatively long (96 single-spaced pages) and includes FCC's actions
related to technical matters not discussed in this report but which we
will discuss in a subsequent report, we have chosen to characterize the
document rather than include it in its entirety. We did not make any
changes to our report based on the draft document we received from FCC.
During our review, we asked FCC officials on several occasions if they
had a plan, and FCC could not reference or provide us with an overall
plan that could be used to manage and coordinate aspects of the DTV
transition or to measure progress. We applaud FCC for its efforts to
compile this information and recognize that FCC has taken numerous
actions related to the transition, as we state in our report. Thus, we
disagree with the Chairman's contention, and that of the FCC staff,
that we did not recognize the work of FCC staff in facilitating aspects
of the DTV transition. Regarding the compilation of FCC actions and
other activities in the draft document, we agree that FCC had this
information in numerous documents collected over the past several years
in FCC dockets, as stated by the Chairman, and we cite the results of
this work throughout our report. We believe compiling this information
into a single document is beneficial for Congress, the public, and
private sector stakeholders. Thus, as discussed earlier, while we do
not believe this document is appropriate for inclusion in our report,
the draft document describes a variety of actions related to DTV, and
contains some information on goals, milestones, and risk mitigation
efforts. Since interested parties might find the information provided
by FCC useful, we are providing a Web link to the draft document, which
is located at FCC draft document or at [hyperlink,
http://www.gao.gov/fccdraft.pdf]. We note, however, that significant
portions of the document simply review past actions as opposed to
analyzing current and future needs to meet the deadline or ensure
nationwide access to television. Thus, the document neither meets the
requirements for a strategic plan, nor is it sufficiently transparent
to guide stakeholders to meeting the DTV goals or in serving as a road
map to facilitate effective collaboration between the various
stakeholders to ensure the intent of the DTV transition. To fully
address our recommendation, we believe more remains to be done to
finalize a comprehensive plan. For example, the completed milestones
and activities in the draft document include the year they were
achieved, but some milestones currently in progress have no estimated
completion dates. Setting completion date goals for all outstanding
activities would assist in gauging performance and measuring future
progress for the transition. Additionally, providing clear measurable
performance metrics would assist all stakeholders in determining
progress. In addition, while the document includes some strategies to
mitigate risks, it is not always clear what risks the mitigation
strategies are intended to address. Moreover, some risks are raised but
have no related mitigation strategy. FCC also does not indicate whether
all goals related to the DTV transition are accounted for and whether
any gaps exist in efforts by the government or the private sector to
achieve transition objectives. It is also unknown how FCC identified
these risks and mitigation strategies and whether a risk assessment
process or other tool was used. Upon learning that we would not include
the draft document in our report, the FCC Chairman submitted a letter,
which we do include (see app. III), stating that generally accepted
government auditing standards (GAGAS) requires us to publish FCC's
draft document. The Chairman also stated that he had significant
reservations and concerns with the report's approach and conclusions.
However, he did not indicate whether he agreed or disagreed with our
recommendation. We have met the GAGAS requirements of including the
commission's comments by summarizing important aspects of the response.
We note that GAGAS does not require us to print in its entirety
responses submitted by an agency in connection with our reports and
allows us to characterize responses where suitable and to include or
not include them as appropriate. Specifically, sections 8.31 and 8.33,
respectively, note that a summary of comments are acceptable and that
agency responses should be "fairly and objectively evaluated," as
appropriate. Also, we are unable to evaluate the Chairman's statement
that he had reservations and concerns about our approach and
conclusions, as neither his letter nor the draft document indicate the
basis for his reservations and concerns. FCC's response is reprinted in
appendix III.
In its comments, DOC acknowledged the risk associated with the
voluntary nature of industry participation in the converter box subsidy
program and in the consumer outreach campaign. However, DOC stated that
the solution is not the establishment of a digital transition czar or a
single, government-mandated message. We did not recommend establishing
a digital transition czar or a single, government-mandated message. DOC
noted that a multiplicity of messages and sources of information is
critical to a well-informed consuming public. DOC also noted NTIA's
progress in implementing the converter box subsidy program, such as
certifying converter boxes, encouraging retailer participation, and
collaborating with stakeholders to reach the over-the-air population.
DOC did not comment on our recommendation. Written comments from DOC
are reprinted in appendix IV. In addition to the written comments, NTIA
provided us with technical comments, which we incorporated as
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 this report
to interested congressional committees; the Chairman of the FCC; and
the Secretary of Commerce. We also will make copies available to others
upon request. In addition, the report will be available at no charge on
the GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions concerning this report, please
contact me on (202) 512-2834 or 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 V.
Signed by:
Mark L. Goldstein:
Director, Physical Infrastructure Issues:
List of Requesters:
The Honorable Edward J. Markey:
Chairman:
The Honorable Fred Upton:
Ranking Member:
Subcommittee on Telecommunications and the Internet:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Joe Barton:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Herb Kohl:
Chairman:
Special Committee on Aging:
United States Senate:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
The objectives of this report are to provide information on the
progress of the digital television (DTV) transition and, in particular,
the progress made (1) by federal entities, in conjunction with other
stakeholders, in facilitating the transition; (2) in educating
consumers about the transition and any related challenges; and (3) in
implementing a subsidy program for converter boxes and any related
challenges.
To meet these objectives, we reviewed statutes, regulations, and
federal agency planning documents that broadly define the role of the
Federal Communications Commission (FCC) and the National
Telecommunications and Information Administration (NTIA) in the DTV
transition. In addition, we reviewed strategic plans for both FCC and
NTIA, FCC periodic reviews and orders related to the transition, and
testimony statements of FCC, NTIA, and officials from broadcasting,
retail, manufacturing, cable, and advocacy groups. Further, we spoke
with a wide variety of stakeholders in the transition, including FCC
and NTIA officials, as well as the nine steering committee members of
the DTV Transition Coalition: AARP, 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. We also interviewed five retailers, the
North American Retail Dealers Association, two additional converter box
manufacturers, the Satellite Broadcasting and Communications
Association, a television station that has completed its transition to
digital, four state broadcaster associations, and two additional
special interest groups that act on behalf of underrepresented
populations. We also attended two meetings of the DTV Transition
Coalition.
Further, we convened a half-day panel of 14 senior management-level
experts in strategic communications to identify and come to consensus
on key planning components for consumer education and outreach. The
panel succeeded in agreeing upon the key phases of a public education
outreach campaign. Additionally, the panel discussed key components of
the implementation and measurement phases of an outreach campaign. We
selected these experts based on their experience overseeing a strategic
communications or social marketing campaign or other relevant
expertise. The experts represented private, public, and academic
institutions: AARP, Academy for Educational Development, American
Legacy Foundation, APCO Worldwide, Edelman, Fleishman-Hillard,
GolinHarris, Issue Dynamics Inc., Ogilvy, PodTech (representing
Sweden's DTV transition), Population Services International, Porter
Novelli, Food and Nutrition Service within the U.S. Department of
Agriculture, and the Darden School of Business at the University of
Virginia.
Finally, to learn about the subsidy program, we reviewed comments
submitted to NTIA regarding the proposed program rules. We reviewed
NTIA's Request for Proposal for administering the program, questions
submitted to NTIA from prospective bidders, NTIA's answers to those
questions, and the NTIA contract for the converter box subsidy program.
However, NTIA awarded the contract in August 2007, which was at the end
of our audit work. Thus, our review was preliminary, and adequate time
has not yet passed for us to evaluate the contractor or NTIA's
performance in administering the contract. We also interviewed the
National Oceanic and Atmospheric Administration, the agency acting as
NTIA's contracting officer for the program. To determine important
practices in administering performance-based contracts, we reviewed the
Office of Federal Procurement Policy's "Seven Steps to Performance-
Based Services Acquisition," as well as prior GAO reports. We conducted
our review from January 2007 to August 2007 in accordance with
generally accepted government auditing standards.
[End of section]
Appendix II: Key Planning Components, Implementation Challenges, and
Evaluation Elements of Public Education Outreach:
The DTV transition presents a communications challenge that is
relatively unique--inform the U.S. population, and particularly
affected subgroups within that population, about an issue that will
require some households to take action within a fixed period of time.
Although the DTV transition is a communications challenge, the process
for informing the public about this issue is similar to the course of
action that occurs in many public education outreach campaigns,
particularly those looking to affect a behavior change. These public
education campaigns typically have three fundamental stages: planning,
implementation, and evaluation. In order to determine the extent to
which a campaign has reached its goals, the steps that comprise each
stage must be understood.
We convened a panel of strategic communications and social marketing
experts on June 28, 2007, to better understand the steps that comprise
a consumer education campaign. The panel focused on communications
campaigns that are intended to elicit a one-time action or behavior
change. The objectives of the panel were to (1) achieve consensus on
key practices of the planning stage of the campaign process; (2)
understand what, if any, potential challenges might obstruct the
implementation of consumer education efforts when moving from
principles to practice; and (3) understand some of the key ways to
evaluate the campaign on process and outcomes.
Key Practices for Planning an Effective Consumer Education Campaign:
We asked the panelists to write their own list of the key elements of a
consumer education campaign. Once they completed writing their list,
each expert shared one of their items and the discussion continued
around the table until all had given one key element. Panelists were
then encouraged to share other elements on their list that had not yet
been shared, or others they thought of during the discussion. At the
end of the session, there were 40 discrete elements that had been
suggested by panelists and then discussed.
The panel agreed to allow us to contact them at a later date to reach
consensus on the key elements of the planning stage of a consumer
education campaign. In the week after the panel concluded, we analyzed
the 40 proposed elements and collapsed them into 11 broader categories.
Each of the panelists was then sent an e-mail showing the 11 categories
with their corresponding definitions, and a description of how each of
the 40 items fit into the 11 broad categories. The panel was requested
to provide feedback in the form of an agreement with the 11 categories
created or to offer suggestions about how they would modify those
categories. We received comments from 11 of the 14 panelists and the
nonresponse from the other 3 was viewed as consensus with our analysis.
Based on the panelists' feedback, we created a final list of 9 key
practices for planning a consumer education campaign. As discussed
previously in this report, these key practices (in no particular order)
are (1) define goals and objectives, (2) analyze the situation, (3)
identify stakeholders, (4) identify resources, (5) research target
audiences, (6) develop consistent, clear messages, (7) identify
credible messengers, (8) design media mix, and (9) establish metrics to
measure success. While this list was created with the DTV campaign in
mind (focusing on a one-time behavior change), the goal in creating
this list was that it could be used to provide a framework for
evaluating other consumer education outreach programs as well.
Key Implementation Challenges That Might Obstruct Consumer Education
Efforts:
In this panel session, participants were asked to draw upon their
previous experiences with public education campaigns to identify key
challenges they have faced when moving from the principles of the
planning stage to the practices of the implementation stage. As
discussed previously in this report, the following challenges were the
four that stood out as the most pressing implementation challenges: (1)
prioritizing limited resources, (2) educating consumers who do not
necessarily need to take action, (3) reaching underserved populations,
(4) aligning stakeholders.
Key Elements for Measuring Campaign Effectiveness:
The final session of our expert panel was a discussion about the role
of evaluation in a strategic communications campaign. While the
evaluation phase is typically considered a distinct component, it can
be integrated into all parts of a campaign. The evaluation process for
a public education campaign is typically thought of in three phases:
(1) inputs, which includes the investments of the evaluation, such as
resources, staff, partners, and technology; (2) outputs, which monitors
the performance of the contractor or service provider in conducting the
program; and (3) outcomes, which evaluates the impact of a campaign at
different time intervals. This process is often represented
schematically by a logic model, which is an evaluation tool used to
describe a program's components and desired results and explain the
strategy--or logic--by which the program is expected to achieve its
goals.[Footnote 31]
Because the panelists were not evaluation experts, per se, but rather
practitioners who used evaluation and measurement in their own
campaigns, the focus of the discussion was primarily on the role of the
outcomes measurement phase. There was also a brief discussion of
outputs measurement. This discussion was not as in-depth as it may have
been with a panel of evaluation experts. The practitioner perspective,
however, yielded some valuable insight to the process.
The panelists agreed that evaluation is an essential element of any
public education campaign. In fact, panelists believed that evaluation
is a "must do" even with limited resources. Panelists suggested that,
with limited resources, a government outreach campaign must work with
stakeholders that also have a vested interest in the issue, in order to
leverage both the work and funding. One panelist noted that, in the
case of the DTV transition, there are "two giants with a vested
interest--the media and the consumer electronics industry." The
panelist suggested that the federal government coordinate its efforts
with these and other interest groups to conduct most of the outcomes
evaluation. Furthermore, panelists stressed the importance of having a
clear understanding of the goals and objectives of the campaign when
designing the metrics that comprise the evaluation component. Once the
goals are clearly defined, planners can establish the necessary targets
to measure the effectiveness of a campaign.
Panel Selection and Representation:
In selecting the panelists, at the institutional level, we sought to
represent a broad spectrum of relevant expertise, including people from
private sector communications firms; special interest groups with
relevant experience in reaching out to special needs populations;
government agencies with relevant experience in communicating one-time
messages or information requiring a behavior change; academic experts
in marketing or social marketing; and relevant nonprofit organizations.
At the individual level, selection of the panelists was based on the
following criteria:
* relevant experience in comparable outreach campaigns, either based on
experience in communicating comparable messages or experiences in
communicating to comparable populations;
* Vice President or Senior Vice President level or above; if not
applicable, individuals who have led relevant outreach campaigns;
* recognized as an expert by peers;
* recommended as an expert by peers;
* several years of experience in the professional/academic field; and:
* based in or around Washington, D.C. (because we are unable to pay any
costs for participation, including travel costs).
* The following organizations were represented on the expert panel:
* Strategic communications firms: APCO Worldwide; Edelman Worldwide;
Fleishman-Hillard; GolinHarris; Issue Dynamics, Inc; Ogilvy; and Porter
Novelli;
* Academic institutions/nonprofits/associations: AARP; Academy for
Educational Development; American Legacy Foundation; Population
Services International; University of Virginia, Darden School of
Business; and:
* Government agencies: Swedish Government; U.S. Department of
Agriculture, Food and Nutrition Service.
[End of section]
Appendix III: Federal Communications Commission Response:
Federal Communications Commission:
Washington:
Office Of The Chairman:
Mr. Mark L. Goldstein, Director:
Physical Infrastructure Issues:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Goldstein:
I have reviewed the Draft Report relating to the Digital Television
Transition and take seriously the findings and recommendations included
therein. I have significant reservations and concerns with the reports
approach and conclusions.
On October 29, 2007, I met with you and presented the Federal
Communications Commission's (the FCC or Commission) written response to
the Draft Report.
The Commission objects to the GAO's refusal to include an unedited copy
of the Commission's written comments when it publishes its final
report. Government Auditing Standards require the GAO to "include in
their report a copy of the officials' written comments." See U.S.
Government Accountability Office, Government Auditing Standards at
section 8.33 (Jan. 2007) ("Government A Auditing Standards" or "Yellow
Book"). In addition, the GAO's published procedures for conducting its
work with Federal agencies require the GAO to include an agency's
written comments in the final report. Specifically, the GAO's Agency
Protocols states that lain agency's electronic or hard-copy written
comments are typically reproduced in an appendix to the issued report."
U.S. Government Accountability Office, Agency Protocols at 22 (Oct.
2004) ("Agency Protocols"). We have even offered to pay for the
inclusion and publication of our response.
The purpose for the requirement to publish an agency's written comments
is clearly stated in the GAO's Government Auditing Standards:
"Including the views of responsible officials results in a report that
presents not only the auditors' findings, conclusions, and
recommendations, but also the perspectives of the responsible officials
of the audited entity and the corrective actions they plan to take."
Government Auditing Standards at section 8.32. By failing to reproduce
the Commission's written comments in an appendix, the GAO's final
report will be denying the Commission an important avenue for
expressing its view of the GAO's report.
Over the course of the past year, the Commission has committed
extensive resources to working with the GAO on this and other matters.
We estimate that the Commission has devoted more than 6,100 staff hours
responding to the GAO's requests and has provided more than 13,650
documents to the GAO. We estimate that American taxpayers have paid
more than $500,000 for the Commission to respond to these requests. In
light of the costs incurred to respond to the GAO's requests, as well
as the GAO's standards cited above, the GAO should publish the agency's
unedited written comments in its final report.
Finally, we note that, should the GAO continue to refuse to publish the
Commission's written comments, Government Auditing Standards require
the GAO to modify its published statements that it performed its
engagement in compliance with Government Auditing Standards.
Specifically, the GAO's Yellow Book states that "[w]hen auditors do not
comply with all applicable [government auditing] requirements, they
should include a modified [government auditing] compliance statement in
the audit report." See Government Auditing Standards at section 8.31.
The GAO should inform readers of this report that it did not comply
with all applicable Government Auditing Standards in this instance.
Sincerely,
Signed by:
Kevin J. Martin:
[End of section]
Appendix IV: Comments from the Department of Commerce:
The Secretary Of Commerce:
Washington, D.C. 20230:
October 15, 2007:
Mr. David M. Walker:
Comptroller General:
Government Accountability Office:
441 G Street, N.W.:
Washington, DC 20548:
Dear Mr. Walker:
Thank you for the opportunity to comment on the Government
Accountability Office's Report entitled, "Digital Television
Transition: Increased Federal Planning and Risk Management Could
Further Facilitate the DTV Transition," GAO-08-43. With a successful
digital transition American consumers will continue to have access to
free, over-the-air television. Completion of the transition by 2009
will make valuable spectrum available for more broadband and public
safety services. The Department of Commerce (DOC) is committed to the
success of this transition through its role in the Digital-to-Analog
Converter Box Coupon Program.
One of the risks you identify in the report is the voluntary nature of
the participation of industry in the Coupon Program, and more
particularly, in educating the American public about the digital
transition. While the DOC certainly understands this risk, the solution
is not the establishment of a digital transition czar or single,
government-mandated message. The broadcasting, consumer electronics,
cable, and satellite television industries and consumer advocates have
as much incentive and as important a role in the education of consumers
as any government agency does. There are a variety of ways that a
consumer can achieve a digital transition, and thus, each of these
industries will use a different message to ensure that consumers
understand all of these choices. A multiplicity of messages and sources
of information is critical to a well- informed consuming public. The
stakeholders in the transition are in the forefront of the education
effort through their individual commitments as well as collaborations
like the Digital TV Transition Coalition.
The Department's National Telecommunications and Information
Administration (NTIA) has made significant progress in implementing the
Coupon Program, much of which is due to the close collaboration of
these stakeholders. In addition to issuing final program rules with
significant input from industry and consumer advocates, NTIA has
awarded a program administration contract to IBM and its partners and
has already certified a number of converter boxes with more to be
expected as testing continues. The consumer electronics retailing
community has also begun making important commitments. At the
Department's recent Digital Television Expo, Radio Shack announced that
its 4,400 stores will participate in the Coupon Program and engage in a
consumer education effort.
NTIA's own efforts will largely be directed at educating the public
about the availability of coupons to assist with the purchase of
converter boxes, if needed. A key component of the recently awarded IBM
contract is the development of a consumer education campaign. NTIA is
paying particular attention to people who rely on over-the-air
television to ensure that they are aware of the end of analog
broadcasting and are prepared to adapt to the required changes. NTIA
has identified five target groups for its consumer education efforts
because these groups use over-the-air television more than the general
population: (1) seniors and older Americans; (2) the economically
disadvantaged; (3) rural residents; (4) people with disabilities; and
(5) minorities. For maximum impact, NTIA is leveraging its effort by
partnering with a diverse range of stakeholders that also serve these
target groups, including over 145 organizations and federal government
agencies and departments. By way of example, on October 3, 2007, the
Family, Career and Community Leaders of America (FCCLA) announced a
partnership with Best Buy to engage FCCLA's 220,000 student volunteers
in 7,000 communities to educate consumers about the Coupon Program.
These are the kinds of diverse public-private partnerships that we
expect to proliferate throughout the transition.
Again, thank you for the opportunity to share the DOC comments on the
GAO Report. The DOC remains committed to a smooth and seamless
transition for consumers to digital broadcasting through the successful
implementation of the Coupon Program.
Signed by:
Carlos M. Gutierrez:
[End of section]
Appendix V: 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; Matthew Cail; Colin
Fallon; Simon Galed; Bert Japikse; Crystal Jones; Joshua Ormond; Andrew
Stavisky; and Margaret Vo.
[End of section]
Related GAO Products:
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] 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] The Congressional Budget Office estimated auction proceeds from the
spectrum currently used by broadcasters has an expected value of $12.5
billion.
[3] These sets, which only have a National Television Systems Committee
(NTSC) tuner, are only capable of receiving and displaying analog
signals.
[4] Such a television would include an Advanced Television Systems
Committee (ATSC) tuner.
[5] Pub. L. No. 109-171, title 3.
[6] 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], [hyperlink,
http://www.dtv.gov], and [hyperlink,
http://www.ntia.doc.gov/dtvcoupon].
[7] NTIA established technical and performance specifications that
converter boxes must meet to be eligible for the subsidy program.
[8] These residents may have to provide additional information to
identify the physical location of the household.
[9] There is up to $510 million in additional funds, bringing total
possible program funding to $1.5 billion, which includes up to $1.34
billion in coupon funds, and up to $160 million in administrative
funds.
[10] Assuming the full administrative amounts are used for
administrative expenses, with none of that amount going toward coupons.
[11] TNIA entered into a memorandum of understanding with FCC
establishing that FCC will test converter box samples at NTIA's
direction.
[12] Digital tuners decode the digital signal and turn it into the
picture that appears on the television screen.
[13] GAO, Telecommunications: Additional Federal Efforts Could Help
Advance Digital Television Transition, GAO-03-7 (Washington D.C.: Nov.
8, 2002).
[14] FCC has not yet adopted general rules mandating low-power
television to transition to digital broadcasting by February 17, 2009,
or how these stations will operate thereafter. There are also more than
2,300 licensed low-power television stations operating throughout the
United States.
[15] Federal agencies faced the potential for critical computer system
failures at the turn of the century due to incorrect information
processing relating to dates. Possible disruptions of Y2K included
delayed financial transactions, grounded flights, and lost power.
[16] GAO, Y2K Computing Challenge: Day One Planning and Operations
Guide, GAO/AIMD-10.1.22 (Washington, D.C.: October 1999).
[17] GAO, 2010 Census: Preparations for the 2010 Census Underway, but
Continued Oversight and Risk Management Are Critical, GAO-07-1106T
(Washington D.C.: July 17, 2007).
[18] GAO, Strategic Budgeting: Risk Management Principles Can Help DHS
Allocate Resources To Highest Priorities, GAO-05-824T (Washington D.C.:
June 29, 2005).
[19] These suggestions were in the form of a letter sent to FCC and
signed by various congressional representatives.
[20] 1-888-DTV-2009.
[21] 1-877-530-2634.
[22] 1-866-495-1161.
[23] 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).
[24] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, GAO-06-15
(Washington, D.C.: Oct. 21, 2005).
[25] For performance-based contacts, the Federal Acquisition Regulation
allows contactors to develop performance measures.
[26] GAO, Contract Management: Guidance Needed for Using Performance-
Based Service Contracting, GAO 02-1049 (Washington D.C.: Sept. 23,
2002).
[27] GAO, Defense Acquisitions: Tailored Approach Needed to Improve
Service Acquisition Outcomes, GAO 07-20 (Washington D.C.: Nov. 9, 2006)
and Contract Management: Opportunities to Improve Surveillance on
Department of Defense Service Contracts, GAO 05-274 (Washington D.C.:
Mar. 17, 2005).
[28] 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).
[29] The entire testing period runs from August 16, 2007, to March 31,
2008. It is possible that the contractor could move out of the start-up
phase before March 31, 2008. April 1, 2008, is the date by which the
coupon operational period must begin; thus, March 31, 2008, is the
latest possible end date for the testing period.
[30] Retailers we contacted noted that demand for the converter boxes
would likely peak just before the transition and rapidly fall
afterward.
[31] For additional information on how logic models are used in a
public outreach campaign, see GAO, Program Evaluation: Strategies for
Assessing How Information Dissemination Contributes to Agency Goals,
GAO-02-923 (Washington D.C. Sept. 30, 2002).
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