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entitled 'Digital Television Transition: Increased Federal Planning and 
Risk Management Could Further Facilitate the DTV Transition' which was 
released on December 11, 2007. 

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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 
consumersí 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 programís 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 retailersí 
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 Nationís 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 Commissionís 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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