**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

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| In the Matter of                 | * | MB Docket No. 07-148         |
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| DTV Consumer Education           | ) | (FCC 07-128)                 |
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**Comments of the**

**Federal Communications Commission's**

**CONSUMER ADVISORY COMMITTEE**

# Table of Contents

I.  INTRODUCTION 3

II. THE CHALLENGE BEFORE THE NATION IS DAUNTING 7

    A.  Most Americans Have Not Made the 7 Transition to Digital TV
        Technology

    B.  People With Disabilities Face Extra Hurdles 8

    C.  At-Risk Consumers Are Also Hardest to Reach 9

    D.  Americans Remain Unaware of the Transition 10 to Digital
        Television

III. THE COMMISSION MUST ADOPT THE LEADERSHIP 13 POSITION IN THE DTV
     EDUCATIONAL CAMPAIGN

     A.  The DTV Campaign Must Be Televised 15

     B.  Electronically Filed Reports Will Help Track Delivery 20

> of the DTV Education Message and Broadcasters Public Service

C.  MVPDs Have a Role in the DTV Education 21 Campaign and Their
    Consumers Must Not Be Harmed by the DTV Transition

D.  Electronics Manufacturers Have a Role in the 23 DTV Education
    Campaign and Electronics Consumers Must Not Be Harmed by DTV
    Transition by Manufacturer Information

E.  Electronics Retailers Have a Role in the DTV 24 Education Campaign
    and Electronics Consumers Must Not Be Harmed by DTV Transition by
    Retail Information

F.  DTV.gov Partners Have a Special Responsibility 26 to Educate DTV
    Consumers

G.  The Commission Must Do Everything in its Capacity 28

H.  The Commission Should Ensure Coordinated 30 Efforts to Resolve
    Technical Problems Associated with Closed Captioning so that
    Consumers with Hearing Loss are Not Harmed by the DTV Transition

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IV. CONCLUSION 32

# APPENDIX A: DATA ON DTV TECHNOLOGY PENETRATION 

# I. INTRODUCTION

Pursuant to the Notice of Proposed Rulemaking ("NPRM") adopted by the
Commission on July 21, 2007 seeking comments on several proposals
relating to consumer education about the digital television ("DTV")
transition, the Federal Communications Commission's Consumer Advisory
Committee ("CAC") hereby submits these comments.

On June 8, 2007, the Commission announced the re-chartering and
appointment of members of its Consumer Advisory Committee, a federal
advisory committee that addresses consumer issues within the
jurisdiction of the Commission.[^1] The CAC is organized under, and
operates in accordance with, the provisions of the Federal Advisory
Committee Act.[^2] The comments below reflect the recommendations of a
majority of CAC members.[^3] Many CAC member organizations may file
separate comments in this proceeding which may not be in complete
agreement with this filing. One CAC member, for example, has already
sent the Commission and the CAC a letter outlining the organization's
voluntary DTV transition education efforts.[^4]

The principal current focus of the CAC is the digital television
transition as the Commission continues its efforts to assist consumers
in understanding and preparing for the transition which, by law, must be
completed by February 17, 2009. Through its work, the CAC provides
valuable insights that should further the Commission's goal of ensuring
that all consumers, especially the elderly, low-income, non-English
speaking consumers and people with disabilities, are aware of the
transition and understand what specific steps, if any, they must take to
continue to be able to watch television after the DTV transition is
complete. The CAC is charged with providing the Commission with specific
recommendations on how the Commission can best ensure a smooth
transition. CAC concerns include consumer protection, education,
inclusion and involvement; access by people with disabilities; and the
impact of new and emerging technologies on consumers.

In this NPRM, the Commission seeks comment on whether there are
additional steps which the Commission can and should take to make
consumers aware of the hard deadline of February 17, 2009 for the end of
full-power analog broadcasting. Specifically, the Commission is
responding to a letter from Congressional leaders[^5] asking if the
Commission should adopt rules requiring A) television broadcasters to
air public service announcements, B) broadcast licensees to report their
consumer education efforts, C) multichannel video programming
distributors (MVPDs) to insert periodic notices in customer bills that
inform consumers about the digital television transition and future
viewing options, D) manufacturers to include information about the
transition with television receivers and related devices, E) retailers
who participate in the converter box coupon program to detail their
employee training and consumer information plans, F) partners identified
on the Commission's digital television Web site to report their specific
consumer outreach efforts, and G) additional proposals mentioned in the
Letter including broadcaster public file requirements or other public
announcements, notice requirements by telecommunications carriers that
receive funds under the Low Income Federal universal service program, or
reporting requirements by 700 MHz auction winners.

For each proposal, the FCC asks for comments concerning: 1) the
Commission's authority to implement the proposal; 2) the likely
effectiveness of the proposal (i.e., whether it would appreciably
increase public awareness and understanding of the DTV transition); 3)
the best methods of implementation; 4) the policy implications; and 5)
constitutional concerns.

In reports to Congress,[^6] the Commission has outlined a three-prong
effort to advance the DTV transition and promote consumer awareness: 1)
get the right rules in place to facilitate a smooth transition, 2)
enforce those rules to protect consumers, and 3) promote awareness of
the transition through consumer education and outreach efforts.

In the comments that follow, the CAC recommends that these three prongs
not function as silos, but as interrelated efforts. Consumers must be
made aware of more than the February 2009 deadline and the options
available to them to continue television viewing: consumers must also be
aware that the "right rules" are in place so that they will not be
harmed by the DTV transition. Moreover, outreach and educational efforts
must be interactive; consumers know best how television serves their
needs and the Commission should be listening to consumers now to ensure
that the "right rules" are in place to ensure America's television
broadcasting system is at least as vibrant as it is before the
transition, hopefully, more so. And, as with all regulation, the "right
rules" are meaningless if not properly enforced. The Commission must
remain vigilant in enforcing rules so that consumers are aware of their
rights and protected from unscrupulous vendors, access by people with
disabilities is ensured, and the transition has a positive impact on
consumers.

**II. THE CHALLENGE BEFORE THE NATION IS DAUNTING**

Never in the history of American broadcasting have we faced such a
monumental task. Television has never played a more important role in
our lives. It is our primary source of news and entertainment[^7] and
emergency alerts.[^8] But digital television signals are not compatible
with analog TV sets in most American homes. These sets will go dark on
February 18, 2009. In order for the DTV transition to be successful,
consumers must be well-informed and primed to adapt successfully to the
new technology. This cannot occur unless there is a comprehensive,
coordinated and robust national consumer outreach effort.

**A. Most American Have Not Made The Transition To Digital TV
Technology**

The vast majority of US consumers have not yet made the transition to
digital TV technology. By January 1, 2008, Nielsen estimates there will
be 112.8 million TV households in the US.[^9] By the end of 2007,
perhaps just over one-third of these households may have a digital
television.[^10] Moreover, there are concerns that even today's cable TV
subscribers are at some risk of losing broadcast TV service on one or
all of their televisions at the end of the DTV transition.[^11]

Bruce Leichtman, president and principal analyst for Leichtman Research
Group, Inc., said \"***With the digital transition now less than two
years away, much work clearly still needs to be done to prevent millions
of TV sets from going dark in February 2009***.\" \[emphasis added\]

**B. People With Disabilities Face Extra Hurdles**

Even for those consumers who have made the switch to digital TV
technology, the transition still may leave them in the dark. In June
2007, the Commission issued a Consumer Advisory[^12] noting its concerns
that consumers may experience difficulty in receiving and/or viewing
closed captioning on some digital television programming, including
HDTV, provided by a programming distributor such as a cable company or a
satellite television provider. In fact, numerous problems already have
been documented, including overlapping captions (two lines of captions
displayed over each other), captions appearing in the middle of the
television screen (blocking faces and other important information on the
screen), garbled captions, captions running off the edge of the picture,
captions exceedingly small, and captions that inadvertently switch to
text mode which causes 95% of the screen image to be obscured. These
failures have their roots in any of a dozen possible technical causes
and there is no way for consumers to be able to track down these
problems. Technical failures associated with accessing and reading
captions may stem from problems with local broadcast station signals,
local cable provider transmissions, broadcast and cable network
transmissions, maladjustment of consumer equipment that is purchased or
leased from cable or satellite companies, satellite transmission
signals, and/or improper encoding and transmission by caption providers.
Finally, new interfaces on digital televisions have made accessing and
activating captions difficult, and sometimes impossible for consumers,
with consumers finding themselves in the predicament of having to wade
through several menu layers in order to access closed captioning
controls. This has become particularly frustrating for consumers
attempting to use digital televisions in hotels or hospitals, and at
homes of family and friends where they are not accustomed to the
television set-up. Similarly, problems accessing video descriptions have
also been experienced. For example, it is not clear that set top boxes
or other digital video equipment are capable of receiving, displaying
and passing through video description because there has been
insufficient material available for testing.

**C. At-Risk Consumers Are Also Hardest To Reach**

The consumers most at risk of losing TV service after the transition are
the most vulnerable in our communities and the hardest to reach. In
2005, the Government Accountability Office (GAO) found that 21 million
homes --- nearly one in five of all television-equipped households ---
rely on free, over-the-air broadcasts.[^13] Of these households, almost
half have annual incomes of less than \$30,000, and two-thirds are
headed by either an individual over age 50[^14] or a native Spanish
speaker.

**D. Americans Remain Unaware Of The Transition To Digital Television**

Most Americans remain unaware of the DTV transition. On January 31,
2007, APTS released survey results finding that the majority of U.S.
households that receive their television signals over the air are still
unaware of the digital TV transition even though an estimated 22 million
over-the-air homes need to make some kind of digital decision by
February 17, 2009.[^15] The bulk of the survey participants---61
percent---had no idea that the DTV transition was taking place. Ten
percent said they had limited awareness, while 25 percent said they were
somewhat aware or very aware. While some respondents were aware of the
digital transition, 53 percent had no idea when analog transmissions
were scheduled to be turned off. Moreover, roughly 45 percent of
respondents to APTS' survey said they will either "do nothing" or "don't
know" what option they will take to obtain digital signals. Nineteen
percent will purchase a converter box, 17 percent are likely to sign up
for cable TV service, and 9 percent will sign up for satellite TV.
Another 9 percent indicated they would buy a digital television set so
that they can continue to receive over-the-air broadcasts.

Many American households must be motivated to act so that they do not
lose TV service after the transition. In June 2007, APTS released
additional findings that, if left to their own devices, the 22 million
American households that rely upon free, over-the-air television will
move slowly to adopt digital TV sets or subscribe to cable or satellite
services:

-   Only 7% of over-the-air households own a digital television set,
    compared to 23% who subscribe to cable or satellite. Therefore, few
    of these households are now equipped to obtain digital TV
    programming on an over-the-air basis and will be slow in making the
    change to television sets capable of receiving digital signals

-   Over-the-air households have resisted subscription campaigns by
    cable and satellite companies. The population of over-the-air
    households has remained virtually unchanged since 2004 at 22.6
    million, compared with 22.5 million in the first quarter of 2007.

-   In the past three years, over-the-air households purchased new TV
    sets at about a 12 percent to 13 percent rate each year. In
    comparison, cable and satellite homes bought new TV sets at an 18
    percent rate per year.[^16] Therefore, retail point-of-sale efforts
    to educate these households about the February 2009 digital
    transition are likely to have limited impact, given that
    over-the-air viewers lag in their purchases of TV sets in general,
    and buying digital sets in particular.

APTS President and CEO John Lawson said, "***We need a Y2K-level
effort*** to ensure that people are aware that their older TV sets will
go dark in 21 months if they don't acquire a digital converter, buy a
new set or incur the monthly cost of a cable or satellite bill. ***They
also need to know that digital over-the-air television will continue to
be free, will offer them many more channels and will give them a better
picture even on an older set---if they get a converter box.***"
\[emphasis added\]

**III. THE COMMISSION MUST ADOPT THE LEADERSHIP POSITION IN THE DTV
EDUCATIONAL CAMPAIGN**

The success of the DTV transition is dependent upon widespread consumer
understanding of the benefits and mechanics of the transition. The
Congressional decision to establish a hard deadline of February 17, 2009
for the end of full-power analog broadcasting has made consumer
awareness even more critical. The Commission, as recognized in the NPRM,
should take whatever steps it can to promote a comprehensive,
coordinated, effective, national consumer education campaign that
includes both information about the transition taking place and steps to
ensure that people with disabilities will not lose access once the
transition occurs.

Recognizing that the Commission mandated the transition to DTV
broadcasting, it is the Commission's responsibility to take the lead in
ensuring that consumers across the country are aware of the transition
and, in the case of people with disabilities, do not lose the captioning
access to which they have become accustomed after it occurs. In their
letter, Chairmen Dingell and Markey noted that the Commission is the
lead agency for the DTV transition and consumer education, and as such,
has important responsibilities.[^17] The Commission has been considering
the matter of advanced television systems and their impact upon the
existing television broadcast service since 1987[^18] and for 20 years
has been considering and adopting rules changes to make the DTV
transition possible.[^19] Only since last year has the NTIA been given a
formal role in the transition.[^20] Moreover, the NTIA does not have the
authority needed to adopt enforceable rules as part of a coordinated,
national DTV consumer education campaign.

CAC recommends that the Commission use as a model its efforts leading up
to January 1, 2000 when, it was feared, many computers would malfunction
("Y2K"). The Commission should immediately appoint one or more
commissioners to lead the DTV education effort in coordination with the
Consumer and Governmental Affairs Bureau. The commissioners and staff
should make as many public appearances, including media appearances such
as daytime talk shows, as practical to discuss the DTV transition.

The Commission's plan should: 1) identify the households most likely to
be at risk of losing TV service; 2) concentrate and leverage its limited
resources on reaching these households; 3) work with partners on
crafting and disseminating the right message to motivate these
households to take necessary action to ensure continued television
service; and 4) ensure that consumers are not harmed by the transition.

The Commission should collect data immediately that reveals the
demographics of these at-risk groups. This data collection should be
ongoing so the FCC and NTIA know who is being reached and who's already
taken steps to make the transition. With that data, the Commission can
then ascertain the special communication needs of these groups.

In his letter to Chairmen Dingell and Markey, Chairman Martin indicated
that the Commission will "consider surveying consumers about their
awareness of and the steps they must take to prepare for the transition"
if the Commission's fiscal year 2008 budget request is approved by
Congress. The CAC recommends that the Commission commit to ongoing data
collection and to immediately reach out to industry players and others
to see if the data already exists and can be shared. If not, the
Commission should request the Census Bureau of the Department of
Commerce to collect this data. The Commission should be an active
participant in writing the Bureau's questions.

The CAC recommends that the Commission's education plan include the
following components at a minimum:

**A. THE DTV EDUCATION CAMPAIGN MUST BE TELEVISED**

The DTV education campaign must reach households that currently rely on
the over-the-air signals of full-power television stations. This is the
group most at-risk of losing television service in February 2009.[^21]
In addition, the Commission should act quickly to determine how analog
cable subscribers who do not rent or own set-top boxes will be impacted
by the DTV transition. Are they also at risk of losing their access to
broadcast TV channels after the transition? The CAC asks that the
Commission coordinate a finding that includes broadcasters, cable
operators, consumer electronics manufacturers and retailers for a
definitive answer on this question.

Obviously, the one thing all at-risk groups will have in common is their
current use of television. To reach these groups, the DTV education
campaign must be primarily conducted through TV. The Commission is
proposing requiring television licensees to conduct on-air consumer
education efforts through public service announcements ("PSAs"). The CAC
endorses this proposal.

The need for the requirement of PSAs goes to the competing business
interests of broadcasters. Granted, television stations need viewers to
make the transition to DTV so that they can retain the audiences they
sell to advertisers. This is a great motivator for broadcasters to reach
out to every household to ensure all viewers make the transition. Many
stations are likely to air PSAs to make sure consumers are aware of the
transition. However, during much of the time when this message is to be
delivered -- 2008 -- the nation will be in the midst of federal
elections including a presidential election. Television ad inventory
will be at a premium. [^22] Some broadcasters may not voluntarily make
enough free PSA time available to reach the desired audience when
candidates and other advertisers are trying to buy that time. Moreover,
even where PSAs are shown voluntarily, there is a good chance they will
not be shown with captions.[^23] Additionally, some of the consumers
most at risk of losing television service may not be a desirable
demographic for advertisers.

The CAC recommends that the Commission require each broadcast television
licensee and encourage each radio licensee to air PSAs about the
transition, consumers' future viewing options, and the NTIA
digital-to-analog converter box discount program. The Commission should
then require quarterly, electronic reporting from each station so the
on-air efforts can be monitored. The Commission should require that
stations certify that they are complying with the PSA requirement and
inform stations that the failure to comply with the PSA requirement
and/or certification may result in the maximum civil penalties permitted
by law.

Moreover, broadcasters should be encouraged to air programming -- either
within local newscasts or separate full-length programs -- that
describes the transition, the benefits, consumer options, and
demonstrate converter boxes.

The CAC recommends that the Commission establish minimum PSA
requirements. The CAC does not make a recommendation about how many PSAs
each licensee should be required to air. However, as a reference point,
CAC notes that in 1998, when contemplating minimum public interest for
all digital TV broadcasters, a broadcaster and member of the
Presidential Advisory Committee on the Public Interest Obligations of
Digital Television recommended, in the Advisory Committee's final
report, that, at a minimum, television broadcasters be required to air
110 to 150 PSAs per week distributed throughout the broadcast day.[^24]

CAC recommends that the Commission tie the PSA requirement to
programming ratings. DTV-related PSAs should be run during a
broadcasters' highest-rated shows and the shows with the highest ratings
for at-risk communities including households with annual incomes of less
than \$30,000 and are headed by either an individual over age 50 or
native Spanish speakers.

PSAs should not confuse consumers. Industry groups are devoting
substantial resources to crafting the messages for DTV PSAs. The FCC
should be part of this process and ensure that the messages accurately
convey that digital over-the-air television will continue to be free,
will offer consumers many more channels and will give them a better
picture even on an older set---if they get a converter box. PSAs should
also convey consumer options -- including the least expensive path to
receiving DTV signals. PSAs should be shown to focus groups to ensure
they make sense to the people who must invest in new digital television
technology.

PSAs must be accessible for many different groups. As appropriate, PSAs
should be in Spanish and Asian languages. The FCC should mandate that
these PSAs be captioned, preferably with open captions, whether for
broadcast, cable, satellite or on the Internet. Information presented
visually in text should be conveyed audibly. The Commission should
encourage and consider producing educational videos in American Sign
Language that are accessible on the Internet. They should also include
toll free numbers in appropriate languages to call for more information
and the numbers should be displayed both visually and audibly. Call
center staff responding to calls must be trained to honor their legal
obligation to receive and respond to phone calls that come into the
center via specialized equipment and telecommunications relay services
(TRS) from persons with hearing and speech disabilities. Voice menu
systems, which are difficult for people with hearing loss to navigate,
should be avoided.

The Commission has the authority to require these PSAs. Congress enacted
the Communications Act of 1934 for the purpose, in part, of \"regulating
interstate and foreign commerce in communication by wire and radio so as
to make available, so far as possible, to all the people of the United
States ... a rapid, efficient, Nation-wide, and world-wide wire and
radio communication service with adequate facilities at reasonable
charges, for the purpose of the national defense, \[and\] for the
purpose of promoting safety of life and property through the use of wire
and radio communication\...\"[^25] Under the Act the Commission \"from
time to time, as public convenience, interest, or necessity requires
shall\" \"make such regulations not inconsistent with law as it may deem
necessary to prevent interference between stations and to carry out the
provisions of \[the\] Act\"[^26] and \"(m)ake such rules and regulations
and prescribe such restrictions and conditions, not inconsistent with
law, as may be necessary to carry out the provisions of this Act.\"[^27]
The Commission already makes similar requirements of broadcasters.[^28]

The extraordinary circumstances of the DTV transition demand this
measure by the Commission. Moreover, the requirement will come with a
sunset. Although PSAs will need to be run frequently through 2008 and
early 2009, the need for the PSAs should end by March 31, 2009 at the
latest.

**B. ELECTRONICLLY FILED REPORTS WILL HELP TRACK DELIVERY OF THE DTV
EDUCATION MESSAGE AND BROADCASTERS' PUBLIC SERVICE**

As noted above, the Commission should require television broadcasters to
file quarterly, electronic reports on their consumer education efforts,
including the time, frequency, and content of public service
announcements aired. The Commission should make these reports available
via a centralized, searchable database on FCC website.

For some time now, the Commission has been working both on its own and
in cooperation with industry, other government agencies, and consumer
groups to advance the transition and promote consumer awareness.
Obviously, these various efforts and others will continue through the
early months of 2009. To best coordinate these efforts and provide easy
access to information for new efforts, the Commission should act as an
information hub for the DTV education campaign. Part of this role should
be to provide, for all these working parts, information about where,
when and how the message of the DTV transition is being delivered to
communities throughout the country. The best way to do this is through
disclosure of television broadcasters' efforts in a centralized
database. By making the reporting a requirement and enforcing the rule,
the Commission would ensure that all stations contributed to the
database.

The Commission should require these filings beginning January 2, 2008,
and continue through May 1, 2009. The data, in turn, should be analyzed
and used in frequent reports to Congress on the progress of the DTV
education plan.

**C.** **MVPDs HAVE A ROLE IN THE DTV EDUCATION CAMPAIGN AND THEIR
CONSUMERS MUST NOT BE HARMED BY THE DTV TRANSITION**

The Commission seeks comments on whether multichannel video programming
distributors (MVPDs) should be required to include in customer bills
information about the digital television transition and consumers'
future viewing options. Such inserts would be an optimal way to reach
consumers that value television service. And, for those consumers, the
inserts would augment information likely first gained through
broadcasted PSAs.

CAC recommends that the Commission require MVPDs to educate their
customers about the effect of the DTV transition on their TV service.
MVPDs should consider a range of options to fulfill this responsibility,
including things such as bill inserts, emails, PSAs, special information
channel, statement messages, individual mailings, website messages, etc.
For printed material, when requested to do so, MVPDs should make DTV
transition information available in alternative formats to individuals
who are blind or low vision. The Commission should also require
quarterly reporting from each MVPD so their efforts can be monitored.

Both the Commission and MVPDs must keep in mind that there could be some
consumer confusion even with the most carefully crafted PSA campaign.
MVPD consumers must receive reliable information about how the
transition will affect them. MVPDs must be a reliable source of that
information and not exploit the opportunity to sell consumers equipment
or services they may not need. MVPD subscribers should be made aware if
they will be required to rent a set-top box or buy a digital-to-analog
converter box to continue viewing broadcast TV channels after the
transition. If the latter, consumers should be made aware of how the
converter box will work with their MVPD hook-up. If MVPDs include
inserts about the transition and future viewing options with bills,
consumer protections should be in place to ensure that these consumers
know their full range of options, including the least expensive ones.
Toll free numbers to call centers should also be noted on the bill
inserts and notices.

CAC recommends that these call centers should be staffed with
multilingual operators appropriate to the communities served by the
MVPD. Toll free numbers to call centers should be set up for the
explicit purpose of responding to consumer calls on this matter, and the
numbers of those centers should be noted on the bill inserts and
notices. Again, such call centers should be familiar with and prepared
to receive and respond to calls made via specialized equipment used by
people with hearing and speech disabilities and through TRS.

**D. ELECTRONICS MANUFACTURERS HAVE A ROLE IN THE DTV EDUCATION CAMPAIGN
AND ELECTRONICS CONSUMERS MUST NOT BE HARMED BY DTV TRANSITION BY
MANUFACTURER INFORMATION**

The Commission seeks comments on whether consumer electronics
manufacturers should be required to provide information about the
digital television transition to consumers. Information on the
transition should accompany other printed information normally provided
the consumer when a television set is purchases. Ideally, such
information should be standardized with input from the Commission. Toll
free numbers to call centers should be provided on this information, and
the call centers prepared to receive and respond to calls made via
specialized equipment used by people with hearing and speech
disabilities and through TRS.

Similar to the concerns raised in section C above, the Commission should
adopt and enforce rules that ensure consumers get the correct
information concerning their future viewing options, the
digital-to-analog converter box coupon program and DTV technology
compatibility with existing technology including VCRs, DVRs, and DVDs.
Consumers should always be made aware of their least expensive migration
paths to DTV.

**E. ELECTRONICS RETAILERS HAVE A ROLE IN THE DTV EDUCATION CAMPAIGN AND
ELECTRONICS CONSUMERS MUST NOT BE HARMED BY DTV TRANSITION BY RETAIL
INFORMATION**

The Commission seeks comments on whether the NTIA and Commission should
require retailers who participate in the converter box coupon program to
detail their employee training and consumer information plans. Moreover,
the Commission asks if it should have Commission staff conduct spot
inspections.

Ideally, the FCC should help create standardized messages that would be
used in such trainings and consumer information plans. Point of sale
information should be provided in the retail outlets in the main
languages spoken in the communities served by these retailers, as well
as in alternative formats for individuals who are blind or low vision.
Toll free numbers to a call center where the consumer could obtain more
information should be provided. The call center should be staffed by
representatives who speak the languages used in the point of sale
information. Such call center staff must be trained to accept, receive,
and respond to phone calls that come into the center through specialized
equipment or via the nation\'s telecommunications relay service system
from persons with hearing disabilities and persons with speech
disabilities who use relay services. If possible, such point of sale
information should be provided by all electronics retailers. Ideally,
information on the DTV transition should also be included in newspaper
ads, etc. placed by these retailers.

Consumer Electronics Retailer Training and Education should include
information on the ability of individual converter boxes to correctly
pass through captions and video description, and on-site demonstration
of any setup steps the converter box requires to display captioning and
video description. Consumers should be able to view captions and hear
video description on television models at the point of sale and test
captioning and video description features.

The training should also include an easy return policy, without
penalties, for DTV converter boxes and other television receiving and
display electronic equipment that do not work correctly and/or do not
display captioning or video description.

Commission enforcement should include visits to retailers to see what
kind of information is passed on to consumers by retail employees.

Similar to the concerns raised in sections C and D above, the Commission
should adopt and enforce rules that ensure consumers get the correct
information concerning their future viewing options, the
digital-to-analog converter box coupon program and DTV technology
compatibility with existing technology including VCRs, DVRs, and DVDs.
Consumers should always be made aware of their least expensive migration
paths to DTV.

**F. DTV.GOV PARTNERS HAVE A SPECIAL RESPONSIBILITY TO EDUCATE DTV
CONSUMERS**

The Commission seeks comments on whether it should require its 50+
DTV.gov partners to report their specific outreach efforts. For the
eight television station owners[^29] in the partnership, their on air
DTV education efforts should be reported as noted above in sections A
and B. For the broadcast-related organizations that are not licensed for
television broadcasting -- ABCNews Now, American Public Television
Stations, the Association for Maximum Service Television (MSTV), the
National Association of broadcasters, and the Public Broadcasting
Service -- they should be asked to report what their on air efforts are
or how they are encouraging their members to participate in on air
efforts.

For all the groups in the partnership, the Commission should remind
them, via Public Notice, that they have an important responsibility to
ensure that consumers get the correct information concerning their
future viewing options, the digital-to-analog converter box coupon
program and DTV technology compatibility with existing technology
including VCRs, DVRs, and DVDs. Consumers should always be made aware of
their least expensive migration paths to DTV.

The CAC also recommends that the Commission reach out and include
consumer groups in the partnership.

But reporting of outreach efforts may not be sufficient. The Commission
should encourage, if not require, that the partners coordinate their
efforts with each other and with government outreach and education. All
outreach and education should use standardized messages that are created
with the help of the Commission. Coordination will help insure that the
hard to reach are reached. Survey data should be used to target
populations and identify in what languages outreach is needed.

Outreach efforts should not rely only on the Internet. While information
provided on web sites and e-lists may be useful to some, other target
populations as those consumers have limited access to the Internet. To
reach all target population, any outreach plan must rely heavily on
community based organizations (CBOs) that serve these consumers. CBOs
will need materials provided for free, in bulk and in the different
languages spoken in the communities they serve. The Commission should
encourage and consider producing educational videos in American Sign
Language. Training materials for CBO staff will be needed in addition to
brochures for consumers. Such brochures must be available in accessible
formats for individuals who are blind. In addition, the CAC notes that
extensive advertisements will need to be placed in the ethnic media at
the national and local level.

**G. THE COMMISSION MUST DO EVERYTHING IN ITS CAPACITY**

The Commission seeks comments on additional education proposals
including broadcaster public file requirements, notice requirements by
telecommunications carriers that receive funds under the Low Income
Federal universal service program and 700 MHz auction winners. As noted
by Chairman Martin, the Commission must do everything in its statutory
and budgetary capacity to make sure that no American is left behind in
the transition to DTV.[^30] The NPRM invites comment on a number of
creative consumer educational mechanisms to move DTV education forward
and the Commission should consider all of them. Specifically:

-   **Broadcaster public file requirements**: CAC recommends quarterly,
    electronic filing above and included in a public station's public
    file and on the station's web site, if it has one.

-   **Lifeline/Link-up Notices**: CAC believes that there is great
    potential to reach a hard to reach at-risk community by encouraging
    notices from telecommunications carriers to their customers,
    especially their Lifeline and Linkup customers. In addition, the
    Commission should partner with the existing Federal programs to
    reach these households. The Commission has established as a baseline
    criteria for Lifeline/LinkUp eligibility participation in Medicaid,
    Food Stamps, Supplemental Security Income (SSI), Federal Public
    Housing Assistance (Section 8), Low-Income Home Energy Assistance
    Program (LIHEAP), Temporary Assistance to Needy Families (TANF) or
    the National School Lunch Programs Free Lunch Program.[^31] The
    Commission should work with these program administrators to
    distribute information about the DTV transition.

-   **700 MHz auction winners**: When 700MHz winners are determined,
    those entities will have a huge financial stake in analog TV
    spectrum being vacated for their use. The CAC recommends that, as
    part of the 700 MHz auction rules, the Commission require the
    winners to participate in the DTV education campaign and report on
    how they have aided the DTV education effort.

In addition, the Commission should consider other ways the Federal
government can lead this effort:

-   According to the Bureau of Labor Statistics, the federal government
    employs nearly 2 million civilians -- 5 out of every 6 work outside
    the Washington, DC area. The Commission should consider using the
    federal government, the nation's largest employer, to inform every
    federal employee about the transition -- perhaps through paycheck
    inserts. This program could be a model for voluntary programs by
    MVPDs, Lifeline/LinkUp providers and other billers noted in the
    NPRM. These employees could then share news of the transition to
    friends and family via word of mouth.

-   The Commission should seek additional Federal partners that have
    local contact points with citizens such as the United States Post
    Office and the Social Security Administration.

-   The Commission should consider producing, and working with industry
    partners to distribute to stations and MVPDs, its own American Sign
    Language and, captioned PSAs. Information presented visually in text
    should be conveyed audibly. In addition, the Commission should post
    these PSAs on Internet video sharing sites such as YouTube. The
    Commission should request money from Congress for a paid-for PSA
    campaign. Such payments are often needed for airing of PSAs in the
    ethnic media.

-   The Commission should encourage every government web site --
    including those of members of Congress -- to link to DTV education
    websites.

-   FCC commissioners and staff should make as many public appearances,
    including media appearances such as daytime talk shows, as practical
    to discuss the DTV transition.

-   The Commission should make frequent reports to Congress on the
    progress of the campaign and make these reports easily available to
    the public.

**H. THE COMMISSION SHOULD ENSURE COORDINATED EFFORTS TO RESOLVE
TECHNICAL PROBLEMS ASSOCIATED WITH CLOSED CAPTIONING SO THAT CONSUMERS
WITH HEARING LOSS ARE NOT HARMED BY THE DTV TRANSITION**

In order to ensure that consumers with disabilities are not harmed by
the transition, efforts at trouble-shooting the various causes
associated with captioning problems needs to occur. To this end, the
Commission should convene a working group that includes representatives
from the broadcasting, cable, and satellite industries, television and
set top box equipment manufacturers, MVPDs, captioning providers,
electronic retailers and captioning consumers. Such a group, which
should include top engineering personnel from the relevant industries
and the Commission, should be tasked with 1) identifying current and
anticipated problems with the transmission and display of captions over
digital programming, 2) evaluating and assessing their components,
systems, and set top boxes for compatibility with captioning services,
3) developing solutions to existing and potential problems in order to
ensure the capability to pass through closed captions intact to the
consumer. Captions provide the only means of access to television
programming for people with hearing loss; even the most comprehensive
efforts to educate this population about the digital transition will be
meaningless if, when the transition takes place, this public cannot
access the captions that are available by the FCC's rules.

**IV. CONCLUSION**

For the DTV transition to work, the Commission needs the cooperation of
broadcasters, MVPDs, consumer electronics manufacturers, consumer
electronics retailers, and, most importantly, consumers. Unfortunately,
this most important link in the broadcast television chain is unaware of
its responsibilities.

The Commission has a Herculean task and scant resources afforded it. In
just over 500 days, millions of US households must be made aware of the
transition and convinced to buy a DTV set, subscribe to a pay TV
service, and/or buy and install a digital-to-analog converter box -- or
lose their broadcast TV service. As the agency leading this transition,
the Commission, too, must lead the education effort. Therefore, the CAC
strongly urges the Commission to focus its efforts on the consumers most
likely to be left behind in the transition. The Commission must use all
the tools -- mainly its rules -- to ensure that the digital TV education
campaign reaches consumers, that consumers are not harmed by the
transition, and that consumers are empowered to act in their own best
interests.

Respectfully submitted,

Federal Communication Commission's

Consumer Advisory Committee

[By: /s/ Debra Berlyn, Chair]{.underline}

[October 1, 2007]{.underline}

**Appendix A**

**Data on DTV Technology Penetration**

![](media/image1.png){width="2.2916666666666665in"
height="0.8020833333333334in"}

## **Methodology**

The report described herein was designed and formulated by the Consumer
Electronics Association (CEA). The data contained in this report
represents a wide variety of studies stretching back to September 1999.
Each study was conducted by telephone with a minimum of 1000 randomly
selected US adults.

The margin of sampling error for aggregate results is +/- 3.1%. Sampling
error is larger for subgroups of the data. As with any survey, sampling
error is only one source of possible error.

As is common practice in survey research, the data was weighted to
reflect the known demographics of the population under study. In this
survey, weights were applied to cases based on gender, age, race and
geographic region. As a result, this data can be generalized to the
entire U.S. adult population.

CEA designed these studies in their entirety and is responsible for all
content contained in this report. During the fielding of this study, CEA
employed the services of MarketFacts (Sept. 1999 -- March 2000) and
Opinion Research Corporation (April 2000 to present) to conduct
telephone interviewing. The telephone interviewing employed industry
standard random-digit dialing and computer assisted telephone
interviewing (CATI). Any questions regarding the study should be
directed to CEA Market Research staff at research@CE.org.

### Table of Contents

### 

### Section 1 -- Introductory Display Statistics............... ................................................... page 3

### Section 2 -- Demographic Differences Between OTA, Cable, and Satellite Households ........ page 4 

### Section 3 -- Televisions in US Homes................................................................ ........ page 4 

### Section 4 -- Awareness of and Familiarity with HDTV............................................ ........ page 5 

### Section 5 -- Buying the Next Household TV........................................................ ......\... page 6 

### Appendix -- Demographic Profile of OTA Households........................................... ......\... page 7 

**Last Updated 7/19/2007**

**I. Introductory Display Statistics**

-   Unit sales of analog television have ended as of March 1, 2007 while
    unit sales of digital television displays are expected to continue
    their increase through 2010.

-   Due to the transition from analog to digital television, wholesale
    revenue from all displays is expected to peak in 2008. Likewise,
    digital television display revenues are expected to peak in 2008,
    with declines expected to follow thereafter.

-   Despite increasing unit sales of displays through 2010, wholesale
    revenues are expected to decline after 2008 due to the fast-falling
    average wholesale price per display.

**Unit Sales of Televisions (millions)**

  ----------------- ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------
                    **2002**     **2003**     **2004**     **2005**     **2006**     **2007e**    **2008p**    **2009p**    **2010p**

                                                                                                                            

  Analog TVs        28.245       25.640       23.824       20.427       10.789       1.349        0            0            0

  Digital TVs       4.145        5.532        8.002        11.369       23.504       30.462       33.638       36.084       37.377

  **TOTAL TVs**     **32.390**   **31.172**   **31.826**   **31.796**   **34.293**   **31.811**   **33.638**   **36.084**   **37.377**
  ----------------- ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------

**Wholesale Revenue Sales of Televisions (billions)**

  ----------------- ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------
                    **2002**     **2003**     **2004**     **2005**     **2006**     **2007e**    **2008p**    **2009p**    **2010p**

                                                                                                                            

  Analog TVs        7.260        5.836        4.483        3.459        1.340        0.141        0            0            0

  Digital TVs       6.383        8.692        12.300       15.563       23.380       25.908       26.595       26.517       25.180

  **TOTAL TVs**     **13.643**   **14.528**   **16.783**   **19.022**   **24.720**   **26.049**   **26.595**   **26.517**   **25.180**
  ----------------- ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------ ------------

**Ownership Rates of Televisions among all US Households\***

  --------------------- ---------- ---------- ---------- ---------- ---------- ---------- -----------
                        **2002**   **2003**   **2004**   **2005**   **2006**   **2007**   **2008p**

                        \%         \%         \%         \%         \%         \%         \%

  Analog TVs            98         98         98         98         98         98         98

  Digital TVs           2          4          8          12         20         33         53
  --------------------- ---------- ---------- ---------- ---------- ---------- ---------- -----------

\* As of January of each year

e -- estimated, p - projected

**Television reception:**

-   11% of all US households receive their television signals **ONLY via
    over the air reception**.

-   18% of all US households have at least one television that receives
    signals via **over the air reception**.

-   58% of all US households have at least one television that receives
    signals from a **cable provider**.

-   26% of all US households have at least one television that receives
    signals from a **satellite provider**.

**II. Demographic Differences Between OTA, Cable, and Satellite
Households**

The chart in the Appendix shows the demographic profiles of the entire
US population and comparisons between Over the Air Only (OTA) households
(meaning none of the televisions in the home is connected to a cable or
satellite provider), Cable households (at least one TV in the home
receives cable television programming), and Satellite households (at
least one TV in the home receives cable television programming).

OTA households are...

-   Less likely to be employed full-time

-   More likely to be white, and less likely to be black

-   More likely to have incomes under \$40K

-   More likely to be separated / divorced / widowed

-   More likely to live in a rural area compared to cable households

-   Less likely to live in rural areas compared to satellite households

-   Less likely to live in the Northeast compared to cable households

-   More likely to live in the Midwest

-   Less likely to live in the South

-   Less likely to live in the West compared to satellite households

**III. Televisions in US Homes**

-   The average number of televisions in US households has not
    significantly changed over the past 6 years.

-   OTA Only households have significantly fewer sets, on average, when
    compared to Cable and Satellite households.

TVs Per Household

+-----------------+-----+-----+------+---+---------+---------+---------+
|                 | **M | **  | **Au |   | **OTA   | **Cable | **Sa    |
|                 | arc | May | gust |   | Only    | House   | tellite |
|                 | h** | 2   | 20   |   | House   | holds** | House   |
|                 |     | 005 | 06\* |   | holds** |         | holds** |
|                 | *   | \*\ | \*** |   |         |         |         |
|                 | *20 | *** |      |   |         |         |         |
|                 | 00\ |     |      |   |         |         |         |
|                 | *** |     |      |   |         |         |         |
+-----------------+-----+-----+------+---+---------+---------+---------+
| Average number  | 2.5 | 2.6 | 2.4  |   | **2.0** | 2.7     | 2.9     |
|                 |     |     |      |   |         |         |         |
| of TVs per      |     |     |      |   |         |         |         |
| household       |     |     |      |   |         |         |         |
+-----------------+-----+-----+------+---+---------+---------+---------+

\* Used at least once in the past 12 months

\*\* Used at least once in the past 3 months

**IV. Awareness of and Familiarity with HDTV**

-   Awareness of all terms has increased since 1999, however the levels
    have remained constant from early 2005 to the present.

-   Familiarity with the details of HDTV has also remained unchanged
    since 2005.

-   Awareness of terms and familiarity with the details of HDTV differs
    very little by type of television reception.

Awareness of Terms\*

+---------------------+------+------+------+------+------+--------+
|                     | *    | **Ju | *    | **M  | *    | **     |
|                     | *Sep | ly** | *Sep | arch | *May | August |
|                     | t.** |      | t.** | 20   | 20   | 2006** |
|                     |      | **20 |      | 05** | 05** |        |
|                     | **19 | 01** | **20 |      |      |        |
|                     | 99** |      | 03** |      |      |        |
+---------------------+------+------+------+------+------+--------+
|                     | \%   | \%   | \%   | \%   | \%   | \%     |
+---------------------+------+------+------+------+------+--------+
| High-definition TV  | 55   | 62   | 73   | 84   | 84   | 83     |
+---------------------+------+------+------+------+------+--------+
| Digital TV          | 76   | 79   | 82   | 87   | 85   | 82     |
+---------------------+------+------+------+------+------+--------+
| HDTV                | 36   | 45   | 61   | 77   | 76   | 78     |
+---------------------+------+------+------+------+------+--------+
| Analog TV           | NA   | 41   | 53   | NA   | NA   | 57     |
+---------------------+------+------+------+------+------+--------+

\*Yes/maybe summary

**Awareness of Terms (con't)**\*

  ---------------------- ---------- -- -------------- -------------- --------------
                         **August      **OTA Only     **Cable        **Satellite
                         2006**        Households**   Households**   Households**

                         \%            \%             \%             \%

  High-definition TV     83            85             85             84

  Digital TV             82            88             84             82

  HDTV                   78            76             78             80

  Analog TV              57            60             57             56
  ---------------------- ---------- -- -------------- -------------- --------------

\*Yes/maybe summary

**Familiarity with Details about HDTVs**\*

  -------------------- -------- ---------- -- -------------- -------------- --------------
                       **May    **August      **OTA Only     **Cable        **Satellite
                       2005**   2006**        Households**   Households**   Households**

  "Very Familiar" +    50%      52%           48%            51%            52%
  "Familiar"                                                                
  -------------------- -------- ---------- -- -------------- -------------- --------------

\*Have at least one TV in household that has been used in the past 3
months

**V. Buying the Next Household TV**

-   The percentage of households expecting to buy a TV within a 12 month
    period is a fairly stable number as the market is nearly all
    replacement. Thus, in May 2005 one-fifth of consumers expected to
    buy a TV in the following 12 months.

-   Significantly fewer OTA households expected to buy a new TV in the
    12 to 24 month time period following the May 2005 survey.

-   The percentage of households that expect their next TV to be an HDTV
    has risen steadily over the past years, and as of May 2005 stood at
    61%. OTA and Cable households have similar intentions, however,
    Satellite households are significantly more likely to make their
    next TV an HDTV.

**Timing of Next TV Purchase**

  ---------------------- -------- -- -------------- -------------- --------------
                         **May       **OTA Only     **Cable        **Satellite
                         2005**      Households**   Households**   Households**

                         \%          \%             \%             \%

  Within 1 year          20          **11**         22             18

  Within 2 years         15          **11**         15             17

  Within 3 years         9           10             9              10

  More than 3 years      42          **52**         39             45

  Don't know             14          16             15             10
  ---------------------- -------- -- -------------- -------------- --------------

**Likelihood of Next TV Being an HDTV**

+---------------------+------+------+---+---------+----------+----------+
|                     | *    | *    |   | **OTA   | **Cable  | **S      |
|                     | *Sep | *May |   | Only    | Hous     | atellite |
|                     | t.** | 20   |   | House   | eholds** | Hous     |
|                     |      | 05** |   | holds** |          | eholds** |
|                     | **20 |      |   |         |          |          |
|                     | 03** |      |   |         |          |          |
+---------------------+------+------+---+---------+----------+----------+
|                     | \%   | \%   |   | \%      | \%       | \%       |
+---------------------+------+------+---+---------+----------+----------+
| All TV households   | 30   | 61   |   | 58      | 59       | **69**   |
+---------------------+------+------+---+---------+----------+----------+

**\*** Definitely/probably summary

#### Appendix: Demographic Profile of Over the Air (OTA) Households

# Demographic Profile of Households by Television Reception\*

+-----------------------------+--------+---------+---------+---------+
| **Segment**                 | **US   | **OTA   | **      | **Sate  |
|                             | Popula | Only    | Cable** | llite** |
| **(Unweighted sample        | tion** | House   |         |         |
| size)**                     |        | holds** | **House | **House |
|                             | **'05  |         | holds** | holds** |
|                             | /'06** | **'0    |         |         |
|                             |        | 5/'06** | **'0    | **'0    |
|                             | **(N=2 |         | 5/'06** | 5/'06** |
|                             | 009)** | **(N    |         |         |
|                             |        | =223)** | **(N=   | **(N    |
|                             |        |         | 1210)** | =536)** |
+-----------------------------+--------+---------+---------+---------+
| ###                         | \%     | \%      | \%      | \%      |
+-----------------------------+--------+---------+---------+---------+
| ### Gender                  |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Male                        | 48     | 46      | 48      | 50      |
+-----------------------------+--------+---------+---------+---------+
| Female                      | 52     | 54      | 52      | 50      |
+-----------------------------+--------+---------+---------+---------+
| ### Age                     |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| 18-24                       | 13     | 13      | 13      | 15      |
+-----------------------------+--------+---------+---------+---------+
| 25-34                       | 18     | 16      | 17      | 18      |
+-----------------------------+--------+---------+---------+---------+
| 35-44                       | 20     | 20      | 20      | 20      |
+-----------------------------+--------+---------+---------+---------+
| 45-54                       | 19     | 23      | 18      | 18      |
+-----------------------------+--------+---------+---------+---------+
| 55-64                       | 13     | 9       | 13      | 13      |
+-----------------------------+--------+---------+---------+---------+
| 65 and over                 | 16     | 17      | 16      | 12      |
+-----------------------------+--------+---------+---------+---------+
| **Employment**              |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Full-time                   | 48     | **42**  | 49      | 52      |
+-----------------------------+--------+---------+---------+---------+
| Part-time                   | 11     | 14      | 11      | 10      |
+-----------------------------+--------+---------+---------+---------+
| Retired                     | 21     | 22      | 21      | 19      |
+-----------------------------+--------+---------+---------+---------+
| Not employed                | 18     | 21      | 18      | 17      |
+-----------------------------+--------+---------+---------+---------+
| **Education**               |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Less than high school       | 8      | 9       | 7       | 10      |
+-----------------------------+--------+---------+---------+---------+
| High school grad            | 31     | 30      | 31      | 31      |
+-----------------------------+--------+---------+---------+---------+
| Some college, no degree     | 20     | 18      | 19      | 20      |
+-----------------------------+--------+---------+---------+---------+
| College degree (2 or 4      | 26     | 28      | 26      | 26      |
| year)                       |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Post graduate degree        | 12     | 10      | 14      | 8       |
+-----------------------------+--------+---------+---------+---------+
| **Race / Ethnicity**        |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| White                       | 74     | **80**  | 72      | 70      |
+-----------------------------+--------+---------+---------+---------+
| Black                       | 12     | **7**   | 14      | 13      |
+-----------------------------+--------+---------+---------+---------+
| Asian                       | 2      | 0       | 2       | 2       |
+-----------------------------+--------+---------+---------+---------+
| Other                       | 11     | 9       | 11      | 14      |
+-----------------------------+--------+---------+---------+---------+
| Hispanic household          | 12     | 9       | 13      | 14      |
+-----------------------------+--------+---------+---------+---------+
| **Income**                  |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Less than \$40,000          | 35     | **47**  | 32      | 32      |
+-----------------------------+--------+---------+---------+---------+
| \$40,000 or more            | 49     | **39**  | 51      | 56      |
+-----------------------------+--------+---------+---------+---------+
| **Marital Status**          |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Married / Living as married | 52     | 45      | 50      | 59      |
+-----------------------------+--------+---------+---------+---------+
| Single, never married       | 26     | 26      | 28      | 25      |
+-----------------------------+--------+---------+---------+---------+
| Separated / Divorced /      | 19     | **25**  | 20      | 13      |
| Widowed                     |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| **Dwelling**                |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Own                         | 68     | 68      | 66      | 74      |
+-----------------------------+--------+---------+---------+---------+
| Rent                        | 30     | 30      | 31      | 23      |
+-----------------------------+--------+---------+---------+---------+
| **Children In Household**   |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Yes                         | 36     | 34      | 36      | 39      |
+-----------------------------+--------+---------+---------+---------+
| No                          | 64     | 66      | 64      | 61      |
+-----------------------------+--------+---------+---------+---------+
| **Location**                |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| ######## **Urban**          | 74     | **71**  | 80      | 64      |
+-----------------------------+--------+---------+---------+---------+
| ######## **Rural**          | 26     | **29**  | 20      | 36      |
+-----------------------------+--------+---------+---------+---------+
| **Region**                  |        |         |         |         |
+-----------------------------+--------+---------+---------+---------+
| Northeast                   | 19     | **16**  | 23      | 13      |
+-----------------------------+--------+---------+---------+---------+
| Midwest                     | 23     | **33**  | 20      | 21      |
+-----------------------------+--------+---------+---------+---------+
| South                       | 36     | **31**  | 37      | 40      |
+-----------------------------+--------+---------+---------+---------+
| West                        | 22     | **20**  | 20      | 26      |
+-----------------------------+--------+---------+---------+---------+

\* Refused/ Don\'t Know responses not shown. Due to rounding, not all
totals equal 100%.

Source: CEA Market Research, May 2005 and August 2006

![](media/image2.png){width="0.25in" height="0.1875in"}

![](media/image2.png){width="0.25in" height="0.1875in"}

[^1]: See DA 07-2426
    http://fjallfoss.fcc.gov/edocs_public/attachmatch/DA-07-2426A1.doc

[^2]: 5 U.S.C. App. 2 (1988)

[^3]: These comments were adopted by the CAC on Thursday September 27,
    2007 with 18 members voting in favor, none opposed. The following
    CAC members abstained when these comments were approved. They
    are:AARP, CableVision, the Consumer Electronic Association, the DTV
    Coalition, EchoStar, the National Association of Broadcasters and
    Verizon. Some of these CAC members have filed separate comments.

[^4]: See letter from Jack Sander, National Association of Broadcasters,
    to FCC Chairman Kevin Martin *In the Matter of DTV Consumer
    Education Initiative*. August 21, 2007.
    (http://www.nab.org/xert/corpcomm/pressrel/releases/082107_Sander_FCC_DTV.pdf)

[^5]: Letter from the Honorable John D. Dingell, Chairman of the
    Committee on Energy and Commerce, and the Honorable Edward J.
    Markey, Chairman of the Subcommittee on Telecommunications and the
    Internet, U.S. House of Representatives, to the Honorable Kevin J.
    Martin, Chairman, the Honorable Michael J. Copps, Commissioner, the
    Honorable Jonathan S. Adelstein, Commissioner, the Honorable Deborah
    Taylor Tate, Commissioner, and the Honorable Robert M. McDowell,
    Commissioner, Federal Communications Commission, received May 24,
    2007. ("Letter")

[^6]: See letter from Chairman Kevin Martin to Honorable John Dingell,
    Chairman of the House Committee on Energy and Commerce, and the
    Honorable Edward Markey, Chairman of the House Subcommittee on
    Telecommunications and the Internet June 18, 2007 ("Martin Response
    Letter")
    (http://energycommerce.house.gov/Press_110/FCC%20response%20DTV%20ed%20plan%2006%2020%2007.pdf)
    and written statement of Catherine Seidel, Chief of the Commission's
    Consumer and Governmental Affairs Bureau before the Senate Committee
    on Commerce, Science & Technology July 26, 2007 ("Seidel Testimony")
    (http://commerce.senate.gov/public/\_files/WrittenStatementofCathySeidel7262007Hearing.pdf).

[^7]: Horrigan, J., Garret, K., & Resnick, P. (2004). The Internet and
    Democratic Debate. Pew Internet and American Life Project and the
    University of Michigan School of Information; Cooper, M. (n.d.).
    Media Ownership and Democracy in the Digital Information Age. Center
    for Internet & Society, 146. Stanford Law School; Carter, S., Fico,
    F., & McCabe, J. (2002). Partisan and Structural Balance in Local
    Television Election Coverage. Journalism and Mass Communications
    Quarterly, 79. p.42; Norris, P. (2002). Revolution, What Revolution?
    The Internet and U.S. Elections, 1992-2000.

[^8]: See, for example, Second Report and Order in the Matter of Review
    of the Emergency Alert System (EB Docket No. 04-296) at 17. Adopted
    May 31, 2007.

[^9]: "Nielsen Ups US TV Homes by 1.3% for 2007-08." TVnewsday. August
    23, 2007. (http://www.tvnewsday.com/articles/2007/08/23/daily.9/)

[^10]: Arnold, Thomas K. "DEG: 52 mil HDTV homes in U.S. by \'08." The
    Hollywood Reporter. July 18, 2007. (see
    http://www.hollywoodreporter.com/hr/content_display/television/news/e3i46597294f152ad2d311c94d12d48670b)
    On July 18, 2007, the Consumer Electronics Association reported that
    more than 30 million U.S. households have at least one high
    definition, digital television ("HDTV"). An estimated 4.5 million
    HDTVs were sold in the first half of 2007, 50% more than in the
    first six months of 2006. CEA projects that 16 million HDTVs will be
    sold by the end of this year, bringing the U.S. household total to
    more than 52 million. That could bring the household penetration
    rate to 36%, with about 20% of homes having more than one HDTV. See
    additional data in Appendix A.

[^11]: In May 2007, Leichtman Research Group, Inc. released findings
    that 23% of all TV sets in consumers\' homes do not receive cable or
    Direct Broadcast Satellite (DBS) programming. This represents over
    70 million TV sets in US households that only receive over-the-air
    broadcast television. Half of all broadcast-only TV sets are in 15%
    of primary households nationwide that do not subscribe to cable,
    DBS, or any other type of multi-channel video service. The other
    half are in households that subscribe to cable or DBS. Nine percent
    of TV sets in cable households are broadcast-only, and 19% of TV
    sets in DBS households are broadcast-only. Other related key
    Leichtman Research findings include: 1) 70% of all TV sets in cable
    households are not connected to a set-top box and 2) 42% of
    households that subscribe to cable TV do not have any cable set-top
    boxes.

[^12]: "Closed Captioning for Digital television (DTV)," Federal
    Communications Commission. June 6, 2007. (See
    http://fjallfoss.fcc.gov/edocs_public/attachmatch/DOC-273678A1.doc)

[^13]: The Government Accountability Office (GAO) found that 19% or 20.8
    million households rely exclusively on free over-the-air television.
    Statement of Mark L. Goldstein, United States Government
    Accountability Office, Testimony Before the Subcommittee on
    Telecommunications and the Internet, Committee on Energy and
    Commerce, House of Representatives, at 7 (Feb. 17, 2005)

[^14]: Additionally, see "APTS Study Shows Older Americans Less Prepared
    for the Digital TV Transition." Association of Public Television
    Stations. July 2007. Many older Americans are at risk of being left
    behind in the transition. On July 24, 2007, the Association of
    Public Television Stations (APTS) released survey results finding
    that older Americans are more likely to rely on over-the-air
    television service and are thus less prepared for the switch-off of
    analog signals in February 2009. According to the APTS findings, 24
    percent of households with people 65 and older receive their TV
    programming over-the-air, while only 19 percent of younger
    households depend on over-the-air signals. The study also found that
    only 17% of those older Americans relying solely on over-the-air
    broadcasts own a digital TV, which means the rest will need to buy a
    digital-to-analog converter box or subscribe to cable or satellite
    service to continue to enjoy television programming. The study,
    which APTS says is the first time it has studied the impact of the
    digital transition on a specific population segment, also found that
    only 41% of Americans 65 and older had purchased a new TV set in the
    past three years, compared to 55 percent of Americans younger than
    65. According to APTS, that suggests that older Americans may not be
    as exposed to \"DTV transition messaging from electronics
    retailers\" as younger Americans, since they are spending less time
    in retail outlets shopping for new TV sets.
    (http://www.apts.org/news/olderamericansotastudy.cfm)

[^15]: "APTS Survey Finds Majority of Americans Remain Unaware of DTV
    Transition." Association of Public Television Stations. January 31,
    2007. (see http://www.apts.org/news/DTVSURVEY.cfm). Note, however,
    that the 22 million estimate does not include Puerto Rico and other
    U.S. territories.

[^16]: For example, the number of cable/satellite households that owned
    a digital television grew from 4.49 percent in the first quarter of
    2005 to 23.45 percent in the first quarter of 2007. However, the
    percentage of over-the-air households that owned a digital
    television only grew from 1.96 percent to 7.12 percent over that
    same period.

[^17]: Letter at page 2.

[^18]: MM Docket No. 87-268

[^19]: This includes various sets of regulations to ensure that users of
    closed captions continue to have access to television programming
    after the digital transition takes place (will provide cites).

[^20]: Deficit Reduction Act of 2005, Public Law 109-171, Sec
    3005©(2)(A), February 8, 2006.

[^21]: Although all Americans need to get the message about the
    transition, given the limited resources for outreach, the message
    needs to be targeted at the populations most at risk of losing TV.

[^22]: See, for example, Pelofsky, Jeremy and Megan Davies. "TV, radio
    look for record ad money in election." Reuters. August 24, 2007
    (http://today.reuters.com/news/articlenews.aspx?type=industryNews&storyID=2007-08-24T113414Z_01_N24285067_RTRIDST_0_INDUSTRY-USA-POLITICS-ADVERTISING-DC.XML&pageNumber=0&imageid=&cap=&sz=13&WTModLoc=NewsArt-C1-ArticlePage3)

[^23]: PSAs that are not federally funded and are under ten minutes are
    not subject to the FCC's closed captioning obligations.

[^24]: Public Interest Obligations of Digital Television. "Charting the
    Digital Future." 1998. James F. Goodmon Supporting Minimum Standards
    for Digital Television Broadcasters including the report of the
    Working Group on Minimum Public Interest Standards with attachment.
    This number reflected the full range of PSAs to be required and did
    not relate to PSAs specifically about the DTV transition.

[^25]: 47 USC 151

[^26]: 47 USC 303(f)

[^27]: 47 USC 303(r)

[^28]: See, for example, the Station Identification requirement (47 CFR
    Section 73.1201). Stations must make identification announcements
    when they sign on and off for the day. They must also make the
    announcements hourly, as close to the hour as possible, at a natural
    programming break. TV stations may make these announcements on-
    screen or by voice only. Official station identification includes
    the station\'s call letters followed by the community or communities
    specified in its license as the station\'s location. Between the
    call letters and its community, the station may insert the name of
    the licensee, the station\'s channel number, and/or its frequency.
    Also see station renewal announcements (47 CFR Section 73.3580). The
    regulations on the announcements that need to be made when a
    licensee files a renewal application are pretty specific - and
    include prefiling and post filing announcements and may vary
    depending on station class. Announcements must be made over the TV;
    stations primarily broadcasting in a foreign language should
    broadcast the announcements in that language. In presenting the
    announcements, TV stations must use visuals with the licensee\'s and
    the FCC\'s addresses when the information is being orally presented
    by the announcer. Licensee must certify they have complied with the
    rule. For pre-filing renewal announcements of TV stations at least
    two of the required announcements must be broadcast at certain times
    of day.

[^29]: ABC, Capitol Broadcasting, CBS, Fox, NBC, Sinclair, Telemundo and
    Univision.

[^30]: Martin Response at page 1.

[^31]: See Commission's Lifeline Link Up Consumer Page
    (http://www.lifeline.gov/lifeline_Consumers.html).