TELECOMMUNICATIONS

Information on Low 

Power Television, 

FCC’s Spectrum 

Incentive Auction, and 

Unlicensed Spectrum 

Use

Report to Congressional Requesters

December 2016

GAO-17-135

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-135, a report to 

congressional requesters

December 2016

TELECOMMUNICATIONS

Information on Low Power Television, FCC's Spectrum 

Incentive Auction, and Unlicensed Spectrum Use

What GAO Found

As of May 2016, there were 2,063 low power television (LPTV) stations and 

3,660 translator stations in the United States and its territories, serving diverse 

communities. However, some LPTV and translator stations may be displaced 

and need to find a new channel or discontinue operation after the Federal 

Communications Commission’s (FCC) ongoing incentive auction of broadcast 

television spectrum. By statute, these stations were not designated as eligible to 

participate in the auction; consequently, they cannot voluntarily relinquish their 

spectrum usage rights in return for compensation. LPTV stations may serve rural 

communities with limited access to full-power stations and niche communities in 

urban areas, whereas translator stations retransmit the programming of other 

stations, mostly to viewers in rural areas who cannot otherwise receive television

signals. After the auction, FCC intends to reorganize the television stations

remaining on the air so that they will occupy a smaller range of channels, thus 

freeing up spectrum for other uses. LPTV and translator stations are not

guaranteed a channel during the reorganization. FCC has acknowledged that the 

auction and channel reorganization may negatively affect an unknown number of 

LPTV and translator stations and that some viewers will lose service, and 

concluded the success of the auction outweighs these concerns. Broadcast 

industry associations and others have raised concerns about viewers’ losing 

access to programming and emergency alert information these stations provide.

Selected stakeholders viewed FCC’s actions to mitigate the effects of the

incentive auction on LPTV and translator stations as helpful in some 

circumstances, but overall as insufficient. FCC’s actions include using its 

software to identify channels that will be available for displaced stations following 

the auction and allowing channel sharing. While broadcast industry associations

generally supported these measures in comments to FCC, some representatives 

told GAO that the actions will not do much to mitigate the effects of the incentive 

auction on LPTV and translator stations. Moreover, in response to GAO’s nongeneralizable survey, representatives of LPTV and translator stations generally 

indicated FCC’s actions have limited usefulness. 

According to selected stakeholders, FCC’s proposal to preserve a vacant 

television channel in all areas throughout the country for unlicensed use, such as 

Wi-Fi Internet, could result in the loss of some existing broadcast service, but 

could have various benefits. Of the stakeholders GAO contacted, the broadcast 

industry associations generally opposed the proposal, while the technology 

companies supported it. According to a broadcast industry association, the 

proposal will force some LPTV and translator stations off the air because there 

will be one less channel where a displaced station can relocate, and many rural 

and underserved communities will likely lose access to the broadcast stations on 

which they rely. On the other hand, technology companies and other supporters 

of the vacant channel proposal maintain that preserving at least one vacant 

channel for unlicensed use will contribute to innovation and the development of 

new technologies. Proponents also said that preserving a vacant channel could 

help expand Wi-Fi more thoroughly giving people and businesses greater 

connectivity and could help extend coverage to people who might not have 

affordable access to the Internet.

View GAO-17-135. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov.

Why GAO Did This Study

In 2012, Congress authorized FCC to 

conduct an incentive auction of 

broadcast television spectrum whereby 

eligible broadcasters can voluntarily 

relinquish their spectrum usage rights 

in return for compensation. This 

auction will make spectrum available

for new uses such as mobile 

broadband and will also potentially 

affect LPTV and translator stations. In 

addition to conducting the auction, 

FCC proposed preserving at least one 

vacant television channel in all areas 

that could be used by unlicensed 

devices to ensure the public continues 

to have access to the benefits 

associated with these devices.

GAO was asked to review the possible 

effects of the auction on LPTV and 

translator stations and their viewers. 

This report examines: (1) LPTV and 

translator stations and how FCC’s 

incentive auction might affect their 

viewers, (2) selected stakeholders’

views on actions FCC has proposed to 

mitigate the possible effects of the 

auction on such stations, and (3)

selected stakeholders’ views on the 

expected outcomes of preserving a 

vacant television channel for 

unlicensed use. GAO reviewed 

relevant FCC proceedings and 

comments associated with those 

proceedings; surveyed a nongeneralizable sample of 330 LPTV and 

translator station representatives with 

available e-mail addresses; and 

interviewed officials from FCC and 

industry stakeholders selected to 

represent various types of 

organizations, such as broadcast

industry associations and technology 

companies. GAO provided FCC with a 

draft of this report. FCC’s technical 

comments have been incorporated.
Page i GAO-17-135 Low Power Television

Letter 1

Background 6

LPTV and Translator Stations Provide Programming and 

Information That Might Not Be Available to Over-the-Air 

Viewers after the Auction 13

Selected Stakeholders View FCC’s Actions as Having Limited 

Usefulness and Have Proposed Additional Actions to Mitigate 

the Auction’s Effects 26

Selected Stakeholders Expressed Varying Views on Outcomes of 

Preserving a Vacant Television Channel 34

Agency Comments 37

Appendix I Objectives, Scope, and Methodology 39

Appendix II Survey of Low Power Television and Translator Stations 43

Appendix III GAO Contact and Staff Acknowledgments 54

Tables

Table 1: Examples of Low Power Television (LPTV) Programming 

That Is Not Locally Produced 20

Table 2: Views on Usefulness of Channel Sharing Provided by 

Survey Respondents Representing Low Power Television 

(LPTV) and Translator Stations 28

Table 3: Views on Usefulness of Optimization Software Provided 

by Survey Respondents Representing Low Power 

Television (LPTV) and Translator Stations 29

Table 4: Views on Usefulness of Extending the Digital Transition 

Deadline Provided by Survey Respondents Representing 

Low Power Television (LPTV) and Translator Stations 30

Table 5: Views on Usefulness of Improving Cross-Border 

Coordination Provided by Survey Respondents 

Representing Low Power Television (LPTV) and 

Translator Stations 30

Table 6: Stakeholders Interviewed 41

Contents
Page ii GAO-17-135 Low Power Television

Figures

Figure 1: Illustration of a Translator Station Daisy Chain 7

Figure 2: Selected Key Dates Related to the Federal 

Communications Commission’s (FCC) Ongoing 

Spectrum Incentive Auction 9

Figure 3: Illustration of Broadcast Television Spectrum and 

Examples of the Incentive Auction’s Spectrum-Clearing 

Targets 10

Figure 4: Low Power Television (LPTV) Stations’ Communities of 

License as of May 2016 15

Figure 5: Translator Stations’ Communities of License as of May 

2016 16

Figure 6: Broadcasting by Low Power Television (LPTV) Stations 

Represented by Survey Respondents 17

Figure 7: Broadcast of Non-Locally Produced Programming by 

Low Power Television (LPTV) Stations Represented by 

Survey Respondents 19

Figure 8: Types of Entities That Own the Low Power Television 

(LPTV) and Translator Stations Represented by Survey 

Respondents 22

Figure 9: Illustration of Situation Where a Station That Relocates 

after the Incentive Auction Would be Unable to Reach All 

of Its Primary Viewers 24
Page iii GAO-17-135 Low Power Television

Abbreviations

ATSC Advanced Television Systems Committee 

CDBS Consolidated Database System 

FCC Federal Communications Commission 

LPTV low power television 

MHz megahertz

NAB National Association of Broadcasters 

NPRM notice of proposed rulemaking 

the 2012 act the Middle Class Tax Relief and Job Creation Act of 2012 

UHF ultra high frequency

VHF very high frequency

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Page 1 GAO-17-135 Low Power Television

441 G St. N.W.

Washington, DC 20548

December 5, 2016

The Honorable Anna G. Eshoo

Ranking Member

Subcommittee on Communications and Technology

Committee on Energy and Commerce

House of Representatives

The Honorable Joe Barton

House of Representatives

There are thousands of low power television (LPTV) and translator 

stations located throughout the country that serve distinct television 

viewing audiences.1 LPTV stations serve both rural audiences and niche 

communities within larger urban areas and may provide locally oriented 

television programming such as non-English language, ethnic, religious, 

or other programming. Translator stations retransmit programming from 

another station—such as a major network (ABC, CBS, Fox, or NBC)—

mostly to viewers in rural and mountainous areas who cannot receive 

signals because of terrain or distance. According to the Federal 

Communications Commission (FCC), LPTV and translator stations have 

always operated in an environment where they could be displaced from 

their operating channel and, if no new channel assignment is available, 

forced to go silent.2

 1Low power television stations transmit over a smaller area, and most are subject to fewer 

regulatory requirements than full-power stations. In addition, they operate at lower power 

levels: The maximum effective radiated power level for a digital low power television 

station will range from 3 kilowatts for very high frequency (VHF) channels to 15 kilowatts 

for ultra high frequency (UHF) channels, 47 C.F.R § 74.735(b), while the maximum 

effective radiated power level for a digital full-power television station ranges from 10 

kilowatts for VHF to 1,000 kilowatts for UHF. In the Matter of Expanding the Economic and 

Innovation Opportunities of Spectrum Through Incentive Auctions, Office of Engineering 

and Technology Releases and Seeks Comment on Updated OET-69 Software, Office of 

Engineering and Technology Seeks to Supplement the Incentive Auction Proceeding 

Record Regarding Potential Interference Between Broadcast Television and Wireless 

Services, 30 FCC Rcd 12049,October 26, 2015, Released, October 21, 2015, Adopted, 

Third Report and Order and First Order on Reconsideration.

2In the Matter of Expanding the Economic and Innovation Opportunities of Spectrum 

Through Incentive Auctions, 30 FCC Rcd 6746, June 19, 2015, Released, June 17, 2015, 

Adopted, Second Order on Reconsideration.

Letter
Page 2 GAO-17-135 Low Power Television

The Middle Class Tax Relief and Job Creation Act of 2012 (the 2012 act) 

authorized FCC to conduct an auction of broadcast television spectrum3

to help meet the nation’s accelerating spectrum needs.4 This auction is 

referred to as an incentive auction because eligible television 

broadcasters can voluntarily relinquish some or all of their spectrum 

usage rights in return for compensation in the incentive auction, which 

depending on the station and market could potentially be hundreds of 

millions of dollars. Following the auction’s conclusion, FCC intends to 

reorganize the television broadcast spectrum band so that the stations 

that remain on the air will occupy a smaller range of channels. LPTV and 

translator stations were not designated as eligible in statute to participate 

in the auction. FCC has stated that some LPTV and translator stations 

may be displaced as a result of the auction or reorganization of the 

television broadcast band and these stations will need to find a new 

channel (from the fewer number of channels available) or discontinue 

operations altogether. FCC stated that making more spectrum available 

for new flexible uses such as mobile broadband services will benefit 

consumers by easing congestion of the airwaves, thus expediting the 

development of new, more robust wireless services and applications and 

spurring job creation and economic growth.

According to FCC, the auction and reorganization of the television 

broadcast band will also likely result in fewer television channels available 

for use by either unlicensed devices (such as Wi-Fi Internet and 

Bluetooth) or wireless microphones.5 Separately, in a June 2015 notice of 

proposed rulemaking (NPRM),6 FCC proposed to preserve at least one 

 3Pub. L. No. 112-96, § 6402, 126 Stat. 156, 224 (codified at 47 U.S.C. § 309(j)(8)(G)).

4Spectrum is a finite natural resource of electromagnetic radiation lying between the 

frequencies of 3 kilohertz and 300 gigahertz. A television broadcast channel consists of 6 

megahertz (MHz) of spectrum. Spectrum is necessary for essential government functions 

and missions such as national defense, homeland security, weather services, and aviation 

communication, as well as commercial services such as television broadcasting and 

mobile voice and data.

5Unlicensed devices are low power radio transmitters, which under 47 C.F.R. part 15 are

allowed to operate on spectrum frequencies allocated to other services on the basis that 

unlicensed devices do not cause harmful interference and have no rights to protection 

from interference. 47 C.F.R. § 15.5(b).

6In the Matter of Amendment of Parts 15, 73, and 74 of the Commission’s Rules to 

Provide for Preservation of One Vacant Channel in the UHF Television Band for Use By 

White Space Devices and Wireless Microphones; Expanding the Economic and 

Innovation Opportunities of Spectrum Through Incentive Auctions,(Vacant Channel 

NPRM) 30 FCC Rcd 6711, June 16, 2015, Released, June 11, 2015,Adopted.
Page 3 GAO-17-135 Low Power Television

vacant channel to help ensure the public continues to have access across 

the nation to the significant public benefits associated with these devices. 

Although this is a separate proceeding from the incentive auction and not 

directly contingent on the auction, if adopted, this proposal could further 

decrease the number of channels available for LPTV and translator 

stations to relocate.

FCC stated that it has taken into consideration the potential impact of the 

auction and reorganization of the television broadcast band on LPTV 

stations and is not required to conduct additional analysis. According to 

FCC officials, when Congress authorized FCC to conduct the incentive 

auction, it signaled a change in priorities away from LPTV and translator 

station service since only full-power and Class A television stations 7 were 

designated as eligible to participate in the auction in the 2012 act. In 

2011, we recommended that FCC explore options for assessing how 

LPTV and translator stations have contributed to FCC’s policy goals of 

localism and diversity, potentially including an evaluation of existing data 

that FCC could use and additional data that should be collected to inform 

such an assessment.8 However, FCC did not implement this 

recommendation. In discussing this prior recommendation with us, FCC 

officials said that an assessment of the impact of LPTV and translator 

stations on localism and diversity is not consistent with the 

implementation of the incentive auction as specified by the 2012 act, 

which will cause consolidation among and elimination of an undetermined 

number of those stations.

You asked us to review the possible effects of FCC’s spectrum incentive 

auction on LPTV and translator stations and their viewers. This report 

examines (1) what is known about LPTV and translator stations and how 

FCC’s spectrum incentive auction might affect viewers’ access to the 

stations’ services, (2) selected stakeholder views on actions FCC has 

proposed or taken to mitigate the possible effects of the incentive auction 

on LPTV and translator stations, and additional stakeholder proposals for 

doing so, and (3) selected stakeholder views on the expected outcomes 

 7Class A stations may not exceed the maximum effective radiated power level of low 

power television stations, but are classified as a primary service and must meet 

requirements that are not applied to LPTV stations, including broadcasting an average of 

at least 3 hours of locally produced programming each week. 47 U.S.C. § 336 (f)(2). 

8GAO, Telecommunications: Enhanced Data Collection and Analysis Could Inform FCC's 

Efforts to Complete the Digital Transition of Low-Power Television Stations and Reallocate 

Spectrum, GAO-11-790 (Washington, D.C.: Sept. 7, 2011).
Page 4 GAO-17-135 Low Power Television

of preserving a vacant channel for unlicensed use of the television 

broadcast spectrum.

To address these objectives, we reviewed FCC’s documents related to 

the incentive auction—including its June 2014 incentive auction report 

and order,9 December 2015 LPTV and translator report and order,10 and 

vacant channel notice of proposed rulemaking11—and selected comments 

and other filings associated with these proceedings.12 We also reviewed 

relevant statutes and regulations, including the Middle Class Tax Relief 

and Job Creation Act of 2012,13 and obtained data as of May 25, 2016, 

from FCC’s Consolidated Database System (CDBS) to determine the 

number of LPTV and translator stations in the U.S. and its territories 

along with their communities of license. To determine the reliability of 

FCC’s data, we reviewed FCC user guides and forms for CDBS and 

interviewed knowledgeable FCC officials regarding data entry and 

analysis procedures. We determined the data were reliable for our 

purposes.

In addition, we conducted a web-based survey of 330 LPTV and 

translator station representatives for whom we were able to obtain e-mail 

addresses. After preparing draft survey questions and response 

categories, we spoke with representatives from three broadcast industry 

associations and a translator station representative chosen for their broad 

industry perspective and expertise in particular segments of the industry 

 9In the Matter of Expanding the Economic and Innovation Opportunities of Spectrum 

Through Incentive Auctions,(Incentive Auction Report and Order) 29 FCC Rcd 6567,

June 2, 2014,Released, May 15, 2014, Adopted.

10In the Matter of Amendment of Parts 73 and 74 of the Commission’s Rules to Establish 

Rules for Digital Low Power Television and Television Translator Stations;Expanding the 

Economic and Innovation Opportunities of Spectrum Through Incentive Auctions;

Amendment of Part 15 of the Commission’s Rules to Eliminate the Analog Tuner 

Requirement, (LPTV and Translator Report and Order) 30 FCC Rcd 14927, December 17, 

2015, Released, December 16, 2015,Adopted.

11Vacant Channel NPRM, 30 FCC Rcd 6711, June 16, 2015, Released, June 11, 2015,

Adopted.

12Other types of filings were letters and notices of ex parte presentations. An ex parte 

presentation discusses the merits or outcome of a proceeding, and if written, is not served 

on all the parties to a proceeding, and if it is oral, it is made without advance notice to the 

parties or an opportunity for them to be present. These notices could include copies of 

written presentations and summaries of oral presentations.

13Pub. L. No. 112-96, 126 Stat. 156 (codified at 47 U.S.C. § 309(j)(8)(G)).
Page 5 GAO-17-135 Low Power Television

to determine whether selected questions were answerable by station 

representatives and whether the answer choices provided were 

appropriate, and updated our survey accordingly. We then pre-tested our 

survey with four representatives of LPTV and/or translator stations—

selected to provide for variety in type of station (LPTV and translator), 

number of stations represented, and geography—to ensure that our 

survey questions and skip pattern were clear and logical and that 

respondents could answer the questions without undue burden. In the 

course of pre-testing our survey we also obtained information that we 

present in this report. Through our survey, we obtained information on: (1) 

LPTV station programming, (2) ownership of LPTV and translator 

stations, and (3) station representatives’ views on actions that FCC has 

proposed or taken and actions Congress or others could take to mitigate 

the effects of the incentive auction on LPTV and translator stations. We 

administered the survey from June 2016 through August 2016 and 

received 115 responses. These responses represent 535 of the 2,063 

LPTV stations and 1,515 of the 3,660 translator stations in the U.S. and 

its territories. In our report, we generally provide survey results based on 

the number of respondents to each question. Because not all 

respondents answered every question of the survey, the total number of 

respondents may be fewer than 115 for some results. The results of our 

survey are not generalizable, and we did not verify respondents’ answers.

We also interviewed officials from FCC and additional stakeholders that 

we selected to represent a range of views from various types of 

organizations. We selected stakeholders based on our review of 

comments filed in FCC’s incentive auction and vacant channel proposal 

proceedings, as well as based on the recommendations of other 

organizations we interviewed. We interviewed six broadcast industry 

associations and three station ownership groups that own LPTV and/or 

translator stations chosen to represent entities with a variety of 

programming types. Additionally, we interviewed two technology 

companies, a technology industry association, and a public interest group 

chosen to present additional views on FCC’s vacant channel proposal. 

More details about our scope and methodology, including a complete list 

of stakeholders we interviewed, can be found in appendix I. A copy of our 

survey and selected results can be found in appendix II.

We conducted this performance audit from January 2016 to December 

2016 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 
Page 6 GAO-17-135 Low Power Television

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

LPTV stations, as indicated by their name, operate at lower power levels 

and transmit over smaller areas than full-power television stations. FCC 

established a licensing process for LPTV stations in 1982 to add to 

programming diversity and provide opportunities for locally oriented 

television service in small communities.14 LPTV stations may originate 

programming and, according to FCC, have created opportunities for new 

entry into television broadcasting, provided a means of local selfexpression, and permitted fuller use of the broadcast spectrum. 

Translator stations retransmit programming from another station—such 

as a major network (ABC, CBS, FOX, or NBC)—to audiences unable to 

receive signals directly, usually because of distance or terrain barriers, 

such as mountains, that limit the signal’s ability to travel long distances. 

FCC rules prohibit translator stations from originating any programming.15

As shown in figure 1, some translator stations are part of a “daisy chain”

in which multiple translator stations relay signals from one translator 

station to another, allowing the originating station’s signal to be received a 

few hundred miles away despite distance or other terrain obstacles.

 14An Inquiry into the Future Role of Low Power Television Broadcasting and Television 

Translators in the National Telecommunications System, 51 R.R.2d 476 (1982).

1547 C.F.R. § 74.731(b) and (f).

Background
Page 7 GAO-17-135 Low Power Television

Figure 1: Illustration of a Translator Station Daisy Chain

LPTV and translator service is secondary, meaning these stations may 

not cause interference to, and must accept interference from, primary 

services including primary television stations, which are full-power and 

Class A television stations.16 When interference with a full-power station 

cannot be remedied by adjusting an antenna or other technological 

methods, LPTV and translator stations must vacate the channel either by 

requesting FCC’s permission to move to another channel or by requesting 

permission to turn off their broadcast signal while searching for another 

channel. LPTV stations generally do not have “must-carry” rights—that is, 

cable and satellite providers are generally not required to carry signals 

 1647 C.F.R. § 74.702(b).
Page 8 GAO-17-135 Low Power Television

from LPTV stations, but cable and satellite providers may agree to do 

so.17

The 2012 act authorized FCC to conduct an incentive auction for 

broadcast television spectrum.18 This auction comprises two separate but 

interdependent auctions—a “reverse auction” to determine the amount of 

compensation that each broadcast television licensee19 would accept in 

return for voluntarily relinquishing some or all its spectrum rights; and a 

“forward auction” to determine the price companies are willing to pay for 

the relinquished spectrum. The spectrum being auctioned is in the UHF 

range, which currently consists of channels 14 through 51, except for 

channel 37. According to FCC, the spectrum being auctioned has 

excellent propagation characteristics that allow signals to cover large 

geographic areas and penetrate walls and other structures.20 As shown in 

figure 2, at the time of this report, the incentive auction was ongoing and 

FCC expected it to conclude at the earliest in late 2016.

 17Federal law requires cable and satellite operators to carry the signal of qualified LPTV 

stations serving their markets. 47 U.S.C. §§ 534 and 535. Federal law further set forth the

qualifications that LPTV stations must meet in order to trigger the cable must-carry 

requirement, including (1) the community of license of the LPTV station and the franchise 

area of the cable system are both outside the largest 160 markets on June 30, 1990, (2) 

the population of the LPTV station’s community of license was not larger than 35,000 as of 

that date, and (3) there is no full-power television station licensed to any community within 

the county served by the cable system. 47 U.S.C. § 534 (h)(2). Similar requirements exist 

for satellite operators. 47 U.S.C. § 338.

18Pub. L. No. 112-96, § 6402, 126 Stat. 156, 224 (codified at 47 U.S.C. § 309(j)(8)(G)) . 

19The 2012 act defines broadcast television licensee as the licensee of (1) a full-power 

television station; or (2) a low power television station that has been accorded primary 

status as a Class A television licensee. Pub. L. No. 112-96, § 6001(6), 126 Stat. 156, 202.

20Incentive Auction Report and Order, 29 FCC Rcd 6567, June 2, 2014, Released, 

Adopted, May 15, 2014.
Page 9 GAO-17-135 Low Power Television

Figure 2: Selected Key Dates Related to the Federal Communications 

Commission’s (FCC) Ongoing Spectrum Incentive Auction

After the auction concludes, FCC reported it intends to reorganize the 

television broadcast band on a smaller range of channels to free up a 

portion of the spectrum; FCC refers to this reorganization as “repacking.”

Relocating the remaining stations on lower channels allows for new, 

flexible-use spectrum licenses suitable for providing mobile broadband 

services. In April 2016, FCC announced an initial spectrum clearing 

target—the amount of spectrum FCC aimed to clear and repurpose in the 

auction and repack—of 126 MHz. In November 2016, after the first and 

second stages of the forward auction concluded without meeting the 

reserve price, FCC announced a new clearing target of 108 MHz, 

requiring television stations to use channels 2 through 32. As shown in 

figure 3, the number of channels available for both television stations and 

spectrum available for mobile broadband services varies depending on 

the clearing target.
Page 10 GAO-17-135 Low Power Television

Figure 3: Illustration of Broadcast Television Spectrum and Examples of the Incentive Auction’s Spectrum-Clearing Targets

Note: Television channels 2–13 operate in three bands in the VHF spectrum. Channels 2–4 operate 

in 54–72 MHz, channels 5–6 operate in 76–88 MHz, and channels 7–13 operate in 174–216 MHz.

The 2012 act authorized FCC to repack the remaining eligible stations 

and directed FCC to make all reasonable efforts to preserve the coverage 

area and population served of each eligible broadcast television licensee 

when making channel reassignments or reallocations following the 

incentive auction.21 In June 2014, FCC released the incentive auction 

report and order adopting rules to implement the incentive auction and 

subsequent repacking process.22 In the report and order, FCC stated that, 

as required by Congress in the 2012 act, FCC will preserve or protect the 

 21Pub. L. No. 112-96, § 6403(b)(2), 126 Stat. 156, 226. 

22Incentive Auction Report and Order, 29 FCC Rcd 6567, June 2, 2014, Released, May 

15, 2014, Adopted.
Page 11 GAO-17-135 Low Power Television

coverage area and population served by eligible broadcast television 

licensees. Further, FCC concluded that protecting other categories of 

facilities, including LPTV and translator stations, which are—secondary in 

nature and not entitled to protection from primary services under FCC’s 

current rule—would unduly constrain FCC’s flexibility in the repacking 

process and undermine the likelihood of meeting FCC’s objectives for the 

incentive auction. FCC recognized the decision not to extend repacking 

protection and not to guarantee channels for LPTV and translator stations 

will result in some viewers losing service, may negatively affect the 

investments displaced LPTV and translator licensees have made in their 

existing facilities, and may cause displaced licensees that choose to 

move to a new channel to incur the cost of doing so. Although FCC does 

not know the number of affected LPTV and translator stations, FCC 

concluded that these concerns are outweighed by the detrimental impact 

that protecting LPTV and translator stations would have on the repacking 

process and on the success of the incentive auction. In two separate 

cases in December 2015, LPTV licensees and an individual party brought 

suit against FCC over the incentive auction and its potential impact, 

claiming, among other things, that FCC denied protections to LPTV 

stations in the auction and repacking process and that FCC’s actions 

violated the 2012 act.23 In 2016, the U.S. Court of Appeals for the District 

of Columbia Circuit dismissed the petition for review in one case and 

sustained FCC’s orders in the other case. At the time of our review a 

separate, late-filed lawsuit raising similar concerns was ongoing.24

In addition to adopting rules related to the incentive auction and 

subsequent repacking process, the incentive auction report and order 

announced a number of actions intended to make a significant amount of 

spectrum available for unlicensed use, including permitting unlicensed 

operations (1) on channel 37 in locations sufficiently removed from 

incumbent users to protect from harmful interference25 and (2) in the 

 23Pub. L. No. 112-96, 122 Stat. 156, 201(2012). See Mako Communications, LLC; Beach 

TV Properties, Inc. v. FCC, No. 15-1264 and 15-1280, (D.C. Cir. 2015) (These two cases 

were consolidated) and Free Access & Broadcast Telemedia, LLC, et al., v. FCC, No. 15-

1346, (D.C. Cir. 2016 – unpublished opinion).

24Free Access & Broadcast Telemedia, LLC, et al. v. FCC, No 16-1100 (D.C. Cir. 2016).

25Channel 37 is allocated for both wireless medical telemetryservice (WMTS) devices and 

radio astronomy service (RAS). WMTS is used for remote monitoring of patient’s vital 

signs and other important health parameters (such as pulse and respiration rates) inside 

medical facilities.RAS is a receive-only service that uses highly sensitive receivers to 

examine and study radio waves of cosmic origin. 
Page 12 GAO-17-135 Low Power Television

spectrum guard bands.26 Additionally, FCC indicated in the incentive 

auction report and order that it anticipated there would be at least one 

channel in all areas throughout the country not assigned to a television 

station that could be used by unlicensed devices. In June 2015, FCC 

issued an NPRM to this effect, proposing to preserve at least one vacant 

channel in the UHF television band throughout the country.27 The NPRM 

proposes that the channel preserved would be a UHF channel above 

channel 20, and the specific vacant channel preserved could vary 

depending on the particular area.28 This proposal, known as the vacant 

channel proposal, would require LPTV and translator stations displaced 

by the repacking process to demonstrate that any new or modified 

facilities needed for a station to relocate to another channel would not 

eliminate the last remaining vacant channel in an area.29 FCC tentatively 

concluded that the vacant channel proposal would ensure the public 

continues to have access to the significant benefits provided by 

unlicensed devices and wireless microphones across the country. 

According to FCC officials at the time of our review, it had not taken 

further action on the vacant channel NPRM and those matters were still 

under consideration.

Unlicensed devices that operate in the television spectrum band are 

sometimes referred to as white space devices because they operate in 

spectrum “white spaces”—buffer zones FCC established to mitigate 

 26Guard bands are designed to prevent harmful interference between licensed services. 

The “duplex gap” is one such guard band and is the spectrum between the wireless 

broadband uplink and downlink bands.

27Vacant Channel NPRM, 30 FCC Rcd 6711, June 16, 2015, Released, June 11, 2015, 

Adopted.

28According to FCC officials, FCC indicated that it would revise this proposal to propose 

preservation of a UHF vacant channel to apply to Channels 14 and above if the rules for 

unlicensed device operations were revised in a subsequent proceeding, which they were 

in August 2015. In the Matter of Amendment of Part 15 of the Commission’s Rules for 

Unlicensed Operations in the Television Bands, Repurposed 600 MHz Band, 600 MHz 

Guard Band and Duplex Gap, and Channel 37, 30 FCC Rcd 9551, August 11, 2015, 

Released, August 6, 2015, Adopted.

29The NPRM goes on to propose that applications that do not comply with this 

requirement be dismissed. Vacant Channel NPRM, 30 FCC Rcd 6711, June 16, 2015,

Released, June 11, 2015, Adopted.
Page 13 GAO-17-135 Low Power Television

unwanted interference between adjacent stations.30 According to FCC, 

unlicensed devices are an important part of the nation’s communications 

capabilities, serve to augment the operations of licensed services, and 

meet the needs of a wide range of wireless applications including Wi-Fi, 

Bluetooth, baby monitors, and garage door openers. The Consumer 

Electronics Association reported in 2014 that devices using unlicensed 

spectrum generate approximately $62 billion annually in retail-level sales 

and that further estimated growth in the market for devices that rely on 

unlicensed spectrum was “extremely strong.”31

 30The term “white space” devices refer to unlicensed devices operating on television 

channels pursuant to 47 C.F.R Part 15, subpart H. The term “wireless microphones” 

refers to wireless microphones and other low power auxiliary stations licensed pursuant to 

47 C.F.R. Part 74, subpart H, and such similar devices authorized on an unlicensed basis 

pursuant to waiver.

31Consumer Electronics Association,Unlicensed Spectrum and the U.S. Economy: 

Quantifying the Market Size and Diversity of Unlicensed Devices, (May 2014).

LPTV and Translator 

Stations Provide 

Programming and 

Information That 

Might Not Be 

Available to Over-theAir Viewers after the 

Auction
Page 14 GAO-17-135 Low Power Television

Through analysis of FCC data, our survey of LPTV and translator station 

representatives, and meetings with stakeholders as discussed below, we 

obtained information on LPTV and translator stations, including (1) the 

number of such stations and their communities of license,32 (2) types of 

programming and hours of broadcasting, and (3) ownership. Information 

obtained through our survey is non-generalizable.

According to our analysis of FCC data, there were 2,063 LPTV stations 

and 3,660 translator stations in the U.S. and its territories as of May 25, 

2016.33 LPTV stations’ communities of license are shown in figure 4. 

According to one broadcast industry association we interviewed, LPTV 

stations serve a wide range of diverse audiences, including those in both 

rural counties with limited access to full-power stations and in large urban 

areas.

 32According to FCC officials, the community of license is the city and state provided by 

applicants to FCC. FCC does not assign communities of license to LPTV and translator 

stations as it does for full-power and Class A stations.The city and state included in the 

information provided by the LPTV and translator stations may or may not be within the 

area served.

33We previously reported that in addition to originating programming, LPTV stations may 

act as translator stations by retransmitting programming from a primary station. The 

number of such stations is unknown.GAO-11-790.

LPTV and Translator 

Stations Are Diverse in 

Their Programming and 

Owned by Various Types 

of Entities

Number of Stations and 

Communities of License
Page 15 GAO-17-135 Low Power Television

Figure 4: Low Power Television (LPTV) Stations’ Communities of License as of May 2016

Note: LPTV stations’ communities of license are also located in the U.S. territories.

According to our analysis of FCC data, translator stations’ communities of 

license are shown in figure 5. Translator stations tend to be concentrated 

in both rural and mountainous areas where they serve communities that 

cannot receive signals from full-power stations because they are too far 

away or because terrain blocks the signals.
Page 16 GAO-17-135 Low Power Television

Figure 5: Translator Stations’ Communities of License as of May 2016

Note: Translator stations’ communities of license are also located in the U.S. territories.

According to FCC officials, pursuant to the First Amendment, FCC does 

not generally monitor broadcast stations’ content and programming 

choices and because the few public service obligations LPTV stations 

have do not pertain to programming provided. Therefore FCC does not 

collect information on the programming provided by LPTV stations or their 

hours of broadcasting, and we did not identify other sources of such data. 

In our non-generalizable survey of LPTV and translator station 

representatives, respondents representing 535 of the 2,063 LPTV 

stations in the U.S. and its territories provided information about the types 

of programming broadcast by the stations they represent (see fig. 6). 

Survey respondents indicated that most of these stations broadcast 

locally produced programming, and almost half of the stations 

represented by survey respondents broadcast at least 18 hours per day 

Programming and Hours of 

Broadcasting
Page 17 GAO-17-135 Low Power Television

and an average of 3 hours per week of locally produced content, two 

factors similar to requirements for Class A status under the Community 

Broadcaster Protection Act of 1999.34

Figure 6: Broadcasting by Low Power Television (LPTV) Stations Represented by 

Survey Respondents

The locally produced programming broadcast by LPTV stations may be 

diverse and is broadcast in a variety of languages. Through our survey 

we identified examples of such content, including:

 34The Community Broadcaster Protection Act of 1999 set forth the following requirements 

for LPTVs to qualify for Class A status: (1) during the 90 days preceding enactment, 

broadcast a minimum of 18 hours per day; (2) during the 90 days preceding enactment, 

broadcast an average of at least 3 hours per week of programming that was produced 

within the market area served by such station, or the market area served by a group of 

commonly controlled low power stations that carry common local programming produced 

within the market area served by such group; (3) during the 90 days preceding enactment, 

be in compliance with FCC’s requirements applicable to LPTV stations; and (4) from and 

after the date of application for a Class A license, be in compliance with FCC’s operating 

rules for full-power television stations.Pub. L. No. 106-113, § 5008, 113 Stat. 1501, 

1501A-594 (codified at 47 U.S.C. § 336(f)(2)).For the purposes of our survey we defined 

locally produced programming as programming produced within the market area served 

by a particular station or in the market area served by a group of commonly controlled low 

power stations that carry common local programming produced within the market area 

served by such a group. 
Page 18 GAO-17-135 Low Power Television

• programming in languages such as Bosnian, Hmong, Italian, Polish, 

Spanish, and various Native American languages;

• local news, weather, and traffic;

• local sports;

• local information, including community events, political debates, and 

volunteer opportunities;

• local recreational and tourism information such as skiing, fishing, and 

hunting reports;

• public health programming;

• arts and special interest programming such as art and cooking shows; 

and

• children’s programming.

Additionally, survey respondents provided information about programming 

broadcast by the stations they represent that is not locally produced. As 

shown in figure 7, the most common type of non-locally produced 

programming broadcast by LPTV stations represented by survey 

respondents is general entertainment.
Page 19 GAO-17-135 Low Power Television

Figure 7: Broadcast of Non-Locally Produced Programming by Low Power 

Television (LPTV) Stations Represented by Survey Respondents

Table 1 provides examples of these different types of programming that is 

not locally produced. These examples are from our survey, comments to 

FCC, and interviews.
Page 20 GAO-17-135 Low Power Television

Table 1: Examples of Low Power Television (LPTV) Programming That Is Not Locally Produced

Programming category Examples

General entertainment Movies and classic television

Infomercials and home shopping

Children’s programming

Arts programming

News, weather, and information Regional, national, and international news programming

Regional and national weather programming

International news and information from Africa, China, Korea, Mexico, and the Middle East

Informational programming of interest to certain communities such as Native American

communities

Religious Christian programming, including church services, discussions, lectures, Bible study, and music

Spanish-language religious programming, including programming from Central and South 

America

Islamic religious programming

Non-English language Arabic; Armenian; Cambodian; Chinese; Farsi; Japanese; Korean; Malay; Filipino;Russian; 

Samoan; Spanish; Vietnamese; various Indian languages such as Hindi; and various Native 

American languages 

Source: GAO survey of LPTV and translator stations, comments to FCC, and interviews with broadcast industry associations and station ownership groups. | GAO-17-135

Moreover, LPTV stations that broadcast digitally may simultaneously 

transmit multiple signals and therefore can broadcast different content on 

multiple sub-channels.35 For example, representatives of a station 

ownership group told us about programming they broadcast on digital 

sub-channels in the Los Angeles area. On one digital sub-channel, they 

broadcast programming imported from Central America that is the primary 

news source for many of the about 2 million immigrants from Central 

America living in the area, according to these representatives. On another 

digital sub-channel, they broadcast programming imported from 

Cambodia, which is the only Cambodian station in the U.S. and reaches 

between 50,000 and 70,000 Cambodian speakers in the area, according 

to these representatives.

 35Digital technology uses the radiofrequency spectrum more efficiently than analog 

technology and, as a result, provides greater flexibility in terms of the television content 

that television stations can provide. Television stations can transmit a single analog signal 

in the 6 MHz of radio spectrum allocated to each television station. In contrast, with digital 

technology, television stations can use that 6 MHz of spectrum to simultaneously transmit 

multiple signals in standard definition digital format, a concept known as “multicasting.”
Page 21 GAO-17-135 Low Power Television

FCC collects information biennially on racial and ethnic minority and 

female broadcast ownership for certain commercial stations.36 FCC’s 

reports based on this data collection do not present data on the number 

of stations owned by different types of entities such as for-profit, not-forprofit, and governmental. Further, while full-power, Class A, and LPTV 

stations are required to provide this information, FCC officials told us that 

translator stations are not required to submit this information and that, 

according to the most recent report based on these filings, about one third 

of LPTV stations did not file the required reports.37

Our survey collected information on the types of entities that own the 

LPTV and translator stations represented by respondents. As shown in 

figure 8, most of the 535 LPTV stations represented by survey 

respondents are owned by for-profit entities, while more than a third of the 

1,515 translator stations represented by survey respondents are owned 

by governmental entities.38 Ownership of translator stations tends to vary 

depending on factors such as the direct market size of full-power stations 

and geography, according to representatives we interviewed from a 

broadcast industry association. For example, in New Mexico and Oregon, 

where the direct market for full-power stations is less populous, full-power 

stations may own and operate translator stations to extend the reach of 

their programming. In mountainous areas where geography may limit the 

reach of full-power stations, translator stations tend to be locally owned 

by governmental entities or other community organizations, according to 

a broadcast industry association we interviewed.

 3647 C.F.R. § 73.3615(a).

37Promoting Diversification of Ownership in the Broadcasting Services, Report on 

Ownership of Commercial Broadcast Stations, 29 FCC Rcd 7835, June 27, 2014, 

Released.

38Governmental entities include cities, counties, tribes, and community entities such as

community translator associations.Not all station representatives indicated the type of 

entity or entities that own the station(s) they represent, so numbers do not add to the total 

number of stations represented by survey respondents. 

Ownership
Page 22 GAO-17-135 Low Power Television

Figure 8: Types of Entities That Own the Low Power Television (LPTV) and Translator Stations Represented by Survey 

Respondents

Note: Some survey respondents indicated that the stations they represent are ow ned by entities that 

fit in multiple categories such as educational and governmental or some other combination.

Ownership type and structure may affect stations’ vulnerability in the 

auction even in areas where spectrum is available following the auction, 

according to various stakeholders as discussed below.

• Government- and community-owned stations typically rely on 

municipal budgets and tax revenues to operate, and in some cases 

the community served would have to raise taxes or dues to obtain the 

capital necessary to relocate, according to representatives from two 

broadcast industry associations we interviewed and three survey 

respondents.

• Stations owned by for-profit, not-for-profit, and educational entities 

may not be able to afford the capital costs required to relocate, 

particularly when the entity operates on a small budget, according to 

two broadcast industry associations we interviewed and two survey 

respondents. For example, while some translator stations may be 

owned by station ownership groups that own a portfolio of stations—

including full-power stations, Class A stations, or both—of the 115 

station representatives who completed our survey, more than twothirds (81) represent 10 stations or fewer, and 33 respondents 

represent a single station. Further, according to a station ownership 

group we interviewed securing financing to fund relocation costs is 

difficult because investors are unwilling to invest in LPTV and 

translator stations because of their uncertain future.
Page 23 GAO-17-135 Low Power Television

• Some station owners, regardless of the type of ownership entity, use 

revenue from stations in more populated areas to supplement funding 

for the operation of stations in less populated areas. For example, 

station representatives who operate three LPTV stations serving 

Native American communities told us that the stations serving less 

populated areas would not be able to operate without supplemental 

revenue from the stations serving more populated areas.39 According 

to these representatives, these stations provide diverse programming 

such as locally produced Native American cultural programming, 

educational programming, information on tribal affairs, and 

programming in multiple Native American languages.

We found LPTV and translator station viewers may lose access to 

programming or emergency alert information through several possible 

ways, including the following:

• Alternatives to broadcast programming are cost-prohibitive or 

unavailable: Many LPTV and translator station viewers are 

economically or geographically disadvantaged and may not be able to 

afford other options for accessing programming such as for satellite 

television or broadband Internet, according to two broadcast industry 

associations we interviewed and six survey respondents, among 

others. For example, one survey respondent, a county 

treasurer/recorder in a rural area, described the situation for viewers 

of the county’s translator stations. The county charges each 

household $30 per year for television service. The survey respondent 

said that there are many county residents who are elderly, on fixed 

incomes, or otherwise low-income and cannot afford to pay a higher 

monthly television subscription fee, such as satellite service. Further, 

some viewers live in areas where paid television service or broadband 

service, or both are unavailable, according to one broadcast industry 

association we interviewed, a station ownership group, and one 

survey respondent.

• Niche programming: Viewers of locally produced programming and 

niche programming, such as the programming described above, may 

lose access to this programming, and similar programming may not 

be available through the remaining over-the-air broadcast channels 

according to three broadcast industry associations and a station 

ownership group we interviewed. For example, if an LPTV station 

 39We obtained information from these station representatives while pre-testing our survey.

The Incentive Auction 

Could Affect Viewers’

Ability to Receive LPTV 

and Translator Stations’

Programming and 

Televised Emergency 

Information
Page 24 GAO-17-135 Low Power Television

broadcasting non-English-language programming in a city is displaced 

in the incentive auction and cannot find an available channel in the 

repack, its viewers may have no other options for similar 

programming. Moreover, LPTV stations that provide niche 

programming to a particular audience in a particular area could be 

forced out of business following the incentive auction and repack even 

if they are able to find available spectrum in the repack. For example, 

a non-English language channel may exist to serve a segment of the 

population that resides in a small pocket of an urban area. If 

displaced, that channel may be unable to relocate to a replacement 

channel that would reach its primary viewers, as shown in figure 9. 

Without access to its primary viewers, the station may not be able to 

raise the funds necessary to continue operation.

Figure 9: Illustration of Situation Where a Station That Relocates after the Incentive Auction Would be Unable to Reach All of 

Its Primary Viewers

• Televised emergency alerts: Some viewers in geographically remote 

areas receive broadcast television signals only from a station or 

stations that are not protected in the incentive auction and repack, 

meaning the station might be unable to relocate and thus cease 

broadcasting. Viewers in these areas may no longer have access to 

televised emergency alerts. Of the 2,050 LPTV and translator stations 
Page 25 GAO-17-135 Low Power Television

represented by survey respondents, more than 10 percent (211) serve 

areas that receive no service from full-power or Class A stations, 

according to survey respondents. Moreover, of the 1,515 translator 

stations represented by survey respondents, 433 rebroadcast signals 

received from another translator station and 212 send signals to 

another translator station. This interconnectedness among translator 

stations could compound these stations’ vulnerability in the auction, 

according to representatives of a broadcast industry association that 

represents translator stations. Although it is possible for LPTV or 

translator stations to serve as the only source of televised emergency 

alerts, FCC considered whether such stations should have special 

priority in the repacking process and declined to adopt any such 

measures. In particular, in a 2012 NPRM FCC sought comment on 

whether the public interest would be served by establishing a set of 

selection priorities to choose among applications of displaced LPTV 

and translator stations and on the types of selection priorities to 

adopt.40 In the incentive auction report and order, FCC declined to 

adopt the particular selection priorities suggested by commenters in 

the NPRM, including providing priority for stations that are primary 

Emergency Alert System providers.41

As noted previously, FCC has acknowledged that the incentive auction 

will potentially displace some LPTV and translator stations.42 FCC officials 

told us they have not systematically analyzed the potential displacement 

impact on LPTV or translator stations because of Congress’s 

determination not to include these stations in the auction or protect them 

in the repacking process.43 As discussed below, FCC has taken some 

actions to try to mitigate the auction’s effects on these stations.

 40In the Matter of Expanding the Economic and Innovation Opportunities of Spectrum 

Through Incentive Auctions, 27 FCC Rcd 12357, Released, October 2, 2012, Adopted, 

September 28, 2012.

41Incentive Auction Report and Order, 29 FCC Rcd 6567, June 2, 2014, Released, May 

15, 2014,Adopted. 

42Incentive Auction Report and Order, 29 FCC Rcd 6567, Released, June 2, 2014, 

Adopted, May 15, 2014. LPTV and Translator Report and Order Auctions;Amendment of 

Part 15 of the Commission’s Rules to Eliminate the Analog Tuner Requirement, 30 FCC 

Rcd 14927, December 17, 2015,Released, December 16, 2015,Adopted.

43FCC officials told us that while the auction will by definition result in fewer channels 

available for television stations, the impact on LPTV and translator stations depends in 

large part on the outcome of the auction.
Page 26 GAO-17-135 Low Power Television

According to FCC officials, FCC’s actions to mitigate the effects of the 

incentive auction include: (1) channel sharing, (2) the digital transition 

deadline, (3) FCC’s optimization software, and (4) cross-border 

coordination.44 While broadcast industry associations generally expressed 

support for these measures in comments to FCC, some representatives 

of these groups told us and stated in comments to FCC that the actions 

will not do much to mitigate the effects of the incentive auction on LPTV 

and translator stations.45 Moreover, we asked the 115 representatives of 

535 LPTV and 1,515 translator stations who responded to our survey to 

rate the usefulness of these four measures, and, in all but one case, the 

number of both LPTV and translator stations represented by respondents 

was greater for those who rated the action as not useful. Furthermore, 

those who rated these measures as useful often did so with caveats.

In the LPTV and translator report and order, FCC announced that it will 

allow channel sharing among LPTV and translator stations and proposed 

allowing channel sharing between LPTV and translator stations and fullpower and Class A stations.46 Stations that enter into such agreements 

 44FCC officials discussed additional rule changes outlined in the incentive auction report 

and order that were intended to mitigate the effects of the incentive auction on LPTV and 

translator stations. For example, FCC adopted rules permitting LPTV and translator 

stations to continue operations on their existing channel assignment until the forwardauction bidder is ready to build. This rule and other actions can be found in the incentive 

auction report and order, Incentive Auction Report and Order, 29 FCC Rcd 6567, June 2, 

2014, Released, May 15, 2014,Adopted.

45Throughout the report we use “some” when three or more stakeholder sources 

combined supported a particular idea or statement.

46LPTV and Translator Report and Order, 30 FCC Rcd 14927, December 17, 2015, 

Released, December 16, 2015,Adopted.

Selected 

Stakeholders View 

FCC’s Actions as 

Having Limited 

Usefulness and Have 

Proposed Additional 

Actions to Mitigate 

the Auction’s Effects

Selected Stakeholders 

View FCC’s Actions as 

Helpful in Some 

Circumstances but 

Insufficient

Channel Sharing
Page 27 GAO-17-135 Low Power Television

may divide the capacity of the shared channel however they would like, 

as long as each station retains spectrum usage rights sufficient to 

transmit at least one standard definition programming stream at all times, 

but will continue to be licensed separately and will separately be subject 

to FCC’s obligations, rules, and policies.47 According to FCC, these 

measures have the potential to be beneficial to LPTV and translator 

stations, and some broadcast industry associations expressed support of 

these measures in comments to FCC. However, all of the broadcast 

industry associations with whom we discussed the issue stated that 

allowing LPTV and translator stations to enter into channel-sharing 

agreements will not be helpful in a meaningful way.48 For example, a 

representative from one broadcast industry association told us that 

channel sharing would likely require stations to degrade their signal, 

which may inhibit multicasting and the use of high-definition signals, and 

another broadcast industry association told us that stations will use 

channel sharing only as a last resort. Additionally, as shown in table 2 

below, survey respondents representing more stations rated channel 

sharing as not useful, than useful.

 47LPTV and Translator Report and Order, 30 FCC Rcd 14927, December 17, 2015, 

Released, December 16, 2015,Adopted.

48An industry association representing translator stations said that channel sharing might 

be helpful for LPTV stations but will not be helpful for translator stations.
Page 28 GAO-17-135 Low Power Television

Table 2: Views on Usefulness of Channel Sharing Provided by Survey Respondents Representing Low Power Television 

(LPTV) and Translator Stations

Usefulness 

rating

Number of 

LPTV stations 

represented

Number of 

translator stations 

represented Key responses 

Useful 195 292 Channel sharing may help LPTV and translator stations stay in business; for 

many, it may be the only alternative.

Channel sharing may help LPTV and translator stations stay in business, 

but it will reduce the visibility and identity of stations, and it may be cost 

prohibitive for many stations.

Not useful 285 924 It is unlikely that there will be stations with which to share channels because 

(1) there are no other stations in the area we serve, (2) there are likely to be 

too few stations in the area we serve remaining after the auction, and/or (3) 

remaining stations may not be able to share due to technical limitations or 

may not want to share.

Channel sharing may undermine the business case because it may limit 

multicasting and/or degrade picture quality.

Channel sharing may be cost prohibitive. For example, one survey 

respondent reported that another station would have charged $1,000,000 to 

share an antenna.

Source: GAO survey of LPTV and translator stations. | GAO-17-135

In the LPTV and translator report and order, FCC announced it will use its 

incentive auction and repacking optimization software to identify channels 

that will be available for displaced stations. FCC plans to publish a list of 

available channels 60 days prior to the beginning of the LPTV and 

translator displacement window, and displaced stations will be able to use 

this information when applying for replacement channels.49 While FCC 

stated in the LPTV and translator report and order that this proposal 

garnered considerable support from broadcast industry associations, 

representatives from the four broadcast industry associations that 

mentioned this measure to us said that it will be minimally helpful. 

Specifically, one broadcast industry association told us that it will provide 

almost no help to LPTV stations, and another stated that the measure is 

hollow and will have limited effect, if any. Additionally, as shown in table 3 

below, survey respondents representing more stations rated this measure 

as not useful, than rated it as useful.

 49LPTV and Translator Report and Order, 30 FCC Rcd 14927, December 17, 2015, 

Released, December 16, 2015,Adopted.

Optimization Software
Page 29 GAO-17-135 Low Power Television

Table 3: Views on Usefulness of Optimization Software Provided by Survey Respondents Representing Low Power Television 

(LPTV) and Translator Stations

Usefulness 

rating

Number of 

LPTV stations 

represented

Number of 

translator stations 

represented Key responses

Useful 169 449 May save LPTV and translator station owners’ time and money, especially if 

there is no charge.

Will hire consulting engineers or use in-house engineers, but this software 

may simplify the process of identifying new channels.

Not useful 318 747 Will still need to hire consulting engineers or use in-house engineers.

The translator network on which our station(s) rely is complex and best 

engineered by those with on-the-ground experience with the network.

It is unlikely that there will be sufficient spectrum in our area following the 

auction; software will not change that.

Source: GAO survey of LPTV and translator stations. | GAO-17-135

In the LPTV and translator report and order, FCC extended the deadline 

by which analog LPTV and translator stations must complete the 

transition to digital so that stations would not have to make significant 

capital investments to meet the digital transition deadline, only to face 

possible displacement in the auction and repack process.50 According to 

FCC, the September 2015 deadline had been established in anticipation 

of the auction being conducted in 2014. While FCC cited broad support 

from the LPTV and translator industry for this measure, two broadcast 

industry associations stated in comments to FCC that this action was 

more a common sense policy change than an action to mitigate the 

effects of the auction. These commenters said it was only fair for FCC to 

extend the date given the cost associated with transitioning to digital and 

then potentially relocating after the auction. As shown in table 4 below, 

survey respondents representing more stations rated extending the digital 

transition deadline as not useful, than useful.

 50The report and order extended the deadline from September 2015 until 12 months 

following the completion of the 39-month post-auction transition period for full-power and 

Class A stations reassigned to a new channel. LPTV and Translator Report and Order, 30 

FCC Rcd 14927, December 17, 2015, Released, December 16, 2015,Adopted.

Digital Transition Deadline
Page 30 GAO-17-135 Low Power Television

Table 4: Views on Usefulness of Extending the Digital Transition Deadline Provided by Survey Respondents Representing 

Low Power Television (LPTV) and Translator Stations

Usefulness 

rating

Number of 

LPTV stations 

represented

Number of

translator stations 

represented Key Responses

Useful 212 201 This extension will enable stations to avoid the capital investment required to 

meet the digital transition deadline only to face possible displacement in the 

auction and repack process, an outcome that could require additional capital 

outlay or loss of the station.

Some stations may need additional time to transition to digital.

Not useful 228 974 Our stations are already broadcasting in digital.

Source: GAO survey of LPTV and translator stations. | GAO-17-135

In the LPTV and translator report and order, FCC addressed commenters’

suggestions that FCC develop a streamlined approach to coordinating 

with foreign governments on the interference and application approval 

process to address situations where stations’ signals may cross an 

international border, such as into Canada or Mexico. FCC stated that the 

cross-border coordination process is continual and that FCC has used its 

existing processes to keep Canada and Mexico fully informed on the 

incentive auction coordination issues. FCC further stated that it intends to 

make efforts to streamline the cross-border coordination processes so 

that it will not delay the post-auction displacement application process for 

LPTV and translator stations. As shown in table 5 below, a greater portion 

of LPTV stations were represented by survey respondents that rated this 

measure as useful than not useful, whereas the opposite is true for 

translator stations. However, regarding cross-border coordination, survey 

respondents provided similar responses regardless of the rating they 

provided.

Table 5: Views on Usefulness of Improving Cross-Border Coordination Provided by Survey Respondents Representing Low 

Power Television (LPTV) and Translator Stations

Usefulness 

rating

Number of 

LPTV stations 

represented

Number of 

translator stations 

represented Key responses

Useful 267 293 Our stations are on the border, and cross-border coordination can take 

years. Any streamlining that reduces delay would be helpful.

Our stations are not on the border, but this seems like it would help 

stations that are.

Not useful 165 651 Given history of cross-border coordination, skeptical that any streamlining 

will be possible.

Our stations are not near the border.

Source: GAO survey of LPTV and translator stations. | GAO-17-135

Cross-Border Coordination
Page 31 GAO-17-135 Low Power Television

In addition to the measures discussed above, the broadcast industry 

associations and station ownership groups we interviewed and the station 

representatives who responded to our survey identified other actions they 

believe FCC or Congress could take that could help mitigate the effects of 

the incentive auction on LPTV and translator stations. The proposals that 

arose the most frequently in the interviews and survey were: (1) 

reconsidering various aspects of the auction, (2) providing funding for 

relocation costs incurred by LPTV and translator stations displaced in the 

auction, (3) allowing LPTV and translator stations to operate with 

alternative technical standards, and (4) providing LPTV and translator 

stations an opportunity to obtain primary interference protection status, 

which would protect these stations from future displacement by primary 

services.51

The suggestions that arose most frequently related to FCC reconsidering 

various aspects of the incentive auction. For example, 15 survey 

respondents suggested that FCC protect LPTV and translator stations in 

the incentive auction and repack; 12 survey respondents suggested that 

FCC or Congress provide compensation for lost spectrum rights to 

displaced LPTV and translator stations; 7 survey respondents suggested 

that FCC provide protection in the auction and repack for certain types of 

stations such as rural translator stations, tribally owned stations, and 

stations broadcasting locally produced content; 6 survey respondents 

suggested that FCC or Congress cancel the auction; and 5 survey 

respondents suggested that FCC provide LPTV and translator stations 

more time to move channels. Regarding these and similar suggestions 

raised in the incentive auction proceeding, FCC stated in the LPTV and 

translator report and order that the proposed measures were fully 

considered in the incentive auction rulemaking proceeding and 

subsequent orders and FCC declined to revisit them.

The second most frequent suggestion related to FCC or Congress 

providing funding for relocation costs incurred by LPTV and translator 

stations that are displaced in the auction, either through a grant program 

or through reimbursement of expenses. While FCC has studied the costs 

 51Suggestions that arose less frequently include granting must-carry rights for LPTV and 

translator stations displaced in the auction; granting certain LPTV and/or translator 

stations priority in the post-auction repack and beyond; altering distance, coverage 

overlap, or interference standards, and allowing LPTV and translator stations facing 

financial challenges to remain off the air for a certain time period. Similar proposals were 

also raised in comments to FCC, and FCC declined to address them, concluding that FCC 

had already resolved the issues in prior orders.

Stakeholders Suggested a 

Variety of Actions to Help 

Mitigate the Potential 

Impact of the Auction

Reconsider Various Aspects of 

the Auction

Provide Funding for Relocation 

Expenses
Page 32 GAO-17-135 Low Power Television

associated with relocating eligible full-power and Class A stations that are 

reassigned to new channels during the repack process,52 FCC officials 

told us that because Congress did not make LPTV or translator stations 

eligible to be reimbursed for certain relocation costs, the officials have not 

studied the costs associated with relocating LPTV and translator stations. 

A broadcast industry association we interviewed indicated that the costs 

for relocating LPTV and translator stations vary widely depending on a 

number of factors such as the distance of the move; whether a new tower 

will be required; and the availability of engineers, tower crews, and 

equipment. Of the 83 survey respondents that represent LPTV stations, 

28 respondents reported estimated relocation costs ranging from $25,000 

to over $600,000 per station. Of the 50 survey respondents that represent 

translator stations, 15 respondents reported estimated relocation costs for 

their stations ranging from approximately $8,500 to approximately 

$37,500, with an additional $100,000 per site if microwave equipment 

were required.53 FCC addressed similar suggestions in the LPTV and 

translator report and order and in previous orders related to the incentive 

auction and stated that the decision whether to authorize such funding is 

Congress’s prerogative and that the 2012 act limits reimbursement to fullpower and Class A stations.54

Half of the broadcast industry associations we interviewed, all of the 

station ownership groups we interviewed, and 13 survey respondents 

proposed various measures by which FCC would allow LPTV and 

translator stations to operate with different technical standards or network 

architectures.55 Proposals include enabling broadcasters to seek 

innovative ways to use their spectrum and adopting Advanced Television 

 52Widelity, Inc., Response to the Federal Communications Commission for the 

Broadcaster Transition Study Solicitation (Dec. 30, 2013).

53According to representatives from one broadcast industry association, microwave 

equipment would allow stations to use microwave frequencies rather than television 

channels to retransmit programming to other translator stations.

54Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96 § 6402, 126 

Stat. 156, 224 (codified at 47 U.S.C. § 309(j)(8)(G)). LPTV and Translator Report and 

Order, 30 FCC Rcd 14927, Released, December 17, 2015, Adopted, December 16, 2015. 

Incentive Auction Report and Order, 29 FCC Rcd 6567, June 2, 2014, Released, May 15, 

2014,Adopted.

55According to FCC officials, network architecture is the method of deploying equipment 

for broadcasting a television signal. For instance, many stations transmit their signals on 

their assigned channel from one location on one antenna.

Permit Use of Alternative 

Technical Standards
Page 33 GAO-17-135 Low Power Television

Systems Committee (ATSC) 3.0.56 ATSC 3.0 is an alternative technical 

standard for digital broadcast television that, according to proponents, 

has the potential to enhance the viewing experience, provide for more 

robust signaling, expand diverse programming opportunities, enhance 

emergency alert capabilities, and provide for new service offerings. 

Additionally, some broadcast industry association representatives we 

interviewed stated that timely adoption of ATSC 3.0 or other alternative 

technical standards for digital broadcast television would enable many 

LPTV and translator stations to survive the auction because stations 

would be more efficient in their use of spectrum, freeing more spectrum 

for broadcast use in the repack. In the LPTV and translator report and 

order, FCC stated that consideration of alternative technical standards, 

including ATSC 3.0, is outside of the scope of the incentive auction 

proceeding and is better left for future proceedings.57 In April 2016, 

several broadcast industry stakeholders filed a joint petition for 

rulemaking asking FCC to amend its rules to allow broadcasters to use 

ATSC 3.0, and later that month FCC issued a public notice seeking 

comment on the petition, with comments due in June 2016. According to 

FCC officials, these comments are under consideration and FCC could 

decide to issue an NPRM; however, as of September 2016, FCC has not 

announced a timeline for doing so.

Two broadcast industry associations and a station ownership group we 

interviewed as well as some survey respondents suggested that FCC 

provide an opportunity for LPTV and/or translator stations to obtain 

primary interference protection status, such as Class A status or some 

other designation, to avoid future displacement by primary users. Some 

proponents stated that such a measure would provide more certainty for 

the industry going forward, which in turn would enable investment in the 

industry. In the LPTV and translator report and order, FCC declined all 

proposals that would allow LPTV and/or translator stations to obtain 

primary interference protection status before the completion of the postauction transition period, but stated that FCC may consider at a later date 

whether to allow LPTV and/or translator stations to obtain primary status 

after the completion of this period.

 56ATSC is an international non-profit organization developing voluntary standards for 

digital television. ATSC works to coordinate television standards among different 

communications media focusing on digital television, interactive systems, and broadband 

multimedia communications.

57LPTV and Translator Report and Order, 30 FCC Rcd 14927, December 17, 2015,

Released, December 16, 2015, Adopted.

Provide Opportunity to Obtain 

Primary Interference Protection 

Status
Page 34 GAO-17-135 Low Power Television

Through our interviews with selected stakeholders—including six 

broadcast industry associations, three station ownership groups, two 

technology companies, a technology industry association, and a public 

interest group—and analyzing comments filed with FCC, we identified 

four primary expected outcomes of preserving a vacant television 

channel:58 (1) loss of existing broadcast service, (2) development of new 

technologies and innovation, (3) improvement of Wi-Fi Internet, and (4) 

improvement of rural broadband service. FCC officials told us these 

outcomes are the main outcomes stakeholders discuss in comments 

submitted to FCC. The broadcast industry associations and station 

ownership groups generally opposed the proposal, while the technology 

companies, the technology industry association, and the public interest 

group were proponents of the proposal. As discussed below, 

stakeholders expressed varying views about the expected outcomes.

Representatives from all the broadcast industry associations told us that 

preserving a vacant channel will result in a loss of existing broadcast 

television service for viewers. For example, a representative from one 

broadcast industry association told us the vacant channel proposal will 

force existing LPTV and translator stations off the air because there will 

be one less channel where a displaced LPTV or translator station can 

relocate and that many rural and underserved communities will likely lose 

access to the broadcast stations on which they rely. Additionally, 

representatives of the three station ownership groups we interviewed also 

expressed concern that the vacant channel proposal would result in a 

loss of existing broadcast service. A representative from one of these 

groups told us the vacant channel proposal will exacerbate the challenges 

faced by LPTV stations by taking at least one more channel and 

preventing them from relocating there following a stations displacement 

after the incentive auction.

In the vacant channel NPRM, FCC stated a tentative conclusion that the 

proposal, if adopted, would not be a significant burden in terms of the 

availability of channels for future use for broadcasters, including LPTV 

 58As described previously, FCC’s vacant channel NPRM stated that if adopted, following 

the incentive auction, FCC intended to preserve a vacant channel for use by white space 

devices, such as Wi-Fi Internet and Bluetooth, and wireless microphones. According to 

the proposal, this vacant channel would not be assigned to a television station in the 

repacking process following the incentive auction. As of September 2016, FCC was 

accepting input on the vacant channel proposal and officials told us FCC has not 

announced a timeline for making a final decision on the proposal.Vacant Channel NPRM,

30 FCC Rcd 6711, June 16, 2015, Released, June 11, 2015, Adopted.

Selected 

Stakeholders 

Expressed Varying 

Views on Outcomes 

of Preserving a 

Vacant Television 

Channel

Loss of Existing Broadcast 

Service
Page 35 GAO-17-135 Low Power Television

and translator stations. The NPRM further stated that the impact will be 

limited because multiple vacant channels will still exist in all or most areas 

after the channel repack. FCC officials told us they have not conducted a 

systematic analysis on the expected effects of the vacant channel 

proposal on LPTV and translator stations, but noted they proposed 

preserving a vacant channel because of the overall potential publicinterest benefits expected from doing so. The officials noted that FCC 

used available information including comments filed with FCC to inform 

the proposal and that they sought additional comment on the proposals 

and tentative conclusions contained in the NPRM. The officials told us 

that the National Association of Broadcasters (NAB) and Google had 

each submitted filings to FCC that included analysis on the expected loss 

of service effects of preserving a vacant channel and that the studies 

reached very different conclusions. According to NAB’s analysis, the 

number of LPTV and translator stations that would go off the air if the 

vacant channel proposal were adopted ranged from 347 stations to 433 

stations, depending on the amount of spectrum that FCC ultimately clears 

in the auction.59 The analysis concluded that FCC’s proposal would have 

a devastating impact on LPTV and translator stations and the viewers 

who rely on those stations to receive over-the-air signals. On the other 

hand, Google’s analysis found that FCC’s vacant channel proposal would

have minimal impact on LPTV and translator stations. Google analyzed 

five markets selected for a variety of reasons including, to represent 

areas with large numbers of LPTV and translator stations, mountainous 

terrain, large rural areas, and urban areas to identify which LPTV and 

translator stations, if any, would be unable to continue operations as a 

result of FCC’s proposed rule. Google concluded that for the typical 

viewer, in the majority of scenarios, no LPTV or translator station will be 

affected. The analysis also indicated that in 72 percent of the nearly 400 

counties included in the analysis, not a single station would be affected, 

and that even in the specific counties likely to be the most affected, the 

preservation of a vacant channel will have only a small impact. Both NAB 

and Google have submitted comments to FCC critiquing the other’s 

conclusions.

Proponents of FCC’s vacant channel proposal whom we interviewed and 

who commented on the proposal generally expect it will contribute to 

innovation and the development of new technologies. In our analysis of 

 59As discussed previously, according to our analysis of FCC data, there were 2,063 LPTV 

stations and 3,660 translator stations in the U.S. and its territories as of May 25, 2016.

Development of New 

Technologies and Innovation
Page 36 GAO-17-135 Low Power Television

comments filed with FCC by proponents of the vacant channel proposal, 

at least five groups expressed the idea that preserving vacant channels 

would help the development of new technologies. For example, one of 

these commenters noted that ensuring unlicensed devices have 

nationwide access to spectrum in the reallocated television spectrum 

band will promote investment and innovation in these technologies. In 

comments filed by another proponent of the proposal, the group stated 

reserving at least one vacant television channel in every market 

nationwide for public use on an unlicensed basis is essential to spurring 

investment and achieving the enormous public interest benefits of 

developing new personal portable devices. The commenter went on to 

state that ensuring a substantial amount of unlicensed spectrum on a 

nationwide basis is critical for developing markets for new, innovative, 

and affordable chips, devices, applications, and services.

Three of the four proponents of the proposal to preserve a vacant channel 

whom we interviewed told us that three channels for unlicensed use are 

needed to develop new technology and that preserving a vacant 

television channel would contribute to this needed amount of spectrum.60

As discussed previously, FCC’s incentive auction report and order 

announced a number of actions intended to make more spectrum 

available for unlicensed use, including permitting unlicensed operations 

on channel 37 (in locations sufficiently removed from incumbent users to 

protect from harmful interference) and in the spectrum guard bands. 

Taken together, these measures will provide two of the three channels 

that, according to proponents of the vacant channel proposal, are needed 

to develop new technologies. For example, one of the proposal’s 

proponents told us that unless FCC guarantees there will be three 

channels available nationwide for unlicensed use, it is very unlikely that 

new mobile uses will move forward into production. This proponent 

explained that for companies to invest the money needed to develop new

unlicensed technologies and innovate, companies need certainty that 

sufficient spectrum will be available to invest the tens of millions of dollars 

needed for development. This proponent also commented that this is 

particularly important because insufficient spectrum (i.e., less than three 

channels) in even a single major market, such as Los Angeles, would 

result in companies not investing money to develop new technologies. 

This proponent said that FCC’s adopting the vacant channel proposal 

 60The fourth proponent of the proposal told us that the business model for white space 

devices requires at least two TV channels be available on a nationwide basis.
Page 37 GAO-17-135 Low Power Television

would help provide this certainty by providing a third channel for 

nationwide unlicensed use.

All representatives from the four organizations we interviewed who are 

proponents of the vacant channel proposal expect the proposal could 

result in improving Wi-Fi Internet.61 Specifically, they told us that the 

proposal could improve Wi-Fi because of the characteristics associated 

with the UHF television spectrum band. They noted that while traditional 

Wi-Fi has a relatively limited range and can be blocked by walls or other 

environmental barriers, Wi-Fi operating in the UHF television spectrum 

band can travel much farther and penetrate obstacles such as buildings 

and hills. Representatives of two groups supporting the vacant channel 

proposal told us that because of the long-range characteristics and ability 

to travel farther through obstructions, Wi-Fi could be expanded more 

thoroughly throughout homes and businesses giving people greater 

connectivity. One of these proponents also added that this could help 

extend coverage to people who might not have affordable access to the 

Internet.

Stakeholders we interviewed supporting FCC’s vacant channel proposal 

generally expect the proposal could result in improved and expanded 

broadband Internet service in rural areas. Specifically, three of the four 

proponents of the proposal we interviewed told us that preserving a 

vacant channel could contribute to improved and expanded broadband in 

rural areas by allowing people to connect their homes and businesses 

wirelessly to the Internet. One proponent told us that in rural areas, 

unlicensed spectrum use allows consumers to connect to the Internet 

wirelessly from their home or business. They noted that this use of 

spectrum is currently occurring and that preserving a vacant channel 

could help lower costs and improve the technology, thus improving and 

expanding broadband in rural areas.

We provided a draft of this report to FCC for review and comment. FCC 

provided technical comments, which we incorporated into the report as 

appropriate.

 61Wi-Fi (wireless fidelity) signals are radio waves that provide Internet access to devices 

equipped with compatible wireless hardware. Each Wi-Fi access point is identified by a 

unique hardware address. Nearby compatible devices are able to receive this information 

and use it to request Internet access.

Improvement of Wi-Fi Internet

Improvement of Rural 

Broadband Service

Agency Comments
Page 38 GAO-17-135 Low Power Television

We are sending copies of this report to the Chairman of FCC and 

appropriate congressional committees. In addition, the report is available 

at no charge on GAO’s website at http://www.gao.gov.

If you or members of your staff have any questions about this report, 

please contact me at (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. Major contributors to this report 

are listed in appendix III.

Mark L. Goldstein

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-17-135 Low Power Television

This report focuses on the possible effects of the Federal Communication 

Commission’s (FCC) spectrum incentive auction on low power television 

(LPTV) and translator stations and their viewers. Specifically, our 

objectives were to examine (1) what is known about LPTV and translator 

stations and how FCC’s spectrum incentive auction might affect viewers’

access to the stations’ services, (2) selected stakeholder views on actions 

has proposed or taken to mitigate the possible effects of the incentive 

auction on LPTV and translator stations, and additional stakeholder 

proposals for doing so, and (3) selected stakeholder views on the

expected outcomes of preserving a vacant channel for unlicensed use of 

the television broadcast spectrum.

To determine what is known about LPTV and translator stations and how 

FCC’s spectrum incentive auction might affect viewers’ access to these 

services, we reviewed FCC documents related to the incentive auction, 

including FCC’s June 2014 incentive auction report and order1 and FCC’s 

December 2015 LPTV and translator report and order.2 We obtained data 

from FCC’s Consolidated Database System (CDBS) as of May 25, 2016, 

to determine the number of LPTV and translator stations in the U.S. and 

its territories along with the communities of license. We determined the 

data were reliable for our purposes after reviewing FCC user guides and 

forms for CDBS and interviewing knowledgeable FCC officials regarding 

data entry and analysis procedures. We also conducted a web-based 

survey of LPTV and translator stations to obtain information on LPTV 

station programming, ownership of LPTV and translator stations, and 

station representatives’ views on actions that FCC has proposed or taken 

and actions Congress or others could take to mitigate the effects of the 

incentive auction on LPTV and translator stations. For the web-based 

survey, we obtained LPTV’s and translator station representatives’ e-mail 

addresses from CDBS; however, because CDBS did not include e-mail 

addresses for representatives of all of the 2,063 LPTV and 3,660 

translator stations, we sent survey invitations for all LPTV and translator 

station representatives for whom we could obtain e-mail addresses. We 

supplemented the e-mail addresses obtained from CDBS with addresses 

obtained from station representatives and in total identified 330 valid email addresses for LPTV and translator station representatives. Because 

 1Incentive Auction Report and Order, 29 FCC Rcd 6567, June 2, 2014, Released, May 15, 

2014,Adopted.

2LPTV and Translator Report and Order, 30 FCC Rcd 14927, December 17, 2015,

Released, December 16, 2015, Adopted.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-17-135 Low Power Television

the e-mail addresses do not represent all LPTV and translator stations, 

the results of our survey are not generalizable and are only used for 

descriptive purposes. After preparing draft survey questions and 

response categories, we spoke with representatives from three broadcast 

industry associations and a translator station representative chosen for 

their broad industry perspective and expertise in particular segments of 

the industry to determine whether selected questions were answerable by 

station representatives and whether the response categories provided 

were appropriate, and updated our survey accordingly. We then pretested our survey with four representatives of LPTV and/or translator 

stations—selected to provide for variety in type of station (LPTV and 

translator), number of stations represented, and geography—to ensure 

that our survey questions and skip pattern were clear and logical and that 

respondents could answer the questions without undue burden. In the 

course of pre-testing our survey, we also obtained information that we 

present in this report. We administered the survey from June 2016 

through August 2016 and received 115 responses. These responses 

represent 535 of the 2,063 LPTV stations, and 1,515 of the 3,660 

translator stations in the U.S. and its territories. In our report, we provide 

survey results based on the number of respondents to each question. 

Because not all respondents answered every question of the survey, the 

total number of respondents may be fewer than 115 for some results. The 

results of our survey are not generalizable, and we did not verify 

respondents’ responses. We also interviewed officials from FCC to 

determine what information they had regarding LPTV and translator 

stations and how the incentive auction might affect viewers’ access to 

these services.

To determine stakeholder views on actions FCC has proposed or taken to 

mitigate the possible effects of the incentive auction on LPTV and 

translator stations, and additional stakeholder proposals for doing so, we 

reviewed selected comments and other filings associated with the

incentive auction proceeding. We selected the comments for review by 

performing keyword searches on filings submitted between October 9, 

2014, (when FCC sought comment on a number of issues related to 

LPTV and translator stations, including additional means to mitigate the 

potential impact of the incentive auction and repacking process on these 

stations) and April 1, 2016, to allow additional time to include comments 

filed after end of the formal comment process. We reviewed filings from 

entities that filed more than one comment, reply to comment, letter, or 

notice of ex parte in this time period. We also interviewed broadcast 

industry associations and station ownership groups that own LPTV and/or

translator stations, as shown in table 6. We selected stakeholders to 
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-17-135 Low Power Television

represent a range of views from various types of organizations based on 

our review of comments filed in FCC’s incentive auction proceeding, as 

well as based on recommendations from other organizations we 

interviewed. We chose three station ownership groups that own LPTV 

and/or translator stations and that broadcast a variety of programming 

types. Through our web-based survey, we also obtained station 

representatives’ views on actions that FCC has proposed or taken and 

that Congress or others could take to mitigate the effects of the incentive 

auction on LPTV and translator stations. In our report, we use “some”

when three or more stakeholder sources combined supported a particular 

idea or statement.

Table 6: Stakeholders Interviewed

Stakeholder category Stakeholder

Station ownership groups Excellence in Christian Broadcasting

Sinclair Broadcasting Group

Venture Technologies Group

Broadcast industry associations Advanced Television Broadcasting Alliance

Association of Public Television Stations

LPTV Spectrum Rights Coalition

National Association of Broadcasters

National Translator Association

Spectrum Evolution

Technology companies and 

technology industry association

Google

Microsoft

Wi-Fi Alliance

Public interest group New America Foundation’s Open Technology 

Institute

Source: GAO. | GAO-17-135

To identify selected stakeholder views on the expected outcomes of 

preserving a vacant channel for unlicensed use of the television 

broadcast spectrum, we reviewed FCC’s June 2015 notice of proposed 

rulemaking where FCC proposes to preserve one vacant channel in the 

ultra high frequency television band for use by white space devices and 

wireless microphones, and we reviewed selected comments and other 

filings association with this proceeding.3 We selected comments and 

 3Vacant Channel NPRM, 30 FCC Rcd 6711, June 16, 2015, Released, June 11, 2015,

Adopted.
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-17-135 Low Power Television

other filings for review, by performing keyword searches on filings 

submitted between October 9, 2014, and April 1, 2016, and we reviewed 

filings from entities that filed more than one comment, reply to comment, 

letter, or notice of ex parte in this time period. We also interviewed 

stakeholders, as shown in table 6 above.

We also reviewed relevant statutes and regulations, including the Middle 

Class Tax Relief and Job Creation Act of 2012,4 which authorized FCC to 

conduct the spectrum incentive auction. We searched various web-based 

databases to identify existing articles, peer-reviewed journals, trade and 

industry articles, government reports, and conference papers related to 

these topics.5 We identified articles from 2010 to 2016 and examined 

summary-level information that we believed to be germane to our report. 

It is possible that we may not have identified all of the reports with 

findings relevant to our objectives.

 4Pub. L. No. 112-96, 126 Stat. 156 (codified at 47 U.S.C. § 309(j)(8)(G)).

5For example, databases we searched included ProQuest and ProQuest Academic, Ei 

Compendex,Nexis, and Gale Group databases, trade & industry, computers, and 

newsletter.
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 43 GAO-17-135 Low Power Television

The questions we asked in our survey of low power television (LPTV) and 

translator stations are shown below. In this appendix, we include all the 

survey questions and aggregate results of responses to the closed-ended 

questions; we do not provide information on responses provided to the 

open-ended questions. However, all respondents did not have the 

opportunity to answer each question because of skip patterns. 

Furthermore, some respondents may have decided not to respond to a 

particular question. For a more detailed discussion of our survey 

methodology see appendix I.

Appendix II: Survey of Low Power Television 

and Translator Stations
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 44 GAO-17-135 Low Power Television

Station Identification

1. Do you represent any licensed LPTV stations as of May 31, 2016? Please do not include Class A 

stations, translator stations, or stations for which you have a construction permit that are not yet in 

service.

Response Number of responses

Yes 83

No 32

No answer/not checked 0

1a. If yes, how many?

Total: 535

1b. If yes, please enter the call sign(s) for the LPTV station(s) you represent or upload a 

document with this information.

(Written responses not included)

1c. If yes, do any of the LPTV stations you represent broadcast at least 18 hours per day?

Response Number of responses

Yes 79

No 2

No answer/not checked 34

1d. If yes, how many?

Total: 451

1e. If yes, do any of these stations also broadcast at least 3 hours of locally produced 

programming per week? For the purposes of this survey, "locally produced" means 

produced within the market area served by a particular station or the market area served 

by a group of commonly controlled low power stations that carry common local 

programming produced within the market area served by such group.

Response Number of responses

Yes 63

No 12

No answer/not checked 40

1f. If yes, how many?

Total: 251
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 45 GAO-17-135 Low Power Television

2. Do you represent any licensed translator stations as of May 31, 2016? Please do not include stations 

for which you have a construction permit that are not yet in service.

Response Number of responses

Yes 50

No 61

No answer/not checked 4

2a. If yes, how many?

Total: 1,515

2b. If yes, please enter the call sign(s) for the translator station(s) you represent or upload a 

document with this information.

(Written responses not included)

2c. If yes, how many of the translator stations you represent receive incoming signals from 

LPTV (excluding Class A) or translator stations rather than from a full-power or Class A station? 

If you are uncertain, please write "uncertain" in the box.

Total: 433

Respondents indicating “uncertain”: 10

2d. If yes, how many of the translator stations you represent send outgoing signals to LPTV 

(excluding Class A) or translator stations? If you are uncertain, please write "uncertain" in the 

box.

Total: 212

Respondents indicating “uncertain”: 10

Ownership Information

3. Do you represent any LPTV and/or translator stations that are owned by an educational entity 

(including government-owned, for-profit, and not-for-profit educational entities)?

Response Number of responses

Yes 23

No 90

No answer/not checked 2
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 46 GAO-17-135 Low Power Television

3a. If yes, how many?

Total number of LPTV stations represented: 95

Total number of translator stations represented: 720

4. Do you represent any LPTV and/or translator stations that are owned by a for-profit non-educational 

entity (including for-profit corporation, sole proprietorship, limited partnership, general partnership)?

Response Number of responses

Yes 63

No 51

No answer/not checked 1

4a. If yes, how many?

Total number of LPTV stations represented: 364

Total number of translator stations represented: 136

5. Do you represent any LPTV and/or translator stations that are owned by a not-for-profit noneducational corporation?

Response Number of responses

Yes 17

No 98

No answer/not checked 0

5a. If yes, how many?

Total number of LPTV stations represented: 40

Total number of translator stations represented: 112

6. Do you represent any LPTV and/or translator stations that are owned by a governmental or 

community entity (including tribe, state, county, city, municipality, and community organization)? 

Please do not include government-owned educational entities.

Response Number of responses

Yes 23

No 91

No answer/not checked 1
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 47 GAO-17-135 Low Power Television

6a. If yes, how many?

Total number of LPTV stations represented: 8

Total number of translator stations represented: 1,134

7. Do you represent any LPTV and/or translator stations that are owned by a type of entity other than 

those listed above?

Response Number of responses

Yes 1

No 100

No answer/not checked 14

7a. If yes, please specify other type of entity.

(Written responses not included)

7b. If yes, how many?

Total number of LPTV stations represented: 1

Total number of translator stations represented: 0

Programming and Service Information

The following questions seek information about the types of programming provided in the past 12 months by 

the LPTV station(s) you represent. Many LPTV stations broadcast programming that falls under multiple 

categories – please include these stations in your answers to each question.

8. Do any of the LPTV stations you represent broadcast locally produced programming? For the 

purposes of this survey, "locally produced" means produced within the market area served by a 

particular station or the market area served by a group of commonly controlled low power stations that 

carry common local programming produced within the market area served by such group.

Response Number of responses

Yes 69

No 9

No answer/not checked 37

8a. If yes, how many?

Total number of LPTV stations represented: 264
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 48 GAO-17-135 Low Power Television

8b. If yes, what kinds of locally produced programming do the LPTV stations you represent 

broadcast? (For example, non-English-language, religious, news, weather, information, sports, 

etc.) Please specify the non-English-language(s) if applicable.

(Written responses not included)

9. Do any of the LPTV stations you represent broadcast non-English-language programming that is not 

locally produced?

Response Number of responses

Yes 30

No 48

No answer/not checked 37

9a. If yes, how many?

Total number of LPTV stations represented: 118

9b. If yes, what kinds of not locally produced non-English-language programming? Please 

specify the language(s).

(Written responses not included)

10. Do any of the LPTV stations you represent broadcast religious programming that is not locally 

produced?

Response Number of responses

Yes 32

No 38

No answer/not checked 45

10a. If yes, how many?

Total number of LPTV stations represented: 237

10b. If yes, what kinds of not locally produced religious programming?

(Written responses not included)
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 49 GAO-17-135 Low Power Television

11. Do any of the LPTV stations you represent broadcast news, weather, and information programming 

that is not locally produced?

Response Number of responses

Yes 44

No 31

No answer/not checked 40

11a. If yes, how many?

Total number of LPTV stations represented: 271

11b. If yes, what kinds of not locally produced news, weather, and information programming?

(Written responses not included)

12. Do any of the LPTV stations you represent broadcast general entertainment programming that is 

not locally produced? (For example, general entertainment programming may include classic TV, 

sports, home shopping, infomercials, etc.)

Response Number of responses

Yes 64

No 13

No answer/not checked 38

12a. If yes, how many?

Total number of LPTV stations represented: 402

12b. If yes, what kinds of not locally produced general entertainment programming?

(Written responses not included)

13. Do any of the LPTV stations you represent broadcast programming that is not locally produced 

other than the types listed above?

Response Number of responses

Yes 13

No 58

No answer/not checked 44

13a. If yes, how many?

Total number of LPTV stations represented: 39
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 50 GAO-17-135 Low Power Television

13b. If yes, what kinds of not locally produced programming other than the types listed above?

(Written responses not included)

14. Do any of the stations you represent provide service to an area that only receives service from 

LPTV and/or translator stations (excluding Class A stations) - that is, the area receives no full-power or 

Class A service?

Response Number of responses

Yes 42

No 49

Uncertain 18

No answer/not checked 6

14a. If yes, please list the call sign(s) of the station(s) you represent for which this is the case 

along with the estimated population within the coverage contour for each call sign. If you 

represent more than 10 such stations or if you would prefer, please upload a document with this 

information.

Number of unique call signs provided: 211

(Written responses not included)

14b. If yes, do any of those stations provide the only service in the area - that is, the area 

receives no other full-power, Class A, LPTV, or translator service?

Response Number of responses

Yes 12

No 2

Uncertain 0

No answer/not checked 101

14c. If yes, please list the call sign(s) of the station(s) you represent for which this is the case 

along with the estimated population within the coverage contour for each call sign. If you 

represent more than 10 such stations or if you would prefer, please upload a document with this 

information.

Number of unique call signs provided: 27

(Written responses not included)
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 51 GAO-17-135 Low Power Television

15. If you would like to provide additional information on the programming provided by the station(s) 

you represent that is not included in the questions above, please do so in the box below.

(Written responses not included)

Perspectives Related to the Incentive Auction

16. Have you estimated relocation expenses for the station(s) you represent in the event of relocation 

following FCC's auction and subsequent channel "repack"?

Response Number of responses

Yes 47

No 61

No answer/not checked 7

16A. If yes, please provide your estimate(s) of relocation expenses, including the types of 

expenses included.

(Written responses not included)

17. If FCC had allowed LPTV and translator stations to participate in the auction, would any of the 

stations you represent have chosen to relinquish spectrum in return for compensation?

Response Number of responses

Yes 32

No 44

Uncertain 34

No answer/not checked 5

17a. If yes, how many of the stations you represent would have chosen to relinquish spectrum

in return for compensation?

Total number of LPTV stations represented: 98

Total number of translator stations represented: 10

17b. If yes, please explain your response.

(Written responses not included)
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 52 GAO-17-135 Low Power Television

18. FCC has announced it is taking or will take the following actions related to the incentive auction. 

How useful do you think these actions will be in mitigating possible effects of the incentive auction on 

the LPTV and/or translator station(s) you represent? Please explain your answer.

(Written responses not included)

Action Response Number of 

respondents

(LPTV) 

Number of 

respondents

(translator)

a. Extending channel sharing to 

LPTV and translator stations

Very useful 14 7

Moderately useful 13 8

Not useful 34 21

Uncertain 15 9

Not applicable 0 1

No answer/not checked 39 69

b. Using FCC's incentive auction 

optimization and repacking 

software to identify new channels 

for displaced stations after the 

incentive auction

Very useful 26 18

Moderately useful 16 8

Not useful 21 13

Uncertain 15 6

Not applicable 0 0

No answer/not checked 37 70

c. Extending the analog-to-digital 

transition date for LPTV and 

translator stations from September 

1, 2015 to after the post-auction 

transition period

Very useful 25 8

Moderately useful 10 7

Not useful 26 15

Uncertain 4 3

Not applicable 14 12

No answer/not checked 36 70

d. Streamlining cross-border 

coordination processes with 

Mexico and Canada so it will not 

delay the post-auction 

displacement application process 

for LPTV and translator stations

Very useful 24 12

Moderately useful 6 7

Not useful 15 7

Uncertain 13 5

Not applicable 18 12

No answer/not checked 39 72
Appendix II: Survey of Low Power Television 

and Translator Stations

Page 53 GAO-17-135 Low Power Television

19. Are there any other actions FCC could take going forward to help mitigate possible effects of the 

incentive auction on LPTV and translator stations?

Response Number of responses

Yes 84

No 5

No answer/not checked 26

19a. If yes, please specify.

(Written responses not included)

20. Are there any other actions Congress or another entity could take going forward to help mitigate 

possible effects of the incentive auction on LPTV and translator stations?

Response Number of responses

Yes 87

No 7

No answer/not checked 21

20a. If yes, please specify.

(Written responses not included)

21. If you would like to expand upon any of your responses to the questions above, or would like to 

provide any other comments about the possible effects of FCC's spectrum incentive auction on LPTV 

and translator stations, please do so in the box below.

(Written responses not included)
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 54 GAO-17-135 Low Power Television

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

In addition to the individual named above, Sally Moino (Assistant 

Director), Aaron Kaminsky, (Analyst in Charge), David Hooper, John 

Mingus, Josh Ormond, Rebecca Rygg, Kelly Rubin, Andrew Stavisky, and 

Michelle Weathers made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff

Acknowledgments

(100543)
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