VIDEO 

PROGRAMMING 

FCC Should Conduct 

Additional Analysis to 

Evaluate Need for 

Set-Top Box 

Regulation

Report to Congressional Requesters

September 2017

GAO-17-785

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-785, a report to 

congressional requesters

September 2017

VIDEO PROGRAMMING

FCC Should Conduct Additional Analysis to Evaluate 

Need for Set-Top Box Regulation

What GAO Found

Set-top boxes play a significant but diminishing role in delivering video content in 

an evolving video market. Subscribers to multichannel video programming 

distributors (MVPD)—companies that provide pay television services via 

subscriptions such as cable and satellite companies—generally need a set-top 

box to access MVPD television services, and most subscribers lease a set-top 

box from their MVPD. However, consumers can now access video through a 

wide range of Internet-based services without a set-top box, using a variety of 

Internet-capable devices, such as tablets. Internet-based services include those 

providing on-demand video such as Netflix and some, such as Sling TV, 

providing live content similar to that from MVPDs. Some Internet-capable 

devices, such as Roku, allow people to watch Internet-based video on 

televisions. In recent years, subscriptions to MVPDs have fallen as more 

Internet-based services have become available. Partly in response to this

competition, many MVPDs have begun offering content over the Internet to 

subscribers, accessible on many Internet-capable devices, including streaming 

devices that display it on televisions. While in most cases, MVPD subscribers still 

need a set-top box, a few MVPDs GAO interviewed now allow subscribers to 

access content they subscribe to solely over the Internet, without a set-top box. 

The Federal Communications Commission (FCC) has conducted limited analysis 

of the need for regulations to assure a commercial market for devices, such as 

set-top boxes, to access MVPD services. Most stakeholders and experts GAO 

interviewed said that further regulations for this purpose were not needed, given 

recent changes in the video content market. FCC is directed by law to set 

regulations to assure a commercial market for devices to access MVPD services. 

However, the law also specifies that any such regulations may no longer apply if 

FCC determines that the markets for both MVPD services and devices to access 

MVPDs are fully competitive. Moreover, while it does not extend to independent 

agencies, Office of Management and Budget guidance says agencies could use 

analyses to evaluate the need for proposed actions. However, FCC proposed a 

new rule in 2016 to promote a commercial set-top box market without 

undertaking a comprehensive analysis of the competitiveness of the market to 

support the proposed rule. FCC did not enact a final rule. Stakeholders had 

differing views on the potential effects of the proposed rule, but some raised 

concerns that the rule could have had negative effects on MVPDs and content 

providers. As described above, widespread changes in the video market in 

recent years have expanded consumers’ choices for video services as well as 

devices to access those services. Nineteen of the 35 industry stakeholders GAO 

interviewed said rules are not needed at this time, while 8 said rules are still

needed. (The rest gave uncertain answers or did not comment on this issue.)

Without a comprehensive analysis, FCC lacks information on the extent of 

consumer choice and, furthermore, the extent to which increased options for 

video services affect the relative importance of consumer choice for devices to 

access MVPDs. Such an analysis could help FCC determine if additional 

regulations are needed and, as the market likely continues its rapid evolution,

could serve as a benchmark in FCC’s further consideration of whether market 

conditions have been met such that regulations may no longer apply.

View GAO-17-785. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov.

Why GAO Did This Study

Millions of households subscribe to 

cable, satellite, and telephone 

companies—known as MVPDs—for 

television, which is generally delivered 

via a set-top box attached to a 

television. Congress directed FCC to 

adopt regulations to assure a 

commercial market for devices to 

access MVPDs, and in February 2016, 

FCC proposed a rule intended to do 

so. Many industry stakeholders raised 

concerns about the proposal’s potential 

effects, and FCC did not issue the 

proposed rule. This report examines:

(1) the role of set-top boxes in 

accessing video programming content

and (2) views of selected stakeholders 

and experts on the need for FCC 

regulation regarding set-top boxes and 

FCC’s analysis of such need.

GAO analyzed data from a media 

research group regarding the video 

market and interviewed 35 industry 

stakeholders including 12 MVPDs, 5

video content producers, 3 device 

manufacturers, 12 industry 

associations, and others; GAO 

selected stakeholders based on 

comments filed with FCC on its 2016 

proposed rule. GAO also interviewed 

11 industry analysts and experts 

selected based on industry coverage 

and publications.

What GAO Recommends

GAO recommends that FCC conduct a 

comprehensive analysis of how recent 

industry changes related to video 

services affect consumer choice for 

devices to access video services.

FCC agreed with GAO’s 

recommendation and provided 

technical comments that GAO 

incorporated as appropriate.
Page i GAO-17-785 Video Programming

Letter 1

Background 4

Set-Top Boxes Play a Significant but Diminishing Role in 

Delivering Programming in an Evolving Video Market 8

Experts and Stakeholders Suggest Additional FCC Efforts on 

Choice in Set-Top Boxes is Not Needed, but FCC has 

conducted Limited Analysis of the Issue 

Conclusions 22

Recommendation 22

Agency Comments 23

Appendix I Industry Stakeholders and Experts and Analysts Interviewed 24

Appendix II Comments from the Federal Communications Commission 26

Appendix III GAO Contact and Staff Acknowledgments 27

Tables

Table 1: 35 Industry Stakeholders Interviewed 24

Table 2: 11 Industry Experts and Analysts Interviewed 25

Figures

Figure 1: Relationships among Stakeholders in the Video 

Programming Market 5

Figure 2: Selected Internet Video Providers’ Launch Dates 9

Figure 3: Range of Possible Devices to View Video Programming 

Content at Home 10

Figure 4: Actual and Projected Sales of Streaming Video Devices 

over Time, 2015–2020 11

Contents

16
Page ii GAO-17-785 Video Programming

Abbreviations

FCC Federal Communications Commission 

MVPD Multichannel video programming distributor

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-785 Video Programming

441 G St. N.W.

Washington, DC 20548

September 29, 2017

The Honorable Greg Walden

Chairman

Committee on Energy and Commerce

House of Representatives

The Honorable Yvette D. Clarke

House of Representatives

Television programming has long been an integral part of society and the 

economy, delivering news, entertainment, advertisements, and more to 

the vast majority of American households. Multichannel video 

programming distributors (MVPD)—which include cable, satellite, and 

telephone companies—enable consumers to subscribe to a large 

package of video programming that includes local broadcast channels 

(such as local NBC stations) as well as an array of cable channels (such 

as ESPN and CNN). Over 75 percent of households subscribe to an 

MVPD for video programming services. To do so, the household typically 

needs a set-top box, which provides the video feed from the MVPD’s 

network to the television, while securing the content to ensure, for 

example, that only channels included in the subscription can be 

accessed.1 According to an analysis cited by the Federal 

Communications Commission (FCC), in 2016 approximately 99 percent of 

households that subscribed to MVPD service leased a set-top box, 

spending an average of $231 per household.2

 1

For the purposes of this report, we consider a set-top box to be a device to access MVPD 

services and not devices to access other types of video services such as those provided 

over the Internet.

2

In the Matter of Expanding Consumers’ Video Navigation Choices and Commercial 

Availability of Navigation Devices, Notice of Proposed Rulemaking and Memorandum 

Opinion and Order, 31 FCC Rcd 1544 (2016). In the proposed rule, FCC noted that there 

was some disagreement over the validity of the findings of this study. FCC referenced that 

one industry association official commented in a letter that this analysis was misleading 

regarding the profits earned by MVPDs for set-top box lease fees. In the proposed rule, 

FCC invited MVPDs to provide FCC additional data on their costs of buying set-top boxes 

and the lease fees they earn from them.

Letter
Page 2 GAO-17-785 Video Programming

In the Communications Act of 1934, as amended by the 

Telecommunications Act of 1996 (herein known as “the Act,”)3 Congress 

directed FCC to adopt regulations to assure the commercial availability of 

devices—such as set-top boxes—that can access MVPD services. FCC 

has made efforts to meet this directive, including by issuing a Notice of 

Proposed Rulemaking in February 2016 that would have required MVPDs 

to offer certain information to companies that are not affiliated with an 

MVPD to allow those companies to design and build devices to access 

video services from MVPDs, giving subscribers more alternatives to 

leasing set-top boxes from their providers.4 However, in May 2017, the 

new FCC Chairman said he did not believe that the proposed rulemaking 

from the previous Commission furthered the goal of promoting a clear, 

consumer-focused, fair, and competitive regulatory path for video 

programming delivery, removed the proposed rule from circulation, and 

said he does not intend to resurrect it. Since FCC proposed the rule, a 

variety of stakeholders have disagreed on whether further regulation in 

this area is needed. In addition, some have claimed that the proposed 

rule would have negatively affected MVPDs and other industry 

stakeholders.

You asked us to review FCC’s efforts to address the Act’s requirements 

to assure commercial availability of devices to access MVPD services. 

This report examines: 1) the role of set-top boxes in accessing video 

programming and 2) views of selected stakeholders and experts on the 

need for FCC regulation regarding set-top boxes and how FCC has 

analyzed such need.

To review the role of set-top boxes in accessing video programming, we 

contracted with Kagan, a unit of S&P Global Market Intelligence, a private 

company, to obtain data and research on the video programming 

industry.5 We obtained data on the video programming industry, including 

data on subscriptions to MVPDs, online video distributors, and sales of 

devices including set-top boxes and devices to access Internet-based 

 3

Communications Act of 1934, Pub. L. No. 73-416, 48 Stat. 1064 (1934), as amended by 

Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 (1996) (codified as 

amended at 47 U.S.C. § 151).

4

31 FCC Rcd 1544 (2016).

5

S&P Global Market Intelligence is a company that collects and integrates financial and 

industry research and data, including data on the telecommunications and media 

industries.
Page 3 GAO-17-785 Video Programming

content, among other types of data. The timeframes for these data vary 

based on the specific data points available. To determine the reliability of 

these data we interviewed representatives of Kagan, reviewed 

documentation on their data collection and analysis methodology, and 

conducted a literature review to gauge how Kagan’s analysis has been 

used in the industry, as well as in previous GAO reports. We also 

considered the fact that Kagan’s data are often used and cited by FCC in 

considering the reliability of the data. We did not assess all aspects of 

Kagan’s methodological techniques, such as its forecasting and 

estimation procedures, due to the proprietary nature of this information. 

We determined that these data were sufficiently reliable for reporting on 

trends in the video programming industry in this report.

To address both objectives, we reviewed the following: relevant federal 

statutes and regulations including the Communications Act of 1934, as 

amended by the Telecommunications Act of 1996, and FCC’s regulations 

issued in response to that statute; proposed rules, including FCC’s 

February 2016 proposed rule on set-top boxes;6 and relevant literature 

identified through a literature search that discussed FCC’s efforts to 

respond to the Act. We also reviewed Office of Management and Budget 

criteria for conducting regulatory analyses. In addition, we interviewed 

officials with FCC and the United States Copyright Office—part of the 

Library of Congress—and conducted semi-structured interviews with 35 

stakeholders selected to include a range of industry stakeholders:

• nine larger MVPDs, including the five largest cable providers, as 

measured by number of subscribers,7 two satellite providers,8 and two 

telephone providers;

• three smaller MVPDs, selected based on recommendations from an 

industry association, WTA-Advocates for Rural Broadband;9

 6

31 FCC Rcd 1544 (2016).

7

To determine subscriber numbers, we used public research published by Leichtman 

Research Group. Data are as of the end of June 2016.

8

While one of these satellite providers also provides telephone-based video services, the 

interview with this provider focused only on its satellite service. As a result, we consider it 

a satellite provider for the purposes of this report.

9

WTA-Advocates for Rural Broadband is an industry association representing rural 

telecommunications companies.
Page 4 GAO-17-785 Video Programming

• three manufacturers of set-top boxes and other devices to access 

video content;

• three public-interest organizations;

• three independent, minority, or diverse programmers and interest 

groups;

• two large video broadcast networks;

• ten industry associations, including associations representing MVPDs, 

technology companies, owners of copyright content, and others; and

• two others representing different interests.

In selecting the industry stakeholders beyond the MVPDs, we considered 

comments filed with FCC on its 2016 proposed rule. Finally, we 

conducted semi-structured interviews with 11 industry experts and 

analysts. We selected these experts and analysts based on prior GAO 

work that included interviews with industry experts and analysts, a review 

of relevant publications and literature, a review of industry analysts who 

cover relevant companies, and recommendations from industry experts 

and analysts already interviewed. These interviews with industry 

stakeholders and analysts and experts covered the market for video 

programming, the role of set-top boxes and other devices to access video 

content, FCC efforts to increase consumer choice in the market for 

devices to access video content, and the need for FCC regulations 

regarding set-top boxes. Following the interviews, we analyzed responses 

across the interviews to identify and report on common themes. The 

results of these interviews are not generalizable. For a complete list of 

industry stakeholders and industry experts and analysts we interviewed, 

please see appendix I.

We conducted this performance audit from September 2016 to 

September 2017 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 that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

Set-top boxes provide a variety of functions, including enabling 

consumers to access their video subscriptions. They also secure the 

video provider’s content to ensure that the subscriber can access only the 

channels subscribed to, and prevent unauthorized use, such as recording 

Background
Page 5 GAO-17-785 Video Programming

of content that subscribers do not have the right to record. Among other 

features, set-top boxes may also allow subscribers to:

• view a channel guide and search for programming and record content 

for later viewing;

• view linear programming—meaning video programming that appears 

on a given channel at a given time; and

• view video on demand—meaning video programming available for 

consumers to access when they want to instead of at a specific time.

Traditionally, video content flows from content producers to households 

through various intermediaries (see fig. 1). Content producers negotiate 

and agree to a variety of terms and conditions with the networks or local

television stations that carry the content, and those networks further 

negotiate and agree to terms and conditions with the MVPDs that 

distribute the content to subscribers. For example, a content producer 

may agree that in addition to its program showing on the linear cable 

channel at a specific time, its program is also available on demand, but 

only for a specific period of time. Furthermore, networks may negotiate for 

and agree to a range of terms with MVPDs regarding channel placement 

and other items. Protections programmed into the set-top box help ensure 

that such agreements are implemented.

Figure 1: Relationships among Stakeholders in the Video Programming Market
Page 6 GAO-17-785 Video Programming

For over two decades, federal statutes and regulations have sought to 

foster consumer choice for video services and devices to access such 

services. The Cable Television Consumer Protection and Competition Act 

of 1992, for example, requires FCC to report annually on the status of 

competition in the video marketplace.10 Furthermore, Section 629 of the 

Communications Act of 1934, as amended by the Telecommunications 

Act of 1996 (“the Act,”) directed FCC to assure the commercial availability 

of devices that access MVPD service (which currently are typically set-top 

boxes) by making them available from third parties unaffiliated with 

MVPDs.

In response to the Act, FCC adopted regulations in October 2003 that 

allowed the direct connection of digital navigation devices (typically, settop boxes) purchased from third parties to MVPD systems. To receive 

and display MVPD content, these devices require a CableCARD, a card 

provided by a subscriber’s MVPD and installed in the third party set-top 

box or other device, allowing a subscriber to view secure content they 

subscribe to with their MVPD.11 As a result, such third party devices, 

which remain available today, are known as CableCARD devices.

Subsequent to the adoption of its CableCARD regulations, as noted 

earlier, FCC issued a Notice of Proposed Rulemaking in February 2016 

that was intended to provide consumers additional choice for set-top 

boxes. In the proposed rule, FCC tentatively concluded that despite the 

availability of CableCARD devices, the market for navigation devices 

(such as set-top boxes) was not competitive, citing a previous analysis 

that found that approximately 99 percent of MVPD subscribers continued 

to lease a set-top box from their MVPD. Therefore, FCC stated in the 

proposed rule that it should adopt new regulations. Moreover, FCC stated 

that technological advances since the CableCARD regulations had been 

adopted enabled new solutions that, with certain ground rules, would 

make it easier to finally fulfill the purpose of the Act. One goal of the 

 10Communications Act of 1934, Pub. L. No. 73-416, 48 Stat. 1064 (1934), as amended by 

Cable Television Consumer Protection and Competition Act of 1992, Pub. L. No. 102-385, 

106 Stat. 1460 (1992) (codified as amended at 47 U.S.C. § 548(g)).

11This rule did not apply to satellite video distributors, for example, because, at the time 

the rule was promulgated, their customers already had commercially available devices to 

purchase at retail and use with their service. In 2010 FCC proposed a successor to 

CableCARD, AllVid, which would have required a FCC-designed standardized device that 

would allow any manufacturer to offer devices at retail without the need to coordinate with 

video providers. However, FCC did not move forward with that proposal.
Page 7 GAO-17-785 Video Programming

proposed rule was to allow third party manufacturers to create new 

devices and user interfaces—the means through which users interact with 

a set-top box such as the menus, remote control, and methods of 

searching for programming—to access MVPD services. For such devices 

to work, the proposal required MVPDs to transmit to third party devices 

video programming content and data about that programming, including 

channel listings and schedules and data on what programming 

subscribers are entitled to access. Such devices, as proposed, would not 

rely on a CableCARD and would be compatible with any MVPD’s 

service.12 As such, as envisioned by FCC, the proposed rule would 

enable a consumer to switch MVPDs without having to change the set-top 

box.

In September 2016, after receiving input from a wide range of 

stakeholders, the former FCC Chairman issued a three page fact sheet 

providing an overview of a proposed final rule that the Chairman 

scheduled for Commission vote in September 2016.13 According to the 

fact sheet, MVPDs would have been required to offer consumers a free 

electronic application (commonly referred to as an “app”), which would be 

controlled by the MVPD, that subscribers could download onto a variety 

of Internet-capable devices such as tablets and smartphones to access 

the programming they subscribe to. Under this scenario, control over the 

user interface would have been maintained by the MVPD, not the thirdparty device manufacturer, as the original proposed rule envisioned. 

However, the former Chairman ultimately deleted the proposed final rule 

from the list of items scheduled for consideration at the September 2016 

meeting, and action on the proposed rule is no longer pending for 

consideration.

 12Unlike the original CableCARD rule, this proposed rule would have applied to satellite 

video distributors in addition to cable companies. The proposed rule sought comment on 

how the proposed rule should be applied differently to small MVPDs. In particular, the 

proposed rule sought comment on the American Cable Association’s proposal to exempt 

MVPDs serving one million or fewer subscribers from any rules adopted in the proceeding.

13As FCC never acted on this proposed final rule, aside from the former Chairman’s fact 

sheet, and never published the details, for the remainder of this report when we discuss 

“proposed rule” we refer to FCC’s February 2016 Notice of Proposed Rulemaking.
Page 8 GAO-17-785 Video Programming

While over 75 percent of households still subscribe to MVPDs for video 

services and rely on a set-top box leased from their provider to access 

content, the Internet has created more opportunities for consumers to 

access video programming services in ways that do not require a leased 

set-top box. These providers vary regarding the types of video services 

they offer:

• Content aggregators (e.g., Netflix and Amazon): These providers offer 

video on-demand through a subscription. They aggregate content 

from multiple sources and may provide their own content (e.g., 

Netflix’s original series House of Cards) along with content from other 

programmers. There are also niche aggregators such as Indie Flix 

that provide specialized programming.

• Direct to Consumer (e.g., CBS All Access, HBONow, and Univision 

Now): Some programmers and networks that distribute their content 

through MVPDs are now separately providing live and on-demand 

content directly to consumers through the Internet for a monthly 

subscription. Consumers do not have to subscribe to an MVPD to 

subscribe to such content. For example, HBO provides its content on 

demand to its customers through the HBO Now app without requiring 

a customer to subscribe through an MVPD.

• Virtual Service Providers (e.g. Sling TV, DIRECTV Now, and 

PlayStation Vue): These providers use a model similar to the MVPD 

model by providing live and on-demand programming from a variety of 

networks over the Internet in generally smaller channel lineups. Such 

services are targeted to households looking for a smaller channel lineup at a lower cost than from MVPDs.

According to Kagan, subscriptions to content aggregators and direct to 

consumer Internet-based services are expected to grow from 109 million 

Set-Top Boxes Play a 

Significant but 

Diminishing Role in 

Delivering 

Programming in an 

Evolving Video 

Market

The Internet Provides 

Opportunities for Viewing 

Video Programming 

without the Need For a 

Set-Top Box
Page 9 GAO-17-785 Video Programming

in 2016 to 137 million in 2020.14 Many new Internet video services have 

launched since 2005, and there has been a particularly large growth since 

2014. (See fig. 2.)

Figure 2: Selected Internet Video Providers’ Launch Dates

Subscribers can access Internet-based video services using many 

different Internet-connected devices and do not need a set-top box. 

These devices include stand-alone devices such as video game consoles 

(e.g., Xbox One), laptops, tablets, smart phones, and smart TVs—which 

include an integrated computer with an Internet browser, operating 

system, and apps to stream Internet video subscriptions without a 

separate device. Third party manufacturers have also developed 

streaming media devices (e.g., Roku) designed to allow viewers to watch 

Internet-provided content on their television set. Some of these devices, 

such as tablets, allow consumers to view video programming content in or 

out of the home with an Internet connection.15 Figure 3 below shows the 

 14Because households can, and many do, subscribe to multiple Internet-based services, 

this figure represents total subscriptions and not households. For example, according to 

Kagan, in 2016 Netflix had approximately 48 million subscribers and Amazon had 41 

million subscribers. While it is likely that some of those subscribers overlap, the extent of 

overlap is unknown.

15Agreements between content providers and distributors may limit the extent to which 

certain content can be viewed outside the home.
Page 10 GAO-17-785 Video Programming

variety of devices, including set-top boxes, households can use to access 

video programming.

Figure 3: Range of Possible Devices to View Video Programming Content at Home

These new Internet-based providers offer greater choice in video 

services, eliminating the need to lease a set-top box for households that 

choose to subscribe to one or more of these providers in lieu of an MVPD 

subscription. According to Kagan, the percentage of households 

subscribing to MVPDs is down from a peak of approximately 91 percent 

of households wired for service in 2009 to 79 percent in 2016, and Kagan 

estimates that in 2016 there were 29 million households that either 

cancelled their MVPD subscription or never had it. Additionally, Kagan 

projects that there will be a continued decline in MVPD video 

subscriptions by 2020, when 74 percent of households will subscribe to 

MVPDs, in part due to competition from Internet video programming. 

Eight of 11 industry experts and analysts we interviewed also stated that 

they believed MVPDs’ market share is falling due in part to Internet video. 

Kagan reports based on results of an online survey it conducted of 

households that never had an MVPD subscription that many in this group 
Page 11 GAO-17-785 Video Programming

are generally younger and have less income than other households, and 

have in the past relied on over-the-air television because the cost of 

MVPD service is too high.16 One industry expert told us that it is unclear 

what will happen to these younger households’ viewing habits as they 

age. According to this expert, in the past these younger non-subscribers 

would eventually subscribe to MVPDs as their income grew, but it is no 

longer clear that this will happen due in part to Internet video options.

While consumers are increasingly subscribing to Internet programming 

that does not require a set-top box, the market for alternative devices to 

access programming is also growing. According to Kagan, sales of these 

alternative devices, such as streaming devices and smart TVs, have been 

growing. (See fig.4.) For example, Kagan estimates that 70 percent of 

television shipments in 2016 were smart TVs.

Figure 4: Actual and Projected Sales of Streaming Video Devices over Time, 2015–

2020

Note: Figures are in millions and include streaming media sticks and devices.

 16March 2017 Kagan online survey of 2,565 U.S. Internet adults matched by age and 

gender to the U.S. census. The survey results have a margin of error of +/-1.9 at the 95 

percent confidence level. GAO did not formally assess the methodology of this survey. 
Page 12 GAO-17-785 Video Programming

Many subscribers to MVPDs are still reliant on at least one set-top box, 

usually leased from their provider, to access video programming. In the 

wake of FCC’s 2003 CableCARD regulations, third-party providers 

developed CableCARD devices that consumers could purchase at retail 

outlets and use to access their MVPD subscription with a CableCARD.17

Such devices are still available currently. For example, one of the betterknown of these options, the TiVo set-top box, was available on 

Amazon.com as of July 2017. However, in spite of the commercial 

availability of these devices, according to FCC in its 2016 proposed rule, 

about 99 percent of subscribers to MVPDs lease at least one set-top box 

from their MVPD. While all five of the large cable providers we 

interviewed said that their customers have the option of using a third party 

device, they all added that very few customers do so and the majority 

lease their set-top box.18 All five of the large cable providers we 

interviewed cited limited customer interest as key reason consumers did 

not adopt third party CableCARD devices. Each also cited one or more of 

the following reasons:

• limited functionality, including limited ability to access on-demand 

content when devices were first available;

• high up-front costs to purchase a third party device; and

• the ease of leasing a set-top box from a provider, which will replace 

the box if it breaks, compared to owning a third party device where if it 

breaks the consumer may have to buy a new one.

However, public interest organizations we interviewed stated they believe 

that the low rate of adoption of CableCARD devices was due to limited 

support from MVPDs. Specifically, representatives of one public interest 

group we interviewed stated that MVPDs have not been advocates of 

third party devices and have not devoted customer service toward this 

effort, for example by providing their technicians with training. They also 

stated that MVPDs have made it difficult for customers to use 

CableCARD devices by, for example, requiring technicians to install the 

 17In EchoStar Satellite L.L.C. v. FCC, the D.C. Circuit vacated two 2003 FCC orders that 

adopted the CableCARD standard. EchoStar Satellite L.L.C v. FCC, 704 F.3d 992 (D.C. 

Circ. 2003); however, most MVPDs we interviewed continue to support CableCARD 

devices. 

18Satellite providers are not required by law to have CableCARD-enabled devices. 

However, one of the two satellite providers we interviewed told us that they provided 

consumers a third party device option to access video programming from them.

MVPDs Generally Still

Require a Set-Top Box but 

Have Offered Subscribers 

Additional Ways to Access 

Video in Response to the 

Changing Marketplace
Page 13 GAO-17-785 Video Programming

CableCARD. 19 Representatives of one public interest group also stated 

that because MVPDs charge their customers a monthly fee for using 

CableCARD devices, as they do for a set-top box, customers have little 

financial incentive to adopt these alternative devices. Another public 

interest group stated that MVPDs do not make their subscribers aware of 

their ability to purchase and use such devices.

Although subscribers to MVPDs generally require a set-top box in most 

cases to access content they subscribe to, many MVPDs are also offering 

their video programming over the Internet and through alternative 

devices. For example, according to Kagan, MVPDs have started to allow 

consumers to access their subscription content via the Internet in and out 

of the home, on multiple devices, and when they want, for example:

• Many cable networks allow subscribers to MVPDs that carry that 

network to access live or on-demand content through an app or 

website specific to that network. MVPDs do not develop or control 

these apps and websites. Such service is often referred to as 

“television everywhere.” Kagan forecasts that views of Internet-based 

television everywhere from MVPDs will increase from approximately 

5.4 billion views in 2016 to 11 billion views in 2020. All nine of the 

larger MVPDs we interviewed told us that their customers can access 

some “television everywhere” content online.

• Many MVPDs have also developed their own apps allowing their 

subscribers to access a range of content. Eight of the nine larger 

MVPDs told us they have developed apps for Internet-capable 

devices such as smart phones and tablets that allow their subscribers 

to access content in and out of the home. Such apps may allow for 

viewing both live and on-demand content. For example, consumers 

can use a Comcast application on their smart phone out of their home 

to view content.20 In addition, some MVPDs have developed apps for 

streaming devices such as Roku. In some, but not all, cases such 

apps can be used as a replacement for a set-top box; however, only 

three of the nine larger MVPDs we interviewed said that their 

 19In October 2010 FCC issued regulations attempting to remedy shortcomings in 

CableCARD devices to improve consumers’ experiences for those who choose to buy a 

retail device rather than lease the MVPD’s set-top box. Among other things these 

regulations require MVPDs to allow their customers to self-install CableCARD devices. 47 

C.F.R. § 76.1205(b).

20MVPD content views away from home might be limited by contractual agreements with 

content developers.
Page 14 GAO-17-785 Video Programming

subscribers may be able to use apps and alternative devices to 

access their subscriptions without the need for any set-top box. For 

example, one MVPD told us that customers can use an app on a 

Roku streaming device to access content without needing any set-top 

boxes.

These changes by MVPDs may be due to competition from new Internetbased services; 10 out of 11 industry experts and analysts we interviewed 

told us that MVPDs are providing access to their programming through 

alternative devices other than set-top boxes due to such competition.

Despite growth in alternative devices and services, a Kagan report 

indicated and MVPDs we interviewed told us that set-top boxes will still 

play an important role in the near future for accessing video content from 

MVPDs as the industry replaces many current set-top boxes with higher 

end versions. For example, the set-top box for one MVPD we interviewed 

now provides advanced functions such as voice control, universal 

searching, and increased storage of programming. All nine larger MVPDs 

we interviewed told us that they foresee the set-top box still playing a role 

in their service in the near future, and only three said their customers may 

be able to access their subscriptions solely on alternative devices without 

the need for a set-top box.21 One MVPD told us that although it sees 

video providers moving to apps on their own in the future, there will still 

be an option for consumers to access content from their set-top box. This 

MVPD has made upgrades to its set-top box to provide more features and 

has incorporated Internet video applications such as Netflix directly into 

its set-top box. Additionally, eight out of the 11 experts and industry 

analysts we interviewed said that they expect the set-top box to continue 

to be needed for traditional provider services for households in the future. 

One expert stated that the set-top box is the most efficient way to access 

and deliver programming, and that it remains the best solution for 

consumers and an important component of video programming.

 21One does not offer such apps and five require their subscribers to have at least one settop box to access content despite the availability of such apps.
Page 15 GAO-17-785 Video Programming

While the Internet has provided consumers with more choice for 

accessing video programming without subscribing to an MVPD and using 

an associated set-top box, consumers must have broadband access to be 

able to use these alternative products. However, FCC, in a 2016 

broadband progress report, estimated that 10 percent of the population 

does not have adequate access to in-home fixed broadband Internet and 

the lack of broadband access is particularly concentrated in rural and 

tribal areas.22

Although subscriptions to broadband Internet service are rising as those 

to MVPD video services are declining, most households are dependent 

upon MVPDs to receive broadband Internet service. According to FCC, 

97 percent of consumers are reliant on their MVPD for broadband 

service, and according to Kagan the ten largest video providers account 

for 91 percent of broadband subscriptions.23 However, as we recently 

reported, continuing technological changes may provide new options for 

obtaining access to broadband as, in the future, wireless Internet access 

may be able to serve as a substitute to in-home broadband for some 

consumers, and satellite-provided Internet service may also become an 

option for consumers who don’t have access to in-home wired 

broadband.24 For example, Kagan expects wireless broadband to serve 

as a growing substitute choice for consumers with the advancement of 

higher speeds in the future.

 22The FCC identified 25Mbps/3 Mbps benchmark as necessary to access “advanced 

telecommunications capability;” according to FCC, while satellite companies that provide 

video services also offer Internet service, no satellite provider offered Internet service at 

those speeds as of January 2016. In the Matter of International Comparison Requirements 

Pursuant to the Broadband Data Improvement Act, International Broadband Data Report, 

31 FCC Rcd 2667 (2016).

2331 FCC Rcd 2667 (2016).

24Recent moves by some wireless providers to offer unlimited data plans make such 

services a better substitute for in-home Internet due to the increase in speed of wireless 

services and the ability for the consumer to access unlimited data, including internet video 

providers. See GAO, Broadband: Additional Stakeholder Input Could Inform FCC Actions 

to Promote Competition GAO-17-742 (Washington, D.C.: Sept. 19, 2017).

Some Consumers May 

have Difficulty Taking 

Advantage of Internet 

Services That Do Not 

Require a Set-Top Box
Page 16 GAO-17-785 Video Programming

Most selected stakeholders and industry experts we spoke to did not see 

a need for FCC to intervene in the set-top box market at this time, given 

the changes taking place that provide consumers with more choices for 

services and devices to access video programming. All 11 of the experts 

and analysts we interviewed said that the industry is moving away from 

set-top boxes on its own by providing content through other means and 9 

of those 11 added that, as a result, there is no need for FCC regulatory 

intervention. Furthermore, only 8 of the 35 total industry stakeholders we 

interviewed stated that regulations are needed.25 These stakeholders

pointed to the development of apps and devices beyond set-top boxes 

that consumers can use to access video content. For example, one of the 

larger MVPDs said that competitive pressures have pushed the company 

to offer consumers new ways and devices with which to access the 

content they subscribe to.

However, representatives of all three public interest organizations we 

interviewed said that FCC regulations are still needed to promote 

consumer choice for devices. Specifically, representatives of one public 

interest organization we interviewed said that although the market has 

evolved to provide more device choices for consumers, the fact that 

almost all MVPD subscribers lease a set-top box shows that the intent of 

the Act has not yet been met. They added that while MVPDs have been 

 25In addition, 19 said regulations are not needed at this time, 2 gave uncertain answers, 

and 6 did not comment

Experts and 

Stakeholders Suggest 

Additional FCC 

Efforts on Choice in 

Set-Top Boxes are 

Not Needed, but FCC 

has Conducted 

Limited Analysis of 

this Issue

Generally, Selected 

Stakeholders and Experts 

Did Not See Need for FCC 

Regulation to Increase 

Consumer Choice for SetTop Boxes
Page 17 GAO-17-785 Video Programming

increasing the development of apps for their subscribers to access 

content, these apps so far do not have all the functionality of leased settop boxes, meaning that the apps are not an adequate substitute. As 

discussed earlier, despite the growth in apps, most larger MVPDs we 

interviewed still require their subscribers to have at least one set-top box.

Some industry stakeholders and experts and analysts we interviewed 

thought that FCC’s proposed rule26 could have had negative effects on 

MVPDs as well as other industry participants, including content providers. 

As discussed earlier, the proposed rule would have required MVPDs to 

transmit information—including video programming itself—to third party 

devices. According to representatives of one industry association we 

interviewed, this could have meant that MVPDs, and the programmers 

whose content they distribute, would lose control over content that they 

had created or purchased the distribution rights to. Programmers 

negotiate terms and conditions—such as channel lineup and other 

issues—with MVPDs that distribute their content. Some stakeholders 

expressed concern that under the proposed rule there would be no 

guarantee that third party device and service companies would adhere to 

all those terms and conditions under which that content was provided to 

the MVPDs. Some MVPDs and programmers expressed concern that 

some third-party device companies might modify the stream of 

programming by, for example, changing channel placement or overlaying 

advertising.

Five of the 11 experts and analysts we interviewed thought that the 

proposed rule could have led to copyright violations.27 Almost all larger 

MVPDs, broadcast networks, and independent and diverse programmers 

and interest groups we interviewed expressed concerns that should there 

be copyright violations, content providers could also be negatively 

affected.28 For example, one industry association said if a third party 

device were to overlay advertising on a program, the value of advertising 

availability that is usually sold by broadcast or cable networks or by cable 

distributors would decrease since there might be competing advertising 

 26As mentioned earlier, the former FCC Chairman issued a “fact sheet” of a proposed final 

rule, but FCC did not publish the proposed final rule. When we discuss “proposed rule” 

here we only refer FCC’s February 2016 Notice of Proposed Rulemaking.

27Six did not comment.

28One larger MVPD did not comment.

Some Experts and 

Industry Stakeholders 

Raised Concerns about 

the Potential Effects of 

FCC’s Recent Proposal to 

Expand Consumers’

Choices for Devices
Page 18 GAO-17-785 Video Programming

displayed to viewers. This stakeholder added that any reduced ad 

revenues would, in turn, reduce the ability to invest in content. Seven of 

the 11 experts and analysts we interviewed reported that the proposed 

rule could negatively affect content providers.29 Furthermore, some 

stakeholders told us that they believed the possible negative effects of the 

proposed rule could have especially affected independent and diverse 

programmers such as Vme, a national Spanish language network. 

According to one independent and diverse programmer we interviewed, 

its business is dependent upon agreements with MVPDs that distribute its 

programming. Those agreements include a range of terms including 

advertising restrictions and channel placement. To the extent a third party 

could modify the content—such as by overlaying advertising—that 

programmer would have a harder time negotiating with MVPDs, 

potentially reducing the compensation received from MVPDs for carrying 

its channel, thus harming its business model. Furthermore, according to a 

letter written by the Copyright Office, the proposed rule could have 

interfered with the rights of copyright owners to license their works by 

requiring MVPDs to provide content to third parties that would not 

necessarily have a contractual relationship with the copyright owner.

However, some other stakeholders we interviewed stated that they 

believed there was little likelihood that the proposed rule would have led 

to licensing terms not being followed and reported that the proposed rule 

may have provided public benefits, specifically:

• Two public interest groups we interviewed said that because there 

have not been violations with copyrights on CableCARD devices, 

such violations would be unlikely on any new devices that would have 

been created under the rule.

• Representatives with one industry association representing 

technology companies said that the proposed rule could have 

benefited independent and diverse programmers by increasing the 

number of devices available to consumers to access content, 

providing such programmers with increased opportunities for 

consumers to find their content.

• Representatives with one public interest group said that consumers 

would benefit from the proposed rule as new devices created in 

 29Two said they may not be negatively affected, one was unsure, and one did not 

comment.
Page 19 GAO-17-785 Video Programming

response to the rule would increase access to programming on new 

devices, thus increasing programming options overall.

• Representatives with a device manufacturer said that the proposal 

could have provided consumers with new and innovative ways to 

access video content.

FCC was directed by statute to adopt regulations to assure a commercial 

market for devices (such as set-top boxes) to access MVPD services, and 

both its existing regulations (the CableCARD regulations) and its 2016 

proposed rule that was not enacted were developed in response to that 

statute. However, in the context of a rapidly evolving video market 

offering increased consumer choices in many relevant areas, FCC 

conducted limited analysis to support the need for its 2016 proposed rule

prior to proposing it. In addition, letters to Congress from the new FCC 

Chairman stating his intention to not move forward with this issue did not 

contain or cite any analysis supporting that decision.30 The Office of 

Management and Budget’s Circular A-4 states that regulatory agencies 

could use regulatory analyses to analyze the need for proposed actions, 

as required under Section 6(a)(3)(C) of Executive Order 12866.31 In the 

proposed rule, FCC supported the need by stating that “consumers have 

few alternatives to leasing set-top boxes from their MVPDs, and the vast 

majority of subscribers lease boxes from their traditional video distributor,” 

adding that, according to an analysis cited by FCC, approximately 99 

percent of consumers lease a device. The proposed rule did not fully 

pursue the question of why approximately 99 percent of consumers lease 

a device when many of them could choose a CableCARD device. The 

proposed rule noted some of the technical limitations of CableCARD 

devices and stated that cable companies generally provided poor 

CableCARD support, making it more difficult for consumers to set up a 

retail device than a leased device. However, it did not give any further 

consideration to why so few consumers have adopted such devices; as 

discussed earlier, cable providers we interviewed said customers have 

 30In commenting on a draft of this report, FCC noted that the limited action of taking a notyet-adopted proposal off circulation would not generally be an occasion for providing a 

regulatory impact analysis since such an action would have no regulatory effect.

31Office of Management and Budget, Circular A-4 (Sept. 17, 2003). We note that this 

requirement—unlike others in Executive Order 12866 like Sections 4(b) and 4(c)—does 

not extend to independent regulatory agencies such as FCC, which are excluded from the 

definition of the term “agency” by Section 3(b) of that order. However, we believe that 

these criteria are still useful and relevant to FCC’s analysis of its 2016 proposed rule.

FCC Has Conducted 

Limited Analysis to 

Support Response to 

Statutory Requirement 

Regarding Consumer 

Choice for Set-Top Boxes
Page 20 GAO-17-785 Video Programming

limited interest in adopting such devices for a variety of reasons, such as 

the ease of leasing a set-top box from a provider, which will replace the 

box if it breaks, compared to owning a third party device where if it breaks 

the consumer may have to buy a new one. 

The proposed rule also contained limited analysis of the potential effects 

of this rule on consumers, MVPDs, or others. For example, while FCC 

supported the proposed rule by stating that the average household pays 

over $230 a year in set-top box lease fees, the proposal did not estimate 

the extent to which any increased competition in the market for set-top 

boxes might lead to cost savings for consumers. More broadly, FCC has 

conducted some analysis of the evolving video market, which, as 

discussed earlier, is providing consumers with more choices for both 

video services as well as devices to access services. For example, FCC’s 

most recent congressionally mandated annual video competition report—

published in January 2017—includes discussion of the increasing 

popularity of Internet-based video services and the competitive pressures 

they have placed on MVPDs, among other things.32

While the Act requires FCC to set regulations to assure the commercial 

availability of devices to access MVPD services, it also states that any 

regulations implemented under the statute shall cease to apply if FCC 

deems that: (1) the market for MVPDs is fully competitive, (2) the market 

for devices used to access MVPD services is fully competitive, and (3) the 

elimination of the regulations would promote competition and the public 

interest. While, as discussed above, FCC has conducted some analyses 

related to these issues, neither the proposed rule nor the recent video 

competition report reflect a comprehensive analysis looking at how these 

interrelated issues affect each other. In addition, May 2017 letters to 

Congress from the new FCC Chairman stating his intention to not move 

 32This report also discusses the limited adoption of CableCARD devices by consumers 

and the fact that most lease a set-top box from their MVPD. It also acknowledges the 

growing use of apps by MVPDs that can be used on a variety of devices and states that it 

is not yet clear if such devices are used as substitutes for set-top boxes leased from 

MVPDs or merely as complements. FCC, Annual Assessment of the Status of 

Competition in the Market for the Delivery of Video Programming: Eighteenth Report 

(Washington, D.C.: Jan. 17, 2017).
Page 21 GAO-17-785 Video Programming

forward with this issue did not contain or cite any analysis supporting that 

decision.33

Specifically, FCC’s analyses do not consider the effect that increasing 

consumer choice for video services has on the importance of consumer 

choice for devices to access MVPD services. Increased consumer choice 

for services may reduce the market power of MVPDs and may restrict 

what they can do and what they can charge for set-top boxes—as well as 

potentially spurring innovation in how they offer access to their MVPD 

services. While the 2017 video competition report touches on consumer 

choice for both services and for devices, it does not discuss the extent to 

which new choices for services have affected the importance of consumer 

choice for devices. Furthermore, this analysis does not consider what 

level of consumer choice for devices must exist for the market for devices 

to be “fully competitive.”

While FCC’s former Chairman believed that new regulations were needed 

to fulfill the requirements of the Act, the current Chairman believes that 

the 2016 proposed rule did not further his goal of promoting a clear, 

consumer-focused, fair, and competitive regulatory path for video 

programming delivery. As stated earlier, the proposed rule contained

limited analysis. In addition, the new Chairman’s letters to Congress noted 

that he had removed his predecessor’s proposal from circulation but were 

silent as to whether the Commission would take any future action in this 

proceeding. A future Commission may again determine that regulations 

are needed or decide not to take any further action on this issue.

As discussed earlier, the market has evolved in recent years and 

provided consumers with expanded choices for video services and for 

devices to access such services. For example, some MVPDs now allow 

their subscribers to access their content with apps on streaming devices 

without the need for a set-top box. It is possible that in the future each 

new year may see the market providing new choices for services and 

devices. Without an analysis of the effects of new Internet-based video 

services on consumer choice for devices to access MVPD programming, 

FCC may not fully understand the extent of consumer choice and 

furthermore, the extent to which increased consumer choices for video 

services affects the relative importance of consumer choice for devices to 

 33In commenting on a draft of this report, FCC noted that the limited action of taking a notyet-adopted proposal off circulation would not generally be an occasion for providing a 

regulatory impact analysis since such an action would have no regulatory effect.
Page 22 GAO-17-785 Video Programming

access MVPDs. Such an analysis, conducted as part of FCC’s existing 

annual video competition reports—which, as discussed, already include 

relevant analyses—could help FCC determine if additional regulations are 

needed.

The market for video services and devices to access video services has 

evolved significantly in recent years so that consumers now have 

considerably more choices for video services and devices to access such 

services than when Congress passed the Telecommunications Act of 

1996. Given the fast pace of change in the video market in recent years 

and the likelihood that it will continue to evolve to offer consumers more 

choices in how they access video content, it is important that FCC 

analyze the implications of these changes for its responsibilities under the 

Act to assure the commercial availability for devices that can access 

MVPD programming.

However, FCC has not conducted a comprehensive analysis to support 

an informed decision as to whether further action is needed or not. FCC’s 

recently proposed rule and most recent annual video competition report 

contain limited analysis of the extent to which Internet-based providers 

affect consumer choice for video programming and what that change 

means for the importance of consumer choice for devices in the context 

of the Act. In contrast, a comprehensive analysis could inform FCC as to 

whether the market conditions of competition for both video services and 

devices have been reached under which, as stated in the Act, any 

regulations implemented under the statute shall cease to apply. Should 

such analysis show that those market conditions have not yet been 

reached, a clear articulation by FCC of what elements have and have not 

yet been met could help as a benchmark in FCC’s further consideration of 

this issue as the market likely continues to evolve. Without more 

comprehensive analysis of the industry’s evolution and its effects on 

consumer choice for devices to access MVPD services, FCC could 

potentially take regulatory action—or choose not to take action—in a way 

that is not beneficial to consumers and does not meet the goals of the 

Act.

To help ensure that any future decisions by FCC regarding its efforts 

under the Act are based on comprehensive analysis, we recommend that 

FCC, as part of its future annual video competition reports, analyze how 

the ongoing evolution in the video programming market affects 

competition in the related market for set-top boxes and devices, including 

Conclusions

Recommendation
Page 23 GAO-17-785 Video Programming

how this evolution affects the extent to which consumer choice for 

devices to access MVPD content remains a relevant aspect of the 

competitive environment. (Recommendation 1)

We provided a draft of this report to FCC and the Library of Congress for 

review and comment. FCC responded with a letter in which it agreed with 

our recommendation. This letter is reprinted in appendix II. FCC also 

provided technical comments that we incorporated as appropriate. The 

Library of Congress reviewed our report and did not provide any 

comments.

We are sending copies of this report to interested Congressional 

committees and the Chairman of the FCC. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov.

If you or 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. GAO staff that made significant contributions 

to this report are listed in Appendix III.

Sincerely yours,

Mark Goldstein

Director, Physical Infrastructure Issues

Agency Comments
Appendix I: Industry Stakeholders and Experts 

and Analysts Interviewed

Page 24 GAO-17-785 Video Programming

The following tables list the industry stakeholders and industry analysts 

and experts GAO interviewed as part of this engagement.

Table 1: 35 Industry Stakeholders Interviewed

Larger Multichannel Video Programming Distributors

Altice

AT&T

Charter Communications

Comcast

Cox Communications, Inc.

DISH Network

Frontier

Mediacom Communications

Verizon

Smaller Multichannel Video Programming Distributors

3 Rivers Communicationsa

Volcano Communicationsa

Wheat State Telephonea

Large Broadcast Networks and Programmers

CBS

The Walt Disney Company

Independent or Diverse Programmers and Non Profit Organizations

Multicultural Media, Telecom and Internet Council

Up Entertainment

Vme

Industry Associations

American Cable Association

Computer and Communications Industry Association

Copyright Alliance

INCOMPAS

Independent Film and Television Alliance

Motion Picture Association of America

NCTA – The Internet & Television Association

National Association of Broadcasters

Writers Guild of America West 

WTA - Advocates for Rural Broadband

Appendix I: Industry Stakeholders and 

Experts and Analysts Interviewed
Appendix I: Industry Stakeholders and Experts 

and Analysts Interviewed

Page 25 GAO-17-785 Video Programming

Device Manufacturers

ARRIS

Hauppauge Digital, Inc.

TiVO

Public Interest Organizations

Consumers Union

Electronic Frontier Foundation

Public Knowledge

Streaming Video Provider

Netflix

Other

Corporation for Public Broadcasting

Source: GAO GAO-17-785

a

These providers were interviewed as part of a meeting with WTA – Advocates for Rural Broadband

Table 2: 11 Industry Experts and Analysts Interviewed

Industry Experts and Analysts

Jason Bazinet, Citi

Professor Nicholas Economides, New York University Leonard J. Stern School of 

Business

George Ford and Lawrence Spiwak, Phoenix Center

Rich Greenfield, BTIG

Jonathan Chaplin, New Street Research

Bryan Kraft, Deutsche Bank

Bruce Leichtman, Leichtman Research Group

Simon Leopold, Raymond James & Associates

Marci Ryvicker, Wells Fargo

Dr. Nicol Turner-Lee, Brookings Institution

Brian Wieser and Jeffrey Wlodorczak, Pivotal Research Group

Source: GAO | GAO-17-785
Appendix II: Comments from the Federal 

Communications Commission

Page 26 GAO-17-785 Video Programming

Appendix II: Comments from the Federal 

Communications Commission
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 27 GAO-17-785 Video Programming

Mark Goldstein, (202) 512-2834 or goldsteinm@gao.gov.

In addition to the contact above, Alwynne Wilbur (Assistant Director); Matt 

Rosenberg (Analyst in Charge); Amy Abramowitz; West Coile; Leia 

Dickerson; Sharon Dyer; Camilo Flores; Joshua Ormond; Nitin Rao; Amy 

Rosewarne; and Elizabeth Wood made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101066)
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