Testimony 

Before the Committee on Commerce, 

Science, and Transportation, U.S. Senate

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 9:30 a.m. EDT 

Tuesday, May 6, 2003 TELECOMMUNICATIONS 

Data Gathering Weaknesses 

In FCC’s Survey Of 

Information on Factors 

Underlying Cable Rate 

Changes 

Statement of William B. Shear, Acting Director 

Physical Infrastructure 

GAO-03-742T 
Based on interviews with 100 randomly sampled cable franchises that 

completed FCC’s 2002 survey, GAO’s preliminary analysis indicates that 

FCC’s survey may not be a reliable source of information on the cost factors 

underlying cable rate increases. Because of the following problems, GAO 

found that there are inconsistencies in how companies completed the 

survey. 

• FCC provided minimal instructions or examples on how the portion 

of the survey covering the cost factors underlying rate increases 

should be completed. It appears that cable companies made varying 

assumptions on how to complete the survey. 

• FCC’s survey required that cable companies fully allocate their 

reported annual rate increase to various cost and non-cost factors. 

Our preliminary findings indicate that there was inadequate guidance 

on how to achieve this requisite balance, and cable companies 

approached the question in varying ways. 

Based on preliminary work, GAO found that FCC’s classification of cable 

franchises as to whether they face effective competition might not 

accurately reflect current conditions. GAO found instances where 

information in the survey responses of some franchises would suggest that 

the criteria for an effective competition finding that was made in the past 

might no longer be present. However, a finding of effective competition is 

only changed if a formal process is instituted. GAO found only two 

instances where a petition was filed that resulted in a reversal of an effective 

competition finding. 

Over 65 percent of American 

households currently subscribe to 

cable television service. There has 

been increasing concern that cable 

television rates have been rising 

faster than the rate of inflation for 

the last few years. 

As required, on a yearly basis, FCC 

prepares a report on cable rates in 

areas that face and those that do 

not face effective competition—a 

term defined by statute. For 

information used in this report, 

FCC maintains information on the 

competitive status of cable 

franchises and annually surveys a 

sample of cable franchises. 

At the request of this committee, 

GAO examined (1) the reliability of 

information that cable companies 

provided to FCC in its annual 

survey regarding cost factors 

underlying cable rate increases and 

(2) FCC’s process for updating and 

revising cable franchise 

classifications as to whether they 

face effective competition. 

What GAO Recommends 

GAO is continuing to evaluate 

these and other issues and may 

include recommendations in a final 

report to be issued in October 2003.

www.gao.gov/cgi-bin/getrpt?GAO-03-742T.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact William B. 

Shear at (202) 512-4325 or shearw@gao.gov. 

Highlights of GAO-03-742T, testimony 

before the Committee on Commerce, 

Science, and Transportation, U.S. Senate. 

May 6, 2003 

TELECOMMUNICATIONS 

Data Gathering Weaknesses In FCC’s 

Survey Of Information on Factors 

Underlying Cable Rate Changes 
Page 1 GAO-03-742T 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to provide preliminary observations from 

our ongoing work on cable television rates. Over 65 percent of American 

households are currently cable television subscribers. As you have noted, 

Mr. Chairman, cable television rates have been rising faster than the rate 

of general inflation for many years. At the request of this Committee, we 

are providing preliminary observations today on two issues: (1) the 

reliability of the information that cable companies have provided to the 

Federal Communications Commission (FCC) in 2002 regarding the costs 

factors underlying their recent cable rate increases, and (2) FCC’s process 

for updating and revising the classification of cable franchises as to 

whether they are facing effective competition—a statutorily-defined term. 

We plan to issue a report with our final analysis of these and other issues 

in October 2003. 

To address the reliability of information that FCC collected, we randomly 

sampled 100 of approximately 700 cable franchises that responded to 

FCC’s 2002 cable rate survey.1

 We selected a random sample of 100 cable 

franchises so that we could make estimates about the entire population of 

about 700 cable franchises that responded to the FCC. We asked these 

franchises a series of questions about how they completed a portion of 

FCC’s survey that asks about the cost factors underlying annual cable rate 

changes. To examine FCC’s process for classifying cable franchises as to 

whether they face effective competition, we reviewed how various 

franchises were classified according to FCC’s information and whether 

these classifications continue to accurately reflect current circumstances. 

Our work has focused on examining whether FCC’s annual report on cable 

rates is providing reliable information on the causes of rate increases and 

the competitive status in video markets. In summary, our preliminary 

analysis suggests that some of FCC’s information on cable companies is 

inconsistent and potentially misleading. In particular: 

• Our preliminary analysis of the responses provided by 100 cable franchises 

indicates that FCC’s 2002 survey does not provide a reliable source of 

information on the cost factors underlying cable rate increases. We found 

two key causes of variation in how companies completed the survey. First, 

 1

FCC samples between 700 and 800 of the universe of roughly 10,000 cable systems using a 

stratified sampling approach based on the status of effective competition and the size of 

the cable operator. 
Page 2 GAO-03-742T 

FCC provided minimal instructions or examples on how the portion of the 

survey covering the cost factors underlying rate increases should be 

completed. As a result, we found that cable companies made varying 

assumptions about how to complete the survey. Second, the FCC survey 

form requires that the reported dollar amounts reported for factors that 

might underlie rate changes—5 cost factors and a non-cost factor are 

included on the form—sum to the reported rate increase for the year. In 

the absence of guidance on how to achieve this requisite balance, cable 

companies approached the question in varying ways. In particular, most of 

the companies told us that they adjusted one of the 5 cost factors for the 

purpose of the required balancing, thereby misreporting actual cost 

changes that had occurred. 

• Our preliminary findings show possible inaccuracies in FCC’s current 

classification of cable franchises regarding their effective competition

status. We found indications that there are cases in which a finding of 

effective competition in a particular franchise area that might have existed 

in the past no longer seemed accurate. Nevertheless, the determination of 

effective competition remained in effect because the franchising authority 

had not filed a petition that would challenge that finding. In fact, we found 

that such petitions are rare. 

Cable television emerged in the late 1940s to fill a need for television 

service in areas with poor over-the-air reception, such as in mountainous 

or remote areas. By the late 1970s, cable began to compete more directly 

with free over-the-air television by providing new networks—available 

only on cable systems—such as HBO (introduced in 1972), Showtime 

(introduced in 1976), and ESPN (introduced in 1979). According to FCC, 

cable’s penetration rate—as a percent of television households—increased 

from 14 percent in 1975 to 24 percent in 1980 and to 65 percent by 2002. 

Cable television is by far the largest segment of the subscription video 

market, a market that includes cable television, satellite service (direct 

broadcast satellite (DBS) providers such as DirecTV), and other 

technologies that deliver video services to customers’ homes. 

Cable companies deliver video programming to customers through cable 

systems. These systems consist of headends—facilities where 

programming from broadcast and cable networks is aggregated—and 

distribution facilities—the wires that carry the programming from the 

headend to customers’ homes. Depending on the size of the community, a 

single headend can serve multiple communities or several headends may 

be required to serve a single large community. At the community level, 

Background 
Page 3 GAO-03-742T 

cable companies obtain a franchise license under agreed-upon terms and 

conditions from a franchising authority, such as a township or county. In 

some cases, state public service commissions are also involved in cable 

regulation. 

During cable’s early years, franchising authorities regulated many aspects 

of cable television service, including franchise terms and conditions and 

subscriber rates. In 1984, the Congress passed The Cable Communications 

Policy Act, which imposed some limitations on franchising authorities’ 

regulation of rates.2

 However, 8 years later, in response to increasing rates, 

the Congress passed The Cable Television Consumer Protection and 

Competition Act of 1992. The 1992 act required FCC to establish 

regulations ensuring reasonable rates for basic service—the lowest level 

of cable service that includes the broadcast networks—unless a cable 

system has been found to be subject to effective competition, which the 

act defined. The act also gave FCC authority to regulate any unreasonable 

rates for upper tiers (often referred to as expanded-basic service), which 

includes cable programming provided over and above that provided on the 

basic tier.3

 Expanded-basic service typically includes such popular cable 

networks as USA Network, ESPN, CNN, and so forth. In anticipation of 

growing competition from satellite and wire-based providers, the 

Telecommunications Act of 1996 phased out all regulation of expandedbasic service rates by March 31, 1999. However, franchising authorities 

retain the right to regulate basic cable rates in cases where no effective 

competition has been found to exist. 

As required by the 1992 act, FCC annually reports on cable rates for 

systems found to have effective competition compared to systems without 

effective competition. To fulfill this mandate, FCC annually surveys cable 

franchises regarding their cable rates. In 2002, the survey included 

questions about a range of cable issues including the percentage of 

subscribers purchasing non-video services and the specifics of the 

 2

The 1984 Act restricted regulation to only basic services for cable systems not subject to 

effective competition. In its rulemaking, FCC initially said that effective competition 

existed if three or more over-the-air broadcast signals existed in a given market. Under this 

narrow definition, over 90 percent of all cable systems would be subject to effective 

competition and therefore not subject to rate regulation. 

3

Basic and expanded-basic are the most commonly subscribed to service tiers—bundles of 

networks grouped into a package—offered by cable companies. In addition, customers in 

some areas can purchase digital tiers and also premium pay channels, such as HBO and 

Showtime. 
Page 4 GAO-03-742T 

programming channels offered on each tier to better understand the cable 

industry. 

Until recently, cable companies usually encountered limited competition 

in their franchise areas. Some franchise agreements were initially 

established on an exclusive basis, thereby preventing wire-based 

competition to the incumbent cable provider. In 1992, the Congress 

prohibited the awarding of exclusive franchises, and in 1996, the Congress 

took steps to allow telephone companies and electric companies to enter 

the video market. Still, only limited wire-based competition has emerged, 

in part because it takes large capital expenditures to construct a cable 

system. However, competition from DBS has grown rapidly in recent 

years. Initially unveiled in 1994, DBS served over 18 million American 

households by June 2002. Today, two of the five largest subscription video 

service providers are DirecTV and EchoStar, the two primary DBS 

companies. 

In a recently released report, we found that competition in the 

subscription video market can have a significant impact on cable rates.4

Using an econometric model, we found that franchise areas with a second 

wire-based video provider had rates approximately 17 percent lower than 

similar franchise areas without such a competitor.5

 We did not, however, 

find that competition from DBS providers is associated with lower cable 

prices, although we did find that where DBS companies provide local 

broadcast networks to their customers, cable companies provide more 

channels than in areas where DBS companies do not provide local 

broadcast channels. Moreover, we also found that DBS providers obtain a 

substantially higher level of subscribers in areas where they are providing 

local broadcast channels. 

 4

See, U.S. General Accounting Office, Telecommunications: Issues in Providing Cable 

and Satellite Services, GAO-03-130 (Washington, D.C.: Oct. 15, 2002). 

5

In a similar analysis, FCC found that cable rates in franchise areas with a wireline 

competitor were nearly 7 percent lower than in franchise areas without such as competitor. 

See, Federal Communications Commission, Report on Cable Industry Prices, FCC 02-107 

(Washington, D.C.: April 4, 2002). 
Page 5 GAO-03-742T 

FCC’s annual cable rate survey seeks information on cable franchises’ cost 

changes that may underlie changes in cable rates during the preceding 

year. To evaluate the reliability of these statistics, we asked 100 of the 

approximately 700 franchises that FCC surveyed in 2002 to describe how 

cost change information that they provided to FCC was calculated. Figure 

1 shows the actual portion of the FCC survey which franchises completed 

to provide their cost change information. 

FCC’s Cable Rate 

Survey Does Not 

Appear to Provide a 

Reliable Source of 

Information on the 

Cost Factors 

Underlying Cable 

Rate Increases 
Page 6 GAO-03-742T 

Figure 1: Section of FCC’s 2002 Rate Survey Covering Rate and Cost Changes 

Source: 2002 FCC Rates Survey 

Our discussions with cable franchises indicated considerable variation in 

how franchises completed this section of the 2002 FCC cable rates survey. 

Our preliminary observations indicate that there are two causes for the 

resulting variation: (1) there were insufficient instructions or examples on 

how the form was supposed to be completed, leading to confusion among 

cable operators regarding what to include for the different cost factors and 

how to calculate each of them; and (2) the requirement that the cost and 

non-cost factors sum to the reported annual rate increase caused many 

cable operators to adjust one or more of the cost factors, thereby resulting 

in data that might not provide an accurate assessment of the cost factors 

underlying cable rate increases. 

CPST2, whether or not it has the most subscribers.

48

49

50

51 Year-to-date change in monthly charge on row 50

52 License or copyright fees, existing programs

53 License or copyright fees, new programs

54 Headend or distribution facility investment

55 General inflation, not included elsewhere

56 Other cost changes (positive or negative)

57 Non-cost-related factors (positive or negative)

58 Total of rows 52-57 (must equal row 51)

-----

Monthly charge for BST plus CPST1 (rows 48 + 49)

For July 1, 2001 and July 1, 2002, allocate the change shown on row 51 by estimating the dollars and cents

Monthly charge for CPST1

and most subscribers among the CPST tiers (if more than one CPST is offered). Sometimes a "mini-tier"

with considerably fewer channels has the most subscribers among the CPSTs. This mini-tier is considered

July 1, 2000 July 1, 2001

or pay-per-view. CPST1 refers to the major CPST and typically meets two criteria: It has the most channels

Monthly Charges for Programming Services

In the following, the "basic cable service tier" or BST is the service tier that includes the retransmission of

Monthly charge for BST

E. Programming Service Charges in Community

over-the-air broadcast signals and may include a few satellite or regional channels. A "cable programming

-----

service tier" or CPST is any other tier containing programming other than that on the BST, pay-per-channel,

July 1, 2002

-----

that each factor, below, contributed. The total of these factors (row 58) should equal the change on row 51.

-----

-----

-----

-----

-----
Page 7 GAO-03-742T 

Lack of adequate instructions. Our interviews with 100 cable franchises 

indicate that the lack of specific guidance regarding the cost change 

section of the survey caused considerable confusion about how to fill out 

the form. Every franchise that we spoke with said it was unclear what FCC 

expected for at least one of the six factors (5 cost factors as well as a noncost factor); 73 of the 100 franchises said that the instructions were 

insufficient. In particular, several cable representatives we interviewed 

noted that there were no instructions or examples to show how to 

calculate investment, what types of cost elements should go into the other 

costs category, and what FCC meant by non-cost factors. This lack of 

guidance created considerable variation in the approaches taken to 

develop the cost factors. Table 1 provides information on the approaches 

cable franchises used to complete the portion of the survey pertaining to 

cost and non-cost factors underlying rate changes. 

Table 1:Summary of Approaches Used by Cable Franchises to Calculate Cost and Non-Cost Factors 

Type of cost/non-cost 

factor (line of FCC 

survey) Discussion of how franchises approached this factor 

License or copyright 

fees, existing and new 

programs (lines 52 and 

53) 

• Most of the cable companies told us they used specific cost data on existing programming costs to 

develop the cost changes associated with increases in existing programming. 

• Thirty-nine of the 47 franchises that reported an increase in new programming costs said they used 

actual information to calculate these cost changes. 

• Some companies took a standard company-wide approach to estimating programming costs as 

opposed to estimating the costs for each individual franchise. 

• Some companies combined cost changes for all programming without separating existing from new 

programs. 

Head-end or distribution 

facility investment (line 

54) 

• Eighty-three of the 100 franchises we surveyed entered zero for these infrastructure investments. Of 

these, 33 told us that there had, in fact, been additional costs for such upgrades that year. The 

reasons provided to us for leaving it blank included concern that it would be too difficult to determine 

how much of these costs would be appropriately allocated to a certain video service or franchise. 

• Some cable companies performed significant calculations to estimate how much should be allocated 

to the support of video services, while other estimates did not include detailed cost calculations. 

General inflation (line 55) • Fifty-seven of the 100 franchises estimated inflation by using either FCC or Bureau of Labor 

Statistics’ inflation factors. 

• Other companies left the inflation factor blank because they assumed that most inflation would be 

captured in the other cost factors. 

Other cost changes (line 

56) 

• Sixty-four of the 100 franchises filled in a zero for the other cost factor. Of these 64 franchises: 

• Thirty-two told us that there were, in fact, cost changes that would have appropriately been 

captured in the other category; 

• Seventeen told us that they did not understand what items should be included in other costs; and 

• Fifteen told us that by the time they got to this line on the form, they had already accounted for 

enough costs to offset the reported rate increase and thus, they did not evaluate whether there 

were any costs that should be included as other costs. 

Non-cost-related factors 

(line 57) 

• Eighty-seven of the 100 respondents said they did not understand what non-cost factors would 

cover, and as a result, 76 of the respondents left the non-cost factor blank. 

• Those that did enter a number for this factor cited such items as a change in profit margin or the 

need to establish uniform rates across franchises. 

Source: GAO Survey of 100 Cable Franchises 
Page 8 GAO-03-742T 

Requirement that factors sum to the reported annual rate change. Our 

survey of 100 cable franchises that responded to FCC’s 2002 cable rates 

survey indicated that a second source of confusion relates to the 

requirement that the sum of the underlying cost and non-cost factors (see 

fig. 1 lines 52-57) equal the change in the franchise’s cable rates (see fig. 1 

line 51). This portion of FCC’s survey was originally designed during the 

1990s when both basic and expanded-basic services were regulated. At 

that time, cable companies were required to justify any rate increases the 

cable company implemented based on cost increases that it had incurred 

during the year. An FCC official told us that the rate/cost factor portion of 

the form was designed to mirror a regulatory form that was used at that 

time to justify rate changes. When expanded-basic services were 

deregulated in March 31, 1999, FCC realized that cost factors would no 

longer necessarily equal the yearly rate change because companies were 

no longer required to tie rate changes to explicit cost factors for regulatory 

purposes.6

 In the 1999 cable rates survey, FCC added the non-cost line in 

this section of the survey and continued to require that the cost factors 

and the non-cost factor sum to the reported annual rate change. 

FCC officials told us that cable operators could use the non-cost factor 

element to make up any difference (positive or negative) between their 

changes in costs and rates. However, based on our findings, it appears that 

this may not have been clearly communicated to cable franchises. We 

found that only 10 franchises took this approach and instead, most 

franchises told us that they chose to change their estimate of one or more 

of the cost factors. In most cases, cable representatives told us that this 

meant reducing other cost factors because most franchises told us that 

their actual annual cost increases for the year covered by the 2002 survey 

exceeded their rate change for expanded-basic service.7

 In other words, 

most franchises—84 of the 100 franchises we spoke with—did not provide 

a complete or accurate accounting of their costs changes for the year. The 

following are some examples of how the franchises we surveyed chose to 

equalize the cost factors with the rate change. 

 6

In unregulated markets, for example, costs are an important factor in price setting by 

companies, but several other key factors, such as consumer demand and the 

competitiveness of the market also influence market price. 

7

Many franchises said that their profit margins for basic and expanded cable services 

decreased in 2002, but many said that those decreases were offset by increased profits 

from other services, such as cable Internet and digital cable. The 3 franchises that said that 

their rate increase exceeded their cost increases made the two balance by entering a 

positive number in non-cost-related factors. 
Page 9 GAO-03-742T 

• Fifteen franchises said they entered dollar values in the factors until the 

entire rate increase was justified and did not consider the remaining cost 

factors; 

• Twenty franchises said they chose to adjust the dollar estimates in existing 

and/or new programming in order to balance costs and rates; 

• Seven franchises said they chose to adjust the costs included for 

investment in order to balance costs and rates; 

• Twenty-seven franchises said they chose to adjust the amount of their 

inflation estimate to ensure that costs and rates were in balance; 

• Twenty-six franchises said they chose to adjust the other costs factor to 

ensure that costs and rate changes were in balance; and 

• Four franchises said they adjusted more than one of the cost factors in 

order to balance costs and rates. For example, one franchise chose to 

adjust all of the factors by a uniform percentage in order to retain a 

constant ratio of cost increases. 

The 1992 Cable Act established three conditions for a finding of effective 

competition, and a fourth was added in the 1996 Act. Specifically, a finding 

of effective competition in a franchise area requires that FCC has found 

one of the following conditions to exist: 

• Fewer than 30 percent of the households in the franchise area subscribe to 

cable service (low-penetration test). 

• At least two companies unaffiliated with each other offer comparable 

video programming service (through a wire or wireless—e.g., DBS—

service) to 50 percent or more of the households in the franchise area and 

at least 15 percent of the households take service other than from the 

largest company (competitive provider test). 

• The franchising authority offers video programming service to at least 50 

percent of the households in the franchise area (municipal test). 

• A local telephone company or its affiliate (or any other company using the 

facilities of such carrier or its affiliate) offers video programming, by 

FCC’s Process for 

Updating and 

Revising its 

Classification of the 

Competitive Status 

of Cable Franchises 

May Lead to 

Classifications that 

are No Longer 

Accurate 
Page 10 GAO-03-742T 

means other than direct broadcast satellite, that is comparable to that 

offered by the cable provider in the franchise area (LEC test).8

Franchising authorities have primary authority to regulate basic cable 

rates. However, these rates may only be regulated if the cable system is 

not facing effective competition. Under FCC rules, in the absence of a 

demonstration to the contrary, cable systems are presumed not to face 

effective competition. The cable operator bears the burden of 

demonstrating that it is facing effective competition.9

 Once the presence of 

effective competition has been established, the franchising authority is no 

longer authorized to regulate basic cable rates. FCC does not 

independently update or revise an effective competition finding once it is 

made. An effective competition finding may be reversed if a franchising 

authority petitions to be recertified to regulate basic rates by 

demonstrating that effective competition no longer exists. However, such 

petitions are rare. 

Our preliminary review of the approximately 700 cable franchises that 

responded to FCC’s 2002 cable rates survey suggests that the agency’s lack 

of any updates or reexamination of the status of competition in franchise 

areas may lead to some classifications of the competitive status of 

franchises that do not reflect current conditions. For example: 

• Forty-eight of the 86 franchises in the sample that FCC had classified as 

satisfying the low-penetration test for effective competition actually 

reported current information to FCC on their operations that appeared, 

based on our preliminary calculations, to indicate that current penetration 

rates are greater than the 30 percent threshold.10 Ten cable franchises 

appeared to have a penetration rate exceeding 70 percent—a full 40 

percentage points above the legislated low-penetration threshold. 

• Forty of the 262 franchises in the FCC survey that had been classified as 

having effective competition by FCC also reported that the franchising 

 8

For this test to be applicable, the telephone company and the cable provider must be 

unaffiliated. 

9

In some cases, franchise authorities do not wish to regulate rates and cable companies 

may choose not to file for a determination of effective competition, even if conditions 

warrant. 

10We calculated the penetration rate by dividing the number of franchise subscribers by the 

number of households in the franchise area, as reported by the cable company to FCC. 
Page 11 GAO-03-742T 

authority was currently regulating basic service rates. This would not be in 

accord with the statutory requirement. It is possible that such an 

inconsistency could occur because cable companies incorrectly completed 

FCC’s survey in some fashion. 

• Although the survey form asks the cable franchise whether they face 

effective competition in the franchise area, those responses are not always 

consistent with information maintained by FCC regarding whether there 

has been an official finding of effective competition. When FCC’s 

information conflicts with the survey response, FCC overrides the answer 

provided by the cable franchise. We found that FCC staff overrode the 

survey responses on effective competition for 24 percent of all franchises 

in its 2002 survey. 

Also, we have searched for instances in which franchising authorities 

sought to have a finding of effective competition reversed. We found two 

instances in which FCC reversed a finding of effective competition. 

However, in one of these instances involving ten franchises in Delaware, 

some of the franchises appear to remain classified as having effective 

competition even though FCC reversed the position in 1999. 

In its 2002 Report on Cable Industry Prices, FCC acknowledges that the 

classification of the competitive status of some franchises may not reflect 

current conditions. Some franchises that face competition may not have 

filed a petition, and therefore are not classified as facing effective 

competition. Also, some franchises may have previously met the criteria 

for a finding of effective competition, but because of changing 

circumstances may not currently meet the criteria and remain classified as 

facing effective competition. 

We are conducting additional work on the issues discussed today and a 

more complete analysis will be included in our final report, which we plan 

to issue in October 2003. In addition to the topics discussed today, we will 

be providing a more comprehensive analysis of the factors underlying 

recent cable rate increases, the impact of competition on cable rates and 

service, and cable tiering issues. 

Mr. Chairman, this concludes my prepared remarks. We would be pleased 

to answer any questions you or other members of the Committee may 

have. 

Additional GAO Work 

on Cable Rate and 

Competition Issues 
Page 12 GAO-03-742T 

For questions regarding this testimony, please contact William B. Shear on 

(202) 512-4325 or at shearw@gao.gov. Individuals making key 

contributions to this testimony included Amy Abramowitz, Mike Clements, 

Keith Cunningham, Michele Fejfar, Wendy Turenne, Mindi Weisenbloom, 

and Carrie Wilks. 

Contact and 

Acknowledgments 

(545033) 
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