Digital Television Transition: Majority of Broadcasters Are Prepared for the DTV Transition, but Some Technical and Coordination Issues Remain
Published: 2008-04-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Digital Television Transition and Public Safety Act of 2005, requires all full-power television stations in the United States to cease analog broadcasting by February 17, 2009, known as the digital television (DTV) transition. Prior to the transition date, the television broadcast industry must take a series of actions to ensure that over-the-air programming will continue to be available to television households once the transition is complete. For example, broadcast stations must obtain, install, and test the necessary equipment needed to finalize their digital facilities, and some stations will need to coordinate the movement of channels on the day the analog signal ceases transmission. This requested report examines (1) the status of broadcast stations in transitioning to digital, (2) the extent to which broadcast stations are encountering issues, and (3) the actions the Federal Communications Commission (FCC) has taken to guide broadcasters in the digital transition. To address these issues, GAO conducted a Web-based survey of full-power television broadcast stations. GAO surveyed 1,682 stations and obtained completed questionnaires from 1,122 stations, for a response rate of 66.7 percent. GAO also reviewed legal, agency, and industry documents and interviewed public, private, and other stakeholders. We provided FCC with a draft of this report, and FCC provided technical comments that we incorporated where appropriate.
section_title: What GAO Found
paragraphs: Television broadcast stations have made substantial progress in transitioning to digital television, with the vast majority already transmitting a digital signal. Approximately 91 percent of the 1,122 full-power stations responding to our survey are currently transmitting a digital signal, with approximately 68 percent of survey respondents transmitting their digital signal at full strength and 68 percent transmitting their digital signal on the channel from which they will broadcast after the transition date. However, some stations still need to complete construction of their final digital facilities, and others need to relocate their digital channel to complete the transition. For example, 23 percent of survey respondents indicated they will be moving their digital channel to their analog channel. In addition, other stations need to move to a completely new channel. While almost all full-power stations are already broadcasting a digital signal, 9 percent of stations responding to our survey indicated that they are not currently broadcasting digitally. Almost all of these stations, however, indicated that they plan to have their digital signal operational by February 17, 2009. Some stations, including those already broadcasting a digital signal, need to resolve various technical, coordination, or other issues before their transition to digital is complete. For example, over 13 percent of stations responding to our survey reported that they need to install or relocate their digital or analog antennas. Some of these stations still need to order equipment, such as antennas, to build their final digital facilities. Furthermore, stations may have coordination issues to address to complete their final digital facilities. In particular, some stations are awaiting agreements with the Canadian and Mexican governments regarding their signals crossing the borders of these respective countries before they can complete their digital facilities. Stations also need to coordinate with cable providers and satellite companies to ensure that cable and satellite facilities receive digital signals when the analog signals are turned off. Lastly, the construction of broadcast towers or financial constraints might affect some stations during their transition. FCC's actions have provided guidance to broadcasters throughout the digital transition, but at the time we completed our survey, some broadcasters were awaiting FCC decisions. Since 1987, FCC has directed broadcasters with a series of rulemakings and orders, including assigning digital broadcast channels and developing timelines for the construction of digital facilities. Furthermore, FCC has conducted periodic reviews of the transition and released a ruling on its third periodic review on December 31, 2007, in which FCC addressed a number of important DTV issues. However, some stations responded to our survey that they needed decisions from FCC, such as approval for a construction permit or for changes to their final digital channel. According to FCC, it will address remaining issues quickly and with the release of an order in March 2008, FCC stated that it believes broadcasters have everything they need from the commission to proceed with construction of their final digital facilities.

section_title: Letter
paragraphs: The Digital Television Transition and Public Safety Act of 2005 requires all  full-power television stations in the United States to cease analog  broadcasting by February 17, 2009. After that time, such television stations  may only broadcast digital transmissions. This change is often referred to  as the digital television (DTV) transition. Prior to the transition date, the  television broadcast industry must take a series of actions. For example,  broadcast stations must obtain, install, and test the necessary equipment  needed for their final digital facilities, and some stations will need to  coordinate the movement of channels on the day that they cease analog  signal transmission. Most television broadcasters are already transmitting  both an analog and a digital over-the-air signal to television households.  However, prior to or on the final transition date, broadcasters will be  vacating portions of the spectrum, and 108 megahertz (MHz) of spectrum  will be reclaimed by the federal government. The Federal  Communications Commission (FCC), which is the federal entity  responsible for guiding the transition, has reallocated 24 MHz of the  spectrum for public safety purposes. In January 2008, FCC began  auctioning the remaining spectrum for commercial purposes.
You asked us to provide information on technical issues surrounding the  DTV transition. We reviewed (1) the status of broadcast stations in  transitioning to digital, (2) the extent to which broadcast stations are  encountering issues during the DTV transition and how these issues  impact the broadcast community, and (3) the actions FCC has taken to  guide broadcasters in the DTV transition and how those actions have  affected the broadcast community. In November 2007, we reported on the  status of consumer issues related to the DTV transition. We are continuing  to review consumer issues related to the DTV transition and will provide  an update on those issues later in 2008.
To obtain information on the status of the broadcast industry in  transitioning to digital and the issues broadcasters were encountering, we  conducted a Web-based survey of the full-power commercial and  noncommercial television broadcast stations (such as network broadcast  stations and public television stations) in the 50 states and the District of  Columbia. Among other things, we asked the broadcasters questions  related to their digital facilities, construction plans, and issues affecting  the digital transition. We obtained the list of full-power stations from FCC  in June 2007. Since FCC did not maintain e-mail addresses for all of the  licensed broadcasters at that time, we needed to obtain contact  information on the broadcasters through alternate sources. Of the 1,747  stations on FCC’s list, we surveyed 1,682 stations located in the 50 states  and the District of Columbia for which we could obtain contact  information. We conducted our survey from December 2007 through  February 2008 and obtained completed questionnaires from 1,122 stations,  for a response rate of 66.7 percent. Of those completed questionnaires,   72 percent were from commercial stations and 28 percent were from  noncommercial stations. This report does not contain all of the results  from the survey. The survey and a more complete tabulation of the results  can be viewed by accessing the following link:   http://www.gao.gov/cgi-bin/getrpt?GAO-08-528SP. Furthermore, we  reviewed relevant law, public comments, FCC proposed and final rules,  and various industry and private sector documents. We interviewed FCC  officials as well as a wide variety of industry and other private sector  stakeholders with an interest in the transition, such as broadcasters,  manufacturers, and industry advocacy groups. Appendix I contains a more  detailed discussion of our objectives, scope, and methodology. We  conducted this performance audit from April 2007 through April 2008 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.
subsections: section_title: Background
paragraphs: The DTV transition has been in progress for over two decades. With a firm  date established in law, all full-power television broadcasters will cease  broadcasting their analog signal by February 17, 2009. There are numerous  benefits to transitioning to digital-only broadcast signals, such as enabling  better quality television picture and sound reception and using the  radiofrequency spectrum more efficiently than analog transmission. With  traditional analog technology, pictures and sounds are converted into  “waveform” electrical signals for transmission through the radiofrequency  spectrum, while digital technology converts these pictures and sounds into  a stream of digits consisting of zeros and ones for transmission. While the  digital signal disperses over distances, a digital receiver can adjust and  recreate the missing zeros and ones from the digital transmission, thus  making the digital picture and sound near perfect until significant fading  occurs, at which point no picture can be seen.
To facilitate the digital transition, Congress and FCC temporarily provided  each eligible full-power television station (both commercial and  noncommercial educational stations, including public stations) with  additional spectrum so they could begin broadcasting a digital signal. This  companion, or paired, digital channel simulcasts the analog program  content in digital format. Assignment of the paired digital channel began in  1997 with the hopes that operating this digital channel would help stations  learn about broadcasting a digital signal, in addition to raising consumer  interest and understanding about the digital transition. The paired digital  channel was intended to be used for a limited period until all stations were  assigned a final digital broadcast station and were able to broadcast on  their final digital channel. FCC completed the digital channel assignment  for most stations in August 2007. A station’s final digital channel could be  (1) the same channel as its paired digital channel, (2) the same channel  that its analog signal uses to broadcast, or (3) an entirely new channel.
The Digital Television Transition and Public Safety Act of 2005 addresses  the responsibilities of FCC related to the DTV transition. The act directs  FCC to require full-power television stations to cease analog broadcasting  after February 17, 2009. Stations are responsible for meeting this  requirement and being prepared to commence digital broadcasting by this  date; stations not ready to commence digital broadcasting risk losing  interference protection and operating authority. The capability to provide  a digital broadcast signal often involves a large outlay of capital and effort  by broadcast stations. Sometimes a new broadcast tower or significant  modifications to an existing tower is required. While a new antenna could  cost a station several hundred thousand dollars, an industry association  stated that stations could spend as much as $2 million to purchase and  install a new broadcast tower, antenna, and equipment. If new towers or  antennas are not required, stations may still need to alter or upgrade  existing towers. Alterations may include moving the digital antenna from a  side-mounted antenna to the top of the tower to increase the coverage of  the digital signal. Upgrades to an existing tower may include strengthening  a tower before additional antennas can be added. For stations building  new towers, installing new antennas, or making changes to existing  structures, the stations must plan in advance to order the proper  equipment and schedule construction crews.
In September 2007, FCC adopted an order designed to ensure that all cable  subscribers, including those with analog television sets, can view digital  broadcasts after the transition. FCC stated that all cable operators must  make all broadcast signals viewable to all subscribers and cannot degrade  any signal so that a difference in the cable signal and the broadcast signal  would be perceptible to a viewer. According to the order, cable operators  can meet this requirement in one of two ways, either (1) carry the signals  of commercial and noncommercial must-carry stations in analog format to  all analog cable subscribers or (2) for all-digital systems, carry those  signals in a digital-only format, provided all subscribers with analog  television sets have the proper equipment to view the digital signals. This  requirement ensures that subscribers will have the ability to view a digital  signal or an analog signal, depending on which best suits their equipment.
While this ruling did not address satellite companies, FCC is considering  how to apply the content and degradation requirements to satellite  carriage of digital broadcast signals, and the commission expects to  complete this ruling before the transition. Satellite companies already  transmit digital signals to subscribers by digitizing broadcasters’ analog  signals.
section_title: Broadcast Stations Have Made Substantial Progress in Transitioning to Digital Television, and the Vast Majority Are Already Transmitting a Digital Signal
paragraphs: Most broadcasters have made significant progress in preparing their  stations for the transition to digital, with 91 percent of survey respondents  reporting that they were already transmitting a digital signal. Of the  broadcasters already transmitting a digital signal and responding to our  survey, 68 percent indicated that they are broadcasting their digital signal  at full strength. In addition, 68 percent of survey respondents are  broadcasting their digital signal on the channel from which they will be  broadcasting after the transition. A small number of stations responding to  our survey (9 percent) have yet to begin broadcasting a digital signal, but  almost all of those stations expect to be broadcasting digitally by   February 17, 2009.
subsections: section_title: Almost All Stations Are Broadcasting a Digital Signal, and the Majority Are Operating at Full Power
paragraphs: Our survey of broadcast television stations found that almost all stations  (91 percent of respondents) are transmitting a digital signal. Of those  stations transmitting a digital signal, the operating status of these survey  respondents, as of February 8, 2008, is shown in figure 1.
As figure 2 shows, 68 percent of stations that responded to our survey said  that their digital channel will not move after the transition. However,  about one third of stations are currently operating on a temporary digital  channel and will move to another channel to complete their transition to  digital. Twenty-three percent of survey respondents said they will abandon  their current digital channel to begin broadcasting digitally at the channel  location currently occupied by their analog channel. Approximately 9  percent of survey respondents will have to move to a completely new  channel once the transition is complete.
section_title: Nine Percent of Stations Responding to the Survey Are Not Broadcasting Digitally, but Almost All Stations Plan to Have a Digital Signal by February 17, 2009
paragraphs: Our survey of broadcast stations found that 97 stations, or 9 percent, are  not broadcasting a digital signal. On the basis of the information provided  by survey respondents, these stations serve a smaller number of  households, on average, compared with those stations broadcasting a  digital signal. In particular, survey respondents that are not broadcasting  digitally transmit their analog signal to approximately 350,000 households,  on average, compared with the average of nearly 775,000 households from  stations responding to our survey that are already broadcasting digitally.  Almost all of these stations that are not yet broadcasting digitally noted  that they plan to have their digital signal operational by February 17, 2009.  Three stations responded that they were not planning to broadcast a  digital signal by February 17, 2009.
According to FCC, stations that are not currently transmitting a digital  signal either (1) were granted a license to operate a digital signal along  with their analog signal but have yet to begin broadcasting digitally or   (2) were not given a digital license and plan to turn off their analog signal  at the same time that they turn on their digital signal—known as “flash  cutting.” According to our survey, 5 percent (61 stations) of the stations  indicated that they plan to flash cut to a digital-only broadcast. According  to FCC, flash cutting may present challenges, since it will involve stations’  ending their analog television operations and beginning their digital  television operations on their current analog channel or, in some cases,  will require that a station change to a new channel to be fully operational.  Of those stations responding to our survey that plan to flash cut, only 21  percent had begun constructing final digital facilities at the time of our  survey. Furthermore, 64 percent of the flash cutters responding to our  survey noted that they need to order equipment to complete their digital  facilities.
section_title: Some Broadcast Stations Face a Range of Technical, Coordination, or Other Issues in Completing Their Transition to Digital Television
paragraphs: Before the transition to digital can be finalized, some stations still have to  resolve technical, coordination, or other issues. According to stations  responding to our survey, a major technical task for over 13 percent of the  stations is the relocation of their digital or analog antenna. Other stations  responding to our survey indicated that they have coordination issues to  resolve prior to completing the transition, such as the U.S. government  reaching agreements with the Canadian and Mexican governments and  coordinating with cable providers and satellite companies. Our survey also  found that other issues, such as the construction of broadcast towers or  financial constraints, have affected some stations’ ability to finalize their  digital facilities.
subsections: section_title: Some Broadcast Stations Need to Address Technical Issues in Building Their Digital Facilities
paragraphs: Broadcast stations and industry representatives have stated that technical  issues might affect television stations’ ability to finalize digital operations.  Technical issues that some stations need to address include (1) antenna  and equipment replacement or relocation and (2) channel relocation.
subsections: section_title: Issues with Antenna and Equipment Replacement or Relocation
paragraphs: One of the major tasks that many television stations have to complete to  build their digital facilities is to install a digital antenna on the top of the  broadcast tower, where the analog antenna resides. According to a  broadcast industry representative, many stations need to have their digital  antenna at the top of the tower to fully replicate the area that their analog  service covers. The broadcast industry representative stated that stations  have two options in placing their digital antenna at the top of the  broadcast tower: (1) move the digital antenna to the top now, and buy a  new side-mounted analog antenna, which would ensure that the analog  signal continues until it is switched off and that the digital signal would be  at full power, or (2) keep the analog antenna at the top of the tower until it  is turned off on February 17, 2009, and then install the digital antenna at  the top of the tower. The industry representative stated that both options,  however, present problems for broadcast stations. For the first option,  stations may have to purchase a new analog antenna, which will only be  used for a few months. Also, as a result of the analog antenna being side  mounted, stations’ analog broadcast coverage area would be reduced by a  range from 2 to 9 percent of the viewing market. Stations agreed that they  might have to reduce their analog service prior to the transition date. For  example, the owner of a station in Minnesota commented that it may not  be possible to complete the construction of its digital facilities without  significantly disrupting its analog operations as well as its digital  operations. The owner said the power of its analog signal would have to be  significantly reduced before February 17, 2009, which would affect a large  number of its viewers.
Several survey respondents that were already broadcasting a digital signal  reported that they needed to take additional steps to complete their digital  facilities. According to our survey results, 151 stations (13 percent)  indicated that they needed to relocate their digital or analog antenna on a  current tower, reinforce an existing tower to allow for additional  antennas, or coordinate antenna placement on another tower. Figure 3  shows the number of stations that need to complete these various steps,  with some stations reporting that they have to complete multiple steps.
FCC recognizes that there are many technical issues associated with  antenna and equipment replacement or relocation that might force  stations to terminate analog signals prior to the transition date. For  example, FCC noted that there are 49 stations that have documented  problems with side-mounted analog antennas. These stations will have to  relocate their analog antenna to another location on their tower and  operate with reduced analog facilities as they complete the transition.  Other stations may have a tower at capacity, preventing the installation of  an additional antenna on the tower. According to FCC, these stations will  have to terminate analog operations prior to the end of the transition to  mount their digital antenna. In addition, stations with an antenna that is  located on a shared tower may need to reduce or terminate analog signals  as the stations coordinate the configuration of their final digital facilities.  Still other stations have equipment currently in use with their analog  operations that they plan to use with their digital operations. Such a  situation will force stations to terminate their analog signals prior to the  transition so that the equipment can be reconfigured for the final digital  facilities. Although FCC established February 17, 2009, as the new  construction deadline for stations facing unique technical challenges, FCC  will also consider stations’ requests to operate their digital facilities at less  then full power until August 18, 2009—provided the stations continue to  serve at least 85 percent of their viewers.
According to an antenna manufacturer with whom we spoke, stations will  need to place orders for their antenna by the second quarter of 2008 for  the stations to be prepared for the February 17, 2009, deadline. According  to this manufacturer, the amount of time needed to design, order, and  install an antenna can range from 6 weeks and 9 months, depending on its  complexity. This manufacturer said a typical antenna serving one station  requires about 4 or 5 months, from design to installation. In its third  periodic review and order on the DTV transition, FCC noted that absent  extraordinary circumstances, it would no longer consider a lack of  equipment as a valid reason for granting an extension of time to construct  facilities. FCC also said that stations demonstrating that they placed  equipment orders well in advance will be considered eligible for an  extension on these grounds.
Antenna work and replacement could be hampered by weather conditions  for towers located in northern climates and on higher elevations.  According to an antenna manufacturer with whom we spoke, although  antenna work can be done during the winter months, it can be much more  difficult, take longer, and entail additional costs. According to this  manufacturer, winds over 10 miles an hour can be problematic for  installing equipment. Installation crews need several days of limited wind  speed to complete antenna work. In addition, ice and snow can present  safety issues when installing antennas on towers. FCC recognizes that for  some stations, work cannot be completed because of weather conditions,  and that those stations facing legitimate delays will be considered for  construction extensions. For example, if a station has a side-mounted  digital antenna and can demonstrate that weather considerations would  force it to reduce or terminate its analog signal well before the transition  date to complete building of their final facility, it might qualify for an early  reduction or termination of analog service prior to February 17, 2009. FCC  states that in such situations, it could be preferable to accept a limited loss  of analog service for a short time prior to the transition date to ensure the  station is able to complete its transition to digital.
section_title: Issues with Channel Relocation
paragraphs: FCC notes that the stations facing the most significant amount of  construction to finalize their facilities are those that are moving to a  different channel. According to FCC, 643 stations will move to a different  channel to complete the transition. FCC states that 514 of these stations  will relocate their current digital channel to their analog channel. Stations  might prefer to relocate their digital channel to the analog channel  because it is the channel that viewers recognize. For example, one station  we visited has its digital signal on channel 16 but plans to relocate the  digital signal to channel 9, which is the station’s current analog channel  and the channel number people recognize for that station. In addition,  stations currently located on channels 52 through 69 need to relocate their  channel because these channel frequencies will be used for public safety  and new wireless services after the transition. According to FCC,   129 stations will move to a completely new channel once the transition is  complete. Such moves entail additional challenges for these stations  because they may need to address such issues as (1) can the stations use  any of their current analog or digital equipment, (2) will their viewers be  impacted during construction of their digital facilities, and (3) will the  stations have to coordinate with other stations because the channel they  are moving to will be occupied by another station until the transition date.
Because of the issues associated with channel relocation, FCC is allowing  stations moving to a different digital channel to cease operations on their  pretransition digital channels and begin operating digitally on their new  channels before the transition date. Stations can operate on their new  channel before the transition date provided (1) the early transitioning  stations will not cause impermissible interference to another station and  (2) the early transitioning stations continue to serve their existing viewers  for the remainder of the transition, and commence their full-power,  authorized posttransition operations upon expiration of the   February 17, 2009, transition deadline. In addition, stations that are  moving to a different digital channel for posttransition operations may  temporarily remain on their pretransition channel while they complete  construction of their final digital facilities. Stations can remain on their  pretransition channel provided (1) they build facilities serving at least the  same population that receives their current analog television and digital  services so that over the air viewers will not lose service and (2) they do  not cause impermissible interference to other stations or prevent other  stations from making their transition.
section_title: Coordination between Broadcast Stations and Various Public and Private Entities May Be Necessary to Support a Smooth Transition
paragraphs: Coordination issues might affect television broadcast stations’ ability to  finalize their digital operations, according to stations that responded to  our survey and our discussions with broadcast stations and industry  representatives. Coordination issues that some stations face include   (1) U.S. government coordination with Canadian or Mexican governments,  (2) coordination with cable providers and satellite companies, and   (3) coordination with other broadcast stations.
subsections: section_title: Coordination with Canadian and Mexican Governments
paragraphs: For some stations located along the northern and southern borders of the  United States, agreements must be reached with the Canadian and  Mexican governments regarding the coverage of the stations’ digital  signals that transmit across the borders. According to FCC officials, there  are 139 and 43 U.S. stations that operate along the Canadian and Mexican  borders, respectively. FCC officials stated that agreements are in place for  most of these stations, and FCC expects agreements to be reached for all  of the remaining stations. In responding to our survey, the stations that  require coordination with a foreign government noted that different levels  of coordination had taken place, as illustrated in figure 4.
However, in responding to our survey, most stations with a signal that  penetrates into Canada or Mexico were not concerned about analog  interference. In particular, 81 percent of respondents operating along the  Mexican border were not concerned about interference, while 86 percent  along the Canadian border were not concerned about such interference.
In responding to our survey question regarding coordination with the  Mexican and Canadian governments, one station commented that the lack  of concurrence from the Mexican government has created significant  concern about the station’s ability to transition to its final digital  operations, and that an agreement is needed as soon as possible. Another  survey respondent stated that objection by the Canadian government to its  final channel assignment was very late in the process and will seriously  jeopardize its ability to build its digital facilities by the transition date.  Another station that responded to our survey expressed concern about  Canadian coordination being completed by the 2009 deadline. In its third  periodic review and order, FCC stated that it will consider extensions of  construction deadlines for stations encountering delays in cases where  resolution of issues related to international coordination is truly beyond  the control of the station. FCC also stated that if agreements cannot be  reached, stations might be required to construct facilities with a smaller  area of signal coverage. At the time of this report, there was a set of  companion bills in the Senate and House known as the DTV Border Fix  Act, which, if enacted, would authorize FCC to allow full-power television  stations serving communities located within 50 miles of the U.S.-Mexican  border to continue operating an analog signal until February 17, 2014.  Among other requirements, stations seeking an extension would have to  satisfy FCC that continued analog operation would be in the public  interest.
section_title: Coordination with Cable Providers and Satellite Companies
paragraphs: As part of finalizing the transition to DTV, cable providers and satellite  companies will need to make sure that their facilities receive digital  signals from television stations when the analog signals terminate. In its  third periodic review and order, FCC made no rules concerning the  coordination between broadcast stations, cable providers, and satellite  companies. However, FCC reiterated that broadcasters must work with  cable providers and satellite companies to ensure a successful transition.
Many broadcast stations are currently coordinating with cable providers  and satellite companies. As shown in figure 5, 55 percent of the stations  responding to our survey indicated that they are currently coordinating  with cable providers, and 50 percent of the stations responding to our  survey indicated that they are currently coordinating with satellite  companies. In addition, nearly 35 percent of stations responding to our  survey indicated that they plan to coordinate with cable providers, and   36 percent of stations indicated that they plan to coordinate with satellite  companies. One percent of stations responding to our survey indicated  that they were not coordinating with and were not planning to coordinate  with cable providers, and 5 percent indicated that they were not  coordinating with and were not planning to coordinate with satellite  companies.
With some stations moving to a new channel or changing the coverage  area of their broadcast signal, cable providers told us there is uncertainty  about whether their cable head-ends will continue to receive the broadcast  signals. For example, if a broadcaster’s digital coverage area differs from  its analog coverage area, there is a possibility the cable head-end will no  longer be able to receive that signal. Approximately 32 percent of survey  respondents that are carried by cable, satellite, or both indicated that they  are concerned their digital signal may not reach one or more cable  providers’ or satellite companies’ facilities once the transition has  occurred. One cable provider told us this issue could be particularly  problematic in smaller markets where head-ends rely on over-the-air  broadcasts to pull in the broadcast signals.
A cable provider and satellite company also told us that they need  broadcast stations to inform them of their coverage areas, or signal  contours, as soon as possible to help them identify areas where the digital  signal may not reach cable head-ends or satellite receiver facilities. This  information is important because even when stations do have their digital  facilities fully operational, they may not broadcast their digital signal to  the exact coverage area that their analog signal covered. As shown in  figure 6, the digital signal coverage of a station can differ from its analog  signal coverage.
Officials with one cable provider with whom we spoke indicated that on  the basis of potential changing signal coverage areas, the provider might  need to reposition its antenna or otherwise update its head-ends so that it  can continue to receive the broadcast signals. The officials went on to say  that since their company has hundreds of head-ends, it could be time- consuming to update them. Officials of a satellite company told us that any  change in the signal coverage area could seriously affect the company’s  ability to retransmit broadcast signals and might require it to build new  facilities in the altered coverage area.
Information from our survey indicates that some stations will have a  different digital signal coverage area compared with their analog signal  coverage area. Of our survey respondents, 24 percent reported that their  digital signal coverage area will vary from their analog coverage area.  While some of these stations’ digital coverage area could be increasing  compared with the analog coverage area, some stations’ digital coverage  area will be smaller, at least in some parts of the coverage area, compared  with their analog coverage area. This is evident by 11 percent of the  stations responding to our survey reporting that they anticipate losing  over-the-air viewers after the transition to digital. On average, those  stations anticipating decreased coverage areas expect to lose 23,000  viewers.
section_title: Stations Coordinating with Each Other
paragraphs: According to our survey, 101 stations (9 percent) that have to relocate  their current digital channel are moving to another channel that might be  occupied by another station. Of these 101 stations, 13 survey respondents  indicated that they are working with the other station to resolve  coordination issues. According to a broadcast industry representative, the  movement of channels will require television stations to closely coordinate  with each other to minimize interference issues. The industry  representative stated that the movement of channels could cause  interference for neighboring channels if they move too early or if the  neighboring channels move too late. The industry representative further  stated that compounding this challenge is the fact that analog signals will  be turned off on February 17, 2009.
section_title: Other Issues, Such as Construction Scheduling and Financial Constraints, Might Affect Some Stations during Their Transition
paragraphs: The construction of broadcast towers or financial constraints might affect  some stations during their transition. Stations that must change their DTV  tower locations might face considerable challenges, especially if the  station must construct a new tower. Nineteen stations responding to our  survey indicated that they needed to construct a broadcast tower to build  their digital facilities. In addition, 62 stations responding to our survey  indicated that they needed to reinforce an existing broadcast tower to  finalize their facilities. A major television broadcast network stated that  equipment manufacturing constraints and the limited number of tower  crews and other key equipment installation resources available between  now and the transition date will impede stations’ movement to final digital  channels by February 17, 2009. A representative with a major tower  construction company told us that the company is already booked 6  months into 2008, and that other construction crews also have full  schedules. The company representative stated he believes that there are a  significant number of stations that will wait until early 2008 to start  making inquiries about work needing to be done on broadcast towers.
According to FCC, stations constructing a new tower should consider  whether there are any existing towers that can be used or if a new tower  must be constructed. FCC states that because of the lead times involved in  purchasing or leasing land with the appropriate federal government  clearances, local and state zoning requirements, and varying timelines for  designing and constructing the new tower, stations must begin planning as  soon as possible to have all of the work completed by the deadline.
Similar to weather conditions affecting work on antennas, winter weather  could hamper tower construction in northern climates and on higher  elevations. Television stations commented that working on towers in the  winter months can be problematic, if not impossible. For example, a major  broadcast network commented that many station transmitting sites are not  readily accessible during the winter, especially to cranes and other heavy  equipment necessary for tower rigging and equipment installation. In fact,  the broadcaster commented that snow and ice make one of its stations  accessible only by a special vehicle from October until March. Another  station commented that it has been difficult to perform heavy construction  at a remote and high-altitude transmitter site, and that the short weather  window, difficult access, and complex work make the transition date hard  to attain. A representative of a major tower construction company stated  that weather is always a factor when determining the amount of time a  project takes. The company representative stated that subzero conditions  and ice are not conducive for tower work, and, although the work can be  done, it is very dangerous and takes a much longer time to complete.
Stations encountering financial constraints may also have difficulties in  completing the digital transition. According to our survey, 38 stations  noted that financial constraints had been an issue during the process of  constructing their final digital facilities. In addition, 39 stations that are  broadcasting a digital signal, but have yet to begin building their final  digital facilities, indicated that financial constraints were a reason they  had not yet started construction. Furthermore, another 33 stations, or 42  percent of stations not yet broadcasting a digital signal, indicated that  financial constraints contributed to delays in building their final digital  facilities. One station commented that the digital transition has been a  financial drain on small-market television stations. This station noted that  the cost for the equipment is the same whether the station serves a small  or large market, but large-market stations have a much higher financial  base to pay for the equipment.
In its third periodic review, FCC acknowledged that some stations face  financial obstacles to completing construction, but stated that it is  imperative that stations devise and implement a plan to complete their  final digital facilities. FCC established criteria for extensions of  construction on final digital facilities due to financial hardship. To obtain  an extension on the grounds of financial hardship, FCC requires a station  to demonstrate that it (1) is the subject of a bankruptcy or receivership  proceeding or (2) has experienced a negative cash flow for the past 3  years. FCC stated that while adopting the tighter financial hardship  standard, it recognizes that some stations, including some noncommercial  educational stations and some smaller stations, face extraordinary  financial circumstances that do not fit within the new financial hardship  criteria but may warrant an extension of time to finalize construction. Two  stations that responded to our survey stated that they would qualify under  FCC’s new criteria of financial hardship. One station commented that it  was in the process of filing bankruptcy after 3 years of negative cash flow.  Another station commented that it would qualify for financial hardship  due to costs associated with locating its analog antenna and operating  with a digital-only signal for a period of time, which resulted in a 30  percent drop in viewers and a negative cash flow from the reduction of  viewers.
section_title: FCC Has Taken Numerous Actions to Guide Broadcast Stations through the Digital Transition
paragraphs: FCC’s actions have provided guidance to broadcast stations throughout  the transition process. A recent FCC ruling addressed many issues  important to broadcasters and provided increased flexibility for  broadcasters in completing DTV transition tasks. At the time we  completed our survey, however, some broadcasters were waiting for FCC  decisions before they could finalize their transition plans.
subsections: section_title: FCC Rulemakings and Orders Have Directed Broadcast Stations’ Preparation for the Digital Transition
paragraphs: For many years, FCC has orchestrated the DTV transition using its  rulemakings process to guide broadcast stations through important  milestones. FCC determined that establishing a digital standard for  broadcasters was critical to begin the transition to digital broadcast; the  establishment of a digital standard was completed with the adoption of an  order in 1996. Since then, FCC has taken additional actions to continue  moving broadcasters toward the digital transition, as shown in table 1. For  example, FCC assigned paired digital channels for stations that would be  broadcasting both a digital and an analog signal prior to the digital  transition. These paired digital channels were important to allow  broadcasters time to gain experience in operating a digital service,  stimulate interest in the DTV transition, and encourage consumers to  begin purchasing digital equipment.
In its December 2007 third periodic review and order, FCC finalized a  number of actions to facilitate broadcasters’ completion of the DTV  transition. For example, the third periodic review and order addressed,  among other things, (1) time frames for television stations to complete  construction of their digital facilities; (2) information all full-power  television stations must provide to FCC by February 19, 2008, detailing the  station’s current transition status, any additional steps needed to  commence its full, digital operations, and its timeline to meet the   February 17, 2009, transition deadline; (3) when and for how long  stations will be permitted to reduce or cease service on their analog or  paired digital channel; and (4) guidelines for rapid approval of minor  expansion of authorized service areas for stations that are moving their  digital channel for posttransition operations to allow these stations  additional flexibility to use their existing analog antenna.
section_title: Some Broadcast Stations Required FCC Decisions Prior to Finalizing Their Digital Facilities
paragraphs: In our survey of broadcast stations, 128 respondents indicated they were  “awaiting action from FCC” to complete building their final digital  facilities. In following up with these stations after they had responded to  our survey, our analysis suggested that the actions many stations were  awaiting were addressed in FCC’s third periodic review and order.  However, at that time, a few broadcasters still had issues that required  FCC decisions—such as approval for a construction permit, petitions to  alter their signal power, or FCC reconsideration of their final digital  channel assignment. According to FCC, approximately 100 petitions for  reconsideration of final DTV channel assignments were filed by  broadcasters. FCC said these petitions needed engineering analysis  performed to determine the feasibility and impact on other stations. FCC  told us that the analysis had been completed, and released its decisions  regarding the petitions in early March 2008. FCC noted that it believes  broadcasters have everything they need from the commission to proceed  with construction of their final digital facilities.
section_title: Agency Comments
paragraphs: We provided a draft of this report to FCC for its review and comment. In  response, FCC noted that since our survey results of broadcast stations  were based on information received between December 2007 and  February 2008, the percentages we cite do not necessarily match  information FCC would derive from its records. FCC also provided  technical comments that we incorporated in this report where  appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of the report to interested  congressional committees and the Chairman of the Federal  Communications Commission. We will make copies available to others  upon request. In addition, the report will be available at no charge on  GAO’s Web site at http://www.gao.gov.
If you or your staffs have any questions concerning this report, please  contact me on (202) 512-2834 or at goldsteinm@gao.gov. Contact points  for our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. Key contributors to this report are listed in  appendix II.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The objectives of this report are to provide information on technical issues  surrounding the digital television (DTV) transition, specifically, (1) the  status of broadcast stations in transitioning to digital, (2) the extent to  which broadcast stations are encountering issues during the DTV  transition and how these issues impact the broadcast community, and   (3) the actions the Federal Communications Commission (FCC) has taken  to guide broadcasters in the DTV transition and how those actions have  affected the broadcast community.
To obtain information on the status of the television broadcast industry in  transitioning to digital and the issues broadcasters were encountering, we  developed and administered a Web-based survey. Our intent was to survey  all full-power commercial and noncommercial broadcast television  stations in the 50 states and the District of Columbia. We asked the  broadcast stations questions related to their (1) digital facilities and plans,  (2) issues affecting the digital conversion, (3) antenna locations, (4) DTV  information advertisements and public service announcements, (5) digital  signal contour and coordination with cable and satellite, (6) relocation of  digital channels, (7) digital and analog signal coverage, (8) international  issues, and (9) translator stations. The initial sample frame for the study  was all FCC licensed full-powered television stations as of June 2007—a  total of 1,747 stations. Since FCC did not maintain e-mail addresses for the  licensed broadcasters at that time, we needed to obtain contact  information on the broadcasters through alternate sources. We requested  and received contact information from the following sources: the  Association of Public Television Stations, ABC, CBS, NBC, CW, FOX, and  Telemundo. In total, we received contact information for 1,058 stations.  For the remaining 625 stations, the engagement team spent 1 week  compiling a list of contact information. Of the 1,747 broadcasters on FCC’s  list, we surveyed 1,682 stations located in the 50 states and the District of  Columbia for which we could obtain contact information. In several  instances, we identified stations that were not on FCC’s list of full-power  broadcast stations, or stations for which we did not initially have contact  information and subsequently sent the survey to these stations. From  September 27, 2007, through October 16, 2007, we conducted a series of  pretests with general managers of broadcast television stations to help  further refine our questions, clarify any ambiguous portions of the survey,  and identify any potentially biased questions. Upon completion of the  pretests and development of the final survey questions and format, we sent  an announcement of the upcoming survey to 1,682 broadcast television  stations on November 30, 2007. These stations were notified that the  survey was available online on December 7, 2007. We sent follow-up e-mail  messages to nonrespondents on December 14, 2007, December 21, 2007,  January 8, 2008, and January 9, 2008, and then attempted to contact by  telephone those stations that had not completed the survey.
The survey was available online until February 8, 2008. Of the 1,682  broadcast stations that were asked to complete the survey, we received  1,122 completed surveys, for an overall response rate of 66.7 percent. Of  those completed questionnaires, 72 percent were from commercial  stations and 28 percent were from noncommercial stations. The practical  difficulties of conducting surveys may introduce errors commonly referred  to as “nonsampling errors.” For example, questions may be misinterpreted  and the respondents’ answers may differ from broadcast stations that did  not respond to the survey. To minimize nonsampling errors, we pretested  the survey and conducted numerous follow-up contacts with  nonrespondents. In addition, steps were taken during data analysis to  further minimize errors, such as performing computer analyses to identify  inconsistencies and completing a review of data analysis by an  independent reviewer. We also conducted a nonresponse bias analysis,  comparing our survey estimates with estimates obtained from FCC  records, and found small, but statistically significant differences. Because  of the differences identified through the bias analysis, we decided to  provide estimates only for respondents and not to project our results to  the population. The survey results were reliable enough for our purpose  because the bias does not appear to be more than a few percentage points.  A difference of 5 percentage points in any of our estimates would not  affect our findings. To view the survey and a more complete tabulation of  the results, go to http://www.gao.gov/cgi-bin/getrpt?GAO-08-528SP.
Furthermore, we reviewed relevant law, public comments, proposed rules,  and other industry and private sector documents. We interviewed officials  with FCC as well as a wide variety of industry and other private sector  stakeholders with an interest in the DTV transition, such as commercial  and noncommercial broadcasters; antenna and equipment manufacturers;  tower construction companies; and industry advocacy groups, such as the  National Association of Broadcasters and the Association for Maximum  Service Television. We conducted this performance audit from April 2007  through April 2008 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.
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, other key contributors to this  report were Sally Moino, Assistant Director; Andy Clinton; Colin Fallon;  Simon Galed; Eric Hudson; Bert Japikse; Aaron Kaminsky; and Andrew  Stavisky.
section_title: Related GAO Products
paragraphs: Digital Television Transition: Increased Federal Planning and Risk  Management Could Further Facilitate the DTV Transition. GAO-08-43.  Washington, D.C.: November 19, 2007.
Digital Television Transition: Preliminary Information on Progress of  the DTV Transition. GAO-08-191T. Washington, D.C.: October 17, 2007.
Digital Television Transition: Preliminary Information on Initial  Consumer Education Efforts. GAO-07-1248T. Washington, D.C.:  September 19, 2007.
Digital Television Transition: Issues Related to an Information  Campaign Regarding the Transition. GAO-05-940R. Washington, D.C.:  September 6, 2005.
Digital Television Transition: Questions on Administrative Costs of an  Equipment Subsidy Program. GAO-05-837R. Washington, D.C.: June 20,  2005.
Digital Broadcast Television Transition: Several Challenges Could Arise  in Administering a Subsidy Program for DTV Equipment. GAO-05-623T.  Washington, D.C.: May 26, 2005.
Digital Broadcast Television Transition: Estimated Cost of Supporting  Set-Top Boxes to Help Advance the DTV Transition. GAO-05-258T.  Washington, D.C.: February 17, 2005.
Telecommunications: German DTV Transition Differs from U.S.  Transition in Many Respects, but Certain Key Challenges Are Similar.  GAO-04-926T. Washington, D.C.: July 21, 2004.
Telecommunications: Additional Federal Efforts Could Help Advance  Digital Television Transition. GAO-03-7. Washington, D.C.: November 8,  2002.
Telecommunications: Many Broadcasters Will Not Meet May 2002  Digital Television Deadline. GAO-02-466. Washington, D.C.: April 23, 2002.