Telecommunications: Information on Low Power Television, FCC's Spectrum Incentive Auction, and Unlicensed Spectrum Use
Published: 2016-12-05T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2012, Congress authorized FCC to conduct an incentive auction of broadcast television spectrum whereby eligible broadcasters can voluntarily relinquish their spectrum usage rights in return for compensation. This auction will make spectrum available for new uses such as mobile broadband and will also potentially affect LPTV and translator stations. In addition to conducting the auction, FCC proposed preserving at least one vacant television channel in all areas that could be used by unlicensed devices to ensure the public continues to have access to the benefits associated with these devices.
GAO was asked to review the possible effects of the auction on LPTV and translator stations and their viewers. This report examines: (1) LPTV and translator stations and how FCC's incentive auction might affect their viewers, (2) selected stakeholders' views on actions FCC has proposed to mitigate the possible effects of the auction on such stations, and (3) selected stakeholders' views on the expected outcomes of preserving a vacant television channel for unlicensed use. GAO reviewed relevant FCC proceedings and comments associated with those proceedings; surveyed a non-generalizable sample of 330 LPTV and translator station representatives with available e-mail addresses; and interviewed officials from FCC and industry stakeholders selected to represent various types of organizations, such as broadcast industry associations and technology companies. GAO provided FCC with a draft of this report. FCC's technical comments have been incorporated.
section_title: What GAO Found
paragraphs: As of May 2016, there were 2,063 low power television (LPTV) stations and 3,660 translator stations in the United States and its territories, serving diverse communities. However, some LPTV and translator stations may be displaced and need to find a new channel or discontinue operation after the Federal Communications Commission's (FCC) ongoing incentive auction of broadcast television spectrum. By statute, these stations were not designated as eligible to participate in the auction; consequently, they cannot voluntarily relinquish their spectrum usage rights in return for compensation. LPTV stations may serve rural communities with limited access to full-power stations and niche communities in urban areas, whereas translator stations retransmit the programming of other stations, mostly to viewers in rural areas who cannot otherwise receive television signals. After the auction, FCC intends to reorganize the television stations remaining on the air so that they will occupy a smaller range of channels, thus freeing up spectrum for other uses. LPTV and translator stations are not guaranteed a channel during the reorganization. FCC has acknowledged that the auction and channel reorganization may negatively affect an unknown number of LPTV and translator stations and that some viewers will lose service, and concluded the success of the auction outweighs these concerns. Broadcast industry associations and others have raised concerns about viewers' losing access to programming and emergency alert information these stations provide.
Selected stakeholders viewed FCC's actions to mitigate the effects of the incentive auction on LPTV and translator stations as helpful in some circumstances, but overall as insufficient. FCC's actions include using its software to identify channels that will be available for displaced stations following the auction and allowing channel sharing. While broadcast industry associations generally supported these measures in comments to FCC, some representatives told GAO that the actions will not do much to mitigate the effects of the incentive auction on LPTV and translator stations. Moreover, in response to GAO's non-generalizable survey, representatives of LPTV and translator stations generally indicated FCC's actions have limited usefulness.
According to selected stakeholders, FCC's proposal to preserve a vacant television channel in all areas throughout the country for unlicensed use, such as Wi-Fi Internet, could result in the loss of some existing broadcast service, but could have various benefits. Of the stakeholders GAO contacted, the broadcast industry associations generally opposed the proposal, while the technology companies supported it. According to a broadcast industry association, the proposal will force some LPTV and translator stations off the air because there will be one less channel where a displaced station can relocate, and many rural and underserved communities will likely lose access to the broadcast stations on which they rely. On the other hand, technology companies and other supporters of the vacant channel proposal maintain that preserving at least one vacant channel for unlicensed use will contribute to innovation and the development of new technologies. Proponents also said that preserving a vacant channel could help expand Wi-Fi more thoroughly giving people and businesses greater connectivity and could help extend coverage to people who might not have affordable access to the Internet.

section_title: Letter
paragraphs: There are thousands of low power television (LPTV) and translator  stations located throughout the country that serve distinct television  viewing audiences. LPTV stations serve both rural audiences and niche  communities within larger urban areas and may provide locally oriented  television programming such as non-English language, ethnic, religious,  or other programming. Translator stations retransmit programming from  another station—such as a major network (ABC, CBS, Fox, or NBC)—  mostly to viewers in rural and mountainous areas who cannot receive  signals because of terrain or distance. According to the Federal  Communications Commission (FCC), LPTV and translator stations have  always operated in an environment where they could be displaced from  their operating channel and, if no new channel assignment is available,  forced to go silent.
The Middle  Class Tax Relief and Job Creation Act of 2012 (the 2012 act)  authorized FCC to conduct an auction of broadcast television spectrum   to help meet the nation’s accelerating spectrum needs. This auction is  referred to as an incentive auction because eligible television  broadcasters can voluntarily relinquish some or all of their spectrum  usage rights in return for compensation in the incentive auction, which  depending on the station and market could potentially  be hundreds of  millions of dollars. Following the auction’s conclusion, FCC intends to  reorganize the television broadcast spectrum band so that the stations  that remain on the air will occupy a smaller range of channels. LPTV and  translator stations were not designated as eligible in statute to participate  in the auction. FCC has stated that some LPTV and translator stations  may be displaced as a result of the auction or reorganization of the  television broadcast band and these stations will need to find a new  channel (from the fewer number of channels available) or discontinue  operations altogether. FCC stated that making more spectrum available  for new flexible uses such as mobile broadband services will benefit  consumers by easing congestion of the airwaves, thus expediting the  development of new, more robust wireless services and applications and  spurring job creation and economic growth.
According to FCC, the auction and reorganization of the television  broadcast band will also likely result in fewer television channels available  for use by either unlicensed devices (such as Wi-Fi Internet and  Bluetooth) or wireless microphones. Separately, in a June 2015 notice of  proposed rulemaking (NPRM), FCC proposed to preserve at least one vacant channel to help ensure the public continues to have access across  the nation to the significant public benefits associated with these devices.  Although this is a separate proceeding from the incentive auction and not  directly contingent on the auction, if adopted, this proposal could further  decrease the number of channels available for LPTV and translator  stations to relocate.
FCC stated that it has taken into consideration the potential impact of the  auction and reorganization of the television broadcast band on LPTV  stations and is not required to conduct additional analysis. According to  FCC officials, when Congress authorized FCC to conduct the incentive  auction, it signaled a change in priorities away from LPTV and translator  station service since only full-power and Class A television stations  were  designated as eligible to participate in the auction in the 2012 act. In  2011, we recommended that FCC explore options for assessing how  LPTV and translator stations have contributed to FCC’s policy goals of  localism and diversity, potentially including an evaluation of existing data  that FCC could use and additional data that should be collected to inform  such an assessment. However, FCC did not implement this  recommendation. In discussing this prior recommendation with us, FCC  officials said that an assessment of the impact of LPTV and translator  stations on localism and diversity is not consistent with the  implementation of the incentive auction as specified by the 2012 act,  which will cause consolidation among and elimination of an undetermined  number of those stations.
You asked us to review the possible effects of FCC’s spectrum incentive  auction on LPTV and translator stations and their viewers. This report  examines (1) what is known about LPTV and translator stations and how  FCC’s spectrum incentive auction might affect viewers’ access to the  stations’ services, (2) selected stakeholder views on actions FCC has  proposed or taken to mitigate the possible effects of the incentive auction  on LPTV and translator stations, and additional stakeholder proposals for  doing so, and (3) selected stakeholder views on the expected outcomes  of preserving a vacant channel for unlicensed use of the television  broadcast spectrum.
To address these objectives, we reviewed FCC’s documents related to  the incentive auction—including its June 2014 incentive auction report  and order, December 2015 LPTV and translator report and order, and  vacant channel notice of proposed rulemaking—and selected comments  and other filings associated with these proceedings. We also reviewed  relevant statutes and regulations, including the Middle Class Tax Relief  and Job Creation Act of 2012, and obtained data as of May 25, 2016,  from FCC’s Consolidated Database System (CDBS) to determine the  number of LPTV and translator stations in the U.S. and its territories  along with their communities of license. To determine the reliability  of  FCC’s data, we reviewed FCC user guides and forms for CDBS and  interviewed knowledgeable FCC officials regarding data entry and  analysis procedures. We determined the data were reliable for our  purposes.
In addition, we conducted a web-based survey of 330 LPTV and  translator station representatives for whom we were able to obtain e-mail  addresses. After preparing draft survey questions and response  categories, we spoke with representatives from three broadcast industry  associations and a translator station representative chosen for their broad  industry perspective and expertise in particular segments of the industry  to determine whether selected questions were answerable by station  representatives and whether the answer choices provided were  appropriate, and updated our survey accordingly. We then pre-tested our  survey with four representatives of LPTV and/or translator stations— selected to provide for variety in type of station (LPTV and translator),  number of stations represented, and geography—to ensure that our  survey questions and skip pattern were clear and logical and that  respondents could answer the questions without undue burden. In the  course of pre-testing our survey we also obtained information that we  present in this report. Through our survey, we obtained information on: (1)  LPTV station programming, (2) ownership of LPTV and translator  stations, and (3) station representatives’ views on actions that FCC has  proposed or taken and actions Congress or others could take to mitigate  the effects of the incentive auction on LPTV and translator stations. We  administered the survey from June 2016 through August 2016 and  received 115 responses. These responses represent 535 of the 2,063  LPTV stations and 1,515 of the 3,660 translator stations in the U.S. and  its territories. In our report, we generally provide survey results based on  the number of respondents to each question. Because not all  respondents answered every question of the survey, the total number of  respondents may be fewer than 115 for some results. The results of our  survey are not generalizable, and we did not verify respondents’ answers.
We also interviewed officials from FCC and additional stakeholders that  we selected to represent a range of views from various types of  organizations. We selected stakeholders based on our review of  comments filed in FCC’s incentive auction and vacant channel proposal  proceedings, as well as based on the recommendations of other  organizations we interviewed. We interviewed six broadcast industry  associations and three station ownership groups that own LPTV and/or  translator stations chosen to represent entities with a variety of  programming types. Additionally,  we interviewed two technology  companies, a technology industry association, and a public interest group  chosen to present additional views on FCC’s vacant channel proposal.  More details about our scope and methodology, including a complete list  of stakeholders we interviewed, can be found in appendix I. A copy of our  survey and selected results can be found in appendix II.
We conducted this performance audit from January 2016 to December  2016 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: LPTV stations, as indicated by their name, operate at lower power levels  and transmit over smaller areas than full-power television stations. FCC  established a licensing process for LPTV stations in 1982 to add to  programming diversity and provide opportunities for locally oriented  television service in small communities. LPTV stations may originate  programming and, according to FCC, have created opportunities for new  entry into television broadcasting, provided a means of local self- expression, and permitted fuller use of the broadcast spectrum.  Translator stations retransmit programming from another station—such  as a major network (ABC, CBS, FOX, or NBC)—to audiences unable to  receive signals directly, usually because of distance or terrain barriers,  such as mountains, that limit the signal’s ability to travel long distances.  FCC rules prohibit translator stations from originating any programming.  As shown in figure 1, some translator stations are part of a “daisy chain”  in which multiple translator stations relay signals from one translator  station to another, allowing the originating station’s signal to be received a  few hundred miles away despite distance or other terrain obstacles.
LPTV and translator service is secondary, meaning these stations may  not cause interference to, and must accept interference from, primary  services including primary television stations, which are full-power and  Class A television stations. When interference with a full-power station  cannot be remedied by adjusting an antenna or other technological  methods, LPTV and translator stations must vacate the channel either by  requesting FCC’s permission to move to another channel or by requesting  permission to turn off their broadcast signal while searching for another  channel. LPTV stations generally do not have “must-carry” rights—that is,  cable and satellite providers are generally not required to carry signals  from LPTV stations, but cable and satellite providers may agree to do  so.
The 2012 act authorized FCC to conduct an incentive auction for  broadcast television spectrum. This auction comprises two separate but  interdependent auctions—a “reverse auction” to determine the amount of  compensation that each broadcast television licensee would accept in  return for voluntarily relinquishing some or all its spectrum rights; and a  “forward auction” to determine the price companies are willing to pay for  the relinquished spectrum. The spectrum being auctioned is in the UHF  range, which currently consists of channels 14 through 51, except for  channel 37. According to FCC, the spectrum being auctioned has  excellent propagation characteristics that allow signals to cover large  geographic areas and penetrate walls and other structures. As shown in  figure 2, at the time of this report, the incentive auction was ongoing and  FCC expected it to conclude at the earliest in late 2016.
After the auction concludes, FCC reported it intends to reorganize the  television broadcast band on a smaller range of channels to free up a  portion of the spectrum; FCC refers to this reorganization as “repacking.”  Relocating the remaining stations on lower channels allows for new,  flexible-use spectrum licenses suitable for providing mobile broadband  services. In April 2016, FCC announced an initial spectrum clearing  target—the amount of spectrum FCC aimed to clear and repurpose in the  auction and repack—of 126 MHz. In November 2016, after the first and  second stages of the forward auction concluded without meeting the  reserve price, FCC announced a new clearing target of 108 MHz,  requiring television stations to use channels 2 through 32. As shown in  figure 3, the number of channels available for both television stations and  spectrum available for mobile broadband services varies depending on  the clearing target.
The 2012 act authorized FCC to repack the remaining eligible stations  and directed FCC to make all reasonable efforts to preserve the coverage  area and population served of each eligible broadcast television licensee  when making channel reassignments or reallocations following the  incentive auction. In June 2014, FCC released the incentive auction  report and order adopting rules to implement the incentive auction and  subsequent repacking process. In the report and order, FCC stated that,  as required by Congress in the 2012 act, FCC will preserve or protect the  coverage area and population served by eligible broadcast television  licensees. Further, FCC concluded that protecting other categories of  facilities, including LPTV and translator stations, which are—secondary in  nature and not entitled to protection from primary services under FCC’s  current rule—would unduly constrain FCC’s flexibility  in the repacking  process and undermine the likelihood of meeting FCC’s objectives for the  incentive auction. FCC recognized the decision not to extend repacking  protection and not to guarantee channels for LPTV and translator stations  will result in some viewers losing service, may negatively affect the  investments displaced LPTV and translator licensees have made in their  existing facilities, and may cause displaced licensees that choose to  move to a new channel to incur the cost of doing so. Although FCC does  not know the number of affected LPTV and translator stations, FCC  concluded that these concerns are outweighed by the detrimental impact  that protecting LPTV and translator stations would have on the repacking  process and on the success of the incentive auction. In two separate  cases in December 2015, LPTV licensees and an individual  party brought  suit against FCC over the incentive auction and its potential impact,  claiming, among other things, that FCC denied protections to LPTV  stations in the auction and repacking process and that FCC’s actions  violated the 2012 act. In 2016, the U.S. Court of Appeals for the District  of Columbia Circuit dismissed the petition for review in one case and  sustained FCC’s orders in the other case. At the time of our review a  separate, late-filed lawsuit raising similar concerns was ongoing.
In addition to adopting rules related to the incentive auction and  subsequent repacking process, the incentive auction report and order  announced a number of actions intended to make a significant amount of  spectrum available for unlicensed use, including permitting unlicensed  operations (1) on channel 37 in locations sufficiently removed from  incumbent users to protect from harmful interference and (2) in the  spectrum guard bands. Additionally,  FCC indicated in the incentive  auction report and order that it anticipated there would be at least one  channel in all areas throughout the country not assigned to a television  station that could be used by unlicensed devices. In June 2015, FCC  issued an NPRM to this effect, proposing to preserve at least one vacant  channel in the UHF television band throughout the country. The NPRM  proposes that the channel preserved would be a UHF channel above  channel 20, and the specific vacant channel preserved could vary  depending on the particular area. This proposal, known as the vacant  channel proposal, would require LPTV and translator stations displaced  by the repacking process to demonstrate that any new or modified  facilities needed for a station to relocate to another channel would not  eliminate the last remaining vacant channel in an area. FCC tentatively  concluded that the vacant channel proposal would ensure the public  continues to have access to the significant benefits provided by  unlicensed devices and wireless microphones across the country.  According to FCC officials at the time of our review, it had not taken  further action on the vacant channel NPRM and those matters were still  under consideration.
Unlicensed devices that operate in the television spectrum band are  sometimes referred to as white space devices because they operate in  spectrum “white spaces”—buffer zones FCC established to mitigate  unwanted interference between adjacent stations. According to FCC,  unlicensed devices are an important part of the nation’s communications  capabilities, serve to augment the operations of licensed services, and  meet the needs of a wide range of wireless applications including Wi-Fi,  Bluetooth, baby monitors, and garage door openers. The Consumer  Electronics Association reported in 2014 that devices using unlicensed  spectrum generate approximately $62 billion annually in retail-level sales  and that further estimated growth in the market for devices that rely on  unlicensed spectrum was “extremely strong.”
section_title: LPTV and Translator Stations Provide Programming and Information That Might Not Be Available to Over-the- Air Viewers after the Auction
subsections: section_title: LPTV and Translator Stations Are Diverse in Their Programming and Owned by Various Types of Entities
paragraphs: Through analysis of FCC data, our survey of LPTV and translator station  representatives, and meetings with stakeholders as discussed below, we  obtained information on LPTV and translator stations, including (1) the  number of such stations and their communities of license, (2) types of  programming and hours of broadcasting, and (3) ownership. Information  obtained through our survey is non-generalizable.
subsections: section_title: Number of Stations and Communities of License
paragraphs: According to our analysis of FCC data, there were 2,063 LPTV stations  and 3,660 translator stations in the U.S. and its territories as of May 25,  2016. LPTV stations’ communities of license are shown in figure 4.  According to one broadcast industry association we interviewed, LPTV  stations serve a wide range of diverse audiences, including those in both  rural counties with limited access to full-power stations and in large urban  areas.
According to our analysis of FCC data, translator stations’ communities of  license are shown in figure 5. Translator stations tend to be concentrated  in both rural and mountainous areas where they serve communities that  cannot receive signals from full-power stations because they are too far  away or because terrain blocks the signals.
According to FCC officials, pursuant to the First Amendment, FCC does  not generally monitor broadcast stations’ content and programming  choices and because the few public service obligations LPTV stations  have do not pertain to programming provided. Therefore FCC does not  collect information on the programming provided by LPTV stations or their  hours of broadcasting, and we did not identify other sources of such data.  In our non-generalizable survey of LPTV and translator station  representatives, respondents representing 535 of the 2,063 LPTV  stations in the U.S. and its territories provided information about the types  of programming broadcast by the stations they represent (see fig. 6).  Survey respondents indicated that most of these stations broadcast  locally produced programming, and almost half of the stations  represented by survey respondents broadcast at least 18 hours per day  and an average of 3 hours per week of locally produced content, two  factors similar to requirements for Class A status under the Community  Broadcaster Protection Act of 1999.
The locally produced programming broadcast by LPTV stations may be  diverse and is broadcast in a variety of languages. Through our survey  we identified examples of such content, including: programming in languages such as Bosnian, Hmong, Italian, Polish,  Spanish, and various Native American languages;  local news, weather, and traffic;  local information, including community events, political debates, and  volunteer opportunities;  local recreational and tourism information such as skiing, fishing, and  hunting reports; public health programming; arts and special interest programming such as art and cooking shows; children’s programming.
Additionally,  survey respondents provided information about programming  broadcast by the stations they represent that is not locally produced. As  shown in figure 7, the most common type of non-locally produced  programming broadcast by LPTV stations represented by survey  respondents is general entertainment.
Table 1 provides examples of these different types of programming that is  not locally produced. These examples are from our survey, comments to  FCC, and interviews.
Moreover, LPTV stations that broadcast digitally may simultaneously  transmit multiple signals and therefore can broadcast different content on  multiple sub-channels. For example, representatives of a station  ownership group told us about programming they broadcast on digital  sub-channels in the Los Angeles area. On one digital sub-channel, they  broadcast programming imported from Central America that is the primary  news source for many of the about 2 million immigrants from Central  America living in the area, according to these representatives. On another  digital sub-channel, they broadcast programming imported from  Cambodia, which is the only Cambodian station in the U.S. and reaches  between 50,000 and 70,000 Cambodian speakers in the area, according  to these representatives.
section_title: Ownership
paragraphs: FCC collects information biennially on racial and ethnic minority and  female broadcast ownership for certain commercial stations. FCC’s  reports based on this data collection do not present data on the number  of stations owned by different types of entities such as for-profit, not-for- profit, and governmental. Further, while full-power, Class A, and LPTV  stations are required to provide this information, FCC officials told us that  translator stations are not required to submit this information and that,  according to the most recent report based on these filings, about one third  of LPTV stations did not file the required reports.
Our survey collected information on the types of entities that own the  LPTV and translator stations represented by respondents. As shown in  figure 8, most of the 535 LPTV stations represented by survey  respondents are owned by for-profit entities, while more than a third of the  1,515 translator stations represented by survey respondents are owned  by governmental entities. Ownership of translator stations tends to vary  depending on factors such as the direct market size of full-power stations  and geography, according to representatives we interviewed from a  broadcast industry association. For example, in New Mexico and Oregon,  where the direct market for full-power stations is less populous, full-power  stations may own and operate translator stations to extend the reach of  their programming. In mountainous areas where geography may limit the  reach of full-power stations, translator stations tend to be locally owned  by governmental entities or other community organizations, according to  a broadcast industry association we interviewed.
Ownership type and structure may affect stations’ vulnerability  in the  auction even in areas where spectrum is available following the auction,  according to various stakeholders as discussed below.
Government- and community-owned stations typically rely on  municipal budgets and tax revenues to operate, and in some cases  the community served would have to raise taxes or dues to obtain the  capital necessary to relocate, according to representatives from two  broadcast industry associations we interviewed and three survey  respondents.
Stations owned by for-profit, not-for-profit, and educational entities  may not be able to afford the capital costs required to relocate,  particularly when the entity operates on a small budget, according to  two broadcast industry associations we interviewed and two survey  respondents. For example, while some translator stations may be  owned by station ownership groups that own a portfolio of stations— including full-power stations, Class A stations, or both—of the 115  station representatives who completed our survey, more than two- thirds (81) represent 10 stations or fewer, and 33 respondents  represent a single station. Further, according to a station ownership  group we interviewed securing financing to fund relocation costs is  difficult because investors are unwilling to invest in LPTV and  translator stations because of their uncertain future.
Some station owners, regardless of the type of ownership entity, use  revenue from stations in more populated areas to supplement funding  for the operation of stations in less populated areas. For example,  station representatives who operate three LPTV stations serving  Native American communities told us that the stations serving less  populated areas would not be able to operate without supplemental  revenue from the stations serving more populated areas. According  to these representatives, these stations provide diverse programming  such as locally produced Native American cultural programming,  educational programming, information on tribal affairs, and  programming in multiple Native American languages.
section_title: The Incentive Auction Could Affect Viewers’ Ability to Receive LPTV and Translator Stations’ Programming and Televised Emergency Information
paragraphs: We found LPTV and translator station viewers may lose access to  programming or emergency alert information through several possible  ways, including the following:
Alternatives to broadcast programming are cost-prohibitive or  unavailable: Many LPTV and translator station viewers are  economically or geographically disadvantaged and may not be able to  afford other options for accessing programming such as for satellite  television or broadband Internet, according to two broadcast industry  associations we interviewed and six survey respondents, among  others. For example, one survey respondent, a county  treasurer/recorder in a rural area, described the situation for viewers  of the county’s translator stations. The county charges each  household $30 per year for television service. The survey respondent  said that there are many county residents who are elderly, on fixed  incomes, or otherwise low-income and cannot afford to pay a higher  monthly television subscription fee, such as satellite service. Further,  some viewers live in areas where paid television service or broadband  service, or both are unavailable, according to one broadcast industry  association we interviewed, a station ownership group, and one  survey respondent.
Niche programming: Viewers of locally produced programming and  niche programming, such as the programming described above, may  lose access to this programming, and similar programming may not  be available through the remaining over-the-air broadcast channels  according to three broadcast industry associations and a station  ownership group we interviewed. For example, if an LPTV station  broadcasting non-English-language programming in a city is displaced  in the incentive auction and cannot find an available channel in the  repack, its viewers may have no other options for similar  programming. Moreover, LPTV stations that provide niche  programming to a particular audience in a particular area could be  forced out of business following the incentive auction and repack even  if they are able to find available spectrum in the repack. For example,  a non-English language channel may exist to serve a segment of the  population that resides in a small pocket of an urban area. If  displaced, that channel may be unable to relocate to a replacement  channel that would reach its primary viewers, as shown in figure 9.  Without access to its primary viewers, the station may not be able to  raise the funds necessary to continue operation.
Televised emergency alerts: Some viewers in geographically remote  areas receive broadcast television signals only from a station or  stations that are not protected in the incentive auction and repack,  meaning the station might be unable to relocate and thus cease  broadcasting. Viewers in these areas may no longer have access to  televised emergency alerts. Of the 2,050 LPTV and translator stations  represented by survey respondents, more than 10 percent (211) serve  areas that receive no service from full-power or Class A stations,  according to survey respondents. Moreover, of the 1,515 translator  stations represented by survey respondents, 433 rebroadcast signals  received from another translator station and 212 send signals to  another translator station. This interconnectedness among translator  stations could compound these stations’ vulnerability  in the auction,  according to representatives of a broadcast industry association that  represents translator stations. Although it is possible for LPTV or  translator stations to serve as the only source of televised emergency  alerts, FCC considered whether such stations should have special  priority in the repacking process and declined to adopt any such  measures. In particular, in a 2012 NPRM FCC sought comment on  whether the public interest would be served by establishing a set of  selection priorities to choose among applications of displaced LPTV  and translator stations and on the types of selection priorities to  adopt. In the incentive auction report and order, FCC declined to  adopt the particular selection priorities suggested by commenters in  the NPRM, including providing priority for stations that are primary  Emergency Alert System providers.
As noted previously, FCC has acknowledged that the incentive auction  will potentially  displace some LPTV and translator stations. FCC officials  told us they have not systematically analyzed the potential displacement  impact on LPTV or translator stations because of Congress’s  determination not to include these stations in the auction or protect them  in the repacking process. As discussed below, FCC has taken some  actions to try to mitigate the auction’s effects on these stations.
section_title: Selected Stakeholders View FCC’s Actions as Having Limited Usefulness and Have Proposed Additional Actions to Mitigate the Auction’s Effects
subsections: section_title: Selected Stakeholders View FCC’s Actions as Helpful in Some Circumstances but Insufficient
paragraphs: According to FCC officials, FCC’s actions to mitigate the effects of the  incentive auction include: (1) channel sharing, (2) the digital transition  deadline, (3) FCC’s optimization software, and (4) cross-border  coordination. While broadcast industry associations generally expressed  support for these measures in comments to FCC, some representatives  of these groups told us and stated in comments to FCC that the actions  will not do much to mitigate the effects of the incentive auction on LPTV  and translator stations. Moreover, we asked the 115 representatives of  535 LPTV and 1,515 translator stations who responded to our survey to  rate the usefulness of these four measures, and, in all but one case, the  number of both LPTV and translator stations represented by respondents  was greater for those who rated the action as not useful. Furthermore,  those who rated these measures as useful often did so with caveats.
subsections: section_title: Channel Sharing
paragraphs: In the LPTV and translator report and order, FCC announced that it will  allow channel sharing among LPTV and translator stations and proposed  allowing channel sharing between LPTV and translator stations and full- power and Class A stations. Stations that enter into such agreements may divide the capacity of the shared channel however they would like,  as long as each station retains spectrum usage rights sufficient to  transmit at least one standard definition programming stream at all times,  but will continue to be licensed separately and will separately be subject  to FCC’s obligations, rules, and policies. According to FCC, these  measures have the potential to be beneficial to LPTV and translator  stations, and some broadcast industry associations expressed support of  these measures in comments to FCC. However, all of the broadcast  industry associations with whom we discussed the issue stated that  allowing LPTV and translator stations to enter into channel-sharing  agreements will not be helpful in a meaningful way. For example, a  representative from one broadcast industry association told us that  channel sharing would likely require stations to degrade their signal,  which may inhibit multicasting and the use of high-definition  signals, and  another broadcast industry association told us that stations will use  channel sharing only as a last resort. Additionally,  as shown in table 2  below, survey respondents representing more stations rated channel  sharing as not useful, than useful.
In the LPTV and translator report and order, FCC announced it will use its  incentive auction and repacking optimization software to identify channels  that will be available for displaced stations. FCC plans to publish a list of  available channels 60 days prior to the beginning of the LPTV and  translator displacement window, and displaced stations will be able to use  this information when applying for replacement channels. While FCC  stated in the LPTV and translator report and order that this proposal  garnered considerable support from broadcast industry associations,  representatives from the four broadcast industry associations that  mentioned this measure to us said that it will be minimally helpful.  Specifically, one broadcast industry association told us that it will provide  almost no help to LPTV stations, and another stated that the measure is  hollow and will have limited effect, if any. Additionally,  as shown in table 3  below, survey respondents representing more stations rated this measure  as not useful, than rated it as useful.
In the LPTV and translator report and order, FCC extended the deadline  by which analog LPTV and translator stations must complete the  transition to digital so that stations would not have to make significant  capital investments to meet the digital transition deadline, only to face  possible displacement in the auction and repack process. According to  FCC, the September 2015 deadline had been established in anticipation  of the auction being conducted in 2014. While FCC cited broad support  from the LPTV and translator industry for this measure, two broadcast  industry associations stated in comments to FCC that this action was  more a common sense policy change than an action to mitigate the  effects of the auction. These commenters said it was only fair for FCC to  extend the date given the cost associated with transitioning to digital and  then potentially relocating after the auction. As shown in table 4 below,  survey respondents representing more stations rated extending the digital  transition deadline as not useful, than useful.
In the LPTV and translator report and order, FCC addressed commenters’  suggestions that FCC develop a streamlined approach to coordinating  with foreign governments on the interference and application approval  process to address situations where stations’ signals may cross an  international border, such as into Canada or Mexico. FCC stated that the  cross-border coordination process is continual and that FCC has used its  existing processes to keep Canada and Mexico fully informed on the  incentive auction coordination issues. FCC further stated that it intends to  make efforts to streamline the cross-border coordination processes so  that it will not delay the post-auction displacement application process for  LPTV and translator stations. As shown in table 5 below, a greater portion  of LPTV stations were represented by survey respondents that rated this  measure as useful than not useful, whereas the opposite is true for  translator stations. However, regarding cross-border coordination, survey  respondents provided similar responses regardless of the rating they  provided.
section_title: Stakeholders Suggested a Variety of Actions to Help Mitigate the Potential Impact of the Auction
paragraphs: In addition to the measures discussed above, the broadcast industry  associations and station ownership groups we interviewed and the station  representatives who responded to our survey identified other actions they  believe FCC or Congress could take that could help mitigate the effects of  the incentive auction on LPTV and translator stations. The proposals that  arose the most frequently in the interviews and survey were: (1)  reconsidering various aspects of the auction, (2) providing funding for  relocation costs incurred by LPTV and translator stations displaced in the  auction, (3) allowing LPTV and translator stations to operate with  alternative technical standards, and (4) providing LPTV and translator  stations an opportunity to obtain primary interference protection status,  which would protect these stations from future displacement by primary  services.
subsections: section_title: Reconsider Various Aspects of the Auction
paragraphs: The suggestions that arose most frequently related to FCC reconsidering  various aspects of the incentive auction. For example, 15 survey  respondents suggested that FCC protect LPTV and translator stations in  the incentive auction and repack; 12 survey respondents suggested that  FCC or Congress provide compensation for lost spectrum rights to  displaced LPTV and translator stations; 7 survey respondents suggested  that FCC provide protection in the auction and repack for certain types of  stations such as rural translator stations, tribally owned stations, and  stations broadcasting locally produced content; 6 survey respondents  suggested that FCC or Congress cancel the auction; and 5 survey  respondents suggested that FCC provide LPTV and translator stations  more time to move channels. Regarding these and similar suggestions  raised in the incentive auction proceeding, FCC stated in the LPTV and  translator report and order that the proposed measures were fully  considered in the incentive auction rulemaking proceeding and  subsequent orders and FCC declined to revisit them.
section_title: Provide Funding for Relocation Expenses
paragraphs: The second most frequent suggestion related to FCC or Congress  providing funding for relocation costs incurred by LPTV and translator  stations that are displaced in the auction, either through a grant program  or through reimbursement of expenses. While FCC has studied the costs associated with relocating eligible full-power and Class A stations that are  reassigned to new channels during the repack process, FCC officials  told us that because Congress did not make LPTV or translator stations  eligible to be reimbursed for certain relocation costs, the officials have not  studied the costs associated with relocating LPTV and translator stations.  A broadcast industry association we interviewed indicated that the costs  for relocating LPTV and translator stations vary widely depending on a  number of factors such as the distance of the move; whether a new tower  will be required; and the availability  of engineers, tower crews, and  equipment. Of the 83 survey respondents that represent LPTV stations,  28 respondents reported estimated relocation costs ranging from $25,000  to over $600,000 per station. Of the 50 survey respondents that represent  translator stations, 15 respondents reported estimated relocation costs for  their stations ranging from approximately $8,500 to approximately  $37,500, with an additional $100,000 per site if microwave equipment  were required. FCC addressed similar suggestions in the LPTV and  translator report and order and in previous orders related to the incentive  auction and stated that the decision whether to authorize such funding is  Congress’s prerogative and that the 2012 act limits reimbursement to full- power and Class A stations.
section_title: Permit Use of Alternative Technical Standards
paragraphs: Half of the broadcast industry associations we interviewed, all of the  station ownership groups we interviewed, and 13 survey respondents  proposed various measures by which FCC would allow LPTV and  translator stations to operate with different technical standards or network  architectures. Proposals include enabling broadcasters to seek  innovative ways to use their spectrum and adopting Advanced Television  Systems Committee (ATSC) 3.0. ATSC 3.0 is an alternative technical  standard for digital broadcast television that, according to proponents,  has the potential to enhance the viewing experience, provide for more  robust signaling, expand diverse programming opportunities, enhance  emergency alert capabilities, and provide for new service offerings.  Additionally,  some broadcast industry association representatives we  interviewed stated that timely adoption of ATSC 3.0 or other alternative  technical standards for digital broadcast television would enable many  LPTV and translator stations to survive the auction because stations  would be more efficient in their use of spectrum, freeing more spectrum  for broadcast use in the repack. In the LPTV and translator report and  order, FCC stated that consideration of alternative technical standards,  including ATSC 3.0, is outside of the scope of the incentive auction  proceeding and is better left for future proceedings. In April 2016,  several broadcast industry stakeholders filed a joint petition for  rulemaking asking FCC to amend its rules to allow broadcasters to use  ATSC 3.0, and later that month FCC issued a public notice seeking  comment on the petition, with comments due in June 2016. According to  FCC officials, these comments are under consideration and FCC could  decide to issue an NPRM; however, as of September 2016, FCC has not  announced a timeline for doing so.
section_title: Provide Opportunity to Obtain Primary Interference Protection Status
paragraphs: Two broadcast industry associations and a station ownership group we  interviewed as well as some survey respondents suggested that FCC  provide an opportunity for LPTV and/or translator stations to obtain  primary interference protection status, such as Class A status or some  other designation, to avoid future displacement by primary users. Some  proponents stated that such a measure would provide more certainty for  the industry going forward, which in turn would enable investment in the  industry. In the LPTV and translator report and order, FCC declined all  proposals that would allow LPTV and/or translator stations to obtain  primary interference protection status before the completion of the post- auction transition period, but stated that FCC may consider at a later date  whether to allow LPTV and/or translator stations to obtain primary status  after the completion of this period.
section_title: Selected Stakeholders Expressed Varying Views on Outcomes of Preserving a Vacant Television Channel
paragraphs: Through our interviews with selected stakeholders—including six  broadcast industry associations, three station ownership groups, two  technology companies, a technology industry association, and a public  interest group—and analyzing comments filed with FCC, we identified  four primary expected outcomes of preserving a vacant television  channel: (1) loss of existing broadcast service, (2) development of new  technologies and innovation, (3) improvement of Wi-Fi Internet, and (4)  improvement of rural broadband service. FCC officials told us these  outcomes are the main outcomes stakeholders discuss in comments  submitted to FCC. The broadcast industry associations and station  ownership groups generally opposed the proposal, while the technology  companies, the technology industry association, and the public interest  group were proponents of the proposal. As discussed below,  stakeholders expressed varying views about the expected outcomes.
subsections: section_title: Loss of Existing Broadcast Service
paragraphs: Representatives from all the broadcast industry associations told us that  preserving a vacant channel will result in a loss of existing broadcast  television service for viewers. For example, a representative from one  broadcast industry association told us the vacant channel proposal will  force existing LPTV and translator stations off the air because there will  be one less channel where a displaced LPTV or translator station can  relocate and that many rural and underserved communities will likely lose  access to the broadcast stations on which they rely. Additionally,  representatives of the three station ownership groups we interviewed also  expressed concern that the vacant channel proposal would result in a  loss of existing broadcast service. A representative from one of these  groups told us the vacant channel proposal will exacerbate the challenges  faced by LPTV stations by taking at least one more channel and  preventing them from relocating there following a stations displacement  after the incentive auction.
In the vacant channel NPRM, FCC stated a tentative conclusion that the  proposal, if adopted, would not be a significant burden in terms of the  availability  of channels for future use for broadcasters, including LPTV and translator stations. The NPRM further stated that the impact will be  limited because multiple vacant channels will still exist in all or most areas  after the channel repack. FCC officials told us they have not conducted a  systematic analysis on the expected effects of the vacant channel  proposal on LPTV and translator stations, but noted they proposed  preserving a vacant channel because of the overall potential public- interest benefits expected from doing so. The officials noted that FCC  used available information including comments filed with FCC to inform  the proposal and that they sought additional comment on the proposals  and tentative conclusions contained in the NPRM. The officials told us  that the National Association of Broadcasters (NAB) and Google had  each submitted filings to FCC that included analysis on the expected loss  of service effects of preserving a vacant channel and that the studies  reached very different conclusions. According to NAB’s analysis, the  number of LPTV and translator stations that would go off the air if the  vacant channel proposal were adopted ranged from 347 stations to 433  stations, depending on the amount of spectrum that FCC ultimately clears  in the auction. The analysis concluded that FCC’s proposal would have  a devastating impact on LPTV and translator stations and the viewers  who rely on those stations to receive over-the-air signals. On the other  hand, Google’s analysis found that FCC’s vacant channel proposal would  have minimal impact on LPTV and translator stations. Google analyzed  five markets selected for a variety of reasons including, to represent  areas with large numbers of LPTV and translator stations, mountainous  terrain, large rural areas, and urban areas to identify which LPTV and  translator stations, if any, would be unable to continue operations as a  result of FCC’s proposed rule. Google concluded that for the typical  viewer, in the majority of scenarios, no LPTV or translator station will be  affected. The analysis also indicated that in 72 percent of the nearly 400  counties included in the analysis, not a single station would be affected,  and that even in the specific counties likely to be the most affected, the  preservation of a vacant channel will have only a small impact. Both NAB  and Google have submitted comments to FCC critiquing the other’s  conclusions.
section_title: Development of New Technologies and Innovation
paragraphs: Proponents of FCC’s vacant channel proposal whom we interviewed and  who commented on the proposal generally expect it will contribute to  innovation and the development of new technologies. In our analysis of  comments filed with FCC by proponents of the vacant channel proposal,  at least five groups expressed the idea that preserving vacant channels  would help the development of new technologies. For example, one of  these commenters noted that ensuring unlicensed devices have  nationwide access to spectrum in the reallocated television spectrum  band will promote investment and innovation in these technologies. In  comments filed by another proponent of the proposal, the group stated  reserving at least one vacant television channel in every market  nationwide for public use on an unlicensed basis is essential to spurring  investment and achieving the enormous public interest benefits of  developing new personal portable devices. The commenter went on to  state that ensuring a substantial amount of unlicensed spectrum on a  nationwide basis is critical for developing markets for new, innovative,  and affordable chips, devices, applications, and services.
Three of the four proponents of the proposal to preserve a vacant channel  whom we interviewed told us that three channels for unlicensed use are  needed to develop new technology and that preserving a vacant  television channel would contribute to this needed amount of spectrum.  As discussed previously, FCC’s incentive auction report and order  announced a number of actions intended to make more spectrum  available for unlicensed use, including permitting unlicensed operations  on channel 37 (in locations sufficiently removed from incumbent users to  protect from harmful interference) and in the spectrum guard bands.  Taken together, these measures will provide two of the three channels  that, according to proponents of the vacant channel proposal, are needed  to develop new technologies. For example, one of the proposal’s  proponents told us that unless FCC guarantees there will be three  channels available nationwide for unlicensed use, it is very unlikely that  new mobile uses will move forward into production. This proponent  explained that for companies to invest the money needed to develop new  unlicensed technologies and innovate, companies need certainty that  sufficient spectrum will be available to invest the tens of millions of dollars  needed for development. This proponent also commented that this is  particularly important because insufficient spectrum (i.e., less than three  channels) in even a single major market, such as Los Angeles, would  result in companies not investing money to develop new technologies.  This proponent said that FCC’s adopting the vacant channel proposal  would help provide this certainty by providing a third channel for  nationwide unlicensed use.
section_title: Improvement of Wi-Fi Internet
paragraphs: All representatives from the four organizations we interviewed who are  proponents of the vacant channel proposal expect the proposal could  result in improving Wi-Fi Internet. Specifically, they told us that the  proposal could improve Wi-Fi because of the characteristics associated  with the UHF television spectrum band. They noted that while traditional  Wi-Fi has a relatively limited range and can be blocked by walls or other  environmental barriers, Wi-Fi operating in the UHF television spectrum  band can travel much farther and penetrate obstacles such as buildings  and hills. Representatives of two groups supporting the vacant channel  proposal told us that because of the long-range characteristics and ability  to travel farther through obstructions, Wi-Fi could be expanded more  thoroughly throughout homes and businesses giving people greater  connectivity. One of these proponents also added that this could help  extend coverage to people who might not have affordable access to the  Internet.
section_title: Improvement of Rural Broadband Service
paragraphs: Stakeholders we interviewed supporting FCC’s vacant channel proposal  generally expect the proposal could result in improved and expanded  broadband Internet service in rural areas. Specifically, three of the four  proponents of the proposal we interviewed told us that preserving a  vacant channel could contribute to improved and expanded broadband in  rural areas by allowing people to connect their homes and businesses  wirelessly to the Internet. One proponent told us that in rural areas,  unlicensed spectrum use allows consumers to connect to the Internet  wirelessly from their home or business. They noted that this use of  spectrum is currently occurring and that preserving a vacant channel  could help lower costs and improve the technology, thus improving and  expanding broadband in rural areas.
section_title: Agency Comments
paragraphs: We provided a draft of this report to FCC for review and comment. FCC  provided technical comments, which we incorporated into the report as  appropriate.
We are sending copies of this report to the Chairman of FCC and  appropriate congressional committees. In addition, the report is available  at no charge on GAO’s website at http://www.gao.gov.
If you or members of your staff have any questions about this report,  please contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. Major contributors to this report  are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report focuses on the possible effects of the Federal Communication  Commission’s (FCC) spectrum incentive auction on low power television  (LPTV) and translator stations and their viewers. Specifically, our  objectives were to examine (1) what is known about LPTV and translator  stations and how FCC’s spectrum incentive auction might affect viewers’  access to the stations’ services, (2) selected stakeholder views on actions  has proposed or taken to mitigate the possible effects of the incentive  auction on LPTV and translator stations, and additional stakeholder  proposals for doing so, and (3) selected stakeholder views on the  expected outcomes of preserving a vacant channel for unlicensed use of  the television broadcast spectrum.
To determine what is known about LPTV and translator stations and how  FCC’s spectrum incentive auction might affect viewers’ access to these  services, we reviewed FCC documents related to the incentive auction,  including FCC’s June 2014 incentive auction report and order and FCC’s  December 2015 LPTV and translator report and order. We obtained data  from FCC’s Consolidated Database System (CDBS) as of May 25, 2016,  to determine the number of LPTV and translator stations in the U.S. and  its territories along with the communities of license. We determined the  data were reliable for our purposes after reviewing FCC user guides and  forms for CDBS and interviewing knowledgeable FCC officials regarding  data entry and analysis procedures. We also conducted a web-based  survey of LPTV and translator stations to obtain information on LPTV  station programming, ownership of LPTV and translator stations, and  station representatives’ views on actions that FCC has proposed or taken  and actions Congress or others could take to mitigate the effects of the  incentive auction on LPTV and translator stations. For the web-based  survey, we obtained LPTV’s and translator station representatives’ e-mail  addresses from CDBS; however, because CDBS did not include e-mail  addresses for representatives of all of the 2,063 LPTV and 3,660  translator stations, we sent survey invitations for all LPTV and translator  station representatives for whom we could obtain e-mail addresses. We  supplemented the e-mail addresses obtained from CDBS with addresses  obtained from station representatives and in total identified 330 valid e- mail addresses for LPTV and translator station representatives. Because  the e-mail addresses do not represent all LPTV and translator stations,  the results of our survey are not generalizable and are only used for  descriptive purposes. After preparing draft survey questions and  response categories, we spoke with representatives from three broadcast  industry associations and a translator station representative chosen for  their broad industry perspective and expertise in particular segments of  the industry to determine whether selected questions were answerable by  station representatives and whether the response categories provided  were appropriate, and updated our survey accordingly. We then pre- tested our survey with four representatives of LPTV and/or translator  stations—selected to provide for variety in type of station (LPTV and  translator), number of stations represented, and geography—to ensure  that our survey questions and skip pattern were clear and logical and that  respondents could answer the questions without undue burden. In the  course of pre-testing our survey, we also obtained information that we  present in this report. We administered the survey from June 2016  through August 2016 and received 115 responses. These responses  represent 535 of the 2,063 LPTV stations, and 1,515 of the 3,660  translator stations in the U.S. and its territories. In our report, we provide  survey results based on the number of respondents to each question.  Because not all respondents answered every question of the survey, the  total number of respondents may be fewer than 115 for some results. The  results of our survey are not generalizable, and we did not verify  respondents’ responses. We also interviewed officials from FCC to  determine what information they had regarding LPTV and translator  stations and how the incentive auction might affect viewers’ access to  these services.
To determine stakeholder views on actions FCC has proposed or taken to  mitigate the possible effects of the incentive auction on LPTV and  translator stations, and additional stakeholder proposals for doing so, we  reviewed selected comments and other filings associated with the  incentive auction  proceeding. We selected the comments for review by  performing keyword searches on filings submitted between October 9,  2014, (when FCC sought comment on a number of issues related to  LPTV and translator stations, including additional means to mitigate the  potential impact of the incentive auction and repacking process on these  stations) and April 1, 2016, to allow additional time to include comments  filed after end of the formal comment process. We reviewed filings from  entities that filed more than one comment, reply to comment, letter, or  notice of ex parte in this time period. We also interviewed broadcast  industry associations and station ownership groups that own LPTV and/or  translator stations, as shown in table 6. We selected stakeholders to  represent a range of views from various types of organizations based on  our review of comments filed in FCC’s incentive auction proceeding, as  well as based on recommendations from other organizations we  interviewed. We chose three station ownership groups that own LPTV  and/or translator stations and that broadcast a variety of programming  types. Through our web-based survey, we also obtained station  representatives’ views on actions that FCC has proposed or taken and  that Congress or others could take to mitigate the effects of the incentive  auction on LPTV and translator stations. In our report, we use “some”  when three or more stakeholder sources combined supported a particular  idea or statement.
To identify selected stakeholder views on the expected outcomes of  preserving a vacant channel for unlicensed use of the television  broadcast spectrum, we reviewed FCC’s June 2015 notice of proposed  rulemaking where FCC proposes to preserve one vacant channel in the  ultra high frequency television band for use by white space devices and  wireless microphones, and we reviewed selected comments and other  filings association with this proceeding. We selected comments and  other filings for review, by performing keyword searches on filings  submitted between October 9, 2014, and April 1, 2016, and we reviewed  filings from entities that filed more than one comment, reply to comment,  letter, or notice of ex parte in this time period. We also interviewed  stakeholders, as shown in table 6 above.
We also reviewed relevant statutes and regulations, including the Middle  Class Tax Relief and Job Creation Act of 2012, which authorized FCC to  conduct the spectrum incentive auction. We searched various web-based  databases to identify existing articles, peer-reviewed journals, trade and  industry articles, government reports, and conference papers related to  these topics. We identified articles from 2010 to 2016 and examined  summary-level information that we believed to be germane to our report.  It is possible that we may not have identified all of the reports with  findings relevant to our objectives.
section_title: Appendix II: Survey of Low Power Television and Translator Stations
paragraphs: The questions we asked in our survey of low power television (LPTV) and  translator stations are shown below. In this appendix, we include all the  survey questions and aggregate results of responses to the closed-ended  questions; we do not provide information on responses provided to the  open-ended questions. However, all respondents did not have the  opportunity to answer each question because of skip patterns.  Furthermore, some respondents may have decided not to respond to a  particular question. For a more detailed discussion of our survey  methodology see appendix I.
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Sally Moino (Assistant  Director), Aaron Kaminsky, (Analyst in Charge), David Hooper, John  Mingus, Josh Ormond, Rebecca Rygg, Kelly Rubin, Andrew Stavisky, and  Michelle Weathers made key contributions to this report.