The Leadership Conference on Civil and Human Rights

Transition in Trouble

• Table of Contents
• Acknowledgements
• Executive Summary
• Introduction
• Many Will Suffer Significant Harm if the DTV Transition Fails
• The Leadership Conference has Identified Numerous Issues that Threaten a Successful DTV Transition
  • Transition Planning Lacks Leadership and a Comprehensive Plan
  • Transition Awareness is Low; Consumers and Retailers are Confused; Outreach Efforts are Inadequate
  • Coupon Program is Confusing, Burdensome, and Restrictive
  • Costs and Burdens to Many Communities and Viewers are Excessive or Overwhelming
  • Many Communities Will Lose, not Gain, Television Stations and Service
  • No Rapid Response is in Place to Deal with Inevitable Transition Problems
• Recommendations
  • Improve Organization of the Transition
  • Fund Increased Consumer Outreach, Education and Research
  • Reduce Costs and Burdens of Transition on Viewers
  • Preserve Communities' Access to Their Television Stations
  • Prepare for Rapid Response to Problems
• Conclusion

Transition Planning Lacks Leadership and a Comprehensive Plan

In November 2007, in response to a request from Congress, the GAO issued its report, DIGITAL TELEVISION TRANSITION: Increased Federal Planning and Risk Management Could Further Facilitate the DTV Transition,²⁸ praising some transition efforts and noting shortcomings in others with the goal of ensuring a successful DTV transition for all Americans on February 17, 2009.

In its report, the GAO criticized the lack of a comprehensive federal government digital television transition plan and issued a single "Recommendation for Executive Action":

To help facilitate the DTV transition through comprehensive planning and risk management, in consultation with public and private stakeholders, we recommend that the Chairman, FCC, develop and communicate a comprehensive plan for the various aspects of the DTV transition, encompassing technical, policy, consumer outreach, and other critical elements. The plan should include (1) detailed goals, milestones, and time frames that can be used to gauge performance and progress, identify gaps, and determine areas for improvement; (2) strategies for collaboration between public and private sector stakeholders to agree on roles and responsibilities; (3) a description of reporting requirements to track stakeholder efforts against planned goals; and (4) strategies for managing and mitigating risks to avoid potential problems and target federal resources.²⁹

In issuing this single Recommendation for Executive Action, the GAO recalled how well the government and citizens had been served by the development and communication of a similar comprehensive plan at the time of an analogous, challenging transition: updating the government's computers for Y2K.³⁰

Drafting and carrying out such a comprehensive plan, involving all agencies of the government, would seem common-sensical, low cost, and ideally suited to a challenge of the magnitude of the upcoming digital television transition. It would clearly establish the goals, priorities, strategies, reporting requirements, responsibilities, timetables, and other relevant information necessary to manage the risks of the transition and ensure its success. It would be overseen by a top government official who would regularly convene meetings with other government, industry, public, and private groups to assess how well the plan was being implemented and decide how to best allocate the scarce resources appropriated to the transition.

The GAO is not alone in criticizing the FCC's approach to the digital television transition. According to members of Congress, the FCC is too preoccupied with other issues now and is not focusing enough on the upcoming transition. Senate Commerce Committee Chairman Daniel Inouye, D. Hawaii, recently told FCC Chairman Kevin J. Martin that "too many Americans remain in the dark about what the digital television transition means... I have deep reservations about the FCC spending its limited time and resources in media areas unrelated to the transition."³¹

Commerce Committee Vice Chairman Ted Stevens, R. Alaska, seconded Inouye's concerns. "The digital transition must be the FCC's number one priority this year. No other issue before the FCC has the same critical countdown as this transition... It is crucial that government officials, industry, and consumer advocacy groups increase their outreach efforts to senior citizens and rural Americans."³²

The federal government should engage in the same kind of comprehensive planning for the nation's digital television transition that it did for the nation's Y2K computer transition. Failing to carry out such comprehensive planning places the digital television transition, already fraught with complications and challenges, at needless additional risk.

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28. Government Accountability Office, DIGITAL TELEVISION TRANSITION: Increased Federal Planning and Risk Management Could Further Facilitate the DTV Transition, November 2007.

29. Id. at 33.

30. Id. at 17.

31. Consumers Having Problems with Digital TV Converter Coupons, Consumer Affairs.

32. Id.