Telecommunications: Data Gathering Weaknesses In FCC's Survey Of
Information on Factors Underlying Cable Rate Changes (06-MAY-03,
GAO-03-742T).
Over 65 percent of American households currently subscribe to
cable television service. There has been increasing concern that
cable television rates have been rising aster than the rate of
inflation for the last few years. As required, on a yearly basis,
FCC prepares a report on cable rates in areas that face and those
that do not face effective competition--a term defined by
statute. For information used in this report, FCC maintains
information on the competitive status of cable franchises and
annually surveys a sample of cable franchises. GAO examined (1)
the reliability of information that cable companies provided to
FCC in its annual survey regarding cost factors underlying cable
rate increases and (2) FCC's process for updating and revising
cable franchise classifications as to whether they face effective
competition.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-742T
ACCNO: A06830
TITLE: Telecommunications: Data Gathering Weaknesses In FCC's
Survey Of Information on Factors Underlying Cable Rate Changes
DATE: 05/06/2003
SUBJECT: Cable television
Surveys
Data collection
Data integrity
Competition
******************************************************************
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GAO-03-742T
Testimony Before the Committee on Commerce, Science, and Transportation,
U. S. Senate
United States General Accounting Office
GAO For Release on Delivery Expected at 9: 30 a. m. EDT Tuesday, May 6,
2003 TELECOMMUNICATIONS
Data Gathering Weaknesses In FCC*s Survey Of Information on Factors
Underlying Cable Rate Changes
Statement of William B. Shear, Acting Director Physical Infrastructure
GAO- 03- 742T
Based on interviews with 100 randomly sampled cable franchises that
completed FCC*s 2002 survey, GAO*s preliminary analysis indicates that
FCC*s survey may not be a reliable source of information on the cost
factors underlying cable rate increases. Because of the following
problems, GAO found that there are inconsistencies in how companies
completed the survey.
FCC provided minimal instructions or examples on how the portion of the
survey covering the cost factors underlying rate increases should be
completed. It appears that cable companies made varying assumptions on how
to complete the survey. FCC*s survey required that cable companies fully
allocate their reported annual rate increase to various cost and non- cost
factors.
Our preliminary findings indicate that there was inadequate guidance on
how to achieve this requisite balance, and cable companies approached the
question in varying ways.
Based on preliminary work, GAO found that FCC*s classification of cable
franchises as to whether they face effective competition might not
accurately reflect current conditions. GAO found instances where
information in the survey responses of some franchises would suggest that
the criteria for an effective competition finding that was made in the
past might no longer be present. However, a finding of effective
competition is only changed if a formal process is instituted. GAO found
only two instances where a petition was filed that resulted in a reversal
of an effective competition finding. Over 65 percent of American
households currently subscribe to cable television service. There has been
increasing concern that cable
television rates have been rising faster than the rate of inflation for
the last few years. As required, on a yearly basis, FCC
prepares a report on cable rates in areas that face and those that do not
face effective competition* a term defined by statute. For information
used in this report, FCC maintains information on the competitive status
of cable franchises and annually surveys a sample of cable franchises. At
the request of this committee, GAO examined (1) the reliability of
information that cable companies provided to FCC in its annual survey
regarding cost factors underlying cable rate increases and (2) FCC*s
process for updating and revising cable franchise classifications as to
whether they face effective competition.
What GAO Recommends
GAO is continuing to evaluate these and other issues and may include
recommendations in a final report to be issued in October 2003.
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 742T. To view the full report,
including the scope and methodology, click on the link above. For more
information, contact William B. Shear at (202) 512- 4325 or shearw@ gao.
gov. Highlights of GAO- 03- 742T, testimony
before the Committee on Commerce, Science, and Transportation, U. S.
Senate.
May 6, 2003
TELECOMMUNICATIONS
Data Gathering Weaknesses In FCC*s Survey Of Information on Factors
Underlying Cable Rate Changes
Page 1 GAO- 03- 742T
Mr. Chairman and Members of the Committee: I am pleased to be here today
to provide preliminary observations from our ongoing work on cable
television rates. Over 65 percent of American households are currently
cable television subscribers. As you have noted, Mr. Chairman, cable
television rates have been rising faster than the rate of general
inflation for many years. At the request of this Committee, we
are providing preliminary observations today on two issues: (1) the
reliability of the information that cable companies have provided to the
Federal Communications Commission (FCC) in 2002 regarding the costs
factors underlying their recent cable rate increases, and (2) FCC*s
process for updating and revising the classification of cable franchises
as to whether they are facing effective competition* a statutorily-
defined term. We plan to issue a report with our final analysis of these
and other issues in October 2003.
To address the reliability of information that FCC collected, we randomly
sampled 100 of approximately 700 cable franchises that responded to FCC*s
2002 cable rate survey. 1 We selected a random sample of 100 cable
franchises so that we could make estimates about the entire population of
about 700 cable franchises that responded to the FCC. We asked these
franchises a series of questions about how they completed a portion of
FCC*s survey that asks about the cost factors underlying annual cable rate
changes. To examine FCC*s process for classifying cable franchises as to
whether they face effective competition, we reviewed how various
franchises were classified according to FCC*s information and whether
these classifications continue to accurately reflect current
circumstances.
Our work has focused on examining whether FCC*s annual report on cable
rates is providing reliable information on the causes of rate increases
and the competitive status in video markets. In summary, our preliminary
analysis suggests that some of FCC*s information on cable companies is
inconsistent and potentially misleading. In particular:
Our preliminary analysis of the responses provided by 100 cable
franchises indicates that FCC*s 2002 survey does not provide a reliable
source of information on the cost factors underlying cable rate increases.
We found two key causes of variation in how companies completed the
survey. First,
1 FCC samples between 700 and 800 of the universe of roughly 10,000 cable
systems using a stratified sampling approach based on the status of
effective competition and the size of the cable operator.
Page 2 GAO- 03- 742T
FCC provided minimal instructions or examples on how the portion of the
survey covering the cost factors underlying rate increases should be
completed. As a result, we found that cable companies made varying
assumptions about how to complete the survey. Second, the FCC survey form
requires that the reported dollar amounts reported for factors that might
underlie rate changes* 5 cost factors and a non- cost factor are included
on the form* sum to the reported rate increase for the year. In the
absence of guidance on how to achieve this requisite balance, cable
companies approached the question in varying ways. In particular, most of
the companies told us that they adjusted one of the 5 cost factors for the
purpose of the required balancing, thereby misreporting actual cost
changes that had occurred.
Our preliminary findings show possible inaccuracies in FCC*s current
classification of cable franchises regarding their effective competition
status. We found indications that there are cases in which a finding of
effective competition in a particular franchise area that might have
existed in the past no longer seemed accurate. Nevertheless, the
determination of effective competition remained in effect because the
franchising authority had not filed a petition that would challenge that
finding. In fact, we found that such petitions are rare.
Cable television emerged in the late 1940s to fill a need for television
service in areas with poor over- the- air reception, such as in
mountainous or remote areas. By the late 1970s, cable began to compete
more directly with free over- the- air television by providing new
networks* available only on cable systems* such as HBO (introduced in
1972), Showtime (introduced in 1976), and ESPN (introduced in 1979).
According to FCC, cable*s penetration rate* as a percent of television
households* increased from 14 percent in 1975 to 24 percent in 1980 and to
65 percent by 2002. Cable television is by far the largest segment of the
subscription video market, a market that includes cable television,
satellite service (direct broadcast satellite (DBS) providers such as
DirecTV), and other technologies that deliver video services to customers*
homes.
Cable companies deliver video programming to customers through cable
systems. These systems consist of headends* facilities where programming
from broadcast and cable networks is aggregated* and
distribution facilities* the wires that carry the programming from the
headend to customers* homes. Depending on the size of the community, a
single headend can serve multiple communities or several headends may be
required to serve a single large community. At the community level,
Background
Page 3 GAO- 03- 742T
cable companies obtain a franchise license under agreed- upon terms and
conditions from a franchising authority, such as a township or county. In
some cases, state public service commissions are also involved in cable
regulation.
During cable*s early years, franchising authorities regulated many aspects
of cable television service, including franchise terms and conditions and
subscriber rates. In 1984, the Congress passed The Cable Communications
Policy Act, which imposed some limitations on franchising authorities*
regulation of rates. 2 However, 8 years later, in response to increasing
rates, the Congress passed The Cable Television Consumer Protection and
Competition Act of 1992. The 1992 act required FCC to establish
regulations ensuring reasonable rates for basic service* the lowest level
of cable service that includes the broadcast networks* unless a cable
system has been found to be subject to effective competition, which the
act defined. The act also gave FCC authority to regulate any unreasonable
rates for upper tiers (often referred to as expanded- basic service),
which includes cable programming provided over and above that provided on
the basic tier. 3 Expanded- basic service typically includes such popular
cable networks as USA Network, ESPN, CNN, and so forth. In anticipation of
growing competition from satellite and wire- based providers, the
Telecommunications Act of 1996 phased out all regulation of expandedbasic
service rates by March 31, 1999. However, franchising authorities retain
the right to regulate basic cable rates in cases where no effective
competition has been found to exist.
As required by the 1992 act, FCC annually reports on cable rates for
systems found to have effective competition compared to systems without
effective competition. To fulfill this mandate, FCC annually surveys cable
franchises regarding their cable rates. In 2002, the survey included
questions about a range of cable issues including the percentage of
subscribers purchasing non- video services and the specifics of the
2 The 1984 Act restricted regulation to only basic services for cable
systems not subject to effective competition. In its rulemaking, FCC
initially said that effective competition existed if three or more over-
the- air broadcast signals existed in a given market. Under this narrow
definition, over 90 percent of all cable systems would be subject to
effective competition and therefore not subject to rate regulation. 3
Basic and expanded- basic are the most commonly subscribed to service
tiers* bundles of networks grouped into a package* offered by cable
companies. In addition, customers in some areas can purchase digital tiers
and also premium pay channels, such as HBO and Showtime.
Page 4 GAO- 03- 742T
programming channels offered on each tier to better understand the cable
industry. Until recently, cable companies usually encountered limited
competition in their franchise areas. Some franchise agreements were
initially established on an exclusive basis, thereby preventing wire-
based competition to the incumbent cable provider. In 1992, the Congress
prohibited the awarding of exclusive franchises, and in 1996, the Congress
took steps to allow telephone companies and electric companies to enter
the video market. Still, only limited wire- based competition has emerged,
in part because it takes large capital expenditures to construct a cable
system. However, competition from DBS has grown rapidly in recent years.
Initially unveiled in 1994, DBS served over 18 million American households
by June 2002. Today, two of the five largest subscription video service
providers are DirecTV and EchoStar, the two primary DBS companies.
In a recently released report, we found that competition in the
subscription video market can have a significant impact on cable rates. 4
Using an econometric model, we found that franchise areas with a second
wire- based video provider had rates approximately 17 percent lower than
similar franchise areas without such a competitor. 5 We did not, however,
find that competition from DBS providers is associated with lower cable
prices, although we did find that where DBS companies provide local
broadcast networks to their customers, cable companies provide more
channels than in areas where DBS companies do not provide local broadcast
channels. Moreover, we also found that DBS providers obtain a
substantially higher level of subscribers in areas where they are
providing local broadcast channels.
4 See, U. S. General Accounting Office, Telecommunications: Issues in
Providing Cable and Satellite Services, GAO- 03- 130 (Washington, D. C.:
Oct. 15, 2002). 5 In a similar analysis, FCC found that cable rates in
franchise areas with a wireline competitor were nearly 7 percent lower
than in franchise areas without such as competitor. See, Federal
Communications Commission, Report on Cable Industry Prices, FCC 02- 107
(Washington, D. C.: April 4, 2002).
Page 5 GAO- 03- 742T
FCC*s annual cable rate survey seeks information on cable franchises* cost
changes that may underlie changes in cable rates during the preceding
year. To evaluate the reliability of these statistics, we asked 100 of the
approximately 700 franchises that FCC surveyed in 2002 to describe how
cost change information that they provided to FCC was calculated. Figure 1
shows the actual portion of the FCC survey which franchises completed to
provide their cost change information. FCC*s Cable Rate
Survey Does Not Appear to Provide a Reliable Source of Information on the
Cost Factors Underlying Cable Rate Increases
Page 6 GAO- 03- 742T
Figure 1: Section of FCC*s 2002 Rate Survey Covering Rate and Cost Changes
Source: 2002 FCC Rates Survey
Our discussions with cable franchises indicated considerable variation in
how franchises completed this section of the 2002 FCC cable rates survey.
Our preliminary observations indicate that there are two causes for the
resulting variation: (1) there were insufficient instructions or examples
on how the form was supposed to be completed, leading to confusion among
cable operators regarding what to include for the different cost factors
and how to calculate each of them; and (2) the requirement that the cost
and non- cost factors sum to the reported annual rate increase caused many
cable operators to adjust one or more of the cost factors, thereby
resulting in data that might not provide an accurate assessment of the
cost factors underlying cable rate increases.
CPST2 , whether or not it has the most subscribers. 48 49 50 51 Year- to-
date change in monthly charge on row 50 52 License or copyright fees,
existing programs 53 License or copyright fees, new programs 54 Headend or
distribution facility investment 55 General inflation, not included
elsewhere 56 Other cost changes (positive or negative) 57 Non- cost-
related factors (positive or negative) 58 Total of rows 52- 57 (must equal
row 51)
----- Monthly charge for BST plus CPST1 (rows 48 + 49) For July 1, 2001
and July 1, 2002, allocate the change shown on row 51 by estimating the
dollars and cents Monthly charge for CPST1 and most subscribers among the
CPST tiers (if more than one CPST is offered). Sometimes a "mini- tier"
with considerably fewer channels has the most subscribers among the CPSTs.
This mini- tier is considered July 1, 2001 July 1, 2000
or pay- per- view. CPST1 refers to the major CPST and typically meets two
criteria: It has the most channels Monthly Charges for Programming
Services
In the following, the "basic cable service tier" or BST is the service
tier that includes the retransmission of Monthly charge for BST E.
Programming Service Charges in Community
over- the- air broadcast signals and may include a few satellite or
regional channels. A "cable programming ----- service tier" or CPST is any
other tier containing programming other than that on the BST, pay- per-
channel,
July 1, 2002 ----- that each factor, below, contributed. The total of
these factors (row 58) should equal the change on row 51. ----- -----
----- ----- -----
Page 7 GAO- 03- 742T
Lack of adequate instructions. Our interviews with 100 cable franchises
indicate that the lack of specific guidance regarding the cost change
section of the survey caused considerable confusion about how to fill out
the form. Every franchise that we spoke with said it was unclear what FCC
expected for at least one of the six factors (5 cost factors as well as a
noncost factor); 73 of the 100 franchises said that the instructions were
insufficient. In particular, several cable representatives we interviewed
noted that there were no instructions or examples to show how to calculate
investment, what types of cost elements should go into the other costs
category, and what FCC meant by non- cost factors. This lack of guidance
created considerable variation in the approaches taken to develop the cost
factors. Table 1 provides information on the approaches cable franchises
used to complete the portion of the survey pertaining to cost and non-
cost factors underlying rate changes.
Table 1: Summary of Approaches Used by Cable Franchises to Calculate Cost
and Non- Cost Factors Type of cost/ non- cost factor (line of FCC survey)
Discussion of how franchises approached this factor License or copyright
fees, existing and new programs (lines 52 and 53)
Most of the cable companies told us they used specific cost data on
existing programming costs to develop the cost changes associated with
increases in existing programming.
Thirty- nine of the 47 franchises that reported an increase in new
programming costs said they used actual information to calculate these
cost changes.
Some companies took a standard company- wide approach to estimating
programming costs as opposed to estimating the costs for each individual
franchise. Some companies combined cost changes for all programming
without separating existing from new
programs.
Head- end or distribution facility investment (line 54)
Eighty- three of the 100 franchises we surveyed entered zero for these
infrastructure investments. Of these, 33 told us that there had, in fact,
been additional costs for such upgrades that year. The reasons provided to
us for leaving it blank included concern that it would be too difficult to
determine how much of these costs would be appropriately allocated to a
certain video service or franchise.
Some cable companies performed significant calculations to estimate how
much should be allocated to the support of video services, while other
estimates did not include detailed cost calculations.
General inflation (line 55) Fifty- seven of the 100 franchises estimated
inflation by using either FCC or Bureau of Labor Statistics* inflation
factors.
Other companies left the inflation factor blank because they assumed
that most inflation would be captured in the other cost factors.
Other cost changes (line 56)
Sixty- four of the 100 franchises filled in a zero for the other cost
factor. Of these 64 franchises:
Thirty- two told us that there were, in fact, cost changes that would
have appropriately been captured in the other category; Seventeen told
us that they did not understand what items should be included in other
costs; and
Fifteen told us that by the time they got to this line on the form, they
had already accounted for enough costs to offset the reported rate
increase and thus, they did not evaluate whether there were any costs that
should be included as other costs.
Non- cost- related factors (line 57)
Eighty- seven of the 100 respondents said they did not understand what
non- cost factors would cover, and as a result, 76 of the respondents left
the non- cost factor blank.
Those that did enter a number for this factor cited such items as a
change in profit margin or the need to establish uniform rates across
franchises. Source: GAO Survey of 100 Cable Franchises
Page 8 GAO- 03- 742T
Requirement that factors sum to the reported annual rate change. Our
survey of 100 cable franchises that responded to FCC*s 2002 cable rates
survey indicated that a second source of confusion relates to the
requirement that the sum of the underlying cost and non- cost factors (see
fig. 1 lines 52- 57) equal the change in the franchise*s cable rates (see
fig. 1 line 51). This portion of FCC*s survey was originally designed
during the
1990s when both basic and expanded- basic services were regulated. At that
time, cable companies were required to justify any rate increases the
cable company implemented based on cost increases that it had incurred
during the year. An FCC official told us that the rate/ cost factor
portion of the form was designed to mirror a regulatory form that was used
at that time to justify rate changes. When expanded- basic services were
deregulated in March 31, 1999, FCC realized that cost factors would no
longer necessarily equal the yearly rate change because companies were no
longer required to tie rate changes to explicit cost factors for
regulatory purposes. 6 In the 1999 cable rates survey, FCC added the non-
cost line in this section of the survey and continued to require that the
cost factors and the non- cost factor sum to the reported annual rate
change.
FCC officials told us that cable operators could use the non- cost factor
element to make up any difference (positive or negative) between their
changes in costs and rates. However, based on our findings, it appears
that this may not have been clearly communicated to cable franchises. We
found that only 10 franchises took this approach and instead, most
franchises told us that they chose to change their estimate of one or more
of the cost factors. In most cases, cable representatives told us that
this meant reducing other cost factors because most franchises told us
that their actual annual cost increases for the year covered by the 2002
survey exceeded their rate change for expanded- basic service. 7 In other
words, most franchises* 84 of the 100 franchises we spoke with* did not
provide a complete or accurate accounting of their costs changes for the
year. The following are some examples of how the franchises we surveyed
chose to equalize the cost factors with the rate change.
6 In unregulated markets, for example, costs are an important factor in
price setting by companies, but several other key factors, such as
consumer demand and the competitiveness of the market also influence
market price.
7 Many franchises said that their profit margins for basic and expanded
cable services decreased in 2002, but many said that those decreases were
offset by increased profits from other services, such as cable Internet
and digital cable. The 3 franchises that said that their rate increase
exceeded their cost increases made the two balance by entering a positive
number in non- cost- related factors.
Page 9 GAO- 03- 742T
Fifteen franchises said they entered dollar values in the factors until
the entire rate increase was justified and did not consider the remaining
cost factors;
Twenty franchises said they chose to adjust the dollar estimates in
existing and/ or new programming in order to balance costs and rates;
Seven franchises said they chose to adjust the costs included for
investment in order to balance costs and rates; Twenty- seven franchises
said they chose to adjust the amount of their
inflation estimate to ensure that costs and rates were in balance;
Twenty- six franchises said they chose to adjust the other costs factor to
ensure that costs and rate changes were in balance; and Four franchises
said they adjusted more than one of the cost factors in
order to balance costs and rates. For example, one franchise chose to
adjust all of the factors by a uniform percentage in order to retain a
constant ratio of cost increases.
The 1992 Cable Act established three conditions for a finding of effective
competition, and a fourth was added in the 1996 Act. Specifically, a
finding of effective competition in a franchise area requires that FCC has
found
one of the following conditions to exist: Fewer than 30 percent of the
households in the franchise area subscribe to
cable service (low- penetration test). At least two companies
unaffiliated with each other offer comparable
video programming service (through a wire or wireless* e. g., DBS*
service) to 50 percent or more of the households in the franchise area and
at least 15 percent of the households take service other than from the
largest company (competitive provider test). The franchising authority
offers video programming service to at least 50 percent of the households
in the franchise area (municipal test).
A local telephone company or its affiliate (or any other company using
the facilities of such carrier or its affiliate) offers video programming,
by FCC*s Process for
Updating and Revising its Classification of the Competitive Status of
Cable Franchises May Lead to Classifications that are No Longer Accurate
Page 10 GAO- 03- 742T
means other than direct broadcast satellite, that is comparable to that
offered by the cable provider in the franchise area (LEC test). 8
Franchising authorities have primary authority to regulate basic cable
rates. However, these rates may only be regulated if the cable system is
not facing effective competition. Under FCC rules, in the absence of a
demonstration to the contrary, cable systems are presumed not to face
effective competition. The cable operator bears the burden of
demonstrating that it is facing effective competition. 9 Once the presence
of effective competition has been established, the franchising authority
is no
longer authorized to regulate basic cable rates. FCC does not
independently update or revise an effective competition finding once it is
made. An effective competition finding may be reversed if a franchising
authority petitions to be recertified to regulate basic rates by
demonstrating that effective competition no longer exists. However, such
petitions are rare. Our preliminary review of the approximately 700 cable
franchises that responded to FCC*s 2002 cable rates survey suggests that
the agency*s lack of any updates or reexamination of the status of
competition in franchise areas may lead to some classifications of the
competitive status of
franchises that do not reflect current conditions. For example: Forty-
eight of the 86 franchises in the sample that FCC had classified as
satisfying the low- penetration test for effective competition actually
reported current information to FCC on their operations that appeared,
based on our preliminary calculations, to indicate that current
penetration
rates are greater than the 30 percent threshold. 10 Ten cable franchises
appeared to have a penetration rate exceeding 70 percent* a full 40
percentage points above the legislated low- penetration threshold.
Forty of the 262 franchises in the FCC survey that had been classified
as having effective competition by FCC also reported that the franchising
8 For this test to be applicable, the telephone company and the cable
provider must be unaffiliated. 9 In some cases, franchise authorities do
not wish to regulate rates and cable companies
may choose not to file for a determination of effective competition, even
if conditions warrant. 10 We calculated the penetration rate by dividing
the number of franchise subscribers by the number of households in the
franchise area, as reported by the cable company to FCC.
Page 11 GAO- 03- 742T
authority was currently regulating basic service rates. This would not be
in accord with the statutory requirement. It is possible that such an
inconsistency could occur because cable companies incorrectly completed
FCC*s survey in some fashion.
Although the survey form asks the cable franchise whether they face
effective competition in the franchise area, those responses are not
always consistent with information maintained by FCC regarding whether
there has been an official finding of effective competition. When FCC*s
information conflicts with the survey response, FCC overrides the answer
provided by the cable franchise. We found that FCC staff overrode the
survey responses on effective competition for 24 percent of all franchises
in its 2002 survey.
Also, we have searched for instances in which franchising authorities
sought to have a finding of effective competition reversed. We found two
instances in which FCC reversed a finding of effective competition.
However, in one of these instances involving ten franchises in Delaware,
some of the franchises appear to remain classified as having effective
competition even though FCC reversed the position in 1999.
In its 2002 Report on Cable Industry Prices, FCC acknowledges that the
classification of the competitive status of some franchises may not
reflect current conditions. Some franchises that face competition may not
have
filed a petition, and therefore are not classified as facing effective
competition. Also, some franchises may have previously met the criteria
for a finding of effective competition, but because of changing
circumstances may not currently meet the criteria and remain classified as
facing effective competition.
We are conducting additional work on the issues discussed today and a more
complete analysis will be included in our final report, which we plan to
issue in October 2003. In addition to the topics discussed today, we will
be providing a more comprehensive analysis of the factors underlying
recent cable rate increases, the impact of competition on cable rates and
service, and cable tiering issues.
Mr. Chairman, this concludes my prepared remarks. We would be pleased to
answer any questions you or other members of the Committee may have.
Additional GAO Work
on Cable Rate and Competition Issues
Page 12 GAO- 03- 742T
For questions regarding this testimony, please contact William B. Shear on
(202) 512- 4325 or at shearw@ gao. gov. Individuals making key
contributions to this testimony included Amy Abramowitz, Mike Clements,
Keith Cunningham, Michele Fejfar, Wendy Turenne, Mindi Weisenbloom, and
Carrie Wilks. Contact and
Acknowledgments
(545033)
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