From: <[email protected]>
To: "Mr. Milton Brown, NTIA, and Comments Collector" <[email protected]>
Date: 9/22/2006 11:56:30 AM
Subject: To: Mr. Milton Brown and NTIA/Commerce Department Committe receiving comments on Docket Item 060512129-6129-01: Please ensure that the government's $1.5 billion subsidy program for Digital-to-Analog converter boxes addresses the needs of diverse constituencies

Comments to: [email protected]
RE: Docket Number: 060512129-6129-01.
Please copy Mr. Brown when you receive this.

September 22, 2006

Mr. Milton Brown and
the NTIA/Commerce Department Committe receiving comments on this Docket Item
National Telecommunications and Information Administration
Office of the Chief Counsel
14 01 Constitution Avenue, Room 4713
Washington, DC 20230

RE: 060512129-6129-01

Dear Mr. Brown:

I am writing to urge the National Telecommunications and Information Administration (NTIA) to
ensure that the government's $1.5 billion subsidy program for Digital-to-Analog converter boxes addresses the needs of our diverse constituencies. As you must know by now, the issue impacts everyone with rabbit ears after 2009 (15% of the population).
Low-income, minority, female, seniors, the deaf and the hard-of-hearing poor and working poor will be disproportionately affected by the rules you make about the future of analog television viewing capabilities, many losing this window on the world if they cannot afford the new technology, and I find it completely unacceptable that you would do away with access to analog systems.
As of now, as I understand it, in 2009, by Act of Congress, Americans with analog television sets will not be able to get a TV signal-these televisions will be useless without a digital converter box. The boxes are small computers that use software to convert the digital over the air transmissions into the analog TV.
I also understand that the National Telecommunications and Information Administration (NTIA) of the Commerce Department is defining the exact terms of the converter boxes that the government will subsidize. Today is the first I have heard of the call for public comments that are due September 25 by 5PMand there are substantial problems with these definitions and regulations which neither you nor the media have sufficiently brought to our attention. Here are problems that need attention:

1. The public is not aware of these changes and those who are poor will likely be disproportionately affected.
2. The Congressional solution - already enacted - is up to a $1.5 Billion subsidy for digital converter boxes (a $40 coupon each). The Commerce Department should be encouraged to launch a public education campaign targeting disadvantaged populations to ensure those individuals most in need have access to the
subsidies as soon as they are available (before the money runs out).
3. Potential problems with digital converter boxes need to be addressed NOW. These are computers; computer software can have problems. Maybe this new product will be perfect. But a computer glitch could disable small or large parts of the capabilities. Channels could be blanked, or switching slowed. We could lose closed-captioning for Deaf and Hard-of-hearing viewers, for example. The rules proposed by NTIA make no provision for breakdowns or repairs; there is not a word about a long term warranty. The most efficient solution is to require the converter boxes to have remote update capabilities so problems can be fixed even before consumers encounter them. This is what is being done in many other countries for digital TV repairs and downloads (e.g. UK, Austria, Japan, Italy, Germany). Cable companies understand this and cable boxes are regularly updated.
I call on you to ensure that the NTIA program assures us that the $1.5 billion is not wasted, and that consumers who cannot afford digital televisions get the subsidies and are not left with a box that doesn't work.
I write as a member of organizations that belong to the National Council of Women's Organizations. While many NCWO organizations were not involved in the legislative process to allocate federal funds to subsidize the digital converter boxes, all of us are united behind the cause of ensuring that these funds are used wisely.
We recognize that these boxes are intended to allow Americans who have analog television sets the opportunity to still watch TV after 2009's digital deadline. Thus, we have an opportunity to ensure that the interests of these consumers are protected now.
First, these converter boxes must allow consumers to watch television on their existing analog TV sets when all broadcast channels are converted to digital by Congressional order in 2009. In other words, the technology must work and be accessible to everyone who needs it.
Second, we urge the Commerce Department to work with our organizations and the media to inform the public about this transition, especially those who may not be able to afford or have easy access to new technology.
Third, the NTIA must ensure that these boxes have the ability to be repaired, patched or updated in the event that there is a glitch in the software. The worst case scenario would be thousands of Americans left without a working television set, including many poor and elderly consumers who have not "upgraded" to
newer technology. Of equal concern are likely potential problems with closed captioning, the emergency alert system, parental controls to protect children with V-Chip technology, and other glitches or inability to update that negatively impact those without digital sets. While upgrade or patch technology is standard for
cable boxes, DVRs, and computers, there is no economic incentive for the maufacturers of these boxes to do this on their own. NTIA must provide this public protection.
The NTIA rules should require the converter boxes to have the capability to receive software downloads to repair software problems and necessary updates for EAS, V-chip, and captioning capabilities. One acceptable method would be according to industry standards developed for this purpose.
With the boomer retirement era fast approaching, this generation will be mobilizing to make sure that our elders and others who need the analog provision to continue, so I urge you to act on these issues at your very earliest convenience, and I look forward to hearing what action you are taking in this regard.
Sincerely,

Jacqueline Fralley
Silver Spring, MD

cc: Susan Scanlan, Chair
National Council of Women's Organizations