Council Tree Council Tree Communications Inc.

Colorado Office

New York Office

2919 17thAvenue, Suite 205

The Chrysler Building

Longmont, Colorado 80503

405 Lexington Avenue, 25th Floor

Phone: (303) 678-1844

New York, New York 10174

Fax: (303) 678-1859

Phone: (212) 286-8700

www.counciltree.com

Fax: (917) 591-4507




September 22, 2006

Mr. Milton Brown
Office of the Chief Counsel
National Telecommunications and Information Administration
1401 Constitution Ave., Room 4713
Washington, DC 20230

Re: Implementation and Administration of a Coupon Program for Digital-to-Analog Converter Boxes [Docket No.: 060512129-6129-01]

Dear Mr. Brown:

We respectfully share some thoughts and concerns about the proposed rules for the above referenced program (the ”Program”).

The NTIA proposes that “[a]n eligible household address shall not be a post office box.”

Council Tree believes that the NTIA may not have been aware that the U.S. Postal Service does not provide home delivery service on most of the approximately 300 Indian Reservations in the U.S. Nearly all of the 1.5 million, mostly poor, reservation residents depend on service to post office boxes to receive their mail.

Similarly, a significant portion of the Alaska Native population live in remote rural locations that do not have the benefit of home postal delivery service, and rely on post office boxes for their mail service.

Since we expect that these population segments will be amongst the most likely to request Program assistance, we suggest that the final Program rules allow for alternative methods of delivering the coupons to Indian Reservations and to Alaskan Native Villages.

Sincerely,

 

Michael Brendzel Vice President Council Tree Communications, Inc.