Comments of the American Association of People With Disabilities (AAPD) to the U.S. Department Of Commerce, National Telecommunications and Information Administration.

In Re Docket Number: 060512129–6129–01, RIN 0660–AA16

--Implementation and Administration of a Coupon Program for Digital-to-Analog Converter Boxes"

September 25, 2006

The American Association of People with Disabilities (AAPD) AAPD is the largest national nonprofit cross-disability member organization in the United States, dedicated to ensuring economic self-sufficiency and political empowerment for the more than 56 million Americans with disabilities. AAPD works in coalition with other disability organizations for the full implementation and enforcement of disability nondiscrimination laws, particularly the Americans with Disabilities Act (ADA) of 1990 and the Rehabilitation Act of 1973, and other statutes.

AAPD has also signed on to the Comments of WGBH National Center for Accessible Media, but adds also this additional comment, in regard to eligibility of persons for the coupons.

Comment on Eligibility For Coupons:

The NPRM asks for comment on whether the poverty level standard is the one they should use in determining eligibility.

 
If the current poverty level guidelines are used, AAPD believes there are persons with disabilities who would not receive the converter box coupon and who should otherwise benefit from the coupon program.  These may be elderly hard-of-hearing persons on SSDI- plus-retirement or others with hearing disabilities and similar limited incomes. 

We therefore recommend that NTIA use the current FCC Lifeline-Linkup phone subsidy scheme for eligibility which allows persons who are beneficiaries of various other programs to be eligible. For instance, the Lifeline Linkup phone assistance program uses 135% of poverty level OR persons who are beneficiaries of any one of the following assistance programs:

Medicaid,

Food Stamps,

Supplemental Security Income (SSI),

Federal Public Housing Assistance (Section 8),

 Low-Income Home Energy Assistance Program (LIHEAP),

Temporary Assistance to Needy Families (TANF),

 The National School Lunch Program¹s Free Lunch Program,

Bureau of Indian Affairs General Assistance,

Tribally-Administered Temporary Assistance for Needy Families (TTANF),

Head Start,

Tribal National School Lunch Program.

 
We believe this eligibility scheme may permit coupons to reach more persons with disabilities.

The transition to digital television in this country promises to enhance the lives of all of us and to free up valuable spectrum for many vital public service and commercial uses.  .  Our most-common and most-comfortably used medium – television – must continue to be available to all Americans. With attention to certain basic principles of access and fairness, including eligibility, America's citizens with disabilities can be equally served by the transition to digital television.

Jenifer Simpson

Senior Director, Telecommunications and Technology Policy

American Association of People with Disabilities (AAPD)

1629 K Street, N.W.,  Suite 503

Washington, DC 20006

Http://www.aapd.com