From: "Terry O'Neill" <[email protected]>
To: <[email protected]>
Date: 9/25/2006 4:35:03 PM
Subject: Docket Number 060512129-6129-01

September 25, 2006

Mr. Milton Brown
National Telecommunications and Information Administration
Office of the Chief Counsel
14 01 Constitution Avenue, Room 4713
Washington, DC 20230

RE: 060512129-6129-01

On behalf of the National Council of Women's Organizations (NCWO), the
coalition of more than 200 women's organizations representing over ten
million women, we 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.

While many of our 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 manufacturers 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.

Sincerely,

Susan Scanlan
Chair
National Council of Women's Organizations

National Council of Women's Organizations
1050 17th Street NW, Suite 250
Washington, DC 20036
202-293-4505 (office)
202-293-4507 (fax)
301-233-8582 (cell)
[email protected]
www.womensorganizations.org