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Before the UNITED STATES DEPARTMENT OF COMMERCE NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION Washington, D.C. 20230
In the Matter of ) Implementation and Administration of a ) Docket No. 060512129-6129-01 Coupon Program for Digital-to-Analog ) Converter Boxes )
Comments of Northern Virginia Resource Center for Deaf and Hard of Hearing Persons
September 25, 2006
The Northern Virginia Resource Center for Deaf and Hard of Hearing Persons has a mission of serving deaf and hard of hearing individuals and their families through education, advocacy and community involvement. Its programs, while targeted primarily for the approximately 200,000 deaf and hard of hearing individuals residing in the Metropolitan Northern Virginia area, are sometimes national in scope. We appreciate this opportunity to provide the comments below to the NTIA on behalf of individuals who are deaf and hard of hearing and their families.
1. It is difficult to address the overall plan without some idea of the projected cost of the converter boxes and whether the $40 coupon will be sufficient for the population which will need to purchase these boxes. We hope that the NTIA will research the financial needs of the prospective buyers to be certain the amount will serve its intended purpose.
2. Without knowing whether stores in an area will have an adequate supply of affordable converter boxes, we are concerned that the January 2008 start date for the coupons may not be enough. Much will also depend on the effectiveness of the public relations effort, which we address below.
3. We would like to see an appeal process for those who are unable to make use of their coupons within the proposed 3-month time limit. Some situations merit exceptions, such as hospitalization or recovery in a rehabilitation facility, being overseas, coupons lost in the mail. There should also be an appeal process for coupons denied by the NTIA or retailer.
4. The current proposal seems to focus on in-person sales of converter boxes. We would like to see this expanded to allow Internet and phone orders.
5. Consumers in rural areas have told us that delivery times for a first class letter can vary widely. We suggest expanding the deadline for use of the coupon to 4 months.
6. Retailers can choose whether or not they will participate in offering converter boxes to coupon users. There is no requirement that they must offer a selection of converter boxes. We would like to see safeguards to prevent their offering only one or a limited number that offer the highest profit, particularly in areas where there may be no competing retailers.
7. The NTIA proposes to require manufacturers to self-certify that their converter boxes meet standards, and invites comment on whether existing industry or government organizations can help speed testing/certification allowed in the time frame of this program. We would like to see WGBH's National Center for Accessible Media, a group that has been actively involved in digital TV captioning, funded to provide testing that ensures the devices will deliver proper captioning integrity.
8. The NTIA asks whether there should be a printed list of converter boxes approved as eligible, and asks where the list should be available -- on a website, or just left to a retailer, or with placards where the retailer sells the converter boxes. Particularly with our constituency, people who have hearing loss, there are often limited ways to receive information. We strongly favor having printed information on websites, and required of retailers at the location where converter boxes are on display.
9. The NTIA asks for comments about a consumer education program. We are particularly interested in having money allocated for this purpose to national consumer organizations serving people who are deaf and hard of hearing who specialize in providing consumer information. We recommend the Deaf and Hard of Hearing Consumer Advocacy Network, a coalition of 17 national organizations including the National Association of the Deaf and Telecommunications for the Deaf and Hard of Hearing, Inc. as well as the Hearing Loss Association of America and Alexander Graham Bell Association for the Deaf and Hard of Hearing.
Thank you again for this opportunity to provide comments.
Cheryl A. Heppner, Executive Director Northern Virginia Resource Center for Deaf and Hard of Hearing Persons 3951 Pender Drive, Suite 130 Fairfax, VA 22030
Empowering deaf and hard of hearing individuals and their families through education, advocacy and community involvement
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