C. Application Process
19. NTIA proposed to require coupon applicants to submit the following information: (1) name; (2) address (no Post Office Box); (3) the number of coupons required, not to exceed two coupons; (4) a certification that they only receive over-the-air television signals using an analog-only (NTSC) television receiver; and (5) a certification that no other member of the household has or will apply for a coupon. Furthermore, consistent with the Act, NTIA proposed to commence the application period on January 1, 2008 and conclude on March 31, 2009. If an applicant does not specify the number of coupons needed, NTIA proposed sending the applicant one coupon. Also consistent with the Act, NTIA proposed sending the requested coupon(s) via the United States Postal Service.
20. Few of the comments raised concerns about the information NTIA proposed to require consumers to provide as part of the application process. CERC, however, argued that certifications that a household receives only over-the-air television signals and that no one else in the household will apply is neither consistent with the Act, nor practical nor fair.[ 49 ] Council Tree Communications Inc. argued that NTIA should allow for “alternative methods of delivering the coupons to Indian Reservations and Alaskan Native Villages.”[ 50 ] Some commenters encouraged the Agency to make applications available in foreign languages.[ 51 ] With respect to the application period, one commenter suggested that the time period be extended to December 31, 2009, because consumers may not understand the need for a converter box until their televisions go dark after February 17, 2009.[ 52 ]
21. The Final Rule requires applicants to provide NTIA with only the information necessary for NTIA to fulfill a coupon request. Accordingly, applicants for coupons must provide the following: (1) name; (2) address; (3) the number of coupons that they require; and (4) a certification as to whether they receive cable, satellite, or other paid television service. NTIA is sensitive to privacy concerns and is not requesting unnecessary personal identification information, such as social security numbers. Multifamily residences (i.e., a residence occupied by more than one family unit) will not be eligible for more than two coupons unless each household is occupied as separate living quarters and has a separate U.S. postal address. Coupons will be mailed via the U.S. postal service along with the terms and conditions of use. Given the sensitivity of commenters to the prevalence of Post Office Boxes in rural America, NTIA will make allowances for households on Indian Reservations, Alaskan Native Villages and other rural areas where Post Office Boxes are the only means of mail delivery. Residents of Indian reservation, Alaskan Native Villages and other rural areas without home postal delivery may be requested to supply additional information to identify the physical location of the household. With respect to the application period, NTIA will adhere to the period provided in the legislation; thus NTIA will accept applications only between January 1, 2008 and March 31, 2009.[ 53 ]
22. Commenters agreed with NTIA’s proposal to make application forms widely available.[ 54 ] NTIA will administer the program to make it accessible particularly to those in need of coupons. As part of the consumer education program, consumers will be made aware of the various ways to access and submit applications for the Coupon Program. NTIA will ensure that applications and accompanying materials are available in other languages consistent with its obligations under Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency,” (Aug. 11, 2000).[ 55 ] The Final Rule provides that coupons may be requested by mail, by phone and electronically (e.g., by email or through a website).
49 CERC Comments at 9.
50 Council Tree Communications Inc. Comments at 1.
51 Sunbelt Multimedia Co. Comments at 12.
52 Robert Diaz Comments.
53 Section 3005(c)(1)(A) of the Act.
54 AARP Comments at 9-10.
55 The Department of Commerce Limited English Proficiency guidelines are provided on the Department’s website at http://www.osec.doc.gov/ocr/doclepplan2003.pdf.