Over half of all households in Puerto Rico may use over-the-air television and should be alerted quickly about the coming digital or "DTV" transition, the self-governing U.S. territory's telecommunications board has warned the Federal Communications Commission.

"It should also be pointed out that the average income per capita of Puerto Rico households is considerably lower than the average income per capita of U.S. households," Puerto Rico's Telecommunications Regulatory Board wrote to the FCC on September 17th. "Therefore, acquiring DTV sets or subscribing to cable television or satellite services not necessarily will be feasible alternatives to a substantial number of these consumers in Puerto Rico."

Congress has designated February 17, 2009 as the last day of analog TV broadcasting. Millions of Americans do not have digital TV sets. Starting on January 1st, 2008, all Americans will be eligible to receive two $40 coupons good towards converter set-top boxes that will make analog TV sets digital ready.

But Puerto Rico's telecom board warns that the income disparity between many Puerto Ricans and mainland Americans needs to be taken into consideration by the FCC. While an estimated 528,304 Puerto Rican households have cable or satellite television, many or most of the rest of the region's 1,261,325 homes depend on conventional analog TV. Many may not have the income to replace their older sets with brand new digital models.

"It would be reasonable to conclude that for more than half of all occupied households in Puerto Rico, demand for such converter boxes will likely be higher in proportion to households in the U.S.," the board writes.

The filing recommends that the FCC instruct television broadcasters to run regular public service announcements (PSAs) about the set top boxes, and in standardized formats.

The Commission should "require PSAs to be aired at specific hours, and in particular instances, in other languages including Spanish, to reach Spanish-speaking audiences," the board writes.

The question of whether the FCC should mandate PSAs on the DTV transition is a source of contention. The National Association of Broadcasters (NAB) opposes the move, while many public interest groups favor such guidelines.

Puerto Rico's telecom board clearly comes down on the latter site of the argument. The group also recommends that the FCC require broadcast licensees to report their consumer education activities to the Commission every three months, "including the time, frequency and content of PSAs aired by each station."

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