I. Introduction.

ACA opposes the Petition for Reconsideration ("Petition") filed by Public Knowledge and others (collectively, "Petitioners"). Petitioners' incorrectly claim that the need for low-cost, limited-capability set-top boxes to facilitate the digital transition has seen significantly reduced. The vast majority of ACA members continue to operate systems that need to transition channels from analog to digital. Therefore, the Commission should deny the Petition based on the following manifest and compelling public interests:

• Evolution's low-cost, limited-capability set-top boxes will help ACA's members reclaim bandwidth and expedite the deployment of advanced digital services in the smaller and rural markets served by ACA's members; and
• Evolution's low-cost, limited-capability set-top boxes will help ACA's members offer affordable broadband service to consumers.

For these reasons, the Commission should deny the Petition and maintain the waiver for its full term.