Before the Bell

“Should the E-Rate program be limited or sunset to reflect today’s extensive connectivity rates? Does the Commission have the authority to limit or sunset the E-Rate program?”

The question that launched the campaign. The E-rate Advocates argued that section 254 is a congressional mandate the FCC cannot end; the Notice says it will seek comment on that premise “rather than assume it” (¶13).

“What services are supported by E-Rate funding, and would there be an impact on schools’ and libraries’ ability to afford these services if the E-Rate program was terminated or limited?”

A district can answer this better than anyone in Washington. Hawthorne's hour-by-hour account is a model answer, and the worksheet below is built around it.

“For example, should E-Rate support be limited to rural areas or to areas served by a single provider?”

Suburban and urban districts would lose support outright. As the Montana analysis shows, rural districts would still face changes to discounts and special construction.

“We seek comment on whether the use of the National School Lunch Program (NSLP) eligibility and urban/rural status in determining an applicant’s discount rate remains an effective method for calculating support…”

The 20% to 90% matrix is how E-rate targets need. Changing it would move money between districts even without a cut to the program's total.

“Are there services that are currently eligible for support that are no longer necessary or are inconsistent with the statute?”

The Notice ties this to the 2025 reversal of hotspots and bus Wi-Fi, and asks about equipment that does not “ultimately transport information to school classrooms or libraries.” Internal connections and their maintenance are where many district requests sit.

“Should funding for special construction be eliminated entirely?”

Special construction and dark fiber built many rural and consortium networks. The FCC asks whether BEAD and similar programs make that support unnecessary.

“We seek comment on whether this presumption should be reversed or otherwise altered and if so, why.”

Today, activity on school or library property is presumed to serve an educational purpose. Reversing that presumption could change what applicants have to document about how the network is used.

“…we should require, as a condition of receiving E-Rate support, that participating schools provide parents with a meaningful opportunity to opt their children out of screen-based instruction or screen use during the school day.”

This would attach an instructional policy to connectivity funding, which is the conflation of screen time and infrastructure that most advocates object to.

“We seek comment on whether Head Start and pre-kindergarten students should continue to receive E-Rate program support…”

Eligibility currently follows state law: 29 states and territories include Head Start and 34 include pre-K in their definition of elementary education.

“We further seek comment on whether our current interpretation of certain key language in the Children’s Internet Protection Act (CIPA) is the best reading of that statutory language.”

CIPA compliance is already a condition of E-rate support. A new reading could change what filtering and supervision schools and libraries must certify.

The Further Notice proposes a definition of “consultant,” an annual certification and disclosure form (FCC Form 5654), and a consultant registration database.

Many small districts rely on consultants to apply at all. These are actual proposed rules, unlike most of the NPRM.