Connectivity Isn't the Problem: Why the FCC Should Leave E-Rate Alone
On June 4, 2026, the Federal Communications Commission released a Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking (WC Docket Nos. 26-133, 13-184, 21-93, and 21-455) that asks, in plain terms, whether the E-Rate program has outlived its purpose. "Should the E-Rate program be limited or sunset to reflect today's extensive connectivity rates?" the notice asks. "At what point should policymakers conclude that the program's core objective has been achieved?"
It's a fair question to ask. It is the wrong conclusion to reach. E-Rate should not be sunset, narrowed to a subset of "underserved" ZIP codes, or quietly wound down because the connectivity gap it was built to close has gotten smaller. And the two other ideas bundled into this same proceeding — folding screen-time regulation into CIPA compliance, and mandating parental opt-out systems as a condition of federal funding — deserve just as much skepticism, for a different reason: they ask the FCC to regulate what happens on a screen, not just whether a school has a wire to the internet.
The mission isn't "connect every school. “ It's 'keep them connected '. " “
E-Rate has done exactly what Congress asked when it created the program in the Telecommunications Act of 1996: it took schools and libraries from spotty, unaffordable internet access to near-universal broadband. That is a genuine success story, and nobody serious disputes it.
But the FCC's framing treats connectivity as a one-time achievement rather than an ongoing cost. Bandwidth needs in classrooms have not stood still since 1996, or even since 2016 — they have grown with online testing, one-to-one device programs, video-based instruction, and now AI-literacy tools that the Department of Education itself is pushing schools to adopt.
Fiber and equipment still need to be paid for, maintained, and upgraded every year. "We built the network once" is not the same as "we no longer need help paying for it." A school district that loses its E-Rate discount doesn't revert to 1996-era access — it reverts to a budget shortfall, and the easiest things to cut are the connections themselves.
There is also a legal issue with treating "mission accomplished" as a trigger to end the program. As a coalition of education and library groups — including the American Library Association, AASA, the National Education Association, and the Schools, Health & Libraries Broadband Coalition — told the FCC in a June 16 letter, nothing in the E-Rate statute gives the Commission authority to end the program "after a certain period of time or after certain benchmarks are met." Congress wrote a program to fund ongoing service, not a project with a finish line. If the FCC wants that finish line, it needs Congress to write one — not to invent one through rulemaking.
Limiting E-Rate to rural or single-provider areas sounds targeted. It isn't.
The notice also floats narrowing eligibility to rural districts or places served by only one internet provider, on the theory that competition elsewhere has already driven prices down. This ignores the fact that many urban and suburban districts serve high-poverty populations, where the E-Rate discount is the difference between adequate bandwidth and none.
Geography is a poor proxy for need. A funding formula built around zip codes instead of the actual cost burden on a district's budget will inevitably cut off schools that still depend on the subsidy, while doing little to address the "insufficient competition" problem the FCC says it's worried about — since removing a discount doesn't create a new provider.
Screen time and content filtering are not connectivity problems
The second thread in this proceeding — reopening the Children's Internet Protection Act to address screen time and considering new limits on how E-Rate-funded devices and networks are used — is a much bigger reach than it first appears. CIPA already requires E-Rate recipients to filter obscene material, child pornography, and content harmful to minors, and to adopt internet safety policies. That is a content-safety function tied directly to what flows over a connection.
Screen time is a different question entirely: how long a student looks at any screen, filtered or not, for any purpose, including E-Rate-funded coursework. FCC Commissioner Anna Gomez put the distinction well when she noted that the FCC "is not the nation's parent. It is not the nation's teacher. It is not the nation's school board."
Decisions about appropriate screen time belong with families, teachers, and locally elected school boards — and, increasingly, with state legislatures, several of which have already passed their own screen-time limits this year. Routing that debate through a federal telecommunications subsidy program doesn't make the underlying question easier to answer; it just adds a compliance layer that has nothing to do with whether a rural library can afford broadband.
As the Software & Information Industry Association put it, the notice "conflates two very different things: screen time and connectivity," and the FCC should target its actual concerns "with precision, rather than risk severing the connectivity that closes the digital divide."
A federal parental opt-out mandate solves a problem better handled locally
The proceeding also asks how far schools should be required to go in offering parents an opt-out from E-Rate-funded network or device use for their children. Transparency and parental input are reasonable goals, and most districts already have some version of an acceptable-use policy that parents can review or push back on. But turning that into a federal funding condition — enforced through E-Rate eligibility — creates a one-size-fits-all mandate for a policy question that varies enormously by community, grade level, and curriculum.
A district that builds its instructional model around shared devices and cloud-based coursework faces a very different operational reality than one that doesn't, and a federal opt-out rule risks either being toothless in practice or disruptive to instruction, depending on how it's drafted. This is exactly the kind of implementation decision that a local school board — accountable to the parents actually affected — is better positioned to make than a national rule tied to a connectivity subsidy.
What the FCC should actually do
None of this means the FCC's broader review of E-Rate is worthless. Real oversight questions deserve real answers: the notice's separate proposals to tighten consultant disclosure rules, close loopholes in competitive bidding, and clean up outdated Emergency Connectivity Fund regulations are a sensible, uncontroversial modernization. Program integrity and connectivity funding are not in tension — the FCC can pursue both without touching eligibility or defunding schools that still rely on the subsidy.
The public comment period is open, and it matters. Anyone who cares about keeping classrooms and library patrons connected — teachers, school administrators, librarians, parents, and taxpayers who'd rather not watch a 30-year investment erode — should file comments in WC Docket Nos. 26-133, 13-184, 21-93, and 21-455 through the FCC's Electronic Comment Filing System (fcc.gov/ecfs) before the comment deadline. The message is simple: don't confuse a program that worked with a program that's finished. E-Rate's job isn't done just because the wires got laid. Keep the funding. Leave the parenting to parents.
Sources: FCC Notice of Proposed Rulemaking, WC Docket Nos. 26-133 et al., June 4, 2026; K-12 Dive, "FCC wants to know: Should the E-rate program be eliminated?" June 25, 2026; FCC, "FCC to Review E-Rate Program to Ensure it Fulfills Congress's Vision"; coalition letter to the FCC, June 16, 2026 (ECFS Doc. 26109834748).
