What YOU can DO
The mechanics
Everything goes into WC Docket No. 26-133 through the FCC's ECFS. Comments are due October 13, 2026; reply comments are due November 12. Three filing tiers: Express (type into a form, good for individuals), standard upload (a letter), and a formal comment with data and exhibits. SHLB's Save Our E-Rate hub has templates for all three, plus congressional email campaigns run through ALA, CoSN, and AASA.
What makes a filing count
Attack the factual premise, with your own numbers. The FCC's central empirical claim is that E-Rate has finished its job because "virtually all schools report having broadband connectivity." That claim is vulnerable to specifics and nearly immune to adjectives. What lands: your actual pre-discount cost of service, your bandwidth growth curve over five years, the line item that would appear in your budget if the discount vanished, how many bids you received on your last RFP, what Category Two actually bought. District-level dollar figures are the raw material a court later looks at.
Engage the legal argument, don't just object to it. The adopted item grew about fifteen paragraphs over the draft, almost entirely to build a defense of the Commission's authority to ask the sunset question (¶¶13–19). Filings that assert "the FCC can't do this" without meeting that reasoning leave the record one-sided on the exact issue most likely to be litigated. If you have counsel, this is where they earn their fee.
Answer the boring questions too. Sunset may be the headline, but the changes most likely to actually happen are the re-basing of the discount matrix from school-lunch eligibility to cost of service, narrowing of eligible services (special construction, dark fiber, MIBS), CIPA expansion beyond school-owned devices, consultant registration with a ban on percentage-of-award fees, and tighter Lowest Corresponding Price enforcement. If the community only files "don't kill the program," it cedes the record on everything that will realistically change. For service providers, LCP and the consultant-fee rules hit your business model directly and almost nobody outside the industry will comment on them.
Use the reply round. November 12 is badly underused. Read what's filed on October 13, find the weakest claims on the other side, and rebut them specifically.
File ex parte. This is permit-but-disclose, so you can meet with Wireline Competition Bureau staff and commissioners' offices — including after comments close — as long as you file a notice afterward. Gomez already dissented; the audience that matters is the majority's staff and the Bureau. Meetings from actual districts and actual carriers read differently than association filings.
Outside the docket
Congress is the other lever, because the FCC's whole argument is about what §254 does and doesn't require. Letters to your full delegation, oversight pressure, and authorizing language all work on that. Congressional pressure demonstrably moved E-Rate policy in 2025 — in the direction of cuts, via the CRA vote on hotspots — so the channel is live in both directions.
Also worth ten minutes: Funds For Learning's annual applicant survey, whose summary statistics go straight to the FCC and USAC. And state E-Rate coordinators and state library agencies can aggregate statewide data no single applicant can produce.
Regardless of how it turns out
Two things are worth doing now because they're cheap and they hedge: build a CIPA compliance file you can produce on demand (your actual internet safety policy, notice and hearing records, filter configuration, monitoring logs), and move any percentage-of-award consultant fee arrangements to flat or hourly. Both are explicitly on the table, and early compliance costs less than retrofitting.
Meanwhile, keep filing normally — FY2027 procedures haven't changed, and any real rule changes realistically land at FY2028 or later.
One caveat: I'm not a lawyer, and if your entity has counsel, formal filings should route through them.
AES erate Campaign kit: https://mcusercontent.com/7eb0df7b9383a96775658494e/files/ddcb9c28-06af-f41c-fe2b-58ac19b487f2/Save_E_Rate_Campaign_Kit.docx
Sources: Federal Register notice · SHLB Save Our E-Rate · SHLB filing instructions · ALA campaign launch · AESA take action · ErateSync on FCC 26-41 changes · ErateSync compliance guidance · Funds For Learning 2026 applicant survey
