Stacy Hawthorne’s recent piece for CoSN, “Before a Single Student Logs On,” begins at 5:30 in the morning, when the buses start their routes. Over the next two and a half hours, in her account, the school network routes those buses and feeds the tracking apps parents check from their kitchens, brings the heating and ventilation online, unlocks the doors and screens visitors against offender registries, processes breakfast transactions that become federal meal-reimbursement claims, and sends attendance into the state reporting systems that funding formulas depend on. Not one student has opened a device. Anyone who has run a district network will recognize that morning, and I suspect most people who have not will be surprised by how much of it there is.
Hawthorne wrote the piece because the Federal Communications Commission has opened what it calls a “top-to-bottom” review of E-rate, the program that has paid a discounted share of internet access and internal networks for schools and libraries since the late 1990s. The Notice of Proposed Rulemaking the Commission adopted on June 25 (FCC 26-41) asks whether the program should “be limited or sunset to reflect today’s extensive connectivity rates” (¶12), whether support should be limited to rural areas or to areas served by a single provider (¶26), and whether some currently eligible services are “no longer necessary” (¶21). It also asks whether schools should be required, as a condition of receiving E-rate support, to give parents a way to opt their children out of screen-based instruction (¶31). Initial comments are due October 13, and reply comments are due November 12.
It is worth being precise about what has and has not happened. The June vote did not end the program, and the chief of the FCC’s Wireline Competition Bureau has written that no school or library will lose support as a result of it. Much of the Notice consists of questions rather than proposed rules, a point Jon Bernstein of the Education and Libraries Networks Coalition made at the AASA town hall that Julia Gilban-Cohen covered for GovTech. But questions in a rulemaking are not idle. They shape the range of orders the Commission can later adopt, and the record that districts and libraries build between now and November is the record the Commission will draw on when it acts.
Where I stand
I should say plainly where I stand, because it complicates what follows. I write critically about screens and AI in classrooms, and I have argued elsewhere that screen time is often the wrong question; the more useful questions concern what the assigned work asks students to do, how platforms are designed to hold attention, and who bears the cost when a tool substitutes for thinking rather than supporting it. I approach educational technology from a declared technoskeptical disposition, not from neutrality. So I read Chairman Carr’s statement, which ties a decade of rising classroom screen time to declining reading and math scores and draws on the Surgeon General’s 2026 advisory on screen use, with more sympathy than many of my colleagues in district technology might expect.
The concern is real. The associations Carr cites deserve careful reading rather than dismissal, even though they do not establish that school devices caused the declines, and the families who cut screen time at home only to watch it rise at school are raising a legitimate question about who decides how learning happens. Where I part ways with the Notice is not on whether that question matters but on where it is being asked.
The wrong layer
In the framework I am developing around pedagogical friction, three learner-facing dimensions rest on an infrastructural base, the systems, policies, access, and enabling conditions that make any kind of learning possible in the first place. E-rate funds a narrow and literal slice of that base. It pays a discounted share of the connection into the building and of the switches, access points, and cabling inside it. It does not buy devices, software, or curriculum. The decisions that determine how much of a school day happens on a screen, and what students are asked to do there, are made above that layer, by teachers, curriculum leaders, principals, and local boards.
Seen that way, the Notice asks an infrastructural program to answer a pedagogical question. What would a sunset actually change? The buses would still need routing, the doors would still need to lock during a lockdown, and the 911 call from a classroom phone would still need to carry a dispatchable location under Kari’s Law and RAY BAUM’s Act. A sunset would not, by itself, change what a second grader is asked to do on a tablet. If it changed classroom practice at all, it would do so by making every networked system in the building harder to afford, which is a blunt instrument for a pedagogical goal.
The network would not go away; its cost would move from a federal discount onto local budgets. Because E-rate discounts run from 20 to 90 percent according to student poverty and rural status, that shift would likely fall hardest on the districts that now receive the deepest discounts. LaTonya Goffney, superintendent of Aldine ISD in Texas, told the same AASA town hall that the district received $11 million in E-rate support over five years and could not absorb its loss “without affecting people,” as Stateline reported. Better-resourced districts would probably find the money somewhere. The districts least able to absorb the cost serve the students with the most at stake.
The opt-out question makes the category error easiest to see. Whether a family should be able to decline screen-based instruction is a serious question, and I think many districts need better answers to it than they have. Making that answer a condition of connectivity funding, however, would let a telecommunications subsidy set instructional policy, and it would do so through the same lever that carries the lockdown system and the attendance record. Commissioner Gomez’s partial dissent names a related contradiction: an administration that has made AI literacy a national priority is now asking whether schools still need the connectivity required to teach it.
What I am asking colleagues to do
Commissioner Trusty, who voted to open the review, used the statement accompanying that vote to invite E-rate advocates to explain how the program can focus on the most pressing connectivity needs of schools and libraries. That invitation is worth accepting, and Hawthorne’s advice about how to accept it is the best I have read. The most useful filing, she suggests, is not an argument but an accurate account of what the network carries and what losing the funding would mean.
If you have one minute, start with CoSN’s Tell Congress page. It asks for your name, address, and email, and sends a pre-written letter to your members of Congress urging them to protect E-rate. It does not file in the FCC docket, but it is the easiest thing anyone reading this can do today.
If you lead technology, a library, or a school and have a little more time, four steps will get that account into the record:
- Find your number. The AASA funding map shows each district’s and library’s E-rate commitments for FY2021 through FY2025. Search by ZIP code.
- Write down what your network carries before the first bell. Use your own systems and your own examples. Specific local facts carry more weight than any template.
- File in WC Docket No. 26-133 by October 13. Comments go through the FCC’s Electronic Comment Filing System. SHLB has templates and step-by-step instructions, and an express comment can be a few paragraphs.
- Tell your congressional delegation, and sign on. If you skipped the one-minute letter above, send it now through CoSN’s Tell Congress page; libraries can use the Save Our E-Rate tools. CoSN also has a petition. Illinois districts can get free help from the Learning Technology Center’s State E-Rate Coordinator.
To make those steps easier, I built a tracker, Before the Bell, that gathers the FCC’s own documents, the reporting, and the advocacy tools in one place. It quotes the Notice’s key questions with paragraph numbers so they can be cited directly, keeps the Commission’s own position visible alongside its critics, and includes a worksheet that turns a checklist of your network’s systems into a comment starter you can edit. The worksheet runs entirely in your browser, and nothing you type is sent anywhere.
Skepticism aimed at the right layer
Technoskepticism, as I use the term, is a disposition of asking what a technology does, whom it serves, and who bears its costs, rather than a reflex against technology as such. Applied to the classroom, those questions lead to hard and necessary conversations about screens, platforms, and the kinds of thinking that should remain with students. Applied to the wiring in the walls, they lead somewhere simpler. The network is load-bearing, and the case for keeping it affordable does not depend on believing that every minute students spend online is well spent. It depends on recognizing that the building runs on it before anyone logs on at all.
Sources
Calascione, J. (2026, July 29). Report cards and diplomas: Progress in meeting the goals of the E-Rate program. Federal Communications Commission. https://www.fcc.gov/news-events/blog/2026/07/29/report-cards-and-diplomas-progress-meeting-goals-e-rate-program
Carr, B. (2026, June 25). Statement of Chairman Brendan Carr (FCC 26-41). Federal Communications Commission. https://docs.fcc.gov/public/attachments/FCC-26-41A2.pdf
Federal Communications Commission. (2026). Ensuring children’s safe use of screens and E-Rate-funded services (FCC 26-41, WC Docket No. 26-133) [Notice of proposed rulemaking and further notice of proposed rulemaking]. https://www.fcc.gov/document/fcc-review-e-rate-program-ensure-congresss-vision
Gilban-Cohen, J. (2026, September 10). School leaders mobilize as FCC weighs future of E-Rate. GovTech. https://www.govtech.com/education/k-12/school-leaders-mobilize-as-fcc-weighs-future-of-e-rate
Gomez, A. M. (2026, June 25). Statement of Commissioner Anna M. Gomez, dissenting in part (FCC 26-41). Federal Communications Commission. https://docs.fcc.gov/public/attachments/FCC-26-41A3.pdf
Hawthorne, S. (2026, July 30). Before a single student logs on. CoSN. https://www.cosn.org/before-a-single-student-logs-on/
Miner, M. (2026). Before the bell: E-rate tracker [Interactive tracker]. GitHub. https://minerclass.github.io/erate-tracker/
Sequeira, R. (2026, September 10). Schools, libraries sound alarm over potential changes to federal internet program. Stateline. https://stateline.org/2026/09/10/schools-libraries-sound-alarm-over-potential-changes-to-federal-internet-program/
Trusty, O. (2026, June 25). Statement of Commissioner Olivia Trusty (FCC 26-41). Federal Communications Commission. https://docs.fcc.gov/public/attachments/FCC-26-41A4.pdf