E-Rate Comments: How Schools Can Make Their Case

E-Rate comments do not need to sound like legal briefs to be useful.

A superintendent, technology leader, librarian, educator, parent, or community member can make a meaningful contribution by explaining what reliable connectivity costs locally, what E-Rate helps cover, and what would happen if that support changed.

Those details matter because the Federal Communications Commission is reviewing whether E-Rate should continue in its current form, be narrowed or restructured, or potentially end. The agency is also considering questions involving children’s online safety, screen time, program administration, and the services eligible for support.

National statistics can show how many schools have broadband. They cannot show which district has only one realistic provider, which library depends on aging network equipment, or which school would have to delay another priority to pay a larger internet bill. Local comments give the FCC that missing context.

Gather the Local Facts

Before drafting, collect a few pieces of information that show how E-Rate works in the community. CoSN’s Guide to Filing E-Rate Comments with the FCC recommends using local examples rather than relying only on broad statements.

Useful details may include:

• The number of students, schools, or library locations served and the organization’s E-Rate discount rate
• The support received in recent years and the estimated cost without it
• The internet service, wireless access points, switches, cabling, or other eligible infrastructure supported through the program
• The number of realistic providers serving the community and any local connectivity challenges
• A planned upgrade or replacement project that could be delayed if support were reduced

The Save Our E-Rate campaign includes a lookup tool that can help schools and libraries review their recent E-Rate funding information. Local business offices and technology departments may also have application records, funding commitments, invoices, and project plans that provide useful context.

Not every comment needs every number. One accurate cost, one clear example, and one realistic consequence can say more than several paragraphs of general support.

Explain the Budget Consequence

“E-Rate is important” is true, but it does not tell the FCC what is at stake.

A more useful comment explains what the district would do if its share of connectivity costs increased. Would it postpone replacing wireless equipment? Reduce bandwidth? Redirect money from staffing, transportation, curriculum, or building needs? Would smaller or more remote schools be affected first? Could the community obtain comparable service from another provider?

The answer does not require a complicated financial model. A reasonable estimate and a straightforward explanation are enough.

For example, a district could explain that E-Rate helps support the wireless network used for instruction, accessibility tools, online assessments, family communication, and administrative systems. It could then identify the project or budget area that would be placed at risk if more of that cost shifted locally.

Respond to What You Know

The FCC’s Notice of Proposed Rulemaking asks many questions. A school district or library does not need to answer all of them.

Technology leaders may be best prepared to address network capacity, equipment replacement, provider competition, filtering, or procurement. Superintendents and school business officials may focus on budgets and operational consequences. Educators and families may speak to accessibility, classroom use, local screen-time decisions, or the difference between school-managed devices and personal phones.

Comments are stronger when people stay close to what they know. Repeating a form letter may add volume to the record, but a local example adds information.

Build a Clear Comment

State the main position early so the reader does not have to search for it. A district might ask the FCC to preserve E-Rate’s core mission, maintain support for external connectivity and internal networks, or avoid tying broadband discounts to federal rules governing classroom screen time. A library might focus on public internet access, community services, or the difficulty of replacing E-Rate with local revenue.

The rest of the comment can follow five steps:

1. Introduce the community. Briefly describe the district, school, library, or organization and the people it serves.
2. State the position. Explain what the FCC should preserve, change, or avoid changing.
3. Describe how E-Rate is used. Include one or two local facts about costs, services, infrastructure, or provider options.
4. Explain the consequence. Describe what would happen if support were reduced, narrowed, or eliminated.
5. Make a specific request. End by telling the FCC what action the commenter wants it to take.

Use a professional, plainspoken tone. A comment can support student safety and responsible technology use while explaining that instructional decisions are best made locally by educators, school leaders, boards, and families.

Review Before Filing

FCC comments become part of the public record. Do not include student information, detailed security configurations, confidential contract terms, personal contact information beyond what the filing system requires, or anything else that should not be publicly available.

Someone submitting on behalf of a district or library should also follow the organization’s normal approval process. Depending on local practice, that may include review by the superintendent, board, legal counsel, communications team, or governing authority.

Before filing, confirm that all figures are accurate, the organization’s position is clear, and the correct document is attached.

How to Submit E-Rate Comments

Comments can be filed through the FCC’s Electronic Comment Filing System. The proceeding includes WC Docket Nos. 26-133, 13-184, 21-93, and 21-455.

The FCC provides two electronic options:

• Standard Filing allows the filer to upload a prepared document, such as a Word file or PDF.
• Express Comment allows the filer to type or paste a shorter statement directly into the system.

For an initial submission, select the appropriate comment filing type and confirm that the filing is associated with the correct proceeding. Review the filer information and attachment before submitting, then save the confirmation.

Initial comments are due October 13, 2026. Reply comments are due November 12, 2026. Reply comments allow participants to respond to arguments or information submitted during the initial comment period.

Take Action

• Read CoSN’s filing guide
• Visit the Save Our E-Rate campaign
• Contact elected officials through CoSN’s Action Center
• Submit comments through the FCC

For additional background, listen to the CoSN Podcast episode Why E-Rate Still Matters: The Case for Action, produced and distributed in partnership with edCircuit.

The FCC already has national data and legal arguments. It still needs to know what a change would mean for individual schools and libraries.

Local leaders can provide that answer by explaining what E-Rate supports, what their communities would face without it, and what they want the FCC to do next.

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