In the Matter of Ensuring Children's Safe Use of Screens and E-Rate-Funded Services; FCC WC Docket No. 26-133

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of

Ensuring Children’s Safe Use of Screens and E-Rate-Funded Services

Modernizing the E-Rate Program for Schools and Libraries

Establishing the Emergency Connectivity Fund to Close the Homework Gap

Promoting Fair and Open Competitive Bidding in the E-Rate Program

WC Docket No. 26-133

WC Docket No. 13-184

WC Docket No. 21-93

WC Docket No. 21-455

Comments of Dan Kleinman, SafeLibraries® brand library educational services

I respectfully submit these comments regarding the Commission’s top-to-bottom review of the E-Rate program. I am Dan Kleinman, owner of SafeLibraries® brand library educational services, that focuses on library policies, compliance with federal requirements such as the Children’s Internet Protection Act (CIPA), and transparency in the use of public funds. I previously filed detailed comments in WC Docket No. 13-184 (September 16, 2013) documenting concerns about E-Rate program integrity and CIPA compliance; those comments remain available at https://safelibraries.blogspot.com/2013/09/FCC.html.

E-Rate Has Outlived Its Original Purpose

The E-Rate program was established under the Telecommunications Act of 1996, at a time when Internet access (often capitalized to reflect its novelty) was expensive, limited, and unavailable to most schools and libraries. The program successfully helped close that gap. Today, however, high-speed broadband is widely available at relatively low cost through competitive private markets, widespread home and mobile adoption, and other public and private initiatives. The dramatic change in circumstances is evident even in language: what was once a specialized "Internet" service is now ordinary "internet" infrastructure; even the capitalization has changed.

In this environment, a dedicated federal subsidy program for basic connectivity in schools and libraries is no longer necessary for most communities. Continuing the program at current levels risks subsidizing services the market now provides efficiently, potentially distorting competition and creating ongoing administrative costs without commensurate public benefit.

Program Integrity, CIPA Compliance, and the Role of the American Library Association

E-Rate funding has long been conditioned on compliance with CIPA, which requires libraries and schools to implement technology protection measures to block obscene material, child p*rnography, and material harmful to minors. Despite these requirements, significant compliance issues have persisted. My 2013 filing documented multiple examples of libraries receiving E-Rate funds while maintaining policies or practices that undermined CIPA protections—such as easily bypassed filters, patron self-unblocking systems, and ALA-influenced guidance that treated filtering as optional or constitutionally suspect. These practices effectively allowed federal funds to flow to institutions that did not fully meet the statutory conditions.

The American Library Association (ALA) has historically provided policy guidance and training to libraries that, in practice, facilitated non-compliance or minimized CIPA’s requirements. With connectivity costs largely covered by E-Rate, libraries have greater flexibility to direct local resources and staff time toward other priorities.

Current Advocacy and Use of Funds

The ALA is currently conducting a coordinated national campaign titled "Save Our E-Rate," that urges libraries, schools, and the public to file comments and contact Congress in support of preserving the program. While advocacy is legitimate, the campaign appears designed to maintain the existing funding stream and even characterizes FCC's current actions as "overreach." Critics reasonably question whether these funds indirectly support the ALA’s broader institutional priorities rather than strictly educational connectivity.

With E-Rate subsidizing infrastructure, libraries have been able to allocate resources to programs and collections that many parents and communities consider inappropriate for children. One prominent example is Drag Queen Story Hour events "sneakily" hosted in public libraries, as American Library Association itself details here: https://web.archive.org/web/20170612040326/https://www.ala.org/advocacy/intersections-glbt-book-month-dispatch-small-town-librarian. 

Dr. James Lindsay has analyzed these programs in detail in "Groomer Schools 4: Drag Queen Story Hour," available at https://newdiscourses.com/2022/06/groomer-schools-4-drag-queen-story-hour/, describing them as vehicles for introducing queer theory and gender ideology to young children under the guise of storytelling and inclusion. Many families view such events as ideological rather than educational. As Dr. Lindsay points out, that's the very purpose of such events. He cites to the writings of Lil Miss Hot Mess, "a performer and board member for Drag Queen Story Hour, and the author of the children’s book The Hips on the Drag Queen Go Swish, Swish, Swish (Running Press Kids, 2020)."  See "Drag Pedagogy: The Playful Practice of Queer Imagination in Early Childhood," in the journal Curriculum Inquiry here: https://doi.org/10.1080/03626784.2020.1864621. "Through this programme, drag artists have channelled their penchant for playfully '"reading" each other to filth' [footnote omitted] into different forms of literacy, promoting storytelling as integral to queer and trans communities, as well as positioning queer and trans cultural forms as valuable components of early childhood education" "We’re reading books while we read each other’s looks, and we’re leaving a trail of glitter that won’t ever come out of the carpet."

Similarly, initiatives such as "Books Unbanned" (promoted in alignment with ALA principles) provide teens nationwide with digital access to books that local school boards and libraries have removed or restricted—often titles containing explicit s*xual content, profanity, or contested gender and s*xuality themes. While framed as defending intellectual freedom, these programs effectively create a national distribution channel that can bypass local community standards and parental oversight.

Recommendation

The E-Rate program has served its historic purpose. Given the maturity of the broadband market, persistent questions about program integrity and CIPA enforcement, and the diversion of attention and resources toward controversial, non-educational programming, I respectfully urge the Commission to phase out or substantially narrow E-Rate support for libraries. If any funding continues, it should be strictly limited to truly unserved or underserved areas, subject to rigorous independent auditing, verifiable CIPA compliance (with librarian-controlled filtering and transparent enforcement), and clear demonstration that funds support core educational objectives rather than subsidizing ideological or age-inappropriate content.

Thank you for the opportunity to comment and for the Commission’s attention to these important issues of child protection, fiscal responsibility, and program effectiveness.

Respectfully submitted,

Dan Kleinman

SafeLibraries® brand library educational services

@OccupyLibraries

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