According to a news release, the Consortium for School Networking (CoSN), along with several other education organizations, jointly filed a letter with public comments in response to a request by the FCC’s Wireline Competition Bureau for input on the matter. They argue that the ongoing series of cyber attacks against schools warrant a major policy update for E-rate funding, which is traditionally used to help schools and libraries access Internet and telecommunication services. CoSN’s news release said K-12 schools are in need of next-generation firewall tools, as well as a “minimally burdensome” application process for E-rate IT security funding uses.
“Cyber attacks on schools disrupt learning, compromise sensitive student and teacher data, and waste millions of limited public resources. Modernizing E-rate to support modern firewalls will help schools — especially schools located in our highest poverty communities — protect themselves,” CoSN CEO Keith Krueger said in a public statement. “Firewalls are not the entire solution, but they are one key piece of the cybersecurity puzzle.”
The news release said CoSN was joined by the State Educational Technology Directors Association (SETDA); the Council of Chief State School Officers (CCSSO); the Council of the Great City Schools (CGCS); the Schools, Health & Libraries Broadband (SHLB) Coalition; the State E-rate Coordinators’ Alliance (SECA); the National Association of State Boards of Education (NASBE); the National School Boards Association (NSBA); All4Ed; the Center for Democracy and Technology (CDT); and the Benton Institute for Broadband & Society.
“This needed program update serves a vital educational purpose, and will help to ensure continuous, uninterrupted broadband connectivity,” the letter read. “The benefits this improvement will deliver to schools and libraries far outweigh the limited related costs and can be accomplished well within the program’s aggregate cap which has vastly exceeded applicant demand since at least 2019.”
While not among the signatories, the Cybersecurity and Infrastructure Security Agency (CISA) released its own advisory in January recommending increased investments in K-12 IT security to address “resource constraints,” pointing out that the education sector remains a favorite target for cyber criminals.
Penn Manor School District — one of the districts that submitted comments with the coalition — urged the FCC to take CISA’s recommendations into account. In another, separate submission to the FCC, the Michigan Educational Technology Leaders argued that, while the FCC has been reluctant to broaden eligibility for funding for advanced firewall solutions, its modernization orders for E-rate in 2014 laid the groundwork for doing so.
“Since its inception, the E-rate program funded equitable access to broadband service in support of educational entities and the wider communities they serve,” METL wrote. “Access to stable and secure broadband connection is essential to educators and students alike. The rise of cyber attacks has resulted in a great deal of loss. Students have lost instructional time due to crashed school networks; students, staff, and patrons have had important personal data stolen and posted to the dark web; and millions of dollars have been paid to bad actors in efforts to recover lost data. Broadband Internet service is a necessity for the daily operation of schools and libraries in support of students and their communities.”
The American Library Association expressed similar sentiments, saying they’ve long supported proposals to expand E-rate eligibility to address network security needs along with CoSN, who has also stressed the need for such eligibility in recent years.
“On the timing of eligibility, we think the commission has sufficient time to conduct all the necessary background work to make all security tools eligible for the July 1, 2024, funding year,” ASA’s comments read. “It is important to note that basic firewalls have been eligible since the program’s inception. Thus, from this perspective, we see adding the eligibility of next-generation firewalls and services as just an extension of the current firewall eligibility.”
Stressing the need to streamline the funding process and update its stipulations, the Wisconsin Department of Public Instruction said its officials “hope the commission will move in an expeditious manner to make all firewalls and security tools E-rate eligible.” The Connecticut Commission for Educational Technology agreed, adding that an increase in the annual funding cap for the E-rate program would likely not be needed for policy updates.
