SIIA’s comments on E-Rate screen time policy urge the FCC to preserve reliable broadband funding and leave instructional technology decisions with local educators. Filed in response to the Commission’s Notice of Proposed Rulemaking on children’s screen use, the comments oppose conditioning E-Rate eligibility on compliance with federal screen time limits.
E-Rate screen time decisions should remain local
SIIA argues that the FCC lacks statutory authority under Section 254 to impose these conditions. Educators, administrators, and school boards are best positioned to decide how technology supports instruction in their communities. A uniform federal mandate would replace that local judgment with a single approach to very different student needs and classroom settings.
The Schools and Libraries E-Rate program provides funding toward eligible connectivity services. SIIA urges the Commission to keep that broadband mission at the center of the program. The comments distinguish the question of access to reliable internet service from decisions about when and how students use digital learning tools.
Protecting purposeful educational technology
The comments also challenge the NPRM’s framing of education technology. SIIA emphasizes that purpose-built ed tech differs fundamentally from passive consumer technology. The comments point to existing protections under FERPA, COPPA, and CIPA as part of the framework governing student privacy and safe technology use.
SIIA also contends that the NPRM misreads or selectively cites the research record, including OECD and JAMA studies. In SIIA’s view, those studies affirm the benefits of structured educational technology use. Evaluating technology by its educational purpose and the way it is used provides a more useful basis for classroom decisions than treating all screen use alike.
Blanket restrictions could harm students who rely on digital tools for personalized learning, special education services, and assessment readiness. SIIA’s position is that E-Rate screen time policy should preserve those opportunities while allowing schools to make informed choices about instruction. The comments call for stable broadband support and respect for the people responsible for meeting students’ learning needs.
Learn more about SIIA’s education technology work and its focus on the role of digital tools in education.