American Library Association advances libraries’ role in digital equity as FCC shapes Learn Without Limits programs

In these comments to the Federal Communications Commission, the American Library Association affirms support for including Wi-Fi hotspots and services in the E-rate program, ALA urges the FCC to:

• Balance the program goals, including protections against waste, fraud, and abuse, with the equitable distribution of funds and minimal administrative burden, especially regarding data collection and recordkeeping. Seek alternative data solutions for determining need. Program goals and any metrics developed to assess the impact of Wi-Fi hotspot lending through E-rate must allow for local variation and library patron privacy constraints.
• Establish rules that are not contrary to state or local patron privacy laws and library best practices in safeguarding patron privacy.
• Find that the Children’s Internet Protection Act (CIPA) does not apply to the use of off-premises patron-owned devices. Find that CIPA does not apply to library-owned computers when a library receives E-rate only for Wi-Fi hotspots for off-site use and is not receiving any E-rate funds for its in-building internet access or internal connections.
• Give applicants maximum flexibility to determine the most cost-effective and efficient solutions to provide off-site internet connectivity.