Joint Comments Urge Immediate Update to E-Rate Firewall Definition and Additional Funding to Address Urgent Need for Stronger Cybersecurity Protection

Washington, D.C. (January 31, 2024)  A coalition of leading education, library and other nonprofits filed comments with the Federal Communications Commission (FCC) responding to the FCC’s Notice of Proposed Rulemaking (NPRM), which proposed a three-year, $200 million Cybersecurity Pilot Program.

The coalition includes the Consortium for School Networking (CoSN), SETDA, the Schools, Health & Libraries Broadband (SHLB) Coalition, the American Library Association (ALA), the Council of the Great City Schools, the National School Boards Association (NSBA), the Council of Chief State School Officers (CCSSO), All4Ed, the National Association of State Boards of Education (NASBE), Common Sense Media, Link Oregon and Pacific Northwest Gigapop.

The FCC’s proposed Pilot Program aims to fortify the security and protection of E-Rate-funded broadband networks and data, recognizing the need for enhanced cybersecurity measures in schools and libraries across the nation. The coalition comments point out that modernizing the E-Rate firewall definition now, based on the 2022 firewall rulemaking, will provide near-term help to schools and libraries while the Pilot Program gathers additional information to guide future cybersecurity policy improvements.

“K-12 school systems have become ‘the playground of cyber criminals,’ according to a recent report from S&P,” said Keith R. Krueger, CEO of CoSN. “Strengthening cybersecurity protection through the E-Rate program and separately launching the Pilot Program are absolutely imperative. These are critical first steps towards protecting our schools’ broadband networks and safeguarding the vast amounts of personal information they store.”

“In the face of rising cyber threats, the $200 million Cybersecurity Pilot Program is vital, bolstering the integrity of our educational and library institutions,” said Julia Fallon, Executive Director of SETDA. “The modernization of the E-Rate firewall definition will provide immediate support while establishing a resilient foundation for future-proof cybersecurity policies. Ensuring swift defense enhancements for schools and libraries, particularly those in critical need, would also provide essential data for informed policy improvements.”

“The escalating cyber threats targeting schools and libraries demand urgent action. While we support the proposed Cybersecurity Pilot Program as a decisive step toward fortifying the digital defenses of anchor institutions, we also recommend updating the definition of firewalls immediately and shortening the Pilot Program to 18 months to provide rapid relief to these vulnerable institutions,” said John Windhausen, Executive Director of SHLB. “The FCC can update the E-Rate program’s firewall definition now to include advanced features and provide an additional $200 million in supplemental Category Two funding for E-Rate applicants to use in 2024 and 2025.”

“Cyberattacks present a triple threat for our nation’s schools and libraries,” said Verjeana McCotter-Jacobs, Executive Director and CEO of the National School Boards Association. “Cyberattacks shut down computer networks, resulting in lost learning time for students and financial losses to districts, but they can also put the personal data of students and school employees at risk, potentially resulting in the theft of social security numbers, birth dates and other private information.”

Read the full comments on the Cybersecurity Pilot Program here.

About CoSN
CoSN, the world-class professional association for K-12 EdTech leaders, stands at the forefront of education innovation. We are driven by a mission to equip current and aspiring K-12 education technology leaders, their teams, and school districts with the community, knowledge, and professional development they need to cultivate engaging learning environments. Our vision is rooted in a future where every learner reaches their unique potential, guided by our community. CoSN represents over 13 million students and continues to grow as a powerful and influential voice in K-12 education.

About SETDA®
Founded in 2001, SETDA is the principal association representing U.S. state and territorial educational technology and digital learning leaders. Through various programs and advocacy, SETDA builds member capacity and engages partners to empower the education community in leveraging technology for learning, teaching, and school operations.

About SHLB
The SHLB Coalition is a nonprofit, 501(c)(3) advocacy organization that supports open, affordable, high-quality broadband connections for anchor institutions and their surrounding communities. The SHLB Coalition is based in Washington, D.C. and has a diverse membership of commercial and non-commercial organizations from across the United States. To learn more, visit

For CoSN: Makenzie Carlin,, 703-967-6954
For SHLB: Saskya Cabral,, 786-486-0257
For SETDA: Jonathan Yang,, 202-715-6636