Dear Ms. Dortch:

In a survey administered early in the pandemic, 52% of professionals serving blind and low vision children could not reach at least one family. Undoubtedly, one of the reasons for limited contact was limited or no access to the home internet services needed to facilitate remote education. At the American Foundation for the Blind, we are deeply concerned about the pandemic’s impact on students with disabilities and their educators who do not have sufficient internet connectivity to participate in school. In the interest of expanding blind and low vision students’ access to the remote classroom, we provide this comment supporting the petitions for emergency relief to allow the use of E-Rate funds to support remote learning during the COVID-19 pandemic.

Remote schooling is already difficult for many blind and low vision students because many of the programs used in virtual education are inaccessible to blind students, as are the paper packets that were sent home in many districts. Nevertheless, students with disabilities have a right to free, appropriate public education. Because paper packets are inaccessible to some students, and students with disabilities have a right to education, delivering effective, timely remote education often necessitates digital communication methods; thus, expanding access to internet services is undoubtedly “essential to education” and “consistent with the public interest, convenience, and necessity” to deliver on students’ rights to their education. Therefore, it is imperative to remove this fundamental barrier to remote education. Because the pandemic has revealed the depth and impact of the digital divide, AFB encourages the Commission to use all available resources to close that divide expeditiously, including providing emergency relief for the use of E-Rate funds for virtual education.

Mobilizing internet access through schools and libraries would provide students with a direct connection to the internet resources needed to access their school and allow schools to advocate on behalf of students needing internet. While the Commission invites comment on the potential for overlap between E-Rate and the Emergency Broadband Program, offering both of these programs ensures that households may independently seek broadband services for a variety of uses while schools are empowered to provide direct outreach and investment to connect students and educators with broadband that is specifically needed for providing education. During a pandemic that has closed many school buildings, effectively meeting the educational needs of students should rise to the highest priority.

Likewise, the benefit must be available as soon as possible and last for at least the length of the public health emergency. Students without reliable internet at this point in the pandemic may have already lost as much as a year of education, requiring rapid and focused attention to get them back on track. The Commission should ensure the E-Rate funds can be mobilized for remote education as quickly as possible. Thus, the application process must be simple, straightforward, and include such waivers necessary to allow funding to flow well before the end of the current school year. Additionally, the pandemic is unlikely to end soon. Funding should remain available through at least the 2021-2022 school year for those schools that continue to provide remote education. Even when most students have returned to the classroom, some students may continue to have medical reasons that prevent or discourage their participation in the physical classroom while the pandemic remains a widespread threat. To the extent that those students may need access to the internet, schools should continue to have flexibility to apply for E-Rate assistance to serve students with Coronavirus-related internet needs.

Thank you for the opportunity to comment on this important effort. Expanding the E-Rate program during the pandemic would have a significant beneficial impact on the delivery of education. We encourage the Commission to take the steps necessary to reduce the digital divide in education.

Sarah Malaier
Senior Advisor, Public Policy and Research