Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

We encourage the Commission to permit schools and libraries to implement cybersecurity measures that best fit their needs, including measures recommended by the Cybersecurity and Infrastructure Security Agency (CISA) and the Department of Education (ED). [...] The Commission requested comment on whether it should “specify eligibility in terms of general criteria rather than as a list of specific technologies” regarding the services and equipment eligible for support under the Pilot Program.2 We urge the Commission to implement the former. [...] The Commission also seeks comment on what types of entities should be allowed to participate in the Pilot Program.12 A key purpose of the program is to obtain valuable data about the current cybersecurity practices of K-12 schools and libraries and to help the Commission 7 See Comment of Crown Castle Fiber LLC, WC Dkt. [...] The Commission seeks comment on the “scope of the Commission’s authority to impose CIPA requirements on third-party devices that may connect with school- or library-owned broadband networks.”23 The Commission has previously determined that CIPA does not extend to the use of third-party owned devices,24 and holding otherwise would fundamentally exceed the Commission’s jurisdiction under CIPA.25 bre. [...] We urge the Commission to define eligible support through general criteria rather than specific technologies, promote inclusivity by involving a diverse range of entities from the E-Rate Program in the Pilot Program, recognize that cybersecurity and privacy are complementary goals, ensure safeguards for student privacy where CIPA applies, and implement the Pilot Program for a year to accommodate t.