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Background

Home Internet Access for All Students: It’s Complicated

The FCC E-Rate program has helped our country connect 99 percent of U.S. schools, including those in rural areas, to high-speed broadband by providing dedicated funding for school building connectivity. However, while the E-Rate program helped us bring connectivity to and through our school buildings, it currently limits the use of that connectivity to the boundaries of the school campus. This means students and teachers who have access to high-speed internet at school might have limited internet access at home if that access is not accessible or affordable.

In rural communities, Internet Service Providers (ISPs) often choose not to build and maintain expensive fiber networks to geographically remote locations with low population densities due to the limited return on investment. In urban communities, there is documented evidence of “digital redlining,” where ISPs invest in building fiber infrastructure in wealthier neighborhoods, while under-investing in the broadband infrastructure in low-income communities resulting in low-income broadband users with more expensive, slower access.1 Access to consistent broadband can also be a challenge for unhoused and highly mobile families due to the lack of a permanent address.2 Further, students from low-income families are more likely to be disconnected, primarily due to issues of affordability.3 According to the 2017 Current Population Survey, 34 percent of households with children aged 3-18 and no internet cite affordability as the major reason for not having a connection.4

In communities where internet access is available and affordable, there may be other barriers limiting adoption by families that schools and other trusted community-based organizations can help address. Often, the sign-up process has not been designed to be accessible to all families and relies on applicants having fluency in the dominant language and the digital skills to successfully navigate the process. Families may also be hesitant to share personal information, like social security numbers, that can be required to secure service. These barriers may disproportionately impact English learners, children of undocumented immigrants, or students experiencing homelessness. Analysis of the U.S. Census Bureau’s Household Pulse Survey by Common Sense Media noted that efforts by states and districts to address home access for students during the pandemic may have had a greater impact on closing the digital divide for Black students as compared to the impact for Hispanic or Latino students.5

To help schools and libraries provide devices and connectivity to students, school staff, and library patrons during the pandemic, Congress established a temporary $7.2 billion Emergency Connectivity Fund as part of the American Rescue Plan Act of 2021 (ARP).6 Funding from the Emergency Connectivity Fund will be distributed to eligible schools and libraries for the purchase of eligible equipment and advanced telecommunications and information services for use by students, school staff, and library patrons at locations other than a school or library. The FCC published final rules for the program on May 10, 2021.7

Short- and Long-Term Solutions

One of the most difficult challenges of addressing home internet access for students is that the solutions are not one-size-fits all. Many districts have used emergency stimulus funding to expand their pre-pandemic solutions – lending mobile hotspots and devices to students, parking school buses in poorly connected neighborhoods to create Wi-Fi hotspots, and extending Wi-Fi to school parking lots so students and families can park and use the internet. Other districts have adopted a sponsored service model to temporarily cover the cost of monthly home internet subscriptions for students.8 A January 2021 report from Common Sense Media found that efforts made by states and districts during the pandemic succeeded in temporarily narrowing the digital divide for students from an estimated 15 to 16 million students in June 2020 to approximately 12 million under connected students in December 2020. The report notes, however, that, “more than 75% of state and local student digital divide efforts will expire in the next one to three years.”9,10

Wi-Fi Hotspots are locations, such as an airport or coffee shop, where people can wirelessly connect their device(s) to the internet using Wi-Fi via a wireless local area network (WLAN). A mobile or portable hotspot uses the smartphone’s data connection to connect or “tether” their device(s) to the internet.

Other school districts are increasingly considering the feasibility of building off-campus Wi-Fi networks as a long-term, sustainable solution to addressing the lack of affordable, high-speed internet access within the homes of many students.

An Out-of-School or Off-Campus Wi-Fi Network is a school-owned Wi-Fi network that provides free, basic wireless internet access to the homes of students or other community sites often in neighborhoods with the greatest need.

Prior to the pandemic, some school districts were already exploring the use of spectrum to deploy off-campus Wi-Fi networks to connect students lacking internet access at home. Spectrum refers to the radio frequencies that wireless signals travel over and supports wireless communication.11 Districts, including those highlighted in this brief, have used several spectrum bands, including the Citizens Broadband Radio Service (CBRS) spectrum, the 2.5GHz (formerly Educational Broadband Service (EBS)) spectrum, and TV White Space (TVWS).

Citizens Broadband Radio Service Spectrum

In April 2015, the FCC established the CBRS by opening up 150 MHz of spectrum in the 3.5 GHz to 3.7 GHz band that was previously reserved for military and other government-approved uses. The FCC has authorized sharing of the CBRS among three tiers of users: incumbent users, priority access license (PAL) users and general authorized access (GAA) users. Tier 1 incumbent users such as the federal government, fixed satellite users, and grandfathered wireless users receive top priority and are protected from interference by other users. Priority Access License (PAL) users are licensed users who acquire spectrum licenses through an FCC auction. General Authorized Access (GAA) users can use any CBRS spectrum not used by PAL holders or the protected incumbents; however, GAA users do not receive interference protection.12

2.5 GHz Band (formerly EBS Spectrum)

Until recently, the former EBS service was the only licensed spectrum available specifically for educational institutions.13 Educational institutions that hold a license in this band can choose to self-deploy a wireless network or lease their excess spectrum to provide low-cost or free mobile internet to schools and low-income households while maintaining provisions for educational use. This spectrum has been leveraged to build county-wide wireless broadband networks for schools and residents often resulting in affordable access to broadband where it was not previously available or too costly to adopt. After licensing of unused spectrum in the former EBS service was frozen in 1995, a few educational institutions were granted waivers by the FCC for new licenses; however, districts and other educational institutions that do not currently hold an existing license may be unable to obtain a new license. In July 2019, the FCC determined that, following a priority window for tribal entities to obtain unassigned 2.5 GHz spectrum over their rural tribal lands, any remaining unassigned 2.5 GHz spectrum in this service will be made available for commercial use via competitive bidding.14 District leaders can check with local educational institutions or organizations, such as community colleges, community organizations, and local government to see who may hold any existing license(s) in their community and whether they are currently being leased.  To the extent the 2.5 GHz spectrum is being leased, it may not be available for the types of projects discussed in this document.

White Space

White space refers to the unused gaps between active TV channels in the VHF and UHF spectrum bands as well as available spectrum in the adjacent 600 MHz Band Service. White Space devices may operate in the 54 MHz to 88 MHz (VHF-TV channels 2-6), the 174 MHz to 216 MHz (VHF-TV channels 7-13) and the 470 MHz to 698 MHz spectrum bands. 15 These “buffer” channels in the TV band were left vacant to prevent interference between adjacent TV channels; however, due to advancements in technology these “white spaces” are no longer needed. Wireless internet that uses white space can travel up to 10 kilometers, through mountainous terrain, forests, and other obstacles. In October 2020, the FCC amended its rules governing unlicensed wireless services provided to allow expanded use of white space devices for the delivery of broadband services in rural and underserved communities while protecting broadcast television stations and other licensed services from interference.16


  1. Electronic Frontier Foundation: https://www.eff.org/deeplinks/2021/01/fcc-and-states-must-ban-digital-redlining
  2. Shapiro, E., & Brittainy Newman. (2019, Nov. 19). 114,000 Students in N.Y.C. Are Homeless. These Two Let U.S. into Their Lives. The New York Times. Retrieved from www.nytimes.com/interactive/2019/11/19/nyregion/student-homelessness-nyc.html.
  3. Ali, T., Chandra, S., Cherukumilli, S., Fazlullah, A., Hill, H., McAlpine, N., McBride, L., Vaduganathan, N., Weiss, D., Wu, M. (2021). Looking back, looking forward: What it will take to permanently close the K–12 digital divide. San Francisco, CA: Common Sense Media. https://www.commonsensemedia.org/sites/default/files/uploads/kids_action/final_-_what_it_will_take_to_permanently_close_the_k-12_digital_divide_vjan26_1.pdf. Students from families with annual household incomes of less than $50,000 are approximately 30% of the overall K–12 population yet account for more than 50% of all disconnected students.
  4. NCES. The Condition of Education. Children’s Internet Access at Home: https://nces.ed.gov/programs/coe/indicator_cch.asp
  5. Ali, T., Chandra, S., Cherukumilli, S., Fazlullah, A., Hill, H., McAlpine, N., McBride, L., Vaduganathan, N., Weiss, D., Wu, M. (2021). Looking back, looking forward: What it will take to permanently close the K–12 digital divide. San Francisco, CA: Common Sense Media. https://www.commonsensemedia.org/sites/default/files/uploads/kids_action/final_-_what_it_will_take_to_permanently_close_the_k-12_digital_divide_vjan26_1.pdf
  6. American Rescue Plan Act, 2021, H.R. 1319, 117th Cong., tit. VII, § 7402 (2021) (enacted), available at https://www.congress.gov/bill/117th-congress/house-bill/1319/text  
  7. FCC. (2021). WCB seeks Comment on Emergency Connectivity Fund to Close Homework Gap: https://www.fcc.gov/document/fcc-launch-717-billion-connectivity-fund-program-0.
  8. EducationSuperHighway. An Introduction to Sponsored Service. https://www.educationsuperhighway.org/a-guide-to-sponsored-service/
  9. Ali, T., Chandra, S., Cherukumilli, S., Fazlullah, A., Hill, H., McAlpine, N., McBride, L., Vaduganathan, N., Weiss, D., Wu, M. (2021). Looking back, looking forward: What it will take to permanently close the K–12 digital divide. San Francisco, CA: Common Sense Media. https://www.commonsensemedia.org/sites/default/files/uploads/kids_action/final_-_what_it_will_take_to_permanently_close_the_k-12_digital_divide_vjan26_1.pdf
  10. 2 CFR § 200.313 Equipment – Code of Federal Regulations (ecfr.io) https://ecfr.io/Title-2/Section-200.313
  11. CTIA. (2018). What is Spectrum? An Explainer. https://www.ctia.org/news/what-is-spectrum-a-brief-explainer
  12. CBRS Alliance. (2020). OnGo Private LTE Deployment Guide. Retrieved from: https://www.cbrsalliance.org/wp-content/uploads/2020/12/OnGo-Private-LTE-Deployment-Guide-2.0.pdf
  13. Eligibility to hold an EBS service license was limited to (1) accredited public and private educational institutions, (2) governmental organizations engaged in the formal education of students, and (3) non-profit organizations whose purposes are educational and include providing educational and instructional materials to accredited institutions and governmental organizations.  Those eligibility requirements were eliminated in 2019.
  14. FCC. (2019). Transforming the 2.5GHz band. https://docs.fcc.gov/public/attachments/FCC-19-62A1.pdf
  15. The UHF TV band extends from 470 MHz to 614 MHz. White space devices may also operate on available channels in the 600 MHz Band Service (617 MHz to 652 MHz and 663-698 MHz) in areas where mobile broadband licensees have not commenced service. White space devices may also operate at 657 MHz to 663 MHz nationwide.
  16. FCC. (2020). Unlicensed White Space Device Operations in the Television Bands. https://www.fcc.gov/document/fcc-increases-unlicensed-wireless-operations-tv-white-spaces-0  

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