February 4, 2022
Members’ Systems Are Models for Closing the Digital Divide

Chiefs for Change CEO Mike Magee today sent the following letter urging the U.S. Department of Commerce to fully acknowledge the eligibility and importance of broadband connectivity projects led by school districts.

Dear Assistant Secretary Davidson:

As CEO of Chiefs for Change, a bipartisan network of school superintendents and state education commissioners, I appreciate the opportunity to comment (in response to your January 10 Federal Register notice) on the implementation of the Infrastructure Investment and Jobs Act Division F grant programs to be administered by the National Telecommunications and Information Administration (NTIA), including the Broadband Equity, Access, and Deployment (BEAD) program and the Digital Equity programs.

The COVID-19 pandemic has made obvious to the broader public what those in education have long known: People need the internet to function in today’s world. When schools shifted to remote learning at the onset of the pandemic, as little as 50 percent of students in some of our members’ school districts had the technology for a meaningful distance learning experience. Nearly 17 million students across America do not have high-speed internet. The problem disproportionately affects children of color, those from low-income families, and students who are already behind in their learning. All children have a fundamental right to a high-quality education. We deny them that right when they don’t have the internet and adequate technology.

Since the beginning of the pandemic, state education agencies and school districts from across the Chiefs for Change membership have intensified their efforts to close the digital divide. These K-12 systems have implemented a number of innovative strategies to ensure students have a home internet signal so they can access the wealth of information they need to succeed.

As a network, we aggressively advocated for dedicated federal funding to expand high-speed internet and are grateful to President Biden and Congress for approving resources for this purpose in the Infrastructure Investment and Jobs Act. 

In order to ensure that broadband funds are used for maximum impact, we respectfully request that NTIA, under the BEAD program, fully acknowledge the eligibility and importance of projects led by community anchor institutions (CAIs) such as school districts.

The statute articulates that subgrants to states through the BEAD program may be used to fund connectivity projects (i) for unserved areas, (ii) for underserved areas, and (iii) that are led by CAIs. Further, the statute grants the highest priority to projects connecting unserved areas, does not allow other projects to go forward unless all residents of those areas are being covered, and does not allow funding for CAI projects unless projects for underserved areas are given priority. While we acknowledge that CAIs are the third priority, we urge NTIA to implement the program in a manner that clarifies and highlights the authority of school districts and other CAIs to lead efforts to connect unserved and underserved areas, within the first two priorities.

Indeed, systems led by our chiefs have demonstrated success in working with partners to provide home internet access for large numbers of families who didn’t previously have it. Given that they are deeply embedded in the communities they serve, school districts and their partners are well positioned to lead this work.

Boulder Valley School District in Colorado and the Phoenix Union High School District in Arizona, both led by members of Chiefs for Change, stand out as two examples of systems that have made significant progress in closing the digital divide for students.


  • In Boulder Valley School District, nearly all students now have a home internet connection, thanks in large part to an innovative partnership between the district and a local service provider. Through an agreement approved by the school board in April 2020, the provider is installing transmitters/receivers on school rooftops that allow customers within a two- to three-mile radius to obtain an over-the-air internet connection. The service is available at no cost for families with children who qualify for free or reduced-price school lunch. Previously, the district purchased Wi-Fi hotspots or low-cost “internet essentials” packages for students who could not get online from home. With the over-the-air service, the district is transitioning families to a more permanent and reliable solution.


  • The Phoenix Union High School District is playing a leading role in a citywide Wi-Fi initiative known as the “Network for the Future.” The goal is to blanket Arizona’s capital city with free Wi-Fi by building a network through a public-private collaboration that includes every local school, community college, the City of Phoenix, and several businesses and community partners. Currently, the community is working on a small pilot covering four square miles and hopes to create a replicable model. The network will provide a wireless canopy of coverage, known as the Digital Education Connection Canopy, with end-to-end security by installing equipment at schools, colleges, and city sites. It will use existing internet connections provided by education partners, allowing students to connect from their home to their school with secure authentication.


Again, we call on NTIA to clarify that CAIs that offer compelling plans to connect students and families in unserved and underserved communities may receive funding under the first two priorities.

Another area in which we are seeking clarification concerns the Digital Equity Planning, Capacity, and Competitive Grant Programs. We understand these programs are intended to ensure that all individuals and communities have the skills, technology, and capacity needed to reap the full benefits of our digital economy. We are also grateful that local education agencies are authorized to receive program grants and subgrants. Yet the specified target populations do not explicitly include students, and the statutory definitions of such terms as digital equity, digital inclusion, and digital literacy do not reference the importance of (or specifically authorize) in-school efforts in achieving the programs’ objectives. We believe the grant programs could support computer science instruction and digital literacy services that are essential to preparing students to succeed in the 21st Century. We thus ask that NTIA, in your implementation of these new grant programs, clarify that school-based digital equity activities are eligible for support and, if possible, make those activities a high priority.

I would welcome the opportunity to speak with you about our requests and the innovative work our chiefs are leading to close the digital divide. Thank you for the opportunity to provide comments​​—and thank you for the work you are doing to ensure all students in America have the home internet connections they need.


Mike Magee