ELI Provides Comments to NTIA on Digital Equity Act Rules

There are tremendous opportunities to fund library technology and programming priorities through the Digital Equity Act, but our sector must participate in developing state plans. Without our libraries and state library agencies being identified in the plans as viable enactors of Congress’ goals, we will not be eligible for funding.

The EveryLibrary Institute has been providing technical assistance and capacity-building support to state library agencies as they prepare for their state planning processes around the Digital Equity Act. As a component of our strategic support for state libraries and local libraries, the EveryLibrary Institute submitted comments to NTIA, the National Telecommunications and Information Administration, on their May 1, 2023 request. In general, we believe that NTIA should look to fund programs demonstrating the three hallmarks of transformational success: 1) minimize system friction, 2) provide a clear benefit, and 3) create self-sufficiency for the future. We see libraries and state library agencies as uniquely positioned within the Community Anchor Institution definitions do smoothly and effectively support the goals of this legislation.

In many states, legislative and local fights about book bans, censorship, and limits to teaching certain topics have created a political climate where words like Equity and Inclusion are being diminished or even outlawed in state vocabulary. We highlighted in our comments that applicants, including libraries and state libraries, should be allowed to propose projects that do not use specific language found in the Digital Equity Act because of these legislative or regulatory issues. Alignment with a state plan should outweigh concerns such as not using the word “equity.”

In our comments, we told NTIA that funded projects should attempt to align with their state digital equity plan. This will allow the Capacity Grant Program dollars to stretch further towards accomplishing project goals while ensuring Competitive Grant Program dollars share objectives. We are suggesting that NTIA should create standardized categories for outcomes, as well as lists of sample metrics for each output category. However, the applying organization should define in its project proposal the specific metrics it will use for each output category. This allows applicants to propose their implementation deliverables appropriate for the needs of those they plan to serve.

We see that collaboration among state agencies will be crucial for sustainability. NTIA should encourage partnerships and coalitions between government agencies to ensure a smooth transition from federal funding to state and local revenue. Success for the Capacity Grant Program should be defined at the state level, allowing states to use appropriate language for their political climate and preferences. NTIA should design the Capacity Grant Program to ensure equity by allowing states to fund successful and replicable programs and withdrawing funding for failures to launch rather than penalizing state administering entities. NTIA should establish clear and stable reporting requirements for grantees to ensure that the voices of those most impacted by the digital divide are reflected in the implementation and updates of the Digital Equity Plans.

Our full comments are included below for you to review:

EveryLibrary Institute NFP Docket No. NTIA-2023-0002 - Digital Equity Act of 2021 Request for Comments (opens PDF)