CoSN Submits Comments to NTIA for Review of Online Protection Technologies
The Consortium for School Networking August 16, 2002, submitted comments to the National Telecommunications and Information
Administration for its review of blocking and filtering technologies, as it was required by Congress under the Children's
Internet Protection Act. Final comments are due with NTIA by August 27, 2002. The CoSN comments can be found below.
Before the National Telecommunications and Information Administration
U.S. Department of Commerce
Washington, D.C. 20230
Request for Comment on the Effectiveness of Internet Protection Measures and Safety Policies
Docket Number: 020514121-2121-01
Comments of the Consortium for School Networking in Response to the Request for Comments, Published May 22, 2002
The Consortium for School Networking (CoSN) respectfully submits these comments in response to the National Telecommunications and Information Administration's request for comments as part of its review of effective strategies for promoting online safety in K-12 schools.
CoSN is a 10-year-old membership-based non-profit association that serves educators who use technology to improve teaching and
learning. Its members include national education associations, local school districts, state education agencies, companies
serving the educational technology market and individuals who are leaders in bringing technology to the country's K-12
CoSN believes it is uniquely qualified to provide input to NTIA about the issues that are at the heart of this rule-making. In October 2000, CoSN launched an initiative, called "Safeguarding the Wired Schoolhouse," that was designed to help schools and school districts work through the question of whether they should manage their students' access to Internet content, and, if so, how best to do that.
At the time, surveys showed that the majority of schools and school districts were already taking steps to address their students' safety. In fall 2000, shortly before the Children's Internet Protection Act was passed, 98 percent of public schools with Internet access already had an Acceptable Use Policy in place, according to a study by the National Center for Educational Statistics that was released in May 2001. Ninety-four percent of schools with AUPs reported that they also relied on monitoring by teachers and staff members, 74 percent were already using blocking or filtering software, 64 percent had adopted honor codes and 28 percent said they were restricting their students' access to a school or district intranet.
Nevertheless, school networks have grown in size and complexity over the past few years. In 1996, according to the NCES, 74
percent of public schools that were connected to the Internet used a dial-up line. By 2000, only 11 percent of public schools
said they used dial-up connections while 77 percent were using dedicated, generally higher-speed lines. Consequently, CoSN believed that schools could benefit by reviewing these issues again in light of such factors as network management and reliability, the realities of the classroom experience and the demands that new technologies placed on their tech support and curriculum staffs.
When the Children's Internet Protection Act was under consideration on Capitol Hill, CoSN opposed the legislation, arguing that decisions on how best to protect children when they go online at school should best be made at the local level. That is still CoSN's policy position. Nevertheless, it has worked to help its members and the wider school community understand what they must do to comply with CIPA, now that it is the law of the land.
CoSN believes that a relatively small number of public school districts have chosen to forego E-rate discounts and other federal ed-tech funding because of their opposition to CIPA's "top-down" mandates. (Some have not been required to comply because of the exemption for those schools that receive E-rate support only for telecommunications services.) From its vantage point, CoSN believes that districts have chosen to interpret the CIPA requirements in a wide variety of ways. Many have concluded, as the three-judge panel of the U.S. District Court in Philadelphia recently did when it reviewed the law that :
"Most importantly, no category definition used by filtering software companies is identical to CIPA's definitions of visual depictions that are obscene, child pornography, or harmful to minors. And category definitions and categorization decisions are made without reference to local community standards. Moreover, there is no judicial involvement in the creation of filtering software companies' category definitions and no judicial determination is made before these companies categorize a Web page or site."
Consequently, school leaders have tried, where possible, to adopt solutions that fit the needs and culture of their schools and to communicate those policies to parents and other members of the community. Still, at a time when education budgets have grown tighter than they were when CIPA was passed, many school leaders have complained that the law's requirements amount to an "unfunded mandate," requiring them to devote scarce dollars to respond to concerns that they were already addressing.
How a school district evaluates particular technology tools will depend, in part, on the culture of the school district and its surrounding community. In some of the districts in CoSN's membership, technology leaders reported that they had been using filters before CIPA passed because they believed their communities would expect that of them. For them, using a filter helped address the concerns of parents and other community members. Most recognized, however, that students still needed to be taught online safety skills and responsible Internet behavior so that they would be protected when using computers at home or outside the school environment.
However, in other districts, there was a stronger concern about protecting free speech rights, and greater familiarity on the part of parents with the Internet. These districts had traditionally emphasized the teaching of online safety skills and information literacy, rather than installing filters. CIPA required them to rethink these strategies, whether they wanted to or not.
(The diversity of school district experiences was also reflected in a study that was released just a few days ago by the Pew Internet and American Life project, which detailed how students view the way they use the Internet in school, and their thoughts on how software filters can hinder their intellectual inquiry.)
NTIA has sought comments addressing very specific questions about these technologies. To inform its response, CoSN solicited the input of its school-based members, asking about their own experiences. This questionnaire was not intended to be a scientific survey, and the responses should be viewed as anecdotal. Answers were volunteered in an online format, and, solicited in the middle of summer when the respondent group unfortunately turned out to be relatively small. Nevertheless, CoSN believes the responses provide a "snapshot" of the perspective of some of the nation's most thoughtful technology leaders. If anything, the diversity of answers reflect the different factors that can play out at the local level.
It should be noted that because schools were not required to be in full compliance with CIPA until the start of the second E-rate funding year after its passage, many school districts waited until close to July 1, 2002, to install whatever technology they had decided to adopt to bring themselves into compliance with the law. Thus, for some, their experience with these technologies is, in fact, somewhat limited, and may have been outside the regular school year. Thus, we encourage NTIA to continue to monitor the real-world experience of school districts in managing online safety in the coming years. CoSN would welcome the opportunity to work with NTIA on this, and would be willing to help organize one or more focus groups to enable the NITA staff to talk directly with school leaders about these issues or help facilitate any other approach that would support the agency's work in this area.
CoSN's corporate members include companies that offer a variety of blocking and filtering solutions. Nevertheless, it strives, in all of its work, to remain vendor-neutral. Consequently, it will not take a position here on whether one particular solution or software package is better than another. And, in fact, it believes that the individual school or school district is the best judge of that.
As an attachment to these comments, CoSN provides the briefing paper that its Safeguarding the Wired Schoolhouse project first
prepared in October 2000. This document was updated in mid-2001 to reflect the passage of CIPA and other developments. The
document cites a number of studies and other documents that NTIA may wish to review as part of this study. One of the challenges
that presents anyone working in this area is that many of the reviews of technology solutions have been conducted by individuals
or organizations with strong opinions, pro or con, about these solutions. Like the Children's Online Protection Act (COPA) Commission, CoSN believes that government agencies like NTIA could make a useful contribution if they would serve as a neutral, third-party reviewer of the available technology solutions, and compare their performance.
NTIA asked commenters to address specific questions. CoSN has responded to those to which it feels most qualified to contribute. It encourages NTIA to work directly with industry representatives to understand the particular capabilities of products on the market and with school districts that have developed their own technology solutions.
Evaluation of Available Technology Protection Measures
Discuss whether available technology protection measures adequately address the needs of educational institutions.
The consensus of most school technology leaders is that no technology solution, be it commercially available blocking and filtering software, a commercial monitoring product or a homegrown solution, is perfect. Schools, as we see it, have three choices. They can permit their students to view a limited number of sites that are prescreened by staff, by an outside evaluation group or that are self-rated according to the standards of the only viable rating organization, the Internet Content Rating Association. Or they can adopt a blocking or filtering solution that may work well at blocking inappropriate sites, but will also block ones that some teachers may want students to be able to access. Or the chosen solution may permit the viewing of most sites, including many that would be considered inappropriate.
Try as they might, companies that provide filtering solutions cannot keep up with the rapid growth of the Internet and are forced, to some extent, to rely on artificial intelligence and other tools to screen sites in advance of actual human review. The basic dilemma for schools is how large should their Internet "library" be? The next question is, would they prefer to err on the side of providing access to content or on the side of preventing students from viewing something inappropriate?
The 26 school officials who provided comments to CoSN represented districts of all sizes, but the group had a disproportionately larger number of respondents from larger school districts (those with more than 10,000 students) than is found in the United States as a whole. Several respondents were speaking from the vantage points of statewide networks, state departments of education or regional service agencies. Hence, they represent larger numbers of schools. Eighty percent of respondents identified themselves as a technology director or technology staff member. (Perspectives on the questions NTIA has raised may vary, based on which district official is supplying the answer.)
About 40 percent of those who commented said they were "very satisfied" with the solution they had chosen. Fifteen percent of the group reported that they were not using a blocking or filtering solution, and three of the four respondents were "very satisfied" with that approach. (None of these respondents identified themselves with a school, school district or other educational entity with more than 9,999 students.) Sixty-nine percent of the respondents said they were using "a commercially available blocking and filtering product or solution," and a third of them reported that they were "very satisfied" with that solution. Two respondents (8 percent) said they use a solution they had developed for their own use.
About 20 percent of respondents said that the approach they had chosen "does not block all the sites that should be blocked," but they were about equally divided as to whether this amounted to a problem or not. Eight percent said their approach "blocks too many sites," but again were divided as to whether that was a problem. When respondents who were not actually blocking content are excluded, about 10 percent said their filter "blocks too many sites," but were divided as to whether this was a problem.
Respondents were evenly divided on the question of whether "the available technology protection measures adequately address your needs?" When prompted for additional comments, respondents provided these statements, some of which appear to be directed to the particular solution they are using, rather than solutions in general:
- It is not cost-effective for what it does
- The best solution would allow us to train teachers.
- The worst part about filter programs, even more so.
- Management is time-consuming and not funded.
- Education is the best solution. T.P. [editor's note: presumably Technology Protection] won't be.
- We always seem to need a customized solution.
- Don't believe there is adequate tech solution.
- Blocks too many sites. We're a K-12 site. [editor's note: This school apparently had K-12 students in the same building, which made it a challenge to find an appropriate solution.]
- Http and ftp filtering OK, but e-mail not filtered
- The extra man hours to open sites up or to close them.
Is the use of particular technologies or procedures more prevalent than others?
Surveys show that a significant majority of school districts have installed filtering or blocking software. Companies that are in the business of selling filtering software have access to studies indicating their relative market share. However, some school districts may choose to rely on filtering technologies installed by their Internet Service Provider or as part of a bundled firewall solution so depending on how a particular question was phrased, data on which kind of solution is preferred may not give a precise picture.
For instance, one respondent to the CoSN questionnaire indicated that blocking and filtering was provided by its state network. Another respondent reported that it used "a monitoring software and hardware solution." With this kind of approach, a school district typically either monitors logs manually or uses software that flags potential inappropriate use. Some school districts review usage logs only when they have a concern about potential misuse.
What technology, procedure or combination has had the most success within educational institutions?
CoSN believes, as the recent National Research Council study also concluded, that schools need to use a combination of approaches to assure that children remain safe when they go online. But access to inappropriate Web sites is only one small part of the problem, and why simply installing a filter is not a strategy for success.
However, NTIA does not define what it means by "success." CoSN believes that most school leaders would define success as achieving a positive environment for learning in the classroom while arming students with the information and technology literacy skills that they will need to be effective Internet users when they move into the workplace or an institution of higher education. CoSN believes that no one approach will work everywhere, which is why it is best to leave these decisions up to the discretion of local school leaders.
Please explain how the technology products block or filter prohibited content. Explain whether these methods successfully block or filter prohibited online content and whether one method is more effective than another.
CoSN provides an overview of the various blocking and filtering technologies in the attached briefing paper. If NTIA needs additional information, we encourage it to discuss this with industry representatives. NTIA may also wish to review some of the technology solutions that individual schools and districts have developed for their own needs. CoSN would be happy to help identify such districts for NTIA.
Expanding on the responses noted above, when asked "which statement best describes your experience with this solution," seven of the 18 respondents who used a commercial product or relied on filtering provided by their ISP reported that they were "very satisfied," with the results. Four more had complaints about either over-blocking (one) or under-blocking (three), but said "this has not been a problem for us." Another five respondents cited problems. One respondent said over-blocking "has been a problem for us," two respondents had the same complaint about under-blocking. Two respondents, in the additional comments, cited both under-blocking and over-blocking as a cause for dissatisfaction. Another said "none of it works as it should."
Nine respondents, including the two whose schools had developed their own solutions, chose the opportunity to provide "Additional Comments" rather than one of the choices that was provided. Comments in addition to the three characterized above were:
- They update nightly, we block additional [sites] by request
- Too soon to tell.
- We have the ability to make changes to the program.
- Still evaluating the impact of the solution
- Can check box saying we filter
- Virtual hosting usually the problem, easy to fix. [Editor's note: This response apparently refers to situations where sites that are otherwise appropriate are blocked because they reside on servers that host other, inappropriate sites.]
The diversity of responses demonstrates why choices about safeguarding children are best made at the local level. While many respondents are satisfied with their solution, many are not. Some of the latter group appear to accept the limitations of the products they have chosen to install, or that they have been required to, but an equal number consider their choices problematic.
Are there obstacles to or difficulties in obtaining lists of blocked or filtered sites or the specific criteria used by technology companies to deny or permit access to certain Web sites? Explain.
Every blocking or filtering solution involves some level of subjective opinion, even if only to set the parameters of an Artificial Intelligence algorithm. Most companies provide some general guidance on the kinds of Web sites they block, or give their customers categories which they can choose to filter. Some, however, treat their specific lists of blocked sites as proprietary information, seeking to protect it both from competitors and from persons committed to undermining filters.
In its materials, CoSN has encouraged school districts to experiment with different solutions before making a decision and to talk to peer school districts about their experience with particular products before making a decision on which product will serve their needs.
The lack of a public list does cause problems when sites are blocked incorrectly, and Web site operators do not know that their site has been mischaracterized. Also, some teachers have complained when they were able to access a site that they felt was appropriate when they prepared a lesson plan from their home computer, only to discover, when they arrived at work the next day, that the site was blocked on the school's network.
Just under half of the CoSN respondents who reported they used a blocking or filtering solution said they had been able to obtain a list of the sites that were being blocked or filtered. Twenty-three percent said they had not been able to. The remaining 34 percent had not tried, maintained their own list, or used a solution based on Artificial Intelligence that did not maintain "a list." One in that group indicated that they, in effect, could check "the list" by testing a site, then unblocking it if necessary.
Do technology companies readily add or delete specific Web sites from their blocked lists upon request?
Fifteen of the respondents said they had tried to get sites added or deleted from the lists. (Not all of these respondents actually used a solution.) Four respondents said they had not tried, and six said the question did not apply.
Those who had tried to get the list changed provided these additional comments on their experience:
- We process the changes for our customers, but when it requires us to go to our vendor, it typically takes a week. (Editor's Note: This comment was apparently provided by someone affiliated with a state or regional educational agency that provided access to schools.)
- We can manually update our site by blocking or unblocking. We also report to the company definite sites that need to be blocked. Within one day, they are then blocked.
- Requests are sent in from across the network and are sent to the filtering team and are judged by the rules set down by the [state] department of education.
- I was told it could not be done.
- We enter the URL into an online form and there is a space for comments.
- Less than five minutes from start to finish.
- Rather simple and straight-forward.
- Our average 10th grader can easily outflank the filters
- I can manually add or delete sites on the blocked list, or send the URL to the vendor to update our lists nightly.
- We log on to their Web site to see if the site is blocked. If not, we notify them of the need to block the site, and within 48 hours it is blocked.
- [School] site will call in and ask to open or close a [web] site. I will clear, then the tech staff must either go into the program and fix or turn off at the router.
- I must request that it be reviewed. If the organization agrees that it should be blocked/not blocked, it follows through. If not, it ignores my request.
- Either through their website or by e-mail. They download new filters every Wednesday. That is when it takes effect.
Discuss the factors that were considered when deciding which technology tools to use (such as training, cost, technology maintenance and upgrades or other factors).
CoSN's briefing paper, initially published before CIPA passed, offered school districts a framework for deciding first, whether they wanted to manage students' access to online content, and then, if they did, suggestions for how to evaluate different products.
The respondents to its survey provided these insights on the factors that influenced their decision. Asked to indicate which factors were considered when they chose their technology tools, 79 percent cited "effectiveness in terms of blocking," 75 percent cited "cost," 67 percent cited "ease of maintenance," 54 percent cited "impact on school's networking resources," 38 percent cited "effectiveness in terms of not over-blocking," and 29 percent chose another factor. Those that specified additional factors mentioned these:
- Must run on our Volera cache boxes
- Ability to have age/position variable profiles
- Ability to make changes and reporting features
- Integration with network operating system
- We used a monitoring system for all the above. [Editor's Note: This respondent appears to be indicating that they chose a monitoring solution rather than a blocking/filtering solution, based on all of the criteria cited above.]
- Do minimal to say we filter
Fostering the Development of Technology Measures
CoSN believes that the federal government could most effectively foster the development of technology protection measures by letting the market respond to the varied needs and requirements of schools and school districts all across the United States. Unfortunately, CIPA, by mandating a particular solution, has forced all of the companies competing in this market to define their products in terms of which best complies with CIPA, rather than how they may serve the needs of different kinds of school districts.
CIPA has unfortunately forced schools to focus their attention on only one small part of promoting online safety-namely, whether a child can access an inappropriate Web site by using a browser. But schools must also be worried about other kinds of online interaction, including e-mail, e-mail attachments, chat rooms and information that may be made available on the Web-in all innocence-about school children. With limited financial resources, schools could decide to choose a solution that will at least make them CIPA-compliant when they may actually be more concerned about other forms of online interaction and network security.
Are current blocking and filtering methods effectively protecting children or limiting their access to prohibited Internet activity?
While blocking and filtering technologies may limit children's access to certain Internet sites, many school leaders believe these determinations are sometimes flawed. In addition, many of them believe it is unclear exactly what "prohibited Internet activity" is, when community norms may vary so widely.
If technologies are available but are not used by educational institutions for other reasons, such as cost or training, please discuss.
What technology features would better meet the needs of educational institutions trying to block prohibited content?
Cost will always be an issue as far as school districts are concerned. The perfect solution may be available, but school districts may not be able to afford it, or may choose not to purchase that solution when weighed against competing demands, particularly in times of tight budgets. Note that 75 percent of the respondents to the CoSN questionnaire cited "cost" as one of their considerations.
Five respondents indicated there were technologies they would rather use, and provided these comments:
- Monitoring software rather than block or [Artificial Intelligence] software that allows for student decision as to whether to access a page that has potentially inappropriate material.
- There is a new breed of filtering software that uses artificial intelligence rather than lists of sites. Internet Content Manager by IPS Networking is an example.
- Blocking and filters are only good till the next guy tries to go around the system. Monitoring allows us to see what people are doing and deal with it. Education of students is the best deterrent available with positive results.
- Don't believe technology is the solution, but rather student supervision and education about appropriate use.
- Being a K-12 facility complicates filtering. We don't want young children to access sites that we do want older children to be able to access. We're going to individual logons this year to attempt to filter more effectively.
Can currently available filtering or blocking technology adjust to accommodate all age groups from kindergarten to grade twelve?
Some products permit school districts to set different filtering parameters for individuals, different schools or different grades. But such features come with a cost. In addition, if a school's Internet access is filtered by its provider, it may be unwilling to devote scarce resources to a solution that would provide it with another layer of customization. And, as one respondent indicated above, instances in which a single building houses children in grades K-12-a situation that is not unusual in rural areas or in private schools-provides particular challenges.
Are these tools easily disabled to accommodate bona fide and other lawful research? Are these tools easily dismantled?
CoSN has observed that the terms "disabled" and "dismantled," as used in CIPA, have led to a great deal of confusion among school leaders as they have tried to comply with the law.
Eighty-seven percent of the respondents to its questionnaire reported that their tool could be "disabled for 'legitimate research purposes.'" One respondent said no, and two said they had no opinion or did not know. (These numbers include those who don't actually use a technology solution.)
Sixty-three percent said their tool could not be "easily dismantled." Twenty-five percent said it could, and 13 percent said they didn't know or didn't have an opinion.
Current Internet Safety Policies
Are Internet safety policies an effective method of filtering or blocking prohibited material consistent with the goals established by educational institutions and the community? If not, please discuss the areas in which the policies do not effectively meet the goals of the educational institutions and/or communities.
Please discuss whether and how the current policies could better meet the needs of the institutions and the community. If possible, provide specific recommendations.
Are educational institutions using a single technology protection method or a combination of blocking and filtering technologies?
Describe any best practices or policies that have been effective in ensuring that minors are protected from exposure to prohibited content. Please share practices proven unsuccessful at protecting minors from exposure to prohibited content.
Although most online schools already had Acceptable Use Policies in place when CIPA was passed, the specific requirements of CIPA may have required many of them to revisit these policies. Although we question the need to dictate what an Internet safety policy must address, we think the agencies charged with enforcing CIPA have correctly left these determinations up to schools, school districts and libraries.
That said, an Internet safety policy can only be effective when its precepts are communicated clearly to students and parents, when they understand what sanctions will be imposed if it is violated and when the school actually enforces the policy. Many school districts have now incorporated these policies into the materials they send home at the beginning of the school year, advising parents on school policies. While many schools ask parents to sign these policies and return them, some parents fail to do so. In the area of Internet usage, as in all aspects of education, "success" relies on a partnership between parents and educators, a partnership that schools, in most cases, cannot impose on those who don't want to participate.
As former U.S. Attorney General Dick Thornburgh, chairman of the committee that advised the National Research Council on its recent report, "Youth Pornography and the Internet," said in a statement when the report was released:
"For the most part, the public-policy debate thus far has focused on the use and effectiveness of filters. These and other technologies do have an important role to play in giving parents and other responsible adults additional choices. But our study found that technology cannot provide a complete-or even a nearly complete-solution. Indeed, though some might wish otherwise, no single approach-technical, legal, economic or educational-will be sufficient to address all of the relevant issues. Rather, an effective framework will require a balance composite of all of these elements, and real progress will require forward movement on all of these fronts."
Even in schools that have chosen to adopt technology controls, CoSN believes that students must be taught online safety skills to help protect them when they use computers, in their own homes or those of their friends, that may not have filtered access, and to prepare them for the day when they use the networks of their colleges or employers. Further, students must be taught how to deal with strangers they may meet online, how much information they should provide about themselves, and how to evaluate information that they receive through e-mails or in reviewing Web sites. All of these are important lessons in online safety and information literacy that cannot be taught by relying solely on filtering and blocking software.
In addition, schools must choose a technology solution that meshes with other security needs. As more and more sensitive student data moves online, school technology leaders have become increasingly concerned about securing their networks from hackers, both inside and outside of their systems, and in improving the ability of their networks to recover from crashes or more catastrophic events. Network managers now evaluate potential solutions in terms of a range of other monitoring and security needs. Cost, maintenance and network performance are among the issues that will be examined when these decisions are made.
In response to the task it was given when CIPA passed, NTIA has raised a number of important questions about how school districts are managing online safety issues. Respondents to the CoSN questionnaire added these final comments after providing answers to the 16 questions in the CoSN survey:
Pornographers are very creative and browsers are the worst culprits because they simply sell their services to whomever wants to pay. Kids' curiosity also hampers some restrictions we put in since they attempt to find ways around any blocking mechanism. I would rather have more restrictions in place that I can unblock upon request than to have a younger child accidentally get to an inappropriate site.
I believe that a majority of the public school educators would not use the Internet if we did not have an adequate filtering system. Even with the filtering in place, there seems to be a lot of fear that they or their students may stumble across something deemed inappropriate. Although we purchase the filtering solution for the whole state, the software is on cache boxes spread across the state so that there is some local control. Districts can decide which filtering categories to use and they can . . .manually block sites the community finds inappropriate.
1) No tool will ever take the place of appropriate and effective supervision by teachers/staff at school and parents at home. 2) Some of our greatest debates have been around the philosophical issue of censorship. That debate cannot be resolved by technology and the introduction of state/federal mandates only fuel the intensity of the local decision-making process. 3) No educational institution has the staff/funding capacity to provide granular access to students/class/time-of-day/etc. Even if the technology provides for that granularity, the time and effort to maintain 24,000 individual profiles is not an acceptable option.
Question 16 [Editor's Note: "Can your tool be "easily dismantled?"] does not make sense. What is dismantled?
Most filtering companies need to address "wildcard" settings to simplify filtering of the numerous new inappropriate sites that surface daily. Getting away from "categorical" blocking would eliminate some of the overblocking. We are on our second program for filtering and it will be interesting to see if our new one works as we anticipate in the upcoming school year.
Internet access is like a swimming pool-it can be dangerous and you can attempt to restrict access, but the most effective way to protect children in swimming pools is to teach them to swim.
This is another example of a mandate coming down from the government without funding attached. I realize that USF [Editor's Note: Universal Service Fund] is a funding source, but that source is being used for communications.
Believe that blocking with technical solution is not the way to go. Rather, use staff/student supervision and education about appropriate use of the Internet. Don't believe there is a dependable technology solution. Do away with the requirement.
State should be kept out of the process.
Our approach has been teaching safety and common sense when using the net. Has that been enough? No, not in some cases.
CoSN has attempted to provide its perspective on these issues as one of the leading policy voices on implementing technology in K-12 schools. Our sampling of anecdotal comments is designed to provide more "front-line" views of these solutions. We anticipate that other school leaders may decide to comment directly to NTIA.
However, we caution NTIA to be careful not to reach sweeping conclusions based solely on the comments that are submitted. Many persons have strongly held opinions on these issues, but we expect that NTIA will hear about the real-world experiences of only a relatively small number of U.S. schools and school districts. It could advance the work that has previously been done by the COPA Commission and the NRC panel if it provided the necessary resources to conduct a detailed, scientific survey of school leaders on this issue, providing them with metrics for evaluating whether a solution was "effective" and whether they had been "successful."
American school leaders already know what they want to do-ensure that children have a positive experience when they go online. The most effective help that NTIA and other government agencies could provide is concrete assistance in evaluating the best strategies that individual schools and districts can undertake to achieve that end.
CIPA is currently the law of the land-and nothing that CoSN says to NTIA will change that. However, NTIA could help school districts respond to the mandates of CIPA by creating new resources to help school technology leaders understand the technologies that can help them secure ever-growing, sometimes decentralized networks. Such a role is in keeping with NTIA's traditional mandate and would serve the needs of the K-12 ed-tech community in a positive way.
Keith R. Krueger
Consortium for School Networking
1555 Connecticut Avenue NW
Washington, DC 20036
 Further information about CoSN and its mission can be found at www.cosn.org.
 National Center for Education Statistics, "Internet Access in U.S. Public Schools and Classrooms: 1994-2000," U.S. Department of Education, Office of Educational Research and Improvement, NCES 2001-071, released May 2001.
 Decision of the U.S. District Court for the Eastern District of Pennsylvania in American Library
Association v. U.S., May 31, 2002, retrieved at www.paed.uscourts.gov/documents/opinions/02D0415P.HTM, August 16, 2002.
 "The Digital Disconnect: The Widening Gap Between Internet-Savvy Students and Their Schools,"
prepared by Douglas Levin and Sousan Arafeh, American Institutes for Research, for the Pew Internet & American Life Project,
released August 14, 2002, retrieved at www.pewinternet.org/reports/toc.asp?Report=67, August 16, 2002.
 One exception was a March 2001 review published by Consumer Reports magazine. (See
retrieved August 16, 2002.) However, this study focused on software solutions that could be installed on individual home
computers, not school networks.
 Opening statement, May 2, 2002, by Dick Thornburgh, chair, Committee to Study Tools and Strategies for Protecting
Kids from Pornography and Their Applicability to Other Inappropriate Internet Content, retrieved at
www4.nationalacademies.org/news.nsf/(ByDocID)/0BE661FA657C861885256BC30053797D?Open, August 16, 2002.
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