Digital Childhood Council
Filings & Public Comments
The DCC (Digital Childhood Council) participates in federal and state regulatory proceedings that bear on child safety, AI governance in schools, and parental rights in educational technology. This page consolidates the Council's filed comments and public correspondence.
Federal Regulatory Filings
Comments to FCC Children's Online Safety / CIPA–E-Rate Notice of Proposed Rulemaking
The DCC submitted comments in response to the Federal Communications Commission's Notice of Inquiry in WC Docket No. 26-133, which examines how CIPA-required internet safety policies and E-Rate-funded infrastructure interact with the deployment of artificial intelligence systems on school networks.
The comment draws on records obtained from large school districts, published board meeting documents, correspondence, and vendor-published documentation to identify governance gaps that arise when a minor uses an AI system on a school-issued device or through a district account. It identifies where the controls the Commission's rules presume are present and where the Council has not found them. The comment and the 11 exhibits can be found here.
State Regulatory Filings — Florida
Comments to Florida State Board of Education Rulemaking on Student AI Instructional Tools
The DCC submitted comments during the rulemaking process for Florida Rule 6A-1.0957, F.A.C., which establishes parental opt-in requirements for AI instructional tools used in Florida's public schools. The rule was adopted September 16, 2026, and takes effect October 29, 2026. Districts must adopt compliant policies by July 1, 2027.
The Council's comment addressed the operationalization gap between the rule's parental consent requirement and the current deployment practices of AI tools that reach students through consumer-facing products rather than district-administered instructional platforms. Under the rule, districts must provide a comparable non-AI alternative for students whose parents do not consent. The comment identified specific product categories where the Council has not found a school-controlled opt-out mechanism, creating a compliance gap that existing district infrastructure cannot resolve without vendor action.
Public Correspondence
Open Letter to Google: Administrator Control Gap for AI Mode in Search
Jill Coleman, Founder of the DCC, published an open letter addressed to Google via LinkedIn asking three questions about the absence of school-level administrative controls for AI Mode in Google Search. Florida Rule 6A-1.0957 requires districts to obtain affirmative parental consent before a student uses an AI instructional tool and to provide a comparable non-AI alternative for non-consenting students. AI Mode in Google Search is deployed directly through Google.com to all users, including students on school-issued devices, and is not governed by Google Admin Console's toggle for Gemini in Classroom.
The letter asks Google to confirm whether a school administrator control for AI Mode exists in Google Admin Console, what timeline Google has committed to for providing one, and how districts are expected to demonstrate compliance with Florida Rule 6A-1.0957 pending such a control. The Council has not found any public Google statement addressing the administrator control gap for AI Mode in Search. The letter documents that blocking google.com entirely would disable safety infrastructure, including content filtering services that depend on Google's infrastructure and district-level crisis-keyword crawling through Google Drive and Gmail.