The following is taken from a statement delivered to the State E-rate Coordinators for Libraries and ALA's E-Rate Task Force (ERTF) on February 9, 2015.
Although the statement addresses TV White Space access specifically, the principle of eligible location is equally applicable to Internet access via mobile hotspots.
During discussion at the Chief Officers of State Library Agencies (COSLA) meeting, both ALA and an ERTF member also indicated that offsite access is not subject to CIPA.
The issue of a library's use of TV White Spaces (TVWS) to extend Internet access beyond the library's property -- and how this impacts the library's E-rate Internet application -- has been the subject of some speculation over the past number of months. For example, it was recently discussed at the COSLA meeting during Midwinter 2015 and elsewhere.
Following these discussions, we contacted the FCC to seek clarity on this issue. FCC staff indicated that if a library (or school) offers off-property Internet access, regardless of the technology used, that access is not E-rate eligible. This is based on the longstanding E-rate requirement that E-rate eligible services be used in an eligible location (so not at home or in a public park or somewhere similar).
The FCC is not actively reviewing the issue of whether the E-rate should pay for Internet access beyond library or school property.
Office for Information Technology Policy
American Library Association/