INTERNET FREE EXPRESSION ALLIANCE
Coalition Letter to FCC Chairman on Internet Filtering
May 13, 1999
Hon. William E. Kennard, Chairman
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554Dear Mr. Chairman:
We are writing in response to your recent remarks concerning Internet filtering software at the Annenberg Public Policy Center's Conference on Internet and the Family. As members of the Internet Free Expression Alliance (IFEA), our organizations are committed to encouraging informed public debate and discussion of proposals to rate and/or filter Internet content. We believe that the public -- and policymakers -- must closely examine filtering systems and carefully evaluate the filtering criteria they employ, as poorly designed systems can damage the unique character of the Internet.
We agree with your observation that parents should be educated on Internet use and provided with the information they need to allow them to better supervise their children's online activities. Such information should enable parents to make informed choices, including non-filtering as well as filtering options, which are consistent with their values. While the "Parents, Kids & Communications" information page at the FCC website seeks to provide such guidance, recent visits suggest that the resource is incomplete. You indicated at the Annenberg conference that, using the information page, "parents will be able to learn about [filtering] products, how they work, and how much they cost." The page currently contains links to the manufacturers of filtering products, but does not provide a balanced set of materials explaining "how they work."
As you may know, several independent studies of these products indicate that the vendors often gloss over some of the serious shortcomings of their filtering systems. We believe that an objective and useful "information page" must apprise parents of these findings. For instance, it seems inappropriate for the Commission to identify the Cybersitter product as a "software option" without alerting potential users to the fact that the system blocks the entire website of the National Organization for Women.
In the interest of presenting a balanced view of the benefits and detriments of filtering products, we request that the Commission include links to the following resources on its "Parents, Kids & Communications" web page:
"Faulty Filters: How Content Filters Block Access to Kid-Friendly Information on the Internet," by the Electronic Privacy Information Center. Report found that filtered search engines reduced access to constitutionally protected and valuable content available on the World Wide Web. It concluded that a "family-friendly search engine" typically blocked access to 95-99 percent of the material available on the Internet that might be of interest to young people.
http://www2.epic.org/reports/filter-report.html
"Censorship in a Box: Why Blocking Software is Wrong for Public Libraries," by the American Civil Liberties Union. Proposes five guidelines for libraries and schools looking for alternatives to clumsy and ineffective blocking software. The report also includes a two-page "Q&A" on blocking software and examples of sites that have been blocked by various products.
http://www.aclu.org/issues/cyber/box.html
"Access Denied: The Impact of Internet Filtering Software on the Gay and Lesbian Community," by the Gay and Lesbian Alliance Against Defamation (GLAAD). This report concludes that most filtering products categorize and block all information about gays and lesbians in the same manner that they block sexually explicit and pornographic material.
http://www.glaad.org/glaad/access_denied/index.html
"Censorship's Tools Du Jour: V-Chips, TV Ratings, PICS and Internet Filters," by the National Coalition Against Censorship. This analysis concludes that the tools available for rating and blocking content on the Internet are imprecise, denying access to constitutionally-protected material. It warns that the technological ability to "customize" information will only deepen the inevitable clash of values, as individuals with diverse views seek to have their personal preferences reflected in their schools and libraries.
http://www.ncac.org/toolsdujour.html
Testimony Submitted to the U.S. Nat'l Commission on Libraries and Information Science ("NCLIS") by People For the American Way Foundation and Mainstream Loudoun, and Testimony Submitted to the Senate Commerce Committee on Legislation seeking to require Internet filtering in public libraries and schools by People For the American Way Foundation. Discusses constitutional and policy issues concerning Internet filtering, particularly for public libraries and schools, and how to address legitimate concerns about Internet content in a way that respects and promotes First Amendment principles as well as individual and family values.
http://www.pfaw.org/netcensorship/
"Censored Internet Access in Utah Public Schools and Libraries," by the Censorware Project. This report that examines the state of Utah's use of a commercial internet censoring product in all Utah public schools and some public libraries. It found that the material blocked includes the Holy Bible, the Book of Mormon, the Declaration of Independence, the United States Constitution, all of Shakespeare's plays, and The Adventures of Sherlock Holmes.
http://censorware.net/reports/utah/
"Filtering Frequently Asked Questions (FAQ)," by Computer Professionals for Social Responsibility. A comprehensive discussion of how various filtering systems function.
http://quark.cpsr.org/~harryh/faq.html
Various software product reviews produced by Peacefire, an organization of young people concerned about the impact of filtering and blocking technology on online expression.
http://www.peacefire.org/censorware/
We also suggest that the Commission include a link to the Internet Free Expression Alliance website (http://www.ifea.net), which contains an extensive list of resources concerning the policy issues surrounding Internet filtering.
Thank you for your efforts to make the Internet a productive resource for young people. We look forward to your response to our request. Correspondence concerning this matter should be directed to David L. Sobel, General Counsel of the Electronic Privacy Information Center, 666 Pennsylvania Avenue, S.E., Suite 301, Washington, DC 20003. Mr. Sobel can be reached by telephone at 202-544-9240, and by fax at 202-547-5482.
Respectfully submitted,
American Booksellers Foundation for Free Expression
American Civil Liberties Union
Computer Professionals for Social Responsibility
Electronic Privacy Information Center
First Amendment Project
Gay & Lesbian Alliance Against Defamation
Journalism Education Association
National Coalition Against Censorship
NetAction
Peacefire
PEN American Center
People For the American Way Foundation
The Censorware Project