The letter below was written by MLA President David Dahl to Dr. Chelsea Brewer, Executive Director of the Literacy Programs and Initiatives Branch, to address concerns related to proposed changes to COMAR 13A.05.04 that could weaken staffing requirements for certified school librarians across Maryland's public schools.

March 9, 2026 

Dr. Chelsea Brewer
Executive Director, Literacy Programs and Initiatives Branch
Office: (410) 767-0520
chelsea.brewer@maryland.gov 

Dear Dr. Brewer: 

I am writing today to express significant concern over proposed substantive alterations to COMAR 13A.05.04, which could undermine Maryland’s school library media programs, risk the jobs of professionally certified school librarians, and ultimately fail the students who rely on our schools to prepare them for college and careers. 

I understand the need to update the regulations for Programs for Library Media Services in order to align with the Freedom to Read Act, and I appreciate the attempt to provide clarity in order to ensure consistency across Maryland’s school systems. I can see how some of the alterations address this. However, the proposed changes in .02 C do not. They represent substantive alterations that are antithetical to the goals of the Freedom to Read Act and abandon the consistent staffing of school library media programs with trained librarians. 

What school Library Media Specialists do every day is important. Every school library needs a certified full-time Library Media Specialist. The following are a small selection of the contributions that Library Media Specialists make in the education of Maryland’s students: 

1. Teach Information Literacy – Librarians educate students on how to evaluate sources, distinguish between credible and unreliable information, and avoid misinformation. 
2. Support Academic Achievement – Research shows that schools with librarians see higher reading and writing test scores, particularly among disadvantaged students. 
3. Provide Access to Diverse Resources – School librarians curate books, digital resources, and databases that reflect a wide range of cultures, perspectives, and experiences. 
4. Encourage Critical Thinking – Librarians guide students in conducting research, analyzing information, and forming well-reasoned arguments. 
5. Bridge the Digital Divide – Many students lack access to technology at home; librarians provide access to computers, digital tools, and instruction on their responsible use. 
6. Collaborate with Teachers – Librarians work with educators to develop lesson plans, integrate research projects, and enhance student learning experiences. 
7. Promote Intellectual Freedom – Librarians protect students’ right to read and explore different perspectives, fostering open-mindedness and curiosity. 
8. Support Special Education Needs – Librarians assist students with disabilities by providing accessible resources and tailored reading programs. 
9. Develop Research and Study Skills – They teach students how to locate, organize, and use information effectively for academic projects and real-world applications. 
10. Create a Safe and Inclusive Space – Libraries serve as welcoming environments where students can explore ideas, seek help, and engage in self-directed learning. 
11. Encourage Media Literacy – Librarians help students critically analyze news, social media, and other digital content to become responsible digital citizens. 
12. Foster a Love of Lifelong Learning – By introducing students to the joy of discovery, librarians cultivate a habit of curiosity and independent learning. 
13. Provide Emotional and Social Support – Libraries offer a quiet refuge for students who need a break, a place to reflect, or someone to talk to. 
14. Increase College and Career Readiness – Research skills, digital literacy, and critical thinking—taught by librarians—are essential for success in higher education and the workforce. 

Certified librarians are connected professionally and engaged in continued education, ensuring that school library media programs remain responsive to the needs of students and proactive in facing future challenges and opportunities. 

I urge you to reconsider these alterations and emphasize consistency across Maryland’s school systems in a way that recognizes the value that certified school librarians provide. The Maryland Association of School Librarians has developed a research-informed recommendation for the staffing of school libraries. I would ask that you collaborate with them on proposed changes to the regulations for Programs for Library Media Services. 

Respectfully,
David Dahl, President, Maryland Library Association