Correction to FCC Comment re Jail Rates - August 2015
Download original document:
![Brief thumbnail](/media/cache/80/54/805483e1cc85b2fe92befb1b95aa6a9f.jpg)
Document text
![Brief thumbnail](/media/cache/80/54/805483e1cc85b2fe92befb1b95aa6a9f.jpg)
Document text
This text is machine-read, and may contain errors. Check the original document to verify accuracy.
Human Rights Defense Center DEDICATED TO PROTECTING HUMAN RIGHTS August 6, 2015 The Honorable Tom Wheeler, Chairman Federal Communications Commission 445 12th St. S.W. Washington, D.C. 20554 Re: Correction to July 29, 2015 Comment Filed on WC Docket 12-375 Dear Chairman Wheeler: The Human Rights Defense Center (HRDC) respectfully submits this correction to our comment filed July 29, 2015 on WC Docket 12-375 regarding the arbitrary, incomplete and inconsistent filings on this Docket concerning, in part, Inmate Calling Service (ICS) rates at local jails. The need for this correction constitutes further evidence related to our July 15, 2015 comment filed on this Docket about the critical need for the Commission to address the lack of transparency in the prison telephone industry as part of comprehensive ICS reform. In our July 29, 2015 comment, we stated the Montgomery County Jail in Clarksville, Tennessee offered collect calls at a flat rate of $1.50. We recently learned this information is not correct, although in addition to a footnote in our comment with a link to the sheriff’s website detailing that rate, we also confirmed the rate by email with the sheriff’s office. Attachment 1. On August 3, 2015 we received a response to our formal public records request to Montgomery County in which we requested a copy of the current ICS contract and rate sheet. The rate sheet produced by the county reflects different ICS rates than those posted on the sheriff’s website, which had been confirmed by the sheriff’s office via email. The $1.50 flat rate for ICS calls applies only to local calls. The effective rate for 15-minute intrastate interLATA calls from the Montgomery County Jail is $0.243/minute for collect and advance pay calls ($1.97 surcharge including 1st min. plus $0.12/min.), and $0.211/minute for debit calls ($1.77 surcharge including 1st min. plus $0.10/min.). Attachment 2 P.O. Box 1151 Lake Worth, FL 33460 Phone: 561-360-2523 Fax: 866-735-7136 pwright@prisonlegalnews.org Page |2 While HRDC used the best data available, we apologize to the Commission for the error in our comment. We note, however, that if transparency was required of ICS providers and the current contract/rate data had been posted on Global Tel*Link’s website, accurate information regarding current rates and fees at the jail would have been available to consumers. We further note that members of the public cannot rely on information provided by government officials with respect to ICS rates. As illustrated in this case, we relied not only on the ICS rates posted on the Montgomery County Jail’s website, but also on information received directly from the sheriff’s office after inquiring as to the accuracy of those rates. Therefore, HRDC renews its request that the Commission require all ICS providers to post their detention facility ICS contracts, rates and fee schedules on their websites where they are publicly available. They should also be required to post the annual itemized amounts they pay to public agencies as well as related law enforcement and corrections associations such as the National Sheriffs’ Association, American Correctional Association, American Jail Association, etc. in exchange for monopoly ICS contracts. This includes money paid as commissions, donations, campaign contributions, in-kind equipment or services and related payments. Such disclosures should be made within 30 days of each payment made. Sincerely, Paul Wright Executive Director, HRDC Attachments Attachment 1 From: To: Subject: Date: Melisa F. Smith on behalf of SOINFO Carrie Wilkinson FW: Form submission from: Contact Montgomery County Sheriff"s Office Wednesday, August 05, 2015 12:06:26 PM I just spoke to Asst. Chief Tackett of our Jail Division. He said that you requested information from our PIO Jamie Dexter; the information that Mr. Dexter sent you is the correct information. -----Original Message----From: Carrie Wilkinson [mailto:cwilkinson@humanrightsdefensecenter.org] Sent: Tuesday, August 04, 2015 9:16 AM To: SOINFO Subject: RE: Form submission from: Contact Montgomery County Sheriff's Office Thanks - I really appreciate the help. I want to be sure we understand this correctly. -----Original Message----From: Melisa F. Smith [mailto:mfsmith@montgomerycountytn.org] On Behalf Of SOINFO Sent: Tuesday, August 4, 2015 7:03 AM To: Carrie Wilkinson Subject: RE: Form submission from: Contact Montgomery County Sheriff's Office I've forwarded your email to Tara Southerland, the Jail Administrative Officer; she should be able to help you. If you have not heard from her in a day or two, please contact me again. -----Original Message----From: Carrie Wilkinson [mailto:cwilkinson@humanrightsdefensecenter.org] Sent: Monday, August 03, 2015 2:29 PM To: SOINFO Subject: RE: Form submission from: Contact Montgomery County Sheriff's Office Hello, Last month you confirmed the data on the Montgomery County jail website that all calls are collect (no debit/prepaid) and cost $1.50 and you were going to correct "minimum" to "maximum." (See below). We just received a response to a public records request that includes the attached GTL rate sheet (with a date of 2014 at the bottom). The rates detailed on the attachment are different than in our prior email. Would you please confirm whether the attached rate sheet is accurate? If not, would you please confirm (or reconfirm) the current cost of telephone calls from the Montgomery County Jail? Thank you. Carrie Wilkinson Prison Phone Justice Director Human Rights Defense Center 801 Second Ave., Suite 800 Seattle, WA 98104 Office: 206.489.5604 Cell: 206.604.6145 www.humanrightsdefensecenter.org -----Original Message----From: Melisa F. Smith [mailto:mfsmith@montgomerycountytn.org] On Behalf Of SOINFO Sent: Tuesday, July 21, 2015 11:37 AM To: Carrie Wilkinson Subject: RE: Form submission from: Contact Montgomery County Sheriff's Office Thank you for your inquiry to the Montgomery County Sheriff's Office website. It is $1.50 for a collect call up to 15 minutes long. The website should say 15 minute maximum, I will update that. We do not offer pre-paid or debit calls. You can go to Global Tel Links' website and see if they offer that or not. Melisa F. Smith Executive Assistant to the Sheriff 120 Commerce Street Clarksville, TN 37040 Direct Line 931-542-5214 Fax Line 931-553-5139 -----Original Message----From: noreply@montgomerycountytn.org [mailto:noreply@montgomerycountytn.org] On Behalf Of Carrie Wilkinson Sent: Tuesday, July 21, 2015 12:27 PM To: SOINFO Subject: Form submission from: Contact Montgomery County Sheriff's Office Submitted on Tuesday, July 21, 2015 - 12:26pm Submitted by anonymous user: [73.140.47.150] Submitted values are: Please choose a topic: Jail Name: Carrie Wilkinson E-mail address: cwilkinson@humanrightsdefensecenter.org Street Address: City: State: Zip: Phone number: Your message: I would like to confirm the information on your website regarding inmate telephone calls: "Phone Service for Inmates Global Tel Link is the telephone provider for the inmates. All phone calls are collect and they are $1.50 per call (15 minutes minimum)" My questions: 1. Is this rate still accurate? If not, what are the current rates? 2. Does the jail offer prepaid or debit calls? and 3. I am a little confused by "15 minutes minimum" Does this mean the charge is $1.50 for a call up to 15 minutes? Thank you. SPAM field: The results of this submission may be viewed at: http://www.mcgtn.org/node/634/submission/48242 Attachment 2