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HRDC FCC Comment for Third FNPRM - Jan 2016

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Human Rights Defense Center

January 19, 2016

Submitted Online Only

The Honorable Tom Wheeler, Chairman
Federal Communications Commission
445 12th St. S.W.
Washington, DC 20554

Re: Comment in Response to Third Further Notice of Proposed Rulemaking,
WC Docket 12-375
Dear Chairman Wheeler:
The Human Rights Defense Center (HRDC) is pleased to submit this comment concerning the
Federal Communications Commission’s (FCC or the Commission) Third Further Notice of
Proposed Rulemaking on WC Docket No. 12-375, with respect to Inmate Calling Services (ICS).
“A dollar a minute strikes me as a fair price” . . . “I guess it
depends what viewpoint you’re coming from. The way I look at it,
we’ve got a captive audience. If they don’t like [the rates], I guess
they should not have got in trouble to begin with.” 1
– Tom Maziarz, Manager, St. Clair County,
Illinois Purchasing Dept., on video visitation
A. Promoting Competition
The key to promoting competition is allowing consumers, the people who actually pay the bills,
to choose the carrier and company that is best suited to their needs and budgets. That is the only
way to inject competition into the government-created and sustained monopoly ICS market that
currently exists. Security concerns by the beneficiaries of the current system are a red herring,
as demonstrated by the State of Iowa, which contracts out the security functions of its ICS and
pockets all the resulting phone revenue itself. There is no reason why the government cannot

1 [Attachment 1].

P.O. Box 1151
Lake Worth, FL 33460
Phone: 561.360.2523 Fax: 866.735.7136

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provide ICS itself without a company middleman in the mix – a middleman whose only purpose
is to extract money from prisoners and their families to pad the coffers of their hedge fund
owners in the case of Global Tel*Link and Securus. Given the latest rate caps imposed by the
Commission, state Departments of Correction may eventually realize that they can dispense with
ICS providers and supply their own in-house telephone services, keeping all of the revenue
generated or, like the Iowa DOC, only contract for certain aspects of ICS.
In a 2013 filing on this Docket regarding commissions and the lack of a competitive ICS market,
Verizon and Verizon Wireless suggested that allowing multiple ICS providers “could promote
competition among ICS providers,” adding, “If the benefits of competition were extended to the
actual users of the service, inmates could select the provider with the lowest rates and therefore
engage in more frequent or lengthy communication with their families.” [Attachment 2]. While
also citing the need to recognize efficiencies from exclusive contracts, Verizon notes that “While
the Commission has previously acknowledged that these considerations may justify exclusive
contracts for ICS services, that analysis may be outdated in light of technological advances.” Id.
at 7. Submitted almost three years ago, Verizon’s assessment that advanced technologies offer
efficient ways in which ICS services can be provided, including the security measures that are
needed, is even more true today.
The Inmate Calling Services industry is an oligopoly controlled by a small number of service
providers; Global Tel*Link (GTL), Securus and Telmate are the three primary ICS providers,
representing 85% of industry revenue in 2013. 2 This structure results in monopoly contracts
granted by the government agencies that run detention facilities to the service provider willing
to pay them the largest site commission, which in reality is nothing more than a legal kickback.
While we will let the ICS providers and sheriffs argue among themselves about who is at fault
for the kickbacks and the unfair, unjust and unreasonable ICS rates that have resulted, there is no
argument that kickbacks artificially inflate the ICS rates that prisoners and their families must
pay to remain in contact during critical times of incarceration. 3 There is also no argument that
this is a recent creation and that prior to the late 1980s most prisoners enjoyed telephone access
at very low rates. Only after Evercom introduced kickbacks to government entities in exchange
for monopoly contracts did the cost of prison and jail phone calls explode to the obscene levels
experienced by prisoners and their families in recent times. No one else in America pays so
much for so little when it comes to telephone service. We can note these concerns would not
be before the Commission if this was a case of the government contracting for services it was
paying for. Instead, they contract for services at the highest price to the consumer when it is the
consumer paying the bill and the agency that gets a kickback from the revenue generated.
The lack of transparency inherent in the ICS industry has hampered the ability of both the
Commission and advocates alike to address what their costs and profits actually are. We urge the
FCC to use its subpoena power to directly review financial documents from all ICS providers
and not rely on their self-serving, self-funded reports.

See Joint Provider Proposal, WC Docket No. 12-375, September 15, 2014 at 1.
“We reiterate, however, that site commissions have been a significant driver of rates.” See Third FNPRM, adopted
October 22, 2015, at ¶118, fn 375.

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Nowhere is this better illustrated than the cost study that Securus submitted to the FCC in this
Docket, purporting to show its cost of providing ICS, compared with the firm’s prospectus 4 that
it provides to potential investors – which shows massive profits made on the backs of the poor
people forced to use their services. It cannot be both. They are either lying to the Commission
or lying to their investors, but in either case it is the public and consumers who are victimized
by this chicanery and gaming of the system. For the public to have trust in our governmental
institutions there must be transparency and openness, which is sadly lacking in the ICS market.
Rather than rely on the ICS industry to submit self-serving reports on their purported costs and
profit margins, the FCC should exercise its subpoena power, obtain the raw financial data and
analyze it itself as it does in other areas of telecom regulation.
The legal kickbacks paid by ICS providers to detention facilities are well documented and
require no further elaboration. What is still largely unknown is the level of illegal and criminal
bribery used to secure detention facility ICS contracts. Recently Mississippi state prison boss
Christopher Epps was convicted of taking bribes from numerous prison vendors, including from
Global Tel*Link consultant Sam Waggoner. The profits of the ICS industry are so vast they can
afford kickbacks to the government as well as to the individuals who lobby for the contracts,
with no oversight. It is unknown at this time what criminal bribery the ICS industry engages in
to obtain these lucrative contracts. 5 The ICS industry is the most glaring example of the axiom
that absolute power corrupts absolutely.
As noted by the Commission, HRDC maintains that a competitive and free market will only
prevail in the ICS industry when consumers are afforded the choice to select the ICS provider
that offers the best service at the lowest price. 6 The monopoly contract holders that oppose this
idea state that investigators would be conducting duplicative search procedures and that there
would be a need to install and maintain separate telephone systems. 7
While we question whether these burdens, if true, should be placed on the backs of prisoners’
families instead of the entities profiting from ICS calls, HRDC encourages the Commission to
require extensive comment from ICS providers with respect to the ways advanced technologies
can be used to overcome obstacles that may have existed previously. If the technology exists,
and it does – as Securus-owned JPay tablets that allow for email are “currently in the hands of
over 60,000 inmates” [Attachment 3, at pg.1], and such wi-fi based tablets for prisoners still
have security features intact – then we are hard-pressed to believe that technologies do not exist
that would allow ICS providers to effectively deal with multiple carriers in correctional facilities.
Moreover, prison and jails provided secure telephone services 30 years ago at a fraction of the
cost with technology that is today obsolete and much cheaper. If the FCC could lower the cost of
consumer telephone calls by breaking up the AT&T monopoly, then it can certainly do the same
with the ICS oligopoly.


See Attachment 5, referenced infra.
See HRDC’s comment submitted on this Docket on October 4, 2015.
See Third FNPRM, adopted October 22, 2015, at ¶293.

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Finally, HRDC believes that the Commission should first adopt rate and ancillary service charge
reform and then take the steps required to address the issue of intra-facility competition. ICS
providers have been allowed to prey on the families of prisoners for decades through egregious
rates and ancillary fees designed to do nothing more than generate profit for predatory hedge
fund-owned corporations and the government. This unfair marketplace evolved over time and
prisoners and their families will benefit most both economically and emotionally if it is regulated
over time, with the immediate adoption of rate and ancillary service charge reform.
Commissioner Mignon Clyburn stated, “for too long we remained idle as families, friends,
clergy, attorneys and coalitions pleaded for relief.” 8 She is correct and we respectfully request
that the Commission take immediate action with respect to the adoption of rates and ancillary
service charge reform.
B. Video Calling and other Advanced Inmate Communications Services
Video calling, including video visitation, has increased since the Commission adopted the 2013
Order 9 and the Commission has good reason to be concerned “that rates for video calling and
video visitation services that do not meet the definition of ICS could used as a way to allow ICS
providers to recover decreased rates as a result of the reform adopted herein.” 10 We need look no
further than daily news reports to tell us this. A December 30, 2015 article reporting that West
Virginia will comply with the FCC ruling regarding prison telephone rates quotes Lawrence
Messina, a spokesman for the agency that oversees the state’s regional jails, as saying “RJA is
exploring other revenue options to offset any effects of the FCC ruling.” The next and final
sentence of the article reads: “One such option is installing video kiosks in the state’s
correctional facilities that offer fee-based services, Messina said.” [Attachment 4].
In a 2015 investor prospectus, Securus boasts that it is expanding into unregulated areas of prison
and jail communications in order to increase its profits. [Attachment 5]. A key form that this
monetization has taken for Securus and other ICS providers is charging to provide services
(visitation, money transfers to prisoners, etc.) previously provided at no cost by the government.
Like kidnappers and extortionists in other contexts, the ICS industry and its government partners
have discovered that people will pay money to communicate with and send money to their loved
ones who are imprisoned against their will. Charging for services previously provided at no cost
to the public is not a technological innovation. It is merely a new form of economic exploitation.
HRDC advocates for video visitation as an affordable option to in-person visitation, but it must
be exactly that. Under no circumstances should in-person visitation be eliminated and replaced
with video visitation, and prisoners’ families should not be price gouged for video visitation
services as they have been with prison phone calls. Video visitation should be provided at no
cost to prisoners and their families. Rather than issue revenue-generating contracts where the

Statement of Commissioner Mignon Re: Rates for Interstate Inmate Calling Services, WC Docket No. 12-375
(October 22, 2015).
See Third FNPRM, adopted October 22, 2015, at ¶296.

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government agency seeks to monetize human contact, government agencies can and should issue
procurement contracts where they purchase the service to provide to prisoners and their families
as part of their agency budgets. Currently people around the world use Skype and other video
platforms at no or low cost – including, it is critical to note, prisoners in other countries that are
not serviced by an exploitive ICS industry, such as the United Kingdom, India and even the
Philippines. We should note that historically, American prisoners and their families have never
paid for visitation. It has always been provided as a government service, and the ICS industry
and its government collaborators are simply seeking to monetize human contact under the guise
of “technological innovation.” The only innovation is charging poor people for a government
service previously provided by and paid for through public agency budgets.
While the dataset for this newer technology is still being developed, what is clear is that the
video visitation business model mirrors the prison telephone business model: monopoly contracts
are granted to ICS providers that reward the government agency with a kickback. We are seeing
the same arbitrary rates and fees being charged to prisoners’ families for video visitation that we
did for prison phone calls, including rates of up to $1.00/min. for video visits in some cases.
The Securus website ( was utilized on January 6,
2016 to obtain the data used in the following table for comparison:
Video Visitation


Duration of Video Visit


Knox Co. Jail, IL
Pottawattamie Co. Jail,
Porter Co. Sheriff’s
Dept., IN
Lake Co., IL
King Co. RJC, WA


20 Minutes
30 Minutes



20 Minutes



30 Minutes
20 Minutes


A report prepared by Grassroots Leadership in Austin, Texas and the Texas Criminal Justice
Coalition in October 2014 provides further detail about the trend to increase video visitation
primarily in jails across the country: Video Visitation: How Private Companies Push for Visits by
Video and Families Pay the Price. [Attachment 6]. Further, the Prison Policy Initiative (PPI)
has done extensive research with respect to video visitation, and in January 2015 reported that
more than 500 facilities in 43 states and the District of Columbia are experimenting with video
visits. See: Screening Out Family Time: The for-profit video visitation industry in prisons and
jails. 11


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The Grassroots Leadership report notes that the American Bar Association (ABA) standards are
clear that video visits should not be a replacement for in-person contact, and that video visitation
systems that had been started in 18 of the 50 state prison systems were “supplemental to inperson visits.” Attachment 6, at 3. The authors of the report considered it “curious” that county
jails with populations largely comprised of non-convicted individuals would be so quick to cite
security concerns as the justification for eliminating in-person visits while state prison systems,
which only hold convicted felons serving prison sentences, do not. Id.
And are the security concerns cited by the jails legitimate? Clearly they weren’t at the Travis
County Jail in Texas. The Travis County Jail went to video-only visitation in May 2013 after
“jail administrators promised that eliminating in-person visits would increase jail security and
reduce contraband and free up guards for other duties.” Id. at 4. As noted in the Grassroots
Leadership/Texas Criminal Justice Coalition report, disciplinary infractions increased from
approximately 820 in May 2012 to 1,160 in April 2014. Disciplinary cases for possession of
contraband increased an overall 54% from May 2013 through May 2014, and prisoner-onprisoner assaults increased 20% between May 2012 and May 2014. Prisoner-on-staff assaults
doubled after the elimination of in-person visits. Id.
In October 2015 the Travis County Commissioners approved a $707,000 measure to reinstate inperson visitation at the Travis County Jail. [Attachment 7].
Further, a March 2015 article cited PPI’s work, noting that “74 percent of county jails that added
video visitation also ended traditional visitation.” [Attachment 8]. The article also referenced
a 2008 study published in the Journal of Research in Crime and Delinquency that concluded
“visitation and more frequent visitation were both associated with a lower likelihood of
recidivism.” Id.
Securus CEO Richard Smith notes that the elimination of face-to-face visits is “a negotiation
point for sure,” adding that “If they’re willing to do less face-to-face because of their needs,
I probably benefit because there’s going to be more remote video visitation.” Id. It is welldocumented on this Docket that a jail’s primary “need” is the highest kickback possible, and
under the perverse business model that exists in the ICS and video visitation industry, there can
be no other result than further elimination of in-person visits for no reason other than profit.
The U.S. Department of Justice’s National Institute of Corrections states in a report published in
December 2014 that “Video visiting cannot replicate in-person visiting,” and that “It is unknown
how effectively [video-based] relationships are established and maintained as compared to inperson visiting.” 12
The digital divide is also a critical consideration that must be addressed in any discussion of
video visitation. As noted in the Grassroots Leadership/Texas Criminal Justice Coalition report,
computer literacy and the demographics of those in American prisons and jails – “poor, mostly

U.S. Department of Justice, National Institute of Corrections, Video Visiting in Corrections: Benefits, Limitations
and Implementation Considerations, at 21; available at:

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minority, a significant portion of whom speak Spanish as a first language” – affects this
population’s ability to use video visitation technology in a meaningful way. 13
Computer literacy, especially for elderly family members, must be addressed in addition to the
economic challenges faced by the families of those who are incarcerated. The Commission
published the following facts in its June 18, 2015 press release, “FCC Takes Steps to Modernize
and Reform Lifeline for Broadband”: 14

While over 95% of households with incomes of $150,000 or more have access, only 48%
of those making less than $25,000 have service at home.
Low-income consumers disproportionately use smart phones for Internet access – but
nearly 50% of them have had to cancel or suspend smartphone service due to financial

Many prisoners’ families fit into these demographics; video-only visitation and/or excessive
rates and fees will do nothing more than further isolate prisoners from their families, the same
way exorbitant prison and jail phone costs have done for decades.
Prisoners in the U.K. are able to make video calls to their families at no cost to them utilizing
Skype [Attachment 9], as are prisoners in the Philippines, where the Solicitor General donated
the computers and the jail administration “pledged to shoulder the 20-dollar monthly WiFi
connection fee.” [Attachment 10]. Both countries utilize Skype and computers with webcams;
calls are monitored by jail and prison staff. Additionally, prisoners in India are provided with
access to video visits at low cost, at the Tihar Jail. 15
Skype is free, and video visitation in the United States should also be free with no additional
ancillary fees or charges. This is not a fanciful idea. Beyond free video visitation at prisons and
jails in other countries, prisoners at the Mike Durfee State Prison in Springfield, South Dakota
are taking part in a pilot program that allows them to have free video visits with approved family
members and friends through Skype. Computers with webcams, audio speakers and headphones
are available inside the facility, and a staff member monitors the video visits. “Visits are limited
to 15 minutes in length and are held on weekdays between 8:25 a.m. and 3:15 p.m. and on
Wednesday evenings from 5:00 p.m. to 9:00 p.m.” Video visits must be scheduled one week in
advance; family members and friends on an approved visit list must call in to set up a video visit
for the following week. Prisoners are limited to two video visits per calendar month. 16
The FCC lacks the ability and the authority to order detention facilities to provide in-person
visits, just as it cannot order them to provide video visitation or not. However, the Commission
can prohibit ICS providers from requiring detention facilities to end in-person visitation as a

See Attachment 6.
15 and

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condition when video visits are implemented. The Commission has the ability and the authority
to prevent prison and jail video visitation from becoming the next form of consumer exploitation
by the ICS industry. So long as ICS providers and their government partners can profit from
visitation, they will have every incentive to eliminate in-person visits and replace them with
costly low-quality video visitation. Video visits can and should be provided at no cost to the
consumer and should not be a revenue-generating service for detention facilities.
C. Recurring Data Collection
ICS providers should be required to submit cost data in annual Mandatory Data Collections for a
minimum of five years. The FCC should use its subpoena power to obtain this information and
also require that the submissions be made under penalty of perjury by the relevant officers of the
companies. At that time it should be clear whether the Commission’s reforms have created and
maintained the proper incentives to drive ICS rates to competitive levels, and a determination
could be made as to whether there is a need to continue Mandatory Data Collections. We need
look no further than the Joint Provider Proposal filed by the three largest ICS providers to see
why such data collection is necessary. 17 The proposal strongly advocated for a unified rate of
$0.20/min. for all debit/prepaid interstate and intrastate calls, and $0.24/min. for all collect
interstate and intrastate calls. But as it turned out, once the cost data submitted through the onetime Mandatory Data Collection was analyzed, the Commission was able to establish rate caps
for debit/prepaid calls well below the rates proposed by the ICS providers, with collect calling
rates at jails being initially higher before they phase down to the rate caps.
HRDC has provided extensive detail on this Docket about state prisons with ICS rates under
$0.11/min., including New York, West Virginia, New Jersey, New Mexico, New Hampshire,
Rhode Island, Ohio, Pennsylvania, South Carolina and Nebraska. Our most recent docket filing
on December 31, 2015 18 reported that Virginia not only reduced its ICS rate to $0.0409/min., but
did so effective December 1, 2015 – after the Commission’s Order capping rates at $0.11/min.
was adopted and during the same period of time that GTL, the Virginia DOC’s ICS provider,
was telling the FCC that the rate caps don’t cover the cost of providing ICS.
Requiring Mandatory Data Collections for a five-year period should allow most ICS contracts to
roll over during that time frame; much will be learned from this data, particularly since most ICS
providers have demonstrated they will not provide such information voluntarily.
D. Contract Filing Requirement
As noted by the Commission in ¶311 of the Third FNPRM, HRDC has noted and documented
“almost a total lack of transparency on behalf of both ICS providers and the government
agencies from which they secure their monopoly contracts,” and Mr. Baker of the Alabama PSC
asserts that the lack of transparency in the ICS industry is “problematic.”

See Joint Provider Proposal, WC Docket No. 12-375, September 15, 2014.
See Human Rights Defense Center Comment, WC Docket No. 12-375, December 31, 2015.

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The lack of transparency is how the ICS industry was able to develop predatory practices and
take advantage of some of this country’s poorest citizens for decades – because they were under
no requirement to disclose what they were doing. It was only after HRDC began collecting ICS
data through state public records requests (sometimes having to sue to get the data) on a national
basis in 2009 that the Campaign for Prison Phone Justice and other interested organizations and
individuals could take the first informed steps towards advocacy for prisoners and their families.
HRDC continues to advocate that ICS providers be required to post their contracts with detention
facilities on their websites and to make them publicly available. Each ICS provider should be
required to publicly post the contract for each facility it services, the cost of the calls and the
amount of the kickback it gives the facility, as well as any in-kind payments such as campaign
donations, equipment, etc. HRDC and other advocates are acutely aware of the gaps in the data,
especially when it comes to jails – such data gaps are exploited by the ICS industry and jails to
argue for higher caps. HRDC has had to file two public records suits to obtain basic ICS contract
information, and currently GTL has filed a court appeal to prevent the Pennsylvania Department
of Corrections from disclosing the details of its ICS contract. The burden on ICS providers to
post these documents on their websites is minimal and the benefits to the public are enormous.
E. International Calling Rates
As the record reflects, it is critical for immigrant detainees to stay in touch with their support
networks outside the U.S. to help them gather substantial records and information required to
present their case in deportation hearings. This segment of the prisoner population is particularly
vulnerable to exorbitant phone rates. Immigrant detainees held by ICE pay “a uniform rate of 15
cents per minute for international calls to landlines and 35 cents per minute for international calls
to mobile phones” with “no additional connection fees or ancillary charges,” based on data
provided at the 2014 FCC Workshop. 19
This data is telling for two reasons:
1. It informs us that companies can provide international ICS with phone rates that are both
significantly more reasonable than most intrastate domestic calls provided by ICS
providers, and connection and ancillary fees are not required; and
2. It begs the question of why there is such a dramatic rate difference between calls made to
landlines and mobile numbers – does the cost data support an increased rate of more than
130% to connect to an international mobile number?
HRDC calls for a two-pronged approach to ICS international calls:
1. After the Commission has reviewed sufficient cost data for international calls, it should
set rate caps for such calls that are fair, just and reasonable, as it did with domestic ICS
rates; and
2. As an interim measure, the rates for international calls should be set at the current rates
charged by the ICS provider for ICE facilities, with no ancillary fees or charges.

See Third FNPRM, adopted October 22, 2015, at ¶321.

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F. Third-party Financial Transaction Fees
HRDC fully supports the Commission’s ruling not to allow any additional fees or markup that
the ICS provider might impose on the end user, and to require ICS providers to pass third-party
transaction fees to end users with no additional markup. 20 Additionally, we urge the FCC to
closely examine the data contained in PPI’s January 19, 2015 submission, titled “Comment Re:
Second Report and Order and Third Further Notice of Proposed Rulemaking ¶¶ 324-326 – the
new regulations leave a loophole for unjust profit-sharing via Western Union and MoneyGram,”
with respect to the loophole created by the Commission’s definition of “Third-party Financial
Transaction Fees” as fees that are paid by “Providers of Inmate Calling Services” – since such
fees are in fact paid by ICS consumers.
Further, key evidence provided by PPI in their report strongly suggests the possibility of gaming
by GTL and Securus. At $10.95 and $10.99 per third-party financial transaction, respectively,
these two ICS providers should be required to explain why the fees consumers must pay to send
money to prisoners through Western Union are higher than those charged for consumers to send
funds through other ICS providers. Presumably, the two largest ICS providers process more
transactions through Western Union and other third-party services. Assuming efficiencies in
their businesses through economies of scale, commission kickbacks to GTL and Securus may
be the reason these third-party transaction fees are so high – as kickbacks make all rates and
fees artificially higher, whether being paid to a sheriff, ICS provider or other entity.
We are watching history repeat itself. As noted in this comment, other filings on the docket and
news media reports, ICS providers and government agencies are clearly applying the same
decades-old prison phone industry business model to video visitation, and are attempting to take
us all down the same path – which leads to egregious price gouging of prisoners’ families so the
telecoms can create excessive profits and correctional facilities can be subsidized by some of our
nation’s poorest citizens.
HRDC calls on the Commission to implement the same comprehensive reforms for prison video
visitation services as it has for the prison phone industry. Video visitation should be provided at
no cost with no ancillary fees, considering it is a service that is free to non-incarcerated persons.
In-person visitation should not be eliminated to increase the volume of video visits; prisoners
being allowed to visit and see their families during times of incarceration is just as important as
being able to talk with them on the phone.
Transparency is a critical part of comprehensive reform. We’ve seen what happened after ICS
providers and correctional facilities created their perverse business model and tried to hide it,
and they will do the same with video visitation. The FCC should utilize its subpoena power to


Id. at ¶324. Note that HRDC opposes the imposition of all ancillary ICS fees, including third-party fees.

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uncover the true costs of all ICS services. The disparity in the form and details of the cost data
produced by ICS providers through the Mandatory Data Collection should be reason enough to
justify why this measure is required.
ICS providers, particularly GTL and Securus, have clearly been upset by the Order adopted by
the Commission on October 22, 2015, and by what they claim is adverse public reaction to the
disclosure of their exploitive business practices. Notably the ICS providers are not upset about
their egregious business model, just the fact that people found out about it and are outraged. The
public reaction should be adverse – in a major way. That the ICS business model was allowed to
even exist let alone require some of our poorest citizens to pay such exorbitantly unjust, unfair
and unreasonable phone rates for so long is exactly the reason the practices of the ICS industry
must be fully transparent. History has shown what this industry and its government allies will
do to citizens and consumers behind closed doors.
Comprehensive regulation for video visitation and other advanced communication technologies
in detention facilities is needed now. Prisoners and their families, especially those with children,
should not be required to suffer for decades while privately-held companies and correctional
facilities use them to generate profit, as was the case with ICS. The Commission has the power
and the responsibility to mandate fair, just and reasonable business practices for all aspects of the
prisoner communication industry, and we urge the immediate implementation of such reforms.
Thank you for your time and attention to this matter. I and other HRDC staff are always
available to provide additional information or details to the Commission and its staff.

Respectfully submitted,

Paul Wright
Executive Director, HRDC