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PLN comment to FCC re prisoner literacy May 2007

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Dedicated to Protecting Human Rights

2400 NW 80th Street #148, Seattle WA 98117 — 206-246-1022 fax: 515-581-0776
Please Reply to Tennessee Office:

May 14, 2007
Direct Dial: 615-255-5357
5341 Mt. View Rd. #130
Antioch, TN 37013


Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

RE: Reply Comment Regarding CC Docket No. 96-128 (Implementation
of Pay Telephone Reclassification and Compensation Provisions of
the Telecommunications Act of 1996)
Dear Ms. Dortch:
On April 19, 2007 I submitted a letter in reference to CC Docket No. 96-128 (the Wright
petition), in my capacity as Associate Editor for Prison Legal News, a non profit, nationallydistributed publication that reports on criminal justice and corrections-related issues.
On May 10 I received a responsive e-mail from Douglas Galbi, an FCC economist, who
requested clarification of one of the statements in my letter, in which I said, "almost 70% [of
prisoners] perform at the lowest levels of reading and are considered functionally illiterate…."
That statement was made in the context that phone calls provide an important link between
prisoners who have literacy problems and their families and children.
The basis for my statement that almost 70% of prisoners perform at the lowest levels of
reading and are considered functionally illiterate can be found at the below link, based on a 1992
report by the National Institute for Literacy (NIFL).
The relevant section states, "In 1992, 40% of the prison population was at quantitative
literacy Level 1, compared to 22% of the household population; 32% were at Level 2, compared
to 25% of the household population; 22% were at Level 3, compared to 31% of the household
population; 6% were at Level 4, compared to 17% of the household population; and 1% were at
Level 5, compared to 4% of the household population (Haigler, p19, Table 2.3)." See:

For a more detailed analysis, please see the following link for a report on the 1992
National Assessment of Adult Literacy (NAAL) study of prisoners, which states, "About 7 in 10
prisoners perform in Levels 1 and 2 on the prose, document, and quantitative scales. These
prisoners are apt to experience difficulty in performing tasks that require them to integrate or
synthesize information from complex or lengthy texts or to perform quantitative tasks that
involve two or more sequential operations and that require the individual to set up the problem."
Also see the following link to the National Adult Literacy Database, which describes the
two lowest levels of literacy in relation to illiteracy rates for prisoners (with footnotes):

There is a more recent and comprehensive 2003 report from the National Center for
Education Statistics available at the following link; however, please note that the definitions for
the lowest literacy levels may not be completely identical between the 1992 and 2003 reports:

Also note that levels of illiteracy among prisoners vary according to the study and other
factors (e.g., prison vs. jail populations). For example, a 2005 UK study found that about half of
prisoners suffered from "poor literacy and numeracy skills; 1998 test results from the UK prison
service found 60% of prisoners "had problems with literacy, and 40% had a severe literacy
problem." And according to a report from the director general of HM Prison Service, "Half of all
prisoners have serious problems with reading, two-thirds with numeracy and four-fifths with
writing." For references please see the following link:

I trust this information is helpful; please do not hesitate to contact me should you require
any additional information on this point or related to other issues raised in my letter regarding the
Wright petition.

Alex Friedmann
Associate Editor, PLN
cc: Paul Wright, PLN Editor