March 25, 2013
Chairman Julius Genachowski
Commissioner Robert McDowell
Commissioner Mignon Clyburn
Commissioner Jessica Rosenworcel
Commissioner Ajit Pai
Federal Communications Commission
445 Twelfth Street, SW
Washington, DC 20054
RE:

WC Docket No. 12-375, Rates for Interstate Inmate Calling Services

Dear Chairman and Commissioners:
As organizations with a strong interest and expertise in criminal justice policy, we write to urge the
Federal Communications Commission to adopt into final rules the proposals in the long-pending Wright
Petition. We are pleased the Commission has finally opened a proceeding to develop a factual record that
will enable the Commission to adopt final rules ending predatory prison phone rates for long-distance
calls. As groups that work to improve the criminal justice system, we see firsthand the challenges that
high telephone rates pose, and write now to specifically emphasize how the high costs of telephone calls
negatively impact the overall societal goal of reintegrating formerly incarcerated individuals to be full
participants in society.
Prisons charge incarcerated individuals significantly higher rates for phone calls than what most people in
the United States are charged. The cost of a typical interstate collect call from a prison includes a $3.95
connection fee (regardless of the length of the call), while per minute rates can be as high as $0.89. This
results in charges of $10-17 for a 15-minute collect call or $300 per month for a weekly one-hour call.
Maintaining family relationships is a primary means to reduce recidivism, which is at crisis levels in the
United States. Within three years of being released, 67 percent of ex-prisoners re-offend, and 52 percent
are re-incarcerated. Americans are paying dearly for this trend. According to the Pew Center on the
States, state and federal spending on corrections has grown 400 percent over the past 20 years, from about
$12 billion to about $60 billion. Interventions that prevent further crime result in substantial cost savings
for local governments. For example, the Urban Institute evaluated a family therapy intervention for
juveniles incarcerated in DC jails, concluding that on average, the program reduced arrests by 22.6
percent for program participants.1 The analysis found that each prevented arrest saves local agencies
$26,100 and federal agencies $6,100 and that, on average, each averted arrest prevents $51,600 in
associated victim harms, which accounts for more than 60 percent of all savings from averted crimes.2

1

Samuel Taxy, et al., The Costs and Benefits of Functional Family Therapy for Washington, D.C., at 3, District of
Columbia Crime Policy Institute (September 2012) available at http://www.urban.org/UploadedPDF/412685-TheCosts-and-Benefits-of-Functional-Family-Therapy-for-Washington-DC.pdf.
2
Id.

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Page 2 of 4

Families and other social networks play a critical role in prisoners’ successful transition from
incarceration to the community,3 and reentry is very difficult without strong social support networks.4 In
addition to offering housing, families may assist incarcerated individuals with securing a job, obtaining
child care while they are working, and decreasing their abuse of alcohol and other drugs.5 In a long series
of studies, the Urban Institute found that the ability of men to secure a job before release was one key
factor in obtaining employment after release. In the same study, men who were strongly attached to their
children fared better on employment and substance abuse after release, and married prisoners were more
likely to report being employed eight months after release.6 Incarcerated individuals who have more
contact and stronger relationships with their families were less likely to be re-incarcerated or arrested
once they are released.7
The Vera Institute recently completed a study on the Family Justice Program’s “Reentry is Relational”
project, which encourages family members and prisoners to maintain their communication and ties as a
way to promote successful reentry into society post-incarceration and to minimize recidivism. In that
study, 92 percent of incarcerated individuals expected to rely on family members for support, and 66
percent expected to rely on friends.8 Among the sources of support that family members provided to
incarcerated individuals were financial support; emotional support, guidance, and advice; and child care
and/or facilitating visits from children.9
3

Margaret diZerega and Sandra Villalobos Agudelo, Piloting a Tool for Reentry, A Promising Approach to
Engaging Family Members at Vera Institute (2011) available at http://www.vera.org/pubs/piloting-tool-reentrypromising-approach-engaging-family-members. See also Jeremy Travis, Amy L. Solomon, Michelle Waul, From
Prison to Home: The Dimensions and Consequences of Prisoner Reentry (Urban Institute, 2001); Nancy G. La
Vigne, et al., Chicago Prisoners’ Experiences Returning Home (2004); Jeremy Travis & Christy Visher, Prisoner
Reentry and Crime in America (Cambridge Univ. Press, 2005); Rebecca L. Naser and Nancy G. La Vigne, “Family
support in the prisoner reentry process: Expectations and realities,” Journal of Offender Rehabilitation, 43 (1): 93106 (2006); Peggy Burke and Michael Tonry, Successful Transition and Reentry for Safe Communities: A Call to
Action for Parole (Center for Effective Public Policy, 2006); Christy Visher and Shannon Courtney, One Year Out:
Experiences of Prisoners Returning to Cleveland (Urban Institute, 2007).
4
See Marta Nelson, Perry Deess and Charlotte Allen, The First Month Out: Post Incarceration Experiences in New
York City (Vera Institute, 1999); Eileen Sullivan et al., Families as a Resource in Recovery from Drug Abuse: An
Evaluation of La Bodega de la Familia (Vera Institute of Justice, 2002); Shirley Klein, Geannina S. Bartholomew,
and Jeff Hibbert, “Inmate Family Functioning.” International Journal of Offender Therapy and Comparative
Criminology 46: 95-111 (2002); Creasie Finney Hairston, “Prisoners and Their Families: Parenting Issues During
Incarceration,” (paper presented at From Prison to Home, a conference hosted by the U.S. Department of Health and
Human Services and Urban Institute, Washington DC, 2002); Nancy G. La Vigne, et al., Chicago Prisoners’
Experiences Returning Home (The Urban Institute, 2004); La Vigne, Schollenberger and Debus, One year out:
tracking the experiences of male prisoners returning to Houston, Texas (Urban Institute, 2009).
5
diZerega and Agudelo (citing La Vigne et al., 2004; Nelson et al. 2002, Eileen Sullivan et al., 2002, Visher et al.,
2004).
6
Visher, et al., Life after Prison: Tracking the Experiences of Male Prisoners Returning to Chicago, Cleveland, and
Houston (Urban Institute Justice Policy Center, 2010) at 5 available at:
http://www.urban.org/UploadedPDF/412100-life-after-prison.pdf.
7
deZerega and Agudelo (citing Damian J. Martinez and Johnna Christian, “The Familial Relationships of Former
Prisoners: Examining the Link Between Residence and Informal Support Mechanisms,” Journal of Contemporary
Ethnography 38, no. 2 (2009): 201-24; Hairston, 2002); Rebecca Naser and Christy Visher, “Family Members’
Experiences with Incarceration and Reentry,” Western Criminology Review 7, no. 2 (2006): 20-31.
8
Id. at 7.
9
Id. at 8.

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In most cases, individuals are incarcerated in facilities that are on average more than 100 miles away from
loved ones, making telephone communication the key to keeping family bonds intact. The research also
supported the need for communication beyond in-person visits, as well as the need for low costs for phone
calls. In one study, more than half of incarcerated parents reported never receiving a personal visit from
their children.10 In the Vera Institute study, 27 percent of the incarcerated people surveyed indicated that
they had not had any visits during their incarceration, and the primary reason was because family
members lived too far away. Seventy-six percent of family members described significant barriers to
maintaining contact, including the cost of calling cards and expensive collect calls.11 In another analysis,
although children who are incarcerated or in juvenile detention were found to do better with family
support, prisoners reported the cost of telephone calls as a major barrier to maintaining contact.12 These
burdens and costs are all the more challenging because family members themselves struggle with their
own limited incomes, educational attainment, and resources.13
High telephone rates, in combination with other policies limiting prisoner’s access to telephone calls, can
make it more difficult for incarcerated people to communicate with their lawyers, which is particularly
problematic for inmates with literacy challenges or limited English.14 Better communication can also
contribute to safer prisons by reducing the number of disciplinary incidents.15
We believe a Federal Communications Commission decision to cap interstate telephone rates for
prisoners will promote a safer society by facilitating more successful reentry for prisoners post-release.
Thank you for your consideration of our views.
Sincerely,
National Organizations
1. American Civil Liberties Union
2. American Probation and Parole Association
3. Campaign for the Fair Sentencing of Youth
4. Drug Policy Alliance
5. Equal Justice Initiative
6. Families Against Mandatory Minimums
10

Jeremy Travis, et al., Families Left Behind, the Hidden Costs of Incarceration and Reentry (Urban Institute, 2005)
available at http://www.urban.org/UploadedPDF/310882_families_left_behind.pdf.
11
diZerega and Agudelo at 9.
12
Families as Partners: Supporting Incarcerated Youth in Ohio, Vera Institute Research Brief at 2 (January 2012)
available at: http://www.vera.org/sites/default/files/resources/downloads/Families_as_partners.pdf.
13
La Vigne et al. 2009; Tracey L. Shollenberger, When Relatives Return: Interviews with Family Members of
Returning Prisoners in Houston, Texas. (Urban Institute, 2009), available at:
http://www.urban.org/UploadedPDF/411903_when_relatives_return.pdf.
14
Resolution of the American Bar Association (2004),
15
John J. Gibbons and Nicholas deBelleville Katzenbach, Confronting Confinement: A Report of The Commission
on Safety and Abuse in America's Prisons, 22 Wash. U. J. L. & Pol’y385, 438-39 (2006), available at
http://digitalcommons.law.wustl.edu/wujlp/vol22/iss1/25.

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7. Fed CURE
8. International Community Corrections Association
9.
10.
11.
12.
13.
14.

Japanese American Citizens League
The Leadership Conference on Civil and Human Rights
Legal Action Center
National Association of Criminal Defense Lawyers
National Association of Evangelicals
National Association of Social Workers

15.
16.
17.
18.
19.
20.
21.

National H.I.R.E. Network
National Legal Aid & Defender Association
The Innocence Project
The Constitution Project
The Sentencing Project
Treatment Communities of America
United Methodist Church, General Board of Church and Society

22. United States Conference of Catholic Bishops
State and Local Organizations
23. A New PATH (Parents for Addiction Treatment & Healing)
24. College and Community Fellowship
25. Correctional Association of NY
26. Criminon New Life DC
27. CURE-Women Incarcerated
28. Direct Action for Rights and Equality
29. North Carolina Harm Reduction Coalition (NCHRC)
30. Protect Families First
31. The Center for NuLeadership on Urban Solutions
32. VOCAL New York