In December the Federal Communications Commission released a notice of proposed rulemaking for interstate inmate calling services. The question before the FCC is whether to issue new incentives and/or regulations to ensure “just and reasonable” telephone rates for individuals at correctional facilities. In the United States, incarcerated adults are typically limited to making collect calls or debit calls (with charges deducted from an account). The rates can entail a per-call setup charge as well as a per-minute charge. The setup charges can vary from $0.50 to $3.95, and per-minute charges from $0.05 to $0.89. For some families, those costs limit the interaction they can have with a loved one in jail or prison.
A regulatory change will create financial costs and benefits for telecommunications companies, corrections departments (which often receive a commission for each call), and the inmates and family members who use facilities’ telephone services. But the policy implications go beyond those perspectives, and are not only financial. In recognition of this, the FCC is seeking public comment on “the costs and benefits of the proposals” and “any information or analysis that would help us to quantify these costs or benefits.”
Many of the comments already posted are about the financial costs of calling services and the negative consequences when people in jail or prison lose touch with their loved ones. (You can read the comments on the Electronic Comment Filing System.) But some comments discuss costs that may be unexpected, for example, that high telephone rates can impede a defendant’s ability to speak with counsel to prepare for court hearings.
A criminal defense attorney noted that telephone costs make it difficult for him to speak with his clients, and in “many cases it completely stops the ability of a defendant to mount a defense.” A director of a statewide public defenders office wrote that her organization has “been impacted by this problem, since most of the phone calls we receive from our incarcerated clients must be ‘collect,’ with our agency absorbing and paying the cost.”
Information on costs and benefits is not always found in spreadsheets and financial reports. The aim of a rigorous cost-benefit analysis (CBA) is to measure a policy’s effects as comprehensively as possible. This task often requires the input of many people, making the public comment process an ideal forum for collecting information for a CBA. Who else would be affected by changes to inmate calling rates? What costs would they bear or how would they benefit? All are welcome to submit to the FCC their answers to these questions.
The comment period ends March 25, and the public can file comments through the Electronic Comment Filing System under WC Docket No. 12-375.
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