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

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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