Groups Disagree on ICS Rates Structure, Ancillary Fees

of communication services nor do they serve [ICS] consumers or the general public," said Worth Rises. There's "no reason that the staff time of a correctional officer should be reflected in rates for phone service, and security and surveillance should not be a profit center," said the United Church of Christ, New America's Open Technology Institute, Free Press, Benton Institute for Broadband & Society, National Consumer Law Center and Public Knowledge. Global Tel*Link and the National Sheriffs Association (NSA) disagreed. Facilities' costs "must include the security and surveillance costs" for providing ICS, said GTL. NSA said some security and administrative tasks are "directly related to and necessary for the provision of inmate calling services." The Prison Policy Initiative asked the FCC to prohibit revenue-sharing agreements between providers and third-party financial institutions. "We do not understand the justification for an ancillary charge in this circumstance above $3.00 and as high as $6.95" for single-call services, said NASUCA. Ensure sufficient cost recovery for facilities if site commissions are regulated, said Pay Tel. Securus backed "phasing out" site commissions from rates and "eliminating duplicative ancillary service charges." NCIC asked the FCC to consider NSA's 2015 data that suggested relying on facilities-based ICS costs rather than provider-generated proposals to develop permanent ICS rates. PPI said NSA's study "suffers from a plethora of problems." Consider how other states are adopting intrastate rates, said the California Public Utilities Commission: Those rates "are multiple times lower than the FCC's proposed interstate rate caps," and the agency should consider if its proposed caps are too high "in light of the ICS providers’ assertions that they incur little to no cost differential to provide interstate versus intrastate calling services." Commenters overwhelmingly backed efforts to expand access to telecom relay services for deaf and hard of hearing incarcerated people. Publicize "the importance of facilities and ICS providers asking individuals whether they require TRS upfront," asked Hamilton Relay. It may not be "administratively feasible" to allow incarcerated individuals to choose their IP captioned telephone service provider, said ClearCaptions. Amend TRS rules "to the maximal extent necessary" to limit barriers to access to communications services for deaf and hard of hearing incarcerated people, said a coalition that included Telecommunications for the Deaf and Hard of Hearing, Communications Services for the Deaf, Hearing Loss Association of America, and National Disability Rights Network. Prohibit ICS providers from charging for "all forms of TRS calls," they said.