The full text of the Community Sign-On Letter is below. Please visit http://nationinside.org/campaign/prison-phone-justice/ and click on “JOIN US” to sign-on to this letter.

December 13, 2013

Marlene H. Dortch, Commission Secretary
Federal Communications Commission
Office of the Secretary
445 12th Street, SW
Room TW-B204
Washington, DC 20554

Dear Commissioners:

We, the undersigned Deaf Community members, allies and national and state organizations, urge you to mandate the installation of videophones, captioned telephones and other auxiliary aids to support access to telecommunication for deaf, hard of hearing, deaf-blind and speech challenged prisoners and their family members.

On August 9, 2013, the Federal Communications Commission (“Commission”) appropriately voted to limit the sky-high rates charged by ICS providers to family members of all prisoners. For years, ICS providers have charged these same excessive rates for calls via Telecommunication Devices for the Deaf (“TTY”)—a technology that can require more than quadruple the amount of time it takes to use a videophone or voice telephone. Some ICS providers have chosen not to provide any technology for prisoners with disabilities, while others provided equipment but erected other barriers to access—charging extra for prisoners to use TTYs; blocking telephone relay numbers, placing TTY technology in locations that are locked or inaccessible, or even creating phone systems that function solely through voice-command.

The Commission’s own reports indicate that TTY calls account for a mere 12% of the total relay volume and that TTY usage is continuously decreasing, having cut in half over the past seven years. To make matters worse, TTYs and videophones are incompatible. This means that deaf prisoners in hundreds of prisons across the nation cannot communicate with their loved ones who no longer use outmoded TTY technology.

Simply put, family members of deaf prisoners have endured an even greater financial burden and often have been entirely denied communication with their loved ones solely based on disability. The Commission emphasizes that its recent efforts are to ensure that “rates for Inmate Calling Services are just, reasonable, and fair.” While we applaud the Commission’s decision to ensure that rates are just and reasonable, we remind the Commission that there is no fairness without equality.

At base, the Commission must employ its authority to mandate that:

(1) ICS providers ensure that deaf and hard of hearing prisoners, prisoners with deaf family members, and prisoners with speech challenges have access to videophones, captioned telephones, TTYs and other auxiliary aids;
(2) ICS providers reduce rates charged for videophone and TTY such that family members of deaf prisoners pay the same amount for the same amount of communication;
(3) ICS providers immediately add all relay numbers, including Spanish relay numbers, to its list of approved numbers; and
(4) ICS providers assemble and report data regarding rates for and complaints from prisoners with disabilities and their family members.

Anything short of a Commission order mandating these four fundamental components of universally accessible Inmate Calling Services will leave countless prisoners and their family members exactly where they were prior to the Commission’s decision—disconnected. Universal accessibility is part and parcel of fairness and the rights of people with disabilities should not be disregarded for regulatory convenience.

The Commission has the authority to ensure that individuals with disabilities have equal telecommunication access and we are calling upon you to ensure that prison telecommunication is affordable and universally accessible—that fair reaches all, not some.

Please sign this letter to show the FCC that there is strong community support for videophones, captioned telephones and auxiliary aids for ALL people regardless of their incarceration status.


Talila A. Lewis, President, HEARD

& the Undersigned Individuals & Organizations

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