Wright v Securus, DC, Pet Opp to Securus Petition, inmate calling services, 2014

Type: Trial Briefs • March 11, 2014 • Locations: United States of America -> District of Columbia • Topics: Telephones, Telephones -> Telephone Rates

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Before The
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of:

Rates For Interstate Inmate
Calling Services

)
)
)
)
)

WC Docket No. 12-375

CONSOLIDATED COMMENTS
Martha Wright, Dorothy Wade, Annette Wade, Ethel Peoples, Mattie Lucas, Laurie
Nelson, Winston Bliss, Sheila Taylor, Gaffney & Schember, M. Elizabeth Kent, Katharine
Goray, Ulandis Forte, Charles Wade, Earl Peoples, Darrell Nelson, Melvin Taylor, Jackie Lucas,
Peter Bliss, David Hernandez, Lisa Hernandez, Vendella F. Oura, along with The D.C.
Prisoners’ Legal Services Project, Inc., Citizens United for Rehabilitation of Errants, the Prison
Policy Initiative, and The Campaign for Prison Phone Justice (jointly, the “Petitioners”) hereby
submit these Consolidated Comments in response to the Public Notice, released March 4, 2014,
regarding two petitions filed by Securus Technologies, Inc. (the “Petitions”). 1
In essence, the Petitions seek to apply the highly individualized relief provided to Pay Tel
Communications to all other ICS providers. 2 Securus claims that all ICS providers serving the
states covered by the Pay Tel Waiver should obtain similar relief, along with being able to
charge an additional $0.02 fee for providing Voice Biometric services.
The Petitioners submitted an Opposition to the Voice Biometric Waiver Request on
February 28, 2014, noting that Securus utterly failed to provide any factual basis for its “Me
Too” waiver request for an additional $0.02 Voice Biometric fee. The Petitioners also noted that
1

Comment Sought On Securus Technologies, Inc. Inmate Calling Services Petition, Public Notice,
DA 14-296, rel. March 4, 2014 (the “Public Notice”).

Wavier Order, DA 14-187 (rel. Feb. 11 2014).

Securus often included the Voice Biometric service for “no charge” when submitting responses
to requests for proposals, and also noted that the Chief Executive Officer and President of
Securus said that Securus “could live” with providing interstate ICS within the price caps, i.e.,
without an additional $0.02 voice biometric fee tacked on.
Moreover, as shown in Exhibit A, Securus may be recovering all of its voice biometric
costs through a $0.40 per call ancillary fee. As shown in the attached interstate tariffs that
became effective in February 2014, Securus lists an ancillary fee of $0.40 per call under the
following circumstance: “[w]here installation of Voice Biometrics is requested by confinement
facilities, this charge applies in addition to all applicable message charges and operator
assistance service charges.” 3 It should be obvious that a $0.40 per call charge would satisfy, and
render moot, the cost-recovery mechanism proposed by Securus in the Me Too petition. Securus
failed to provide any explanation why a $0.02 per minute increase, in addition to the current
$0.40 per call ancillary fee is necessary, and therefore, the Petition must be denied.
The second petition – “Us Too” – fails for the same reasons. First, the application of the
Waiver Order broadly to the entire ICS industry in 13 states simply has not been justified.
Securus cannot rely on the Siwek study to argue that “all of those carriers are subject to the same
‘below-average-cost intrastate rate constraints’ as Pay Tel” for the simple reason that the Siwek
study did not address that issue at all. 4 Instead, Mr. Siwek’s study made several assertions
regarding Securus’ costs, without (as noted the Petitioners) providing any foundational cost data,
or even addressing the fundamental basis for Pay Tel’s waiver request, i.e., the below-cost
intrastate price caps imposed by several states. 5
3

Exhibit A, pg. 4 (emphasis added).

Petition to Expand Pay Tel Waiver, pg. 2.

Petitioners’ Reply Comments, WC Dkt. 13-275, pgs. 9-10, Exhibit A (filed April 22, 2013).
2

Moreover, Mr. Siwek’s statement bears no similarity to the cost study and audited
financial statements provided by Pay Tel in connection with its waiver request, and Securus has
steadfastly refused to provide any actual cost data to the FCC. In fact, as noted in the Us Too
Petition, Securus and several other ICS providers have gone to the extreme step of obtaining an
order staying the FCC’s data collection rules so that they will not have to provide cost studies.
Thus, the Siwek “study”, which did not address intrastate price caps, and failed to provide
detailed cost information, simply cannot serve as the sole basis for granting the broad relief
requested in the Petition.
Finally, in a remarkable moment of candor, Securus confirms that “this is really about
revenue, not costs.” 6 Securus argues that it “will not have the excess revenue” earned by Pay Tel
as a result of the waiver. However, despite such candor, Securus fails to mention that it has
apparently stopped paying commissions on interstate revenue to correctional facilities. Attached
as Exhibit B is a letter from Securus, addressed to its “Valued Customers”, stating that “[d]ue to
the FCC’s Order, Securus no longer will pay site commissions on interstate calls.” GTL has
taken a similar approach, stating that “[c]ommissioning on Interstate calling has been removed.” 7
Because the ICS providers are not required to provide their cost information at this time,
it is not clear how many correctional institutions are no longer receiving commission payments
on interstate calls. However, any prior analysis of providing ICS service at “below cost” must be
recast to take into account that the two largest ICS providers are no longer making commission
payments for interstate ICS telephone calls.
6

Petition to Expand Pay Tel Waiver, pg. 6.

GTL kindly offers its assistance in finding alternative ways to raise rates or fees so that
correctional institutions may maintain their revenue stream. This helpful assistance provides further
justification for the Petitioners’ request that the FCC apply a uniform rate to all ICS calls, and to eliminate
ancillary fees. If the ICS providers are willing to find other costs to impose on ICS customers, then the
intended relief provided by merely addressing interstate rates will fail.
3

Thus, Securus has failed to provide any reasonable basis to increase its per-minute rates
to $0.23 per minute for debit and prepaid interstate calls, and $0.27 per minute for collect
interstate calls. It has also failed to provide any substantive basis for granting a blanket waiver
for all ICS providers in the 13 states served by Pay Tel Communications. In light of the
termination of commission payments for interstate ICS telephone calls, any prior analysis of ICS
providers’ costs are no longer relevant. Thus, until such time that Securus and the other ICS
providers are willing to submit the same financial information as provided by Pay Tel
Communications in connection with its Petition for Waiver, i.e., audited Financial Statements,
substantive cost studies, the FCC must deny any attempt to extend similar relief.

Respectfully submitted,

By:/s/ Deborah M. Golden, Esquire
Deborah M. Golden, Esquire
D.C. PRISONERS' PROJECT
WASHINGTON LAWYERS' COMMITTEE
FOR CIVIL RIGHTS AND URBAN AFFAIRS
11 Dupont Circle, NW, Suite 400
Washington, DC 20036
Telephone 202-319-1000
Fax 202-319-1010
Counsel to the Petitioners
March 11, 2014

EXHIBIT A

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

SERVICES AND RATES

Interstate Institutional Operator Assisted Calls
Automated operator assisted collect calling services for use by inmates of confinement facilities are charged
individually for each call placed through the company’s network. Consumers are billed based on their use of
the company’s service.
A.

Interstate Collect Rate
The rate listed below is charged for interstate collect calls from most confinement facilities. The rate
is as specified by Federal Communications Commission 47 CFR Part 64 [WC Docket No. 12-375;
FCC 13-113] – Rates for Interstate Calling Services – effective February 11, 2014. However, rates
may vary if service is offered on an individual contract basis to meet specialized requirements of the
confinement facility. These exceptions are listed herein under section E but will still comply with
FCC rate requirements.
Usage Rate Per Minute:

$0.25

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

SERVICES AND RATES (Continued)
Interstate Institutional Operator Assisted Calls (Continued)
B.

Prepaid Institutional Calling Services
Prepaid Calling Rate
The rate listed below is charged for interstate prepaid calling card, prepaid debit, inmate
debit, and AdvanceConnect calls from most confinement facilities. The rate is as specified
by Federal Communications Commission 47 CFR Part 64 [WC Docket No. 12-375; FCC 13113] – Rates for Interstate Calling Services – effective February 11, 2014.
Usage Rate Per Minute:

$0.21

Prepaid Expiration and Refund Policy: The End User may request a refund of the
available balance in an AdvanceConnect Account either by written request to the Company
or by contacting the Company at its toll free telephone number once the End User verifies
certain account information. Any such unused balances will expire in one hundred eighty
(180) days following the last call made, unless the balance is either fully depleted or a refund
has been requested. No refunds of unused balances will be issued after the expiration date.

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

SERVICES AND RATES (Continued)
Interstate Institutional Operator Assisted Calls (Continued)
C.

Inmate Debit – Inmate Debit is a prepaid telephone account offering made available to Inmates by
the Company when permitted by the Confinement Facility. Inmates fund and replenish their Inmate
Debit account through electing to transfer funds from either their facility’s inmate trust fund or
commissary account to their Inmate Debit account. Inmate Debit accounts may also be funded by
inmate friends and family members via the Company’s points-of-sale. Funds placed in this account
become the property of the inmate.
Refunds of unused Inmate Debit account balances are issued by the entity controlling the actual cash
deposits, which is either the Company, the commissary, the Confinement Facility or its agent,
depending on the specific arrangements, unless otherwise directed by state law. Depending on the
entity issuing the refund, refund fees and/or minimum refund amounts may apply. The prepaid
balance expires ninety (90) days from the date of the last call placed on the Inmate Debit account
unless alternative arrangements are expressly requested by the Confinement Facility. No refunds of
unused balances will be issued after the expiration date.

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

SERVICES AND RATES (Continued)
D.

Other Charges
1. Voice Biometrics (f/k/a SECUREvoice™): This charge may apply to automated calls placed by
inmates of confinement facilities when such calls are provided through Securus Technologies, Inc.
own processing equipment. Voice Biometrics provides validation of inmate personal identification
numbers (PINs) through voice verification technology for purposes
of improved
securityy and reduced
p p
p
ppotential of fraud and consumer harassment by
y inmates. Where installation of Voice Biometrics is
by
requested
q
y confinement facilities,, this charge aapplies in addition to all applicable message charges
and operator assistance service charges.
Voice Biometrics Rates and Charges
Per Call Charge (where available, at the request of a
confinement facility):

$ 0.40

2. Federal Universal Service Fund Fee: The federal government requires that all telephone
companies providing interstate service contribute to a fund to make phone service affordable and
available to all Americans, including consumers with low incomes, those living in areas where the
cost of providing telephone service is high as well as to schools, libraries, and rural health care
providers. The law permits companies to pass this charge on to its consumers. This fee, which is
known as the federal Universal Service Fund fee (USF), is based on a specific percentage of the cost
of interstate calls that is set by the federal government. Companies are also permitted to charge the
consumer an administrative fee to cover their costs for administering the government’s USF fees.
Federal USF Fee

Percentage Rate Varies Quarterly

3. Federal Regulatory Recovery Fee:
The Federal Regulatory Recovery Fee helps recover costs associated with the provision of state-tostate and international long distance services including the administration of the federal universal
service fund (USF), other federal regulatory fees, proceedings and compliance items. The Federal
Regulatory Recovery Fee of $3.49 applies each month in which an end-user accepts state-to-state
and/or international calls.

4. Location Validation Fee - At facilities where applicable, a four percent (4%) per-call surcharge
will be applied to the base rate of all call types. The base rate of a call is set forth in Sections A, B , E
and F and does not include any applicable taxes that may apply to the call. The Location Validation
Fee is applied to calls originating from facilities that have elected to utilize Securus’ Location Based
Services technology and recovers the cost of verifying the geographic location of the called party for
security purposes pursuant to Correctional Institution contracts. The Location Validation Fee will not
be assessed on End Users who are billed for services through their LECs.

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

SERVICES AND RATES (Continued)
D.

Other Charges
5. Bill Statement Fee: In order to partially offset increased expenses associated with billing calls
through local telephone companies, a billing fee may apply each billing period in which local or long
distance collect calls are billed to a consumer’s local telephone company. This fee will be charged
only once per billing period regardless of the number of calls. The fee will not apply in any billing
period in which no collect calls are billed via the consumer’s local telephone company. This fee does
not apply to prepaid services or for services billed directly to the consumer by the company.
Bill Statement Fee
Bill Statement Fee, per month where applicable:

$3.49

6. Wireless Administration Fee – a monthly fee of up to $3.99 is applicable to any
AdvanceConnect account with a wireless telephone number included as a number authorized to
receive calls. This fee applies once per month, per account regardless of the number of wireless
telephone numbers authorized. The fee amount will be deducted from the AdvanceConnect account
balance on a monthly basis as long as a wireless number remains on the AdvanceConnect account.
As of the initial effective date of this fee, existing AdvanceConnect accounts with existing authorized
wireless numbers will be Grandfathered and the Wireless Administration Fee will not apply. If an
existing AdvanceConnect account adds or changes a wireless number on the account, the Wireless
Administration Fee will apply going forward.

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

SERVICES AND RATES (Continued)
E.

Contract Rates
At the option of the company, service may be offered on an individual contract basis to meet
specialized requirements of the confinement facility. In some instances, the interstate rates may
differ to meet the specialized requirements, which are determined by contract. The following
contract rates are currently effective at certain Securus facilities and are available to similarly situated
facilities. Calls are billed in one (1) minute increments following an initial period of one (1) minute.
Contract includes a facility-specific mix of services and non-regulated screening and blocking
equipment. Rates are not mileage sensitive or time-of-day sensitive. All contract rates offered shall
comply with Federal Communications Commission 47 CFR Part 64 [WC Docket No. 12-375; FCC
13-113] – Rates for Interstate Calling Services – effective February 11, 2014.

Contract 1
The following flat rate is applicable to all call types regardless of time of day or mileage. including
collect, prepaid calling card, prepaid debit, inmate debit and AdvanceConnect.
Collect Rates:
Per call:

$3.75

Prepaid Calling Cards, Prepaid Debit, AdvanceConnect:
Per call:
$3.15

Contract 2
The following rates apply regardless of time of day or mileage.
Collect Rates:
Per call:
$1.20
Per minute:
$0.06
Prepaid Calling Cards, Prepaid Debit, Inmate Debit, AdvanceConnect:
Per call:
$1.02
Per minute:
$0.06

Contract 3
The following flat rates apply regardless of time of day or mileage.
Collect, Prepaid Calling Cards, Prepaid Debit, Inmate Debit:
Per Call:
$0.65
AdvanceConnect:
Per Call:
$0.59

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

SERVICES AND RATES (Continued)
E.

Contract Rates (Continued)
Contract 4
The following rates apply regardless of time of day or mileage.
Collect Rates:
Per call:
$1.25
Per minute:
$0.15
Prepaid Debit and Inmate Debit:
Per call:
$0.50
Per minute:
$0.10
AdvanceConnect:
Per call:
$1.00
Per minute:
$0.10

Contract 5
The following rate applies regardless of time of day or mileage.
Collect, Prepaid Calling Cards, AdvanceConnect:
Per Minute:
$0.09
(No per call rate applies.)

Contract 6
The following rates apply regardless of time of day or mileage.
Collect Rates:
Per call:
$1.00
Per minute:
$0.05
Prepaid Calling Cards, Prepaid Debit, Inmate Debit, AdvanceConnect:
Per minute:
$0.05
(No per call rate applies.)

Contract 7
The following rate applies regardless of time of day or mileage.
Collect, Prepaid Debit, Inmate Debit, Prepaid Calling Cards, AdvanceConnect:
Per Minute:
$0.1183
(No per call rate applies.)

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

International Rates and Charges
The rates listed below are those charged for international calls from most confinement facilities.
International calling is offered on a prepaid basis only via debit or calling card services.
The following domestic international locations receive the standard interstate rates applicable to the
facility where the call originates and shall comply with Federal Communications Commission 47
CFR Part 64 [WC Docket No. 12-375; FCC 13-113] – Rates for Interstate Calling Services –
effective February 11, 2014.
1.
American Samoa
Anguilla
Antigua
Bahamas
Barbados
Bermuda
British Virgin Islands
Canada
Cayman Islands
Dominica
Dominican Republic
Grenada
Guam
Jamaica
Montserrat
Puerto Rico
Saipan
St. Kitts/Nevis
St. Lucia
St. Vincent
Trinidad
Turks and Caicos
U S Virgin Islands

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

International Rates and Charges (Continued)
2.

The following list details the Company’s standard available international calling destinations
and rates.

Country
Afghanistan
Albania
Algeria
Andorra
Angola
Antarctica
Argentina
Armenia
Aruba
Ascension Island
ATLANTIC WEST
Australia
Austria
AZERBAIJAN
Bahrain
Bangladesh
Belarus
Belgium
Belize
Benin
Bhutan
Bolivia
Bosnia
Botswana
Brazil
Brunei
Bulgaria
Burkina Faso
Burundi
Cambodia
Cameroon
Cape Verde
Central African
Chad

Connection Fee
(if applicable)

(NEW)

4.00

(NEW)

4.00

Per Minute Rate
$
3.28
$
1.20
$
2.16
$
1.52
$
4.63
$
1.40
$
1.97
$
2.27
$
1.39
$
2.49
$
1.00
$
1.71
$
1.20
$
1.00
$
1.95
$
3.19
$
2.27
$
1.65
$
1.85
$
1.95
$
4.98
$
1.99
$
1.70
$
1.83
$
1.78
$
1.89
$
1.95
$
3.23
$
4.74
$
3.98
$
2.19
$
2.63
$
4.56
$
5.28

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

Country
Chile
China
Colombia
Cook Island
Costa Rica
Cote D'ivoire
Croatia
Cuba
Cyprus
Czechoslovakia
Dem People Rep Korea
Dem Rep Congo
Denmark
Diego Garcia
Djibouti
Ecuador
Egypt
El Salvador
Equatorial Guine
Eritrea
Estonia
Ethiopia
Falkland Islands
Faroe Islands
FEDERATED MICRONESIA
Fiji Islands
Finland
France
French Antilles
French Guiana
French Polynesia
Gabon
Gambia
GEORGIA
(NEW)
Germany
Ghana
Gibraltar
Greece
Greenland

Connection Fee
(if applicable)

4.00

Per Minute Rate
$
1.70
$
2.44
$
1.84
$
4.99
$
1.60
$
2.58
$
1.70
$
1.62
$
1.73
$
1.84
$
3.47
$
2.60
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$

1.50
3.29
3.05
1.71
2.44
1.56
4.41
3.52
2.92
2.59
3.78
1.54
2.18
2.62
1.56
1.39
1.54
1.67
2.31
2.15
2.07
1.00
1.36
2.04
1.71
2.03
1.90

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

Country
Guadeloupe
Guatemala
Guinea
Guinea Bissau
Guyana
Haiti
Honduras
Hong Kong
Hungary
Iceland
India
Indonesia
IRAN
Iraq
Ireland
Israel
Italy
Japan
Jordan
Kenya
Kiribati
Kuwait
KYRGYZSTAN
Laos
Latvia
Lebanon
Lesotho
Liberia
Libya
Liechtenstein
Lithuania
Luxembourg
Macao
Macedonia
Madagascar
Malawi
Malaysia
Maldives
Mali

Connection Fee
(if applicable)

(NEW)

4.00

(NEW)

4.00

Per Minute Rate
$
1.47
$
1.70
$
4.41
$
4.95
$
2.28
$
1.67
$
1.87
$
1.79
$
1.80
$
1.70
$
2.39
$
2.16
$
1.00
$
2.94
$
1.45
$
1.96
$
1.50
$
1.70
$
1.81
$
2.11
$
3.29
$
1.94
$
1.00
$
5.58
$
3.00
$
2.76
$
1.81
$
1.84
$
1.46
$
1.50
$
2.79
$
1.51
$
2.41
$
1.75
$
5.08
$
1.99
$
2.10
$
3.24
$
3.28

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

Country
Malta
MARISAT ATLANTIC SHI (NEW)
MARISAT INDIAN
(NEW)
MARISAT PACIFIC
(NEW)
Marshall Islands
Mauritania
Mauritius
MAYOTTE
Mexico
Moldova
Monaco
Mongolia
Morocco
Mozambique
Myanmar/Burma
Namibia
Nauru
Nepal
Netherlands
Netherlands Antilles
New Caledonia
New Zealand
Nicaragua
Niger
Nigeria
Niue
Norway
Oman
Pakistan
Palau
Palestine
Panama
Papua New Guinea
Paraguay
Peru
Philippines
Poland
Portugal

Connection Fee
(if applicable)
$
$
$

4.00
4.00
4.00

(NEW)

4.00

(NEW)

4.00

Per Minute Rate
$
2.26
$
1.00
$
1.00
$
1.00
$
2.31
$
3.10
$
3.34
$
1.00
$
1.20
$
2.66
$
1.39
$
5.36
$
2.62
$
3.55
$
3.67
$
1.97
$
3.63
$
1.00
$
1.33
$
1.50
$
2.13
$
1.91
$
1.98
$
2.60
$
1.86
$
5.15
$
1.38
$
1.99
$
3.81
$
3.54
$
1.96
$
1.63
$
1.60
$
2.16
$
1.94
$
2.10
$
1.57
$
1.72

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

Country
Qatar
Reunion Island
Romania
Russia
Rwanda
Samoa
San Marino
Sao Tome
Saudi Arabia
Senegal
Seychelles
Sierra Leone
Singapore
Slovakia
Slovenia
Solomon Island
Somalia
South Africa
South Korea
Spain
Sri Lanka
St Pierre/Miquel
St Helena
Sudan
Suriname
Swaziland
Sweden
Switzerland
Syria
Taiwan
TAJIKISTAN
Tanzania
Thailand
Togo
Tokelau
Tonga
Tunisia
Turkey

Connection Fee
(if applicable)

(NEW)

4.00

Per Minute Rate
$
2.02
$
3.18
$
2.16
$
2.27
$
3.57
$
3.23
$
1.39
$
4.89
$
2.00
$
2.70
$
3.45
$
2.84
$
1.56
$
1.25
$
1.76
$
3.55
$
3.18
$
1.60
$
1.91
$
1.70
$
2.40
$
1.32
$
3.40
$
1.57
$
2.69
$
1.91
$
1.35
$
1.50
$
3.23
$
1.94
$
1.00
$
2.11
$
2.06
$
2.21
$
2.21
$
2.95
$
1.97
$
1.91

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

Connection Fee
(if applicable)

Country
TURKMENISTAN
Tuvalu
Uganda
Ukraine
United Arab Emirates
United Kingdom
Uruguay
UZBEKISTAN
Vanuatu
Vatican City
Venezuela
Vietnam
Wallis/Futuna
Yemen
Yugoslavia
Zambia
Zimbabwe

(NEW)

4.00

Per Minute Rate
$

1.00

$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$

5.76
2.10
2.27
1.68
1.12
1.98
1.00
4.59
1.50
1.32
2.60
4.45
1.99
1.83
4.00
2.21

Securus Technologies, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate Rates

Updated: February 14, 2014

International Rates and Charges
3.

The following are international flat rate optional applicable to all international calling
destinations allowed by a subscribing confinement facility.

Surcharge
9.95
5.00
4.50
4.45
4.36
4.25
4.19
4.14
4.10
4.10
4.09
4.00
3.95
3.95
3.20
3.00
2.25
1.55
1.50
1.50
1.40
1.20
1.20
1.00
0.50
0.00

First Minute
0.00
0.00
0.89
1.00
0.77
0.89
1.00
1.00
0.00
1.00
0.89
1.00
0.69
1.00
0.80
0.65
0.75
0.75
0.25
0.50
0.00
0.00
0.50
0.50
0.50
0.75

Additional Minute
0.00
0.00
0.89
1.00
0.77
0.89
1.00
1.00
0.00
1.00
0.89
1.00
0.69
1.00
0.80
0.65
0.75
0.75
0.25
0.50
0.00
0.00
0.50
0.50
0.50
0.75

T-NETIX Telecommunications Services, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate and International Rates

Updated February 11, 2014

SERVICES AND RATES
Interstate Institutional Operator Assisted Calling
Automated operator assisted collect calling services for use by inmates of confinement facilities are charged
individually for each call placed through the company’s network. End users are billed based on their use of
the company’s service.
A.

$0.25

T-NETIX Telecommunications Services, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate and International Rates

Updated February 11, 2014

SERVICES AND RATES (Continued)
Interstate Institutional Operator Assisted Calling (Continued)
B.

$0.21

T-NETIX Telecommunications Services, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate and International Rates

Updated February 11, 2014

SERVICES AND RATES (Continued)
Interstate Institutional Operator Assisted Calling (Continued)
C.

T-NETIX Telecommunications Services, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate and International Rates

Updated February 11, 2014

SERVICES AND RATES (Continued)
Interstate Institutional Operator Assisted Calling (Continued)

Other Charges
1. Voice Biometrics: (f/k/a PIN-LOCK®/Secure Voice): Applies to automated calls placed by
inmates of correctional facilities when such calls are provided through T-NETIX’ own processing
equipment. Voice Biometrics provides validation of inmate personal identification numbers (PINs)
through voice verification technology for purposes
of improved
securityy and reduced ppotential of
p
p
y inmates. Where installation of Voice Biometrics is requested
q
by
y
fraud and customer harassment by
correctional facilities,, this charge
g applies
pp
in addition to all applicable message charges and operator
assistance service charges specified in this tariff.
Voice Biometrics Rates and Charges
Per Call Charge
g ((where available, at the request of a
confinement facility)

$ 0.40

Percentage Rate Varies Quarterly

4. Location Validation Fee - At facilities where applicable, a four percent (4%) per-call surcharge
will be applied to the base rate of all call types. The base rate of a call is set forth in Sections A, B
and E and does not include any applicable taxes that may apply to the call. The Location Validation
Fee is applied to calls originating from facilities that have elected to utilize T-NETIX’s Location
Based Services technology and recovers the cost of verifying the geographic location of the called
party for security purposes pursuant to Correctional Institution contracts. The Location Validation
Fee will not be assessed on End Users who are billed for services through their LECs.

T-NETIX Telecommunications Services, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate and International Rates

Updated February 11, 2014

SERVICES AND RATES (Continued)
Interstate Institutional Operator Assisted Calling (Continued)

Other Charges (Continued)
5. Bill Statement Fee: In order to partially offset increased expenses associated with billing calls
via local exchange carriers, an undiscountable bill statement fee will apply each billing period in
which local or long distance collect calls are billed to a customer’s local exchange carrier. This fee
will be charged only once per billing period regardless of the number of calls. The fee will not apply
in any billing period in which no collect calls are billed via the customer’s local exchange carrier.
This fee does not apply to prepaid services paid for by commercial credit card, check, money order or
wire, or for services billed directly to the customer by the company.
Bill Statement Fee
Bill Statement Fee, per month where applicable

$3.49

T-NETIX Telecommunications Services, Inc.
14651 Dallas Parkway, Suite 600
Dallas, Texas 75254

Interstate and International Rates

Updated February 11, 2014

SERVICES AND RATES (Continued)
Interstate Institutional Operator Assisted Calling (Continued)
E.

Contract Collect Rates
At the option of the company, service may be offered on an individual contract basis to meet
specialized requirements of the confinement facility. In some instances, the interstate rates may
differ to meet the specialized requirements, which are determined by contract. The following
contract rates are currently effective at certain T-NETIX facilities and are available to similarly
situated facilities. Calls are billed in one (1) minute increments following an initial period of one (1)
minute. Contract includes a facility-specific mix of services and non-regulated screening and
blocking equipment. Rates are not mileage sensitive or time-of-day sensitive. All contract rates
offered shall comply with Federal Communications Commission 47 CFR Part 64 [WC Docket No.
12-375; FCC 13-113] – Rates for Interstate Calling Services – effective February 11, 2014.
Contract 1
The following rates apply regardless of time of day or mileage.
Collect Rates:
Per call:
$1.20
Per minute:
$0.06
Prepaid Calling Cards, Prepaid Debit, Inmate Debit, AdvanceConnect:
Per call:
$1.02
Per minute:
$0.06

EXHIBIT B

SECURUS™

TECHNOLOGIES

February 2, 2014

RE: Billing Impacts of FCC Ruling on Interstate Calls

To Our Valued Customers,
In accordance with Federal Communications Commission 47 CFR Part 64 [WC Docket No. 12-375;
FCC 13-113]- Rates for Interstate Calling Services - effective February 1 J, 2014, tbe Federal
Communications Commission (FCC) has mandated new rate caps on interstate calls for companies
that provide telephone services to prison inmates. The FCC's new caps include interstate calls rated
at $0.21 per minute for debit calls and $0.25 per minute for collect calls. Without limitation, these
rates will go into effect without anything required on behalf of our customers. Due to the FCC's
Order, Securus no longer will pay site commissions on interstate calls.
This FCC change will go into effect on February 11, 2014. As such, Securus must modify our
billing policies as follows:
For Interstate, Traditional Collect and Direct Bill Calling:
Interstate call rates will be set at $0.25 per minute
For Interstate, AdvanceConnect and Debit Calling:
Interstate call rates will be set at $0.21 per minute
For customer who use Securus SCP Debit:
Interstate call rates will be set at $0.21 per minute
Correctional Facilities' SCP Debit usage invoice will be adjusted to eliminate Facility
discount on interstate debit calls beginning on February 11, 2014
Prepaid Calling Cards:
Beginning February 11, 2014, all Prepaid Calling Card discounts will be reduced by the
percent of interstate calling revenue used on prepaid cards over the past 12 months.
o Example:
• Facility Prepaid Calling Card discount (before) = 30%
• Facility percent of interstate calling revenue = S%
• Adjusted Facility Prepaid Calling Card discount = 28.5%
Due to the FCC ruling, Securus will be changing the way in which prepaid cards are invoiced and
commissioned. These new changes may include selling cards at face value (vs. net of discount)
and subsequently paying commissions on the actual usage, as is typical with other products.
These decisions have not been formalized but will begin with additional notice in 2014.

In accordance with Securus' published price list, some fees will continue to apply to interstate calls
separate from the new FCC mandated calls rates.

Proprietary & Confidential

Page 1 of 2

SECURUS Technologies Inc.

SECURUS™
TECHNOLOGIES

SeculUs appreciates you r selecting us as your communications provider and your understanding and
support in our implementation of these changes required by law. Secu lUs remai ns committed to
prov iding industry-leading communication and investigati ve products and services to our customers
and will continue to communicate openly regarding changes required due to FCC rulings. If you
have questions regarding the impact of these changes, please contact your Account Manager who
will be happy to discuss them with you.

Propr ietary & Confidential

Page 2 of 2

SECURUS Technologi es Inc.

February 25, 2014

DELIVERED VIA EMAIL

Mr. Phil Lisk
IT Director
Bergen County Sheriff’s Office
County of Bergen
Bergen County Jail
160 South River Street
Hackensack, NJ 07601

Re: FCC Order to Cap Inmate Interstate Rates

Dear Phil,
Pursuant to GTL’s emails and our telephone conversations, please use this letter as formal notification
that Bergen County’s Sheriff Department (BCSD) inmate interstate calling currently conforms to the new
FCC Order and Federal Stay actions.
th

As of February 7 2014 GTL changed all interstate rates to the required $0.25 per minute for traditional
collect inmate calls and $0.21 per minute for prepaid collect/debit inmate calling throughout the Country
including Bergen County Jail.
All other Instate rates remain the same. Commissioning
g on Interstate calling
g has been removed. GTL would
pleased to conduct a studyy to explore
be p
p
rate and fee increases to make your Department and GTL whole
and recover any possible revenue lost to the Sheriff’s Department.
Please advise and contact me at my office number 732-928–7600 should you have any questions. Thank
you.
Sincerely,

Timothy Miller
GTL Regional Sales Manager
tmiller@gtl.net

Local Sales Office: 255 Butterfly Road, Jackson, New Jersey 08527