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Securus Technologies v. FCC, DC, Jt. Brief for the ICS Providers/Intervenors, Prison Phone Rates, 2014

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USCA Case #13-1280

Document #1494131

Filed: 05/22/2014
Page
1 of 77
INITIAL
VERSION

ORAL ARGUMENT NOT YET SCHEDULED

United States Court of Appeals
for the District of Columbia Circuit
No. 13-1280
Consolidated with 13-1281, 13-1291, 13-1300, 14-1006

SECURUS TECHNOLOGIES, INC., GLOBAL TEL*LINK,
CENTURYLINK PUBLIC COMMUNICATIONS, INC.,
MISSISSIPPI DEPARTMENT OF CORRECTIONS,
SOUTH DAKOTA DEPARTMENT OF CORRECTIONS,
ARIZONA DEPARTMENT OF CORRECTIONS,
Petitioners,
v.
FEDERAL COMMUNICATIONS COMMISSION
and UNITED STATES OF AMERICA,
Respondents.
On Petitions for Review of an Order of the
Federal Communications Commission
JOINT BRIEF FOR THE ICS PROVIDER PETITIONERS
AND SUPPORTING INTERVENOR
Stephanie A. Joyce
G. David Carter
ARENT FOX LLP
1717 K Street, N.W.
Washington, D.C. 20036-5342
(202) 857-6081
Counsel for Petitioner Securus
Technologies, Inc.

Michael K. Kellogg
Courtney Simmons Elwood
Aaron M. Panner
John B. Ward
KELLOGG, HUBER, HANSEN, TODD,
EVANS & FIGEL, P.L.L.C.
1615 M Street, N.W., Suite 400
Washington, D.C. 20036
(202) 326-7900

May 22, 2014

Counsel for Petitioner Global
Tel*Link Corporation
(additional counsel listed on inside cover)

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Robert A. Long, Jr.
Matthew J. Berns
COVINGTON & BURLING LLP
1201 Pennsylvania Avenue, N.W.
Washington, D.C. 20004-2401
(202) 662-6000

Adam Proujansky
Daniel A. Broderick
DICKSTEIN SHAPIRO LLP
1825 Eye Street, N.W.
Washington, D.C. 20006
(202) 420-2200

John E. Benedict
Vice President, Federal Regulatory
Affairs & Regulatory Counsel
CENTURYLINK
1099 New York Avenue, N.W.
Washington, D.C. 20001
(202) 429-3114

Counsel for Intervenor Telmate, LLC

Counsel for Petitioner CenturyLink
Public Communications, Inc.

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CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES
Pursuant to D.C. Circuit Rule 28(a)(1), Petitioners Securus Technologies,
Inc. (“Securus”), Global Tel*Link (“GTL”), CenturyLink Public Communications,
Inc. (“CenturyLink”), and supporting Intervenor Telmate, LLC (“Telmate”) –
collectively, the “ICS Providers” – certify as follows:
A.

PARTIES AND AMICI
1.

Parties Before the Court

Petitioners in these consolidated cases are Securus (No. 13-1280), GTL (No.
13-1281), CenturyLink (No. 13-1291), the Mississippi Department of Corrections
and the South Dakota Department of Corrections (No. 13-1300), and the Arizona
Department of Corrections (No. 14-1006).
Respondents in these consolidated cases are the Federal Communications
Commission (“FCC” or “Commission”) and the United States of America.
Intervenors in support of Petitioners in these consolidated cases are the
Arkansas Department of Correction, the Barnstable County Sheriff’s Office, the
Indiana Department of Correction, and Telmate.
Intervenors in support of Respondents in these consolidated cases are Peter
Bliss, Winston Bliss, Ulandis Forte, Gaffney & Schember, Katharine Goray, David
Hernandez, Lisa Hernandez, M. Elizabeth Kent, Jackie Lucas, Mattie Lucas,
Darrell Nelson, Laurie Nelson, Vendella F. Oura, Earl J. Peoples, Ethel Peoples,

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Melvin Taylor, Sheila Taylor, Annette Wade, Charles Wade, Dorothy Wade, and
Martha Wright.
2.

Parties to the Proceeding Below

The parties that participated in the agency proceeding below – Rates for
Interstate Inmate Calling Services, WC Docket No. 12-375 – are listed in
Appendix B of the order under review.
B.

RULING UNDER REVIEW
The order under review is the FCC’s Report and Order and Further Notice of

Proposed Rulemaking, Rates for Interstate Inmate Calling Services, FCC 13-113,
28 FCC Rcd 14107 (2013) (“Order ”) (JA___-__).
C.

RELATED CASES
The order under review has not previously been the subject of a petition for

review by this Court or any other court. The ICS Providers are unaware of any
related cases pending before this Court or any other court.

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CORPORATE DISCLOSURE STATEMENTS
Pursuant to Federal Rule of Appellate Procedure 26.1 and D.C. Circuit
Rule 26.1, the ICS Providers respectfully submit the following corporate disclosure
statements:
CenturyLink is a direct and wholly owned subsidiary of Embarq
Corporation. Embarq Corporation is in turn a direct and wholly owned subsidiary
of CenturyLink, Inc., a publicly traded corporation that, through its wholly owned
affiliates, provides voice, broadband, video, and communications services to
consumers and businesses. CenturyLink, Inc. has no parent company, and no
publicly held company owns 10 percent or more of its stock.
GTL is a privately held and wholly owned subsidiary of GTEL Holdings,
Inc. No publicly held company has a 10 percent or greater ownership interest in
GTL. Insofar as relevant to this litigation, GTL’s general nature and purpose is to
provide inmate telephone calling services, solutions, and equipment in correctional
facilities throughout the United States.
Securus is wholly owned by Securus Technologies Holdings, Inc., whose
principal investor is Securus Investment Holdings, LLC (“SIH”). SIH is indirectly
controlled by ABRY Partners VII, LP (“ABRY”). Neither SIH nor ABRY has
stock that is publicly traded. No entity having publicly traded stock owns 10
percent or more of either company. Securus, a Delaware corporation, is a

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telecommunications service and technology company that provides calling services
and call management software to correctional facilities exclusively.
Telmate is a telecommunications company that develops, deploys, and
services inmate communications systems to correctional facilities throughout
North America. Telmate is a privately held corporation, and no parent corporation
or publicly held corporation owns 10 percent or more of its stock.

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TABLE OF CONTENTS
Page
CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES ............. i
CORPORATE DISCLOSURE STATEMENTS ..................................................... iii
TABLE OF AUTHORITIES .................................................................................. vii
GLOSSARY............................................................................................................ xii
STATEMENT OF JURISDICTION..........................................................................1
STATEMENT OF THE ISSUES...............................................................................1
STATUTES AND REGULATIONS.........................................................................2
PRELIMINARY STATEMENT ...............................................................................2
STATEMENT OF THE CASE..................................................................................4
STANDARD OF REVIEW .....................................................................................13
SUMMARY OF ARGUMENT ...............................................................................14
STATEMENT OF STANDING ..............................................................................16
ARGUMENT ...........................................................................................................16
I.

The FCC’s Cost-Based-Rate Rule in § 64.6010 Is Unlawful .......................16
A.

The FCC Adopted Rate-of-Return Regulation Without
Notice and an Opportunity for Comment............................................16

B.

The FCC’s Adoption of a Disfavored Regulatory Approach
Without Explanation Was Arbitrary and Capricious ..........................22

C.

The FCC’s Failure To Provide Meaningful Guidance on the
Implementation of the Cost-Based-Rate Rule Was Arbitrary
and Capricious.....................................................................................25

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D.
II.

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The FCC’s Refusal To Permit Recovery of Site Commission
Costs Exceeds Its Statutory Authority ................................................26

The “Interim” Rate Caps in § 64.6030 Are Unlawful...................................30
A.

The Order’s One-Size-Fits-All Approach to Rate Caps
Inexplicably Disregards Significant Differences Among
Institutions ...........................................................................................30

B.

The Order Ignores the Practical Consequences of Its Failure
To Account for High-Cost Facilities in Setting Rate Caps.................34

C.

The Order’s Rate Caps Are Tainted by Methodological
Flaws....................................................................................................37

III.

The Safe Harbor Rates in § 64.6020 Are Independently Unlawful ..............40

IV.

The Commission’s Attempt To Regulate “Ancillary Fees” Is
Contrary to Law.............................................................................................44

V.

The FCC’s Refusal To Exempt Existing Contract Rates from the
Order’s Cost-Based-Rate Rule and Rate Caps Was Arbitrary and
Capricious ......................................................................................................46

CONCLUSION........................................................................................................49
RULE ECF-3(B) ATTESTATION
CERTIFICATE OF COMPLIANCE
ADDENDUM

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TABLE OF AUTHORITIES
Page
CASES
ALLTEL Corp. v. FCC, 838 F.2d 551 (D.C. Cir. 1988) ..........................................33
AT&T v. FCC, 978 F.2d 727 (D.C. Cir. 1992) ........................................................46
* American Library Ass’n v. FCC, 406 F.3d 689 (D.C. Cir. 2005) ...........................45
* American Radio Relay League, Inc. v. FCC, 524 F.3d 227
(D.C. Cir. 2008) .............................................................................................22
American Trucking Ass’ns, Inc. v. Federal Motor Carrier Safety
Admin., 724 F.3d 243 (D.C. Cir. 2013) .........................................................16
Amoco Prod. Co. v. FERC, 158 F.3d 593 (D.C. Cir. 1998) ....................................35
CSX Transp., Inc. v. Surface Transp. Bd., 584 F.3d 1076
(D.C. Cir. 2009) .......................................................................................20, 44
City of Brookings Mun. Tel. Co. v. FCC, 822 F.2d 1153
(D.C. Cir. 1987) .............................................................................................14
Competitive Telecomms. Ass’n v. FCC, 87 F.3d 522 (D.C. Cir. 1996)...................24
Computer & Communications Indus. Ass’n v. FCC, 693 F.2d 198
(D.C. Cir. 1982) .............................................................................................22
Council Tree Communications, Inc. v. FCC, 619 F.3d 235
(3d Cir. 2010).................................................................................................21
* Environmental Integrity Project v. EPA, 425 F.3d 992
(D.C. Cir. 2005) .............................................................................................20
Exxon Mobil Corp. v. FERC, 315 F.3d 306 (D.C. Cir. 2003) ...........................14, 22
FCC v. Fox Television Stations, Inc., 556 U.S. 502 (2009) ....................................22
Authorities principally relied upon are designated by an asterisk (*).

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Fox v. Clinton, 684 F.3d 67 (D.C. Cir. 2012)..........................................................13
* Home Box Office, Inc. v. FCC, 567 F.2d 9 (D.C. Cir. 1977)...................................33
International Ladies’ Garment Workers’ Union v. Donovan,
722 F.2d 795 (D.C. Cir. 1983).......................................................................35
* Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm Mut. Auto.
Ins. Co., 463 U.S. 29 (1983)....................................................................13, 48
National Black Media Coal. v. FCC, 791 F.2d 1016 (2d Cir. 1986).......................20
National Rural Telecom Ass’n v. FCC, 988 F.2d 174 (D.C. Cir. 1993)............18, 23
National Tel. Coop. Ass’n v. FCC, 563 F.3d 536 (D.C. Cir. 2009) ........................46
Northeast Maryland Waste Disposal Auth. v. EPA, 358 F.3d 936
(D.C. Cir. 2004) .............................................................................................21
Orloff v. FCC, 352 F.3d 415 (D.C. Cir. 2003).........................................................21
Paralyzed Veterans of Am. v. D.C. Arena L.P., 117 F.3d 579
(D.C. Cir. 1997) .............................................................................................25
* Pennsylvania Dep’t of Corr. v. Yeskey, 524 U.S. 206 (1998) .................................27
Petal Gas Storage, LLC v. FERC, 496 F.3d 695 (D.C. Cir. 2007) .........................38
Phillips Petroleum Co. v. FERC, 792 F.2d 1165 (D.C. Cir. 1986) .........................24
* Preiser v. Rodriguez, 411 U.S. 475 (1973)..............................................................27
Public Citizen v. Steed, 733 F.2d 93 (D.C. Cir. 1984).............................................19
SEC v. Chenery Corp., 318 U.S. 80 (1943) .............................................................24
Salzer v. FCC, 778 F.2d 869 (D.C. Cir. 1985) ........................................................25
* Shell Oil Co. v. EPA, 950 F.2d 741 (D.C. Cir. 1991)..................................13, 21, 44
Small Bus. in Telecomms. v. FCC, 251 F.3d 1015 (D.C. Cir. 2001).........................1

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Small Refiner Lead Phase-Down Task Force v. EPA, 705 F.2d 506
(D.C. Cir. 1983) .............................................................................................20
Southwestern Bell Tel. Co. v. FCC, 168 F.3d 1344 (D.C. Cir. 1999) .....................38
Sprint Corp. v. FCC, 315 F.3d 369 (D.C. Cir. 2003) ..............................................44
* United States Tel. Ass’n v. FCC, 188 F.3d 521 (D.C. Cir. 1999)......................38, 41
STATUTES AND REGULATIONS
5 U.S.C. § 706(2) .....................................................................................................13
28 U.S.C. § 2342(1) ...................................................................................................1
28 U.S.C. § 2344..................................................................................................1, 16
47 U.S.C. § 151........................................................................................................45
47 U.S.C. § 154(i) ....................................................................................................45
47 U.S.C. § 201........................................................................................................21
47 U.S.C. § 201(b) ...................................................................................................26
47 U.S.C. § 276(b)(1)(A) .........................................................................................28
47 U.S.C. § 276(d) ...................................................................................................45
47 U.S.C. § 402(a) ...............................................................................................1, 16
47 C.F.R. § 0.291(e).................................................................................................44
47 C.F.R. § 64.6000 .................................................................................................11
47 C.F.R. § 64.6010 .............................................................. 1, 13, 14, 22, 29, 30, 44
47 C.F.R. § 64.6020 .................................................................................2, 13, 29, 30
47 C.F.R. § 64.6020(a).............................................................................................29

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47 C.F.R. § 64.6030 ...................................................................................................1
47 C.F.R. § 64.6060 ...............................................................................13, 29, 30, 44
Miss. Code Ann. § 47-5-158....................................................................................27
Tex. Gov’t Code Ann. § 495.027(a) ........................................................................48
ADMINISTRATIVE MATERIALS
Declaratory Ruling, Petition for Declaratory Ruling by the Inmate
Calling Services Providers Task Force, 11 FCC Rcd 7362
(1996) (“ICS Declaratory Ruling”) .............................................................6, 7
Memorandum Opinion and Order, Orloff v. Vodafone Airtouch
Licenses, LLC, 17 FCC Rcd 8987 (2002)......................................................22
Memorandum Opinion and Order, Petition of USTelecom for
Forbearance, 28 FCC Rcd 7627 (2013)........................................................23
Memorandum Opinion and Order, Ryder Communications, Inc. v.
AT&T Corp., 18 FCC Rcd 13603 (2003) ......................................................48
Order and Notice of Proposed Rulemaking, Petition of Comsat Corp.,
13 FCC Rcd 14083 (1998).............................................................................23
Order on Remand and Notice of Proposed Rulemaking,
Implementation of the Pay Telephone Reclassification and
Compensation Provisions of the Telecommunications Act of
1996, 17 FCC Rcd 3248 (2002) (“ICS Order on Remand and
NPRM”) .....................................................................................................6, 28
Report and Order, Implementation of the Pay Telephone
Reclassification and Compensation Provisions of the
Telecommunications Act of 1996, 11 FCC Rcd 20541 (1996)........................7
Report and Order, International Settlement Rates, 12 FCC Rcd 19806
(1997).............................................................................................................23
Report and Order, Policies and Rules Concerning Operator Service
Providers, 6 FCC Rcd 2744 (1991).................................................................7
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Report and Order, Request to Update Default Compensation Rate for
Dial-Around Calls from Payphones, 20 FCC Rcd 20231 (2004) .................39
Report and Order and Second Further Notice of Proposed
Rulemaking, Policy and Rules Concerning Rates for Dominant
Carriers, 4 FCC Rcd 2873 (1989) (“Report and Order on Rates
for Dominant Carriers”)..........................................................................18, 23
Second Further Notice of Proposed Rulemaking, Billed Party
Preference for InterLATA 0+ Calls, 11 FCC Rcd 7274 (1996)......................6
Second Report and Order, Policy and Rules Concerning Rates for
Dominant Carriers, 5 FCC Rcd 6786 (1990) (“Second Report
and Order on Rates for Dominant Carriers”).........................................18, 23
Second Report and Order and Order on Reconsideration, Billed Party
Preference for InterLATA 0+ Calls, 13 FCC Rcd 6122 (1998)
(“Billed Party Preference Second Report and Order”)...............................6, 7
Sixth Order on Reconsideration and Memorandum Opinion and
Order, Connect America Fund, 28 FCC Rcd 2572 (2013)............................23
Third Report and Order, and Order on Reconsideration of the Second
Report and Order, Implementation of the Pay Telephone
Reclassification and Compensation Provisions of the
Telecommunications Act of 1996, 14 FCC Rcd 2545 (1999)........................28
OTHER AUTHORITIES
Access Charge Reform; Price Cap Performance Review for Local
Exchange Carriers; Transport Rate Structure, 62 Fed. Reg.
56,121 (Oct. 29, 1997)...................................................................................24
Rates for Interstate Inmate Calling Services, 78 Fed. Reg. 67,956
(Nov. 13, 2013)..........................................................................................1, 12

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GLOSSARY
Bureau

Wireline Competition Bureau

Communications Act or Act

Communications Act of 1934, as
amended,47 U.S.C. § 151 et seq.

DOC

A State Department of Corrections

FCC or Commission

Federal Communications Commission

ICS

Inmate Calling Services

NPRM

Notice of Proposed Rulemaking, Rates for
Interstate Inmate Calling Services, 27 FCC
Rcd 16629 (2012)

Order

Report and Order and Further Notice of
Proposed Rulemaking, Rates for Interstate
Inmate Calling Services, FCC 13-113, 28 FCC
Rcd 14107 (2013)

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STATEMENT OF JURISDICTION
This Court has jurisdiction over this appeal under 47 U.S.C. § 402(a) and
28 U.S.C. § 2342(1). The Order was released on September 26, 2013. The new
regulations adopted in the Order were published in the Federal Register on
November 13, 2013, at 78 Fed. Reg. 67,956. The petitions were timely filed
within 60 days of publication of the new regulations. 28 U.S.C. § 2344; see also
Small Bus. in Telecomms. v. FCC, 251 F.3d 1015, 1024 (D.C. Cir. 2001).
STATEMENT OF THE ISSUES
1.

Whether the requirement in Rule 64.6010 that interstate inmate calling

rates and ancillary charges be cost-based is unlawful because the FCC adopted it
without notice and an opportunity for comment; failed to explain its embrace of
rate-of-return regulation, which the FCC has long disfavored; failed to provide
adequate clarity about how to comply with the requirement; and failed to permit
recovery, through interstate rates, of the costs of site commissions required by
many correctional authorities.
2.

Whether the rate caps in Rule 64.6030 – which govern interstate

calling rates at all correctional facilities across the country, irrespective of size or
type – are arbitrary, capricious, or contrary to law.

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3.

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Whether the safe harbor rates in Rule 64.6020 – which also apply at

all correctional facilities in the country – are arbitrary, capricious, or contrary to
law.
4.

Whether the FCC’s regulation of “ancillary fees” is arbitrary,

capricious, or contrary to law.
5.

Whether the FCC’s failure to exempt from its new rules the interstate

calling rates set under existing contracts is arbitrary, capricious, or contrary to law.
STATUTES AND REGULATIONS
Pertinent statutes and regulations have been reproduced in the Addendum.
PRELIMINARY STATEMENT
Last year, the FCC adopted sweeping new rules to reduce the rates for
interstate telephone calls from prisons and jails. The Order establishes two rate
caps – one for interstate collect calls, and another for interstate debit calls – which
apply to every interstate call, from every correctional facility in the country (absent
a waiver for “unique circumstances”). The Order also goes much further,
requiring that ICS providers charge rates for interstate calls no greater than costs
“reasonably and directly related to the provision of ICS,” plus some reasonable
return on investment. Although the Order creates “safe harbor” rates for debit and
collect calls – at a level about half the rate caps – those rates entitle a provider only
to a presumption of compliance with the cost-based-rate rule, not an exemption

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from it. The Order imposes the same cost-based requirement (though without
offering safe harbors) on account set-up and maintenance fees and other “ancillary
charges.”
These new rules are unlawful. The cost-based-rate rule should be
overturned because the FCC provided no notice that it was considering a regime of
rate review based on providers’ historic costs. That rule is also arbitrary and
capricious: the FCC did not justify its decision to adopt a rate-of-return regime it
has disfavored for decades, or provide adequate guidance about how ICS providers
may comply with the rule. Moreover, the FCC’s conclusion that cost-based rates
cannot include the costs of site commissions – which many state and local
correctional institutions require and use to finance inmate welfare programs –
exceeds the FCC’s statutory authority under the Communications Act while
impinging on state and local authority to choose how to run and fund their prisons.
The Order’s “interim” overlay of rate caps and safe harbor rates on the costbased-rate rule cannot survive this Court’s review, either. The FCC’s refusal to
adopt rate caps tailored to facilities of different types and sizes ignores the
unrebutted evidence that ICS costs vary widely among correctional facilities, and
will make it impossible for providers to continue to provide service at many
facilities at rates that permit recovery of costs. The FCC’s rate caps are also
tainted by serious methodological flaws. The cap for collect calls, for example,

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was set based on a cost study that omitted the three highest-cost data points. And
the safe harbors – which would be necessary only if the cost-based-rate rule
survives (and it should not) – suffer from the same defects as the rate caps. In
establishing the safe harbor rates, the FCC ignored a critical data set – cost data for
jails, which comprise a substantial proportion of the facilities regulated by the
Order, and can be much costlier to serve.
Compounding these problems, the FCC declined to exempt existing
contracts from the Order’s cost-based-rate rule and rate caps – even though
contracts with above-cap interstate rates and contracts that require payment of site
commissions will be affected. Where ICS providers find themselves unable to
renegotiate or unilaterally terminate existing (multi-year) contracts, they will be
forced to absorb the costs, without any mechanism of recovering the lost revenue
later.
The Order should be vacated in full.
STATEMENT OF THE CASE
A.

The ICS Providers – CenturyLink, GTL, Securus, and Telmate –

provide inmate telecommunications services in correctional facilities throughout
the country. Their customers range from municipal and county jails that house
fewer than ten inmates to state correctional systems that house tens of thousands

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and from minimum-security to maximum-security facilities.1 The ICS Providers
provide these telecommunications services pursuant to exclusive multi-year
contracts with correctional authorities, which select their providers through a
competitive bidding process. Order ¶¶ 21, 98 (JA___, ___-__). Collectively, the
ICS Providers have contracts with departments of corrections in nearly all 50
states, and with numerous city and county jails.2
The costs of providing these services are substantial and vary widely by
institution.3 Security considerations partly account for the costs. Correctional
authorities require their contract providers to make available customized security
and network features, including special automated voice-processing systems to
enable call screening; sophisticated blocking mechanisms to prevent inmates from
evading screening; “monitor[ing] for frequent calls to the same number,” which

1

Comments of GTL at 3 (FCC filed Mar. 25, 2013) (JA___) (“GTL
Comments”).
2

See Comments of Human Rights Defense Center, Ex. A (FCC filed Mar.
25, 2013) (“HRDC Comments”) (JA___) (identifying ICS providers for each
state); see also Letter from Glenn B. Manishin, Counsel for Telmate, to Marlene H.
Dortch, FCC, at 1 (July 26, 2013) (“July 26, 2013 Telmate Letter”) (JA___)
(noting the “thousands of smaller county and municipal jails served by ICS
providers like Telmate”).
3

Comments of Network Communications International Corp. at 3-4 (FCC
filed Mar. 25, 2013) (“NCIC Comments”) (JA___-__); Comments of CenturyLink
at 7 (FCC filed Mar. 25, 2013) (“CenturyLink Comments”) (JA___); GTL
Comments at 6-7 (JA___-__); July 26, 2013 Telmate Letter at 1 (JA___).

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might signal “possible criminal activity or a scheme to evade calling restrictions”;
listening and recording capabilities; and “detailed, customized reports” concerning
inmates’ telephone use.4 The composition and costs of these security features
depend on each facility’s size and needs.5
Most correctional authorities also require, under their contracts, that their
ICS providers pay them site commissions, which typically are based on calling
revenues. Order ¶ 33 (JA___). Correctional authorities often use those fees in part
to pay for inmate welfare services they provide. Id. ¶ 34 (JA___). Owing to these
and other costs, inmate calling rates often exceed, sometimes substantially, rates
for ordinary toll calls. Id. ¶¶ 32-34 (JA___-__).

4

Order on Remand and Notice of Proposed Rulemaking, Implementation of
the Pay Telephone Reclassification and Compensation Provisions of the
Telecommunications Act of 1996, 17 FCC Rcd 3248, ¶ 9 (2002) (“ICS Order on
Remand and NPRM”); accord Notice of Proposed Rulemaking, Rates for Interstate
Inmate Calling Services, 27 FCC Rcd 16629, ¶ 6 (2012) (“NPRM”) (JA___);
Comments of GTL at 5, CC Docket No. 96-128 (FCC filed May 2, 2007) (“2007
GTL Comments”) (JA___).
5

See ICS Order on Remand and NPRM ¶ 9; Second Report and Order and
Order on Reconsideration, Billed Party Preference for InterLATA 0+ Calls,
13 FCC Rcd 6122, ¶ 56 (1998) (“Billed Party Preference Second Report and
Order”); Second Further Notice of Proposed Rulemaking, Billed Party Preference
for InterLATA 0+ Calls, 11 FCC Rcd 7274, ¶ 48 (1996); Declaratory Ruling,
Petition for Declaratory Ruling by the Inmate Calling Services Providers Task
Force, 11 FCC Rcd 7362, ¶¶ 23, 25 (1996) (“ICS Declaratory Ruling”).

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B.

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Because the provision of ICS is subject to unique “concerns and

requirements of corrections authorities,”6 the FCC has historically refrained from
intrusive regulation of inmate calling rates. In 1991, the FCC found that “the
provision of [inmate-only phones] to inmates presents an exceptional set of
circumstances that warrants their exclusion from . . . any requirements under the
[Telephone Operator Consumer Services Improvement] Act or the Commission’s
rules.”7 In 1996, after again finding that ICS was subject to unique concerns and
demands of correctional facilities, the FCC “deregulated inmate payphones.”8 In
1998, the FCC opted against “intrusive” regulatory measures for ICS providers,
such as the adoption of a “billed party preference” rule or benchmark rates for
outgoing calls by prison inmates, in favor of “less intrusive” new disclosure rules.9
C.

In 2012, the FCC issued a Notice of Proposed Rulemaking to consider

several specific proposals to lower ICS rates. The proceeding was initiated in
6

ICS Declaratory Ruling ¶ 25; see also Billed Party Preference Second
Report and Order ¶ 57 (structure of exclusive ICS contracts is driven by “the
special security requirements applicable to inmate calls”).
7

Report and Order, Policies and Rules Concerning Operator Service
Providers, 6 FCC Rcd 2744, ¶ 15 (1991).
8

Report and Order, Implementation of the Pay Telephone Reclassification
and Compensation Provisions of the Telecommunications Act of 1996, 11 FCC
Rcd 20541, ¶ 143 (1996); accord ICS Declaratory Ruling ¶ 26 (“[customer
premises equipment] used in providing inmate-only services must be provided on
an unregulated, unbundled basis by those who provide inmate-only services”).
9

Billed Party Preference Second Report and Order ¶ 59.

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response to two petitions for rulemaking filed by Martha Wright and other
individuals seeking new ICS regulations. The first petition, filed in 2003, asked
the FCC to prohibit exclusive ICS contracts and collect-call-only restrictions, but
only at privately administered prisons.10 The second petition, filed in 2007,
proposed as an alternative that the FCC establish rate caps “for all interstate,
interexchange inmate calling services” and require ICS providers to offer debit
calling services at all prison facilities they serve.11 The 2007 petition asked the
FCC to adopt benchmark rates no higher than $0.20 per minute for debit calls and
$0.25 per minute for collect calls, with no additional set-up or per-call charges.12
The NPRM sought comment on these and several other discrete proposals,
focusing on rate caps.13 Interested parties, including GTL, CenturyLink, and
Securus, filed comments addressing each of these specific issues.

10

Petition of Martha Wright, et al. for Rulemaking or, in the Alternative,
Petition To Address Referral Issues in Pending Rulemaking at 3, Implementation
of the Pay Telephone Reclassification and Compensation Provisions of the
Telecommunications Act of 1996, CC Docket No. 96-128 (FCC filed Nov. 3, 2003)
(“Wright Pet.”) (JA___).
11

Petitioners’ Alternative Rulemaking Proposal at 4, 23, Implementation of
the Pay Telephone Reclassification and Compensation Provisions of the
Telecommunications Act of 1996, CC Docket No. 96-128 (FCC filed Mar. 1, 2007)
(“Alternative Wright Pet.”) (JA___, ___).
12

Id. at 5 (JA___).

13

NPRM ¶¶ 18-26, 28, 30-34, 36, 39-40 (JA___-__) (seeking comment on
eliminating per-call charges, capping per-minute rates, using marginal location

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On September 26, 2013, the FCC released the Order. The Order
acknowledged the specific relief sought in the two petitions for rulemaking and the
specific ICS issues about which it had sought comment. Order ¶¶ 9, 10 (JA_____). It adopted several of those proposals at least in part, including “interim rate
cap[s]” nearly identical to the rate caps the Wright petitioners had sought – “$0.21
per minute for debit and prepaid interstate calls, and $0.25 per minute for collect
interstate calls.” Id. ¶ 48 (JA___-__).
The FCC also went much further, adopting, by a 2-1 vote,14 a sweeping new
rule requiring that all interstate ICS rates be based on providers’ costs. Id. ¶ 12
(JA___). Under this rule, all interstate ICS rates above the rate caps are unlawful
(absent a waiver for “extraordinary circumstances”), and any interstate ICS rate,
even if below the rate caps, is unlawful if not based on a provider’s costs to
provide interstate ICS. Id. ¶ 120 (JA___). Expressly excluded from those costs,

methodology to establish rate caps, adopting tiered pricing (with different
per-minute rates for different volumes of usage), establishing different caps for
collect calls and debit calls, capping interstate rates at intrastate long-distance rates,
requiring ICS providers to offer debit or prepaid calling options, mandating a
certain amount of free calling per inmate per month, and restricting billing-related
call blocking).
14

The prior Chairman and one other Commissioner had left the FCC when
this item was voted. The new Chairman and Commissioner had been nominated
but not yet confirmed.

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and therefore unrecoverable through interstate ICS rates, are site commissions –
which many ICS contracts require providers to pay. Id. ¶ 7 (JA___-__).
As part of its cost-based regime, the Order creates interim “safe harbor”
levels for interstate rates ($0.12 per minute for debit and prepaid calls, and $0.14
per minute for collect calls), below which rates are presumed permissible. Even
rates at safe harbor levels are unlawful, however, if not based on costs the FCC
deems “allocable” to interstate ICS, id. ¶¶ 60, 120 (JA___, ___), and the “safe
harbor” is unavailable to an ICS provider that charges rates above safe harbor
levels at any of the facilities that it serves, id. ¶ 60 n.226 (JA___). Rates above the
safe harbor level are not presumed reasonable and could result in refunds and
forfeitures (of more than one million dollars per “continuing violation”), even if
they are lower than the rate caps. Id. ¶¶ 89, 118 (JA___, ___).

Safe Harbor

Interim Rate
Cap

Call Type

Per-Minute

15-Minute
Total

Debit

$0.12

$1.80

Credit

$0.14

$2.10

Debit

$0.21

$3.15

Credit

$0.25

$3.75

The Order’s cost-based-rate requirement applies not only to rates for
interstate calls but also to “ancillary charges,” a term that the NPRM did not even

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mention and which the Order defines broadly to include any ICS charges not
assessed on a per-call basis. Order at 89 (Rule 64.6000) (JA___). ICS providers
assess such charges for services related, for example, to the debit and prepaid
account systems that they maintain for inmate callers. See id. ¶ 90 (JA___) (e.g.,
charges to “set up or add money to a debit or prepaid account [or] to refund any
outstanding money in a prepaid or debit account”) (footnote omitted). The Order
requires that these charges be cost-based without creating safe harbors or caps.
Commissioner Pai issued a 21-page dissent stating that he could not support
an order which, rather than “institut[e] simple rate caps, . . . essentially imposes
full-scale rate-of-return regulation on ICS providers.” Dissenting Statement of Ajit
Pai at 111 (“Pai Dissent”) (JA___). He noted that the FCC had not informed the
public that such a rule was on the table, lacks the “competence to micromanage”
ICS prices, and lacks the resources to review the tremendous quantity of data
providers will soon be required to file. Id. at 111-12 (JA___-__). Commissioner
Pai also objected to the FCC’s “one-size-fits-all approach” to rate caps and safe
harbors, which he said ignored substantial evidence that ICS costs vary widely as a
result of differences in facility size, composition of inmate population, and other
factors. Id. at 116-22 (JA___-__).

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The Order’s new rules were published in the Federal Register on November
13, 2013, and were scheduled to take effect on February 11, 2014. 78 Fed. Reg.
67,956.
D.

Securus and a group of correctional institutions each petitioned the

FCC for a stay of the Order in full.15 GTL petitioned the FCC for a stay of the
cost-based-rate regime adopted in the Order.16 On November 21, 2013, the FCC’s
Wireline Competition Bureau denied Securus’s and GTL’s petitions, and deferred
ruling on the correctional institutions’ petition.17 Two other ICS providers,
CenturyLink and Pay Tel, subsequently filed petitions for stay.18
E.

Securus, GTL, CenturyLink, and the Mississippi and South Dakota

Departments of Corrections petitioned this Court for review of the Order, and each
moved the Court for a stay of all or part of the Order pending review.19 On

15

Securus Petition for Stay of Report and Order Pending Appeal (FCC filed
Oct. 22, 2013); Correctional Institutions Petition for Stay Pending Judicial Review
(FCC filed Nov. 12, 2013).
16

GTL Petition for Stay Pending Judicial Review (FCC filed Oct. 30, 2013).

17

Order Denying Stay Petitions and Petition To Hold in Abeyance, Rates for
Interstate Inmate Calling Services, 28 FCC Rcd 15927, ¶¶ 60, 62 (Wireline Comp.
Bur. 2013) (“Bureau Denial ”) (JA___).
18

CenturyLink Petition for Stay (FCC filed Nov. 27, 2013); Pay Tel Petition
for Partial Stay (FCC filed Nov. 26, 2013).
19

GTL Motion for Partial Stay Pending Judicial Review (filed Nov. 25,
2013); Securus Emergency Motion for Stay of FCC Order Pending Review (filed
Nov. 25, 2013); CenturyLink Motion for Stay Pending Judicial Review (filed Dec.

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January 13, 2014, a panel of this Court granted a stay of the Order’s cost-basedrate rule, 47 C.F.R. § 64.6010, and the regulations deriving from it, id. §§ 64.6020
(the safe harbor rule), 64.6060 (an annual reporting requirement). Order, Nos. 131280, et al. (Jan. 13, 2014). The panel noted that, with respect to those rules,
“petitioners have satisfied the stringent requirements for a stay.” Id.
STANDARD OF REVIEW
This Court will vacate an FCC order that is contrary to law, arbitrary and
capricious, unsupported by evidence, or without observance of procedure required
by law. 5 U.S.C. § 706(2). An order is unlawful if it adopts new rules without
“adequate notice and opportunity for comment” by affected parties. Shell Oil Co.
v. EPA, 950 F.2d 741, 747 (D.C. Cir. 1991) (per curiam).
An order is arbitrary and capricious if the FCC has “relied on factors which
Congress has not intended it to consider, entirely failed to consider an important
aspect of the problem, [or] offered an explanation for its decision that runs counter
to the evidence before the agency.” Motor Vehicle Mfrs. Ass’n of U.S., Inc. v.
State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Fox v. Clinton,
684 F.3d 67, 74-75 (D.C. Cir. 2012). This Court will also reverse, as arbitrary and
capricious, “a decision that departs from established precedent without a reasoned
4, 2013); Mississippi Department of Corrections and South Dakota Department of
Corrections Motion for Stay Pending Judicial Review (filed Dec. 13, 2013).

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explanation.” Exxon Mobil Corp. v. FERC, 315 F.3d 306, 309 (D.C. Cir. 2003).
“Post hoc rationalizations advanced to remedy inadequacies in the agency’s record
or its explanation are bootless.” City of Brookings Mun. Tel. Co. v. FCC, 822 F.2d
1153, 1165 (D.C. Cir. 1987).
SUMMARY OF ARGUMENT
I. The cost-based-rate rule, codified at 47 C.F.R. § 64.6010, is unlawful for
four independent reasons. First, the FCC failed to provide notice that it was
contemplating the adoption of such a rule. Second, the FCC failed to explain its
decision to adopt in this context a regulatory mechanism that it has uniformly
disfavored for decades. Third, the FCC imposed obligations on ICS providers
without providing adequate guidance about how they are to comply with the costbased-rate regime – what rate of return is permissible, for example, and which
costs count. Finally, the FCC exceeded its statutory authority by refusing to permit
providers to recover the costs of site commissions through the cost-based rates they
must now charge. These defects require vacatur of the cost-based-rate rule and the
regulations that hinge on it.
II. The Order’s one-size-fits-all “interim” regime of rate caps disregards
unrebutted evidence that differences in facilities’ size and functions warrant
different rates and that average per-minute costs at some facilities far exceed the
rate caps adopted in the Order. Indeed, even the FCC now concedes that the rate

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caps will force providers either to charge rates below their costs for many small,
high-cost institutions or to cease providing service to those institutions.
III. The Order’s safe harbor rates – which depend upon and thus should fall
with the cost-based-rate rule – suffer from the same flaws as the rate caps. Among
other methodological errors, they too were set without regard to differences in size,
function, and cost of providing ICS at correctional facilities across the country, and
despite substantial and unrebutted evidence that costs in many cases far exceed
even the rate caps, not to mention the much lower safe harbor rates.
IV. The FCC’s regulation of ancillary charges must be vacated for three
reasons: the Commission gave no notice that it was considering cost-based
regulation of ancillary charges; the fees are outside of its jurisdiction; and the FCC
fails to offer any guidance on how providers should determine whether their
ancillary charges are cost-based.
V. In refusing to exempt existing contract rates from the Order’s costbased-rate requirement and rate caps, the FCC improperly ignored the practical
effects of its Order, namely, that ICS providers will be precluded from recovering
substantial costs, including site commissions, built into their existing contracts.

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STATEMENT OF STANDING
The ICS Providers have constitutional standing because the Order has
directly caused them injury: it imposes new limitations on the interstate calling
rates and ancillary fees they are permitted to charge end users for the inmate
calling services they provide, and refuses to exempt existing contracts from those
rules. See Order ¶¶ 5-7 (JA___-__). The ICS Providers have prudential standing
because each participated in the proceedings that led to the Order. See 47 U.S.C.
§ 402(a); 28 U.S.C. § 2344; American Trucking Ass’ns, Inc. v. Federal Motor
Carrier Safety Admin., 724 F.3d 243, 246 (D.C. Cir. 2013).
ARGUMENT
I.

The FCC’s Cost-Based-Rate Rule in § 64.6010 Is Unlawful
A.

The FCC Adopted Rate-of-Return Regulation Without
Notice and an Opportunity for Comment

1.

Until the Order was released, “[n]o party could have foreseen” that

the Commission was contemplating a regime that would require every ICS
provider to calculate every interstate rate on the basis of its costs. Pai Dissent at
112 (JA___). The two petitions for rulemaking that prompted the 2012 NPRM did
not request it. The first petition did not propose regulation of ICS rates at all.20

20

See generally Wright Pet. at 8-9 (JA___-__) (describing relief requested);
see also Comments of Martha Wright, et al., Ex. C at 5 (FCC filed Mar. 25, 2013)
(“Wright Comments”) (JA___) (“In regulating prison payphone rates, a simple

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The second petition proposed rate caps, not regulation limiting providers to
recovery of costs the FCC considers “allocable” to interstate ICS. Alternative
Wright Pet. at 5 (JA___). The Wright petitioners clearly distinguished that rate cap
proposal from cost-based rate of return.21 The NPRM also failed to hint at the
possibility of a cost-based regime in which any rate – even if beneath the “caps” –
could be invalidated if deemed not based on allowable interstate ICS costs.
Instead, the NPRM sought comment on rate cap proposals. See NPRM ¶¶ 18-40
(JA___-__) (seeking comment on, among other things, across-the-board perminute caps, caps tied to usage volumes, different caps for collect and debit calls,
and caps tied to intrastate long-distance rates).
The difference between rate caps and the Order’s “cost-based” rule is
fundamental. Rate caps provide certainty by setting “limits on prices carriers can

benchmark rate – which sets a maximum allowed rate, but not a minimum or
required rate, for all service providers – is appropriate.”).
21

See Alternative Wright Pet. at 19-20 (JA___-__) (describing the proposed
caps as “proxies” – i.e., substitutes – for “actual incremental cost plus a marketbased rate of return”); Wright Comments at 32 (JA___) (proposing caps akin to
“price caps [that would] provide a powerful incentive for service providers to
become more efficient”); see also, e.g., 2007 GTL Comments at 7 (JA___)
(describing Wright petitioners’ proposal to “impos[e] a rigid system of national
rate caps”).

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charge for their services.”22 They are also easy to administer; although rate caps
may be based on cost data, they do not require that rates be justified by reference to
each provider’s individual costs, and thus do not require the FCC to gather
“detailed cost data from the regulated firms,” or “formulae for allocating the costs
among the firm’s services.” National Rural Telecom Ass’n v. FCC, 988 F.2d 174,
178 (D.C. Cir. 1993).23 The Order’s cost-based-rate rule, by contrast, requires
each ICS provider to track and account for its costs, to make determinations about
which costs are properly allocable to the regulated service, and to ensure that its
rate of return is “allowable.”24
As Commissioner Pai observed, the Order’s cost-based-rate requirement
thus operates as rate-of-return regulation, which the NPRM indisputably did not
put on the table. Pai Dissent at 123-29 (JA___-__). But, irrespective of labels, the

22

Second Report and Order, Policy and Rules Concerning Rates for
Dominant Carriers, 5 FCC Rcd 6786, ¶ 22 (1990) (“Second Report and Order on
Rates for Dominant Carriers”).
23

The NPRM expressly noted such benefits when it described the
petitioners’ argument that “several benefits would accrue from setting per-minute
rate caps, such as administrative ease and the absence of jurisdictional challenges.”
NPRM ¶ 22 (JA___) (citing Alternative Wright Pet. at 7-8 (JA___-__) (emphasis
added).
24

Report and Order and Second Further Notice of Proposed Rulemaking,
Policy and Rules Concerning Rates for Dominant Carriers, 4 FCC Rcd 2873, ¶ 18
(1989) (“Report and Order on Rates for Dominant Carriers”) (describing rate of
return); see Order ¶ 53 n.195 (JA___).

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NPRM failed to provide notice that the FCC might adopt a rule that ICS providers
set each of their rates equal to certain allowable costs plus a reasonable return. See
Public Citizen v. Steed, 733 F.2d 93, 98 (D.C. Cir. 1984) (“[I]t is the substance of
what the [FCC] has purported to do and has done which is decisive.”) (internal
quotation marks omitted).
2.

The FCC’s shifting justifications for the adequacy of notice do not

accurately describe the new rules it has adopted. In the Order, the FCC conflates
its cost-based-rate rule and rate caps, claiming that the pair amount to a “variant on
rate caps” similar to the NPRM’s rate cap proposals. Order ¶ 59 n.222 (JA___). In
fact those two rules operate (and are codified) independently; neither needs the
other. The nature of this Court’s stay order – which permitted the rate caps to go
into effect on schedule without the cost-based-rate rule – proves that point. The
FCC’s more recent claim (in briefing before this Court) that the Order is at bottom
a rate cap regime of “safe harbor rate[s],” FCC Opposition to Motions for Stay
at 14 (filed Dec. 16, 2013) (“FCC Stay Opp.”), forgets that the “[g]eneral
[s]tandard” governing each interstate ICS rate is the cost-based-rate rule, Order
at 28 (JA___). That rule – not the safe harbor, which provides no exemption from
it – is the crux of the regulatory regime in the Order. See, e.g., id. ¶ 5 n.19
(JA___) (“emphasiz[ing] that ICS providers” cannot “increase rates up to either the

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interim safe harbor or interim rate caps” except “when necessary to ensure
recovery of [ICS] costs”).
The Order identifies no language in the NPRM supporting its claim that the
FCC previously provided notice of the cost-based-rate rule. The NPRM’s request
for other “proposals in the record,” NPRM ¶ 35 (JA___), and for “alternative
methodologies” to determine rates, id. ¶ 25 (JA___); FCC Stay Opp. at 14, could
not establish notice because “catch-all” requests for comment do not give parties
adequate notice of specific rules.25
The NPRM’s discussion of costs and solicitation of cost data likewise failed
to provide notice, because the FCC sought such data only for the purpose of setting
rate caps. Notice of the possibility of rate caps reflecting cost data did not provide
notice of a rule requiring every provider’s interstate ICS rates to be set based on
that provider’s costs.26 Providers had no reason to anticipate that approach, which

25

See Environmental Integrity Project v. EPA, 425 F.3d 992, 998 (D.C. Cir.
2005); accord National Black Media Coal. v. FCC, 791 F.2d 1016, 1022-23 (2d
Cir. 1986) (reference to “variants, modifications, or alternatives” “can hardly be
said to have apprised interested parties” of the specific rule later adopted) (internal
quotation marks omitted); Small Refiner Lead Phase-Down Task Force v. EPA,
705 F.2d 506, 549 (D.C. Cir. 1983) (“Agency notice must describe the range of
alternatives being considered with reasonable specificity.”).
26

See CSX Transp., Inc. v. Surface Transp. Bd., 584 F.3d 1076, 1082 (D.C.
Cir. 2009) (agency rule for resolving rail rate disputes, which permitted parties to
draw from four most recent years of railroad movement data, was not a “logical
outgrowth” of NPRM, which proposed a rule permitting parties to draw from most

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the FCC has long disfavored, see infra Part I.B, and therefore had no “opportunity
to . . . criticize” it. Shell Oil, 950 F.2d at 751; see Council Tree Communications,
Inc. v. FCC, 619 F.3d 235, 256 (3d Cir. 2010) (finding no notice where “no
commenter manifested an understanding that the FCC was considering” rule); cf.
Northeast Maryland Waste Disposal Auth. v. EPA, 358 F.3d 936, 952 (D.C. Cir.
2004) (per curiam) (concluding rule was logical outgrowth of proposed rule, where
“[n]umerous commenters – including two that are among the Industry Petitioners
here – filed comments” on the issue).
Finally, the FCC’s assertion that the cost-based-rate rule is “nothing new,”
FCC Stay Opp. at 15, conflates the provider-specific adjudication of a complaint
with rules that, if upheld, will govern every ICS provider. At the outset, nothing in
section 201 of the Communications Act requires “provider[s] . . . to show that its
rates are based on its costs,” id. – section 201 requires that charges for interstate
communication services be “just and reasonable,” not cost-based. This Court and
the Commission itself have often held that market-based rates are just and
reasonable irrespective of costs. See, e.g., Orloff v. FCC, 352 F.3d 415, 421 (D.C.
Cir. 2003) (upholding Commission determination that sales concessions did not

recent year of data); Shell Oil, 950 F.2d at 752 (rule is “not a logical outgrowth of
the proposed regulations” if it “is not implicit in . . . the system presented in the
proposed regulations”).

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constitute unjust and unreasonable discrimination); Memorandum Opinion and
Order, Orloff v. Vodafone Airtouch Licenses, LLC, 17 FCC Rcd 8987, ¶ 26 (2002)
(rejecting claim that concession practices were unjust and unreasonable); see also
Computer & Communications Indus. Ass’n v. FCC, 693 F.2d 198, 211 (D.C. Cir.
1982). Just as important, the cost-based rule, if upheld, will require all providers
to undertake the data collection, jurisdictional separations, and cost allocation
obligations the Order requires. When the FCC chooses to proceed through
rulemaking, it must provide notice and an opportunity for comment first. See
American Radio Relay League, Inc. v. FCC, 524 F.3d 227, 236 (D.C. Cir. 2008).
B.

The FCC’s Adoption of a Disfavored Regulatory Approach
Without Explanation Was Arbitrary and Capricious

Rule 64.6010 is defective also because the FCC adopted it without justifying
(or even acknowledging) its departure from more than two decades of contrary
FCC precedent. An agency must provide “good reasons” for its new regulations,
FCC v. Fox Television Stations, Inc., 556 U.S. 502, 515-16 (2009), and articulate
“a reasoned explanation” for “depart[ing] from established precedent,” Exxon
Mobil, 315 F.3d at 309. The Order does not explain its embrace of a regulatory
approach – rate of return – that the FCC has long disfavored.
Since the late 1980s, the FCC has retreated from rate-of-return regulation,
recognizing that it “has certain inherent flaws,” presents carriers with “perverse”

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incentives, and is “difficult[ to] administer[] . . . under any circumstances.”27
Because rate of return ties profits directly to the amount of costs in the rate base, it
encourages carriers to “attribute unnecessary costs to their operations in an effort
to generate more revenue.” Second Report and Order on Rates for Dominant
Carriers ¶ 29; accord id. ¶ 9. Rate of return creates a similar incentive to
misallocate costs from unregulated services to services subject to rate-of-return
rules (where costs can be passed on to consumers). Report and Order on Rates for
Dominant Carriers ¶ 100. And it produces “high administrative costs,” id.,
because the agency must use its finite resources to police cost padding and
misallocation, Second Report and Order on Rates for Dominant Carriers ¶ 34;
accord id. ¶ 24. For all these reasons, the FCC concluded long ago that rate of
return is “not the best” regulatory strategy and that “incentive regulation is
superior.” Id. ¶ 29.28

27

Report and Order on Rates for Dominant Carriers ¶¶ 29, 30, 33, 100;
National Rural Telecom Ass’n, 988 F.2d at 178; see also Sixth Order on
Reconsideration and Memorandum Opinion and Order, Connect America Fund,
28 FCC Rcd 2572, ¶ 2 (2013); Memorandum Opinion and Order, Petition of
USTelecom for Forbearance, 28 FCC Rcd 7627, ¶ 153 (2013); Report and Order,
International Settlement Rates, 12 FCC Rcd 19806, ¶ 24 (1997); Order and Notice
of Proposed Rulemaking, Petition of Comsat Corp., 13 FCC Rcd 14083, ¶ 4
(1998).
28

Even the inmate groups that requested an ICS rulemaking proceeding
recognized the FCC’s longstanding “concern that traditional rate-of-return
regulation did not result in sufficient incentives to improve efficiency,” and thus

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The Order’s suggestion that, in regulating ICS rates, the FCC was required
to adopt a cost-based-rate rule unless the record “specially justif[ied]” a different
approach, Order ¶ 45 (JA___), not only ignores the FCC’s longstanding view, it
also misreads this Court’s precedent. In the case on which the FCC principally
relies, this Court held that the FCC must justify a rate structure “that does not
reflect cost.” Competitive Telecomms. Ass’n v. FCC, 87 F.3d 522, 529 (D.C. Cir.
1996) (“Comptel ”). This Court did not hold, in Comptel or any other case, that
rate of return is the default “cost-based” rate structure.29 Any mandate for “costbased” rates provides no basis for choosing between rate-of-return regulation and
rate caps that reflect costs. The FCC’s adoption of a regulation based on its
misunderstanding of this judicial precedent provides additional reason to vacate the
cost-based-rate rule. See SEC v. Chenery Corp., 318 U.S. 80, 87-90 (1943) (an
agency order that rests on a misunderstanding of judicial precedent cannot be
sustained); Phillips Petroleum Co. v. FERC, 792 F.2d 1165, 1172 (D.C. Cir. 1986).

asked instead for benchmark rates akin to “price caps.” Wright Comments at 32
(JA___).
29

As the FCC recognized at the time, a “cost-based” rate structure is simply
one in which costs are recovered “(1) only from the party that causes the costs to
be incurred; and (2) in the manner in which the costs are incurred (e.g., non-trafficsensitive costs should be recovered on a non-traffic-sensitive basis).” Access
Charge Reform; Price Cap Performance Review for Local Exchange Carriers;
Transport Rate Structure, 62 Fed. Reg. 56,121, 56,128 (Oct. 29, 1997).

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Finally, the FCC’s justification for the Order – that lower call rates will
reduce inmate recidivism – is a goal wholly outside the FCC’s authority to pursue
and which has virtually no record support. See Correctional Institutions Br. 35.
C.

The FCC’s Failure To Provide Meaningful Guidance on the
Implementation of the Cost-Based-Rate Rule Was
Arbitrary and Capricious

The cost-based-rate requirement is also flawed because it lacks “sufficient
content and definitiveness” to qualify as “a meaningful exercise in agency
lawmaking.” Paralyzed Veterans of Am. v. D.C. Arena L.P., 117 F.3d 579, 584
(D.C. Cir. 1997); see also Salzer v. FCC, 778 F.2d 869, 875 (D.C. Cir. 1985)
(vacating FCC decision based on directions that were too vague concerning when
“new submissions were required and what form they had to take”). The Order
requires all interstate ICS rates and all ancillary charges to be reduced to costbased levels, with violators subject to refund obligations and forfeiture penalties.
Order ¶ 118 (JA___). Yet it withholds critical information providers need to
determine whether they are in compliance with the rule.
For example, although the Order demands that ICS providers build into
interstate rates only their historical costs “reasonably and directly related to the
provision of ICS,” it does not specify which costs count, other than to say that site
commissions do not. (Even the agency’s definition of site commissions is
ambiguous, because it may be read to cover not only profit-sharing payments but

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also reimbursement for costs incurred by a facility to provide telecommunications
services to inmates. See id. ¶ 54 nn.199, 203 (JA___-__).) At most, the Order
suggests some cost categories that will “likely” count and some that “likely” will
not, id. ¶ 53 & n.196 (JA___); but it makes no promises.30 In addition, the FCC
refuses to “opine” on what rate of return it will permit. Id. ¶ 54 n.203 (JA___).
Thus, despite the potential for refunds and forfeitures, providers are left to guess at
what the FCC considers a fair or permissible return.
D.

The FCC’s Refusal To Permit Recovery of Site Commission
Costs Exceeds Its Statutory Authority

In requiring ICS providers to set cost-based rates that exclude the costs of
site commissions they are required to pay, the Order travels beyond the FCC’s
statutory authority. The Communications Act empowers the FCC to ensure that
interstate calling rates are “just and reasonable,” 47 U.S.C. § 201(b), but it does not
entitle the FCC to ignore real costs of providing service.
Site commission payments – like the purchase of telephone equipment or the
lease of local telephone lines – are a real cost of providing ICS. As the Order
acknowledges, these payments comprise a sizable percentage of the total cost of

30

The Order also requires ICS providers to “apportion” their costs between
interstate and intrastate calls, Order ¶ 53 n.195 (JA___), but provides no guidance
on how to do so. The FCC nonetheless threatens penalties if it disagrees after the
fact with a provider’s jurisdictional separations.

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providing calling services at inmate institutions. See Order ¶¶ 33-34, 38 (JA_____, ___-__). And, for ICS providers, the costs are often unavoidable. Many state
and local correctional authorities require commissions in their ICS contracts, see
id., sometimes because of a statutory mandate, see, e.g., Miss. Code Ann. § 47-5158. “[P]rison administrators and other local policymakers” use these
commissions to “fund inmate health and welfare programs” they provide. Order
¶ 34 (JA___); see Correctional Institutions Br. 22-26.
The Order’s conclusion that these actual costs are not a permissible cost of
providing ICS and are “therefore not compensable in interstate ICS rates,” Order
¶ 54 (JA___), reflects a policy preference that the FCC is not entitled, under the
Communications Act, to write into law. Commissions exist because state and local
authorities have chosen to use them to finance the inmate programs and services
their prisons provide. Such choices are theirs – not the FCC’s – to make. See
Pennsylvania Dep’t of Corr. v. Yeskey, 524 U.S. 206, 208-09 (1998)
(“administration of state prisons” is a core state function reserved to states absent
an “unmistakably clear expression of intent to alter the usual constitutional balance
between the States and the Federal Government”) (internal quotation marks
omitted); Preiser v. Rodriguez, 411 U.S. 475, 491-92 (1973) (“It is difficult to
imagine an activity in which a State has a stronger interest, or one that is more

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intricately bound up with state laws, regulations, and procedures, than the
administration of its prisons.”).
The ICS Order on Remand and NPRM – which the Order cites as support
for excluding site commissions from recoverable costs, Order ¶ 54 (JA___) – is
not to the contrary. That decision referred to a prior order in which, pursuant to the
statutory mandate to ensure “fair[] compensat[ion]” for payphone service
providers, 47 U.S.C. § 276(b)(1)(A), the FCC established a default per-call
compensation amount to be paid to providers for calls made using their payphones.
The FCC ultimately elected to base that default rate on costs to provide service at a
“marginal payphone location,” i.e., a location where call volume generates just
enough revenue to permit the provider to recoup its costs without making any
payments to the owner of the premises where the payphone is installed. See Third
Report and Order, and Order on Reconsideration of the Second Report and Order,
Implementation of the Pay Telephone Reclassification and Compensation
Provisions of the Telecommunications Act of 1996, 14 FCC Rcd 2545, ¶¶ 15, 59
(1999).
The FCC’s prior conclusion, in the payphone context, has no relevance here.
The FCC’s method of calculating the default per-call compensation rate did not
require payphone providers to charge cost-based rates, nor did it prohibit payment
of site commissions at higher-volume locations. To the contrary, where call

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volumes exceeded the volume at the hypothetical “marginal” location, any revenue
above costs would presumably be shared with the location owner in the form of
commissions. (Indeed, as in the ICS context, because of robust competition among
payphone service providers, location owners were presumably able to capture the
lion’s share of any excess of revenues above costs.)
The Order, by contrast, forbids ICS providers from building site
commissions (real costs that providers are contractually required to pay) into their
interstate calling rates – including for existing contracts negotiated on the premise
that the costs of site commissions would be recoverable in rates. That rule is both
unprecedented and wrong.
* * *
Each of the defects identified above requires vacatur not just of the costbased-rate rule, but also of the safe harbor and data collection rules that hinge on it.
The safe harbor, Rule 64.6020, “only makes sense as part of a rate-of-return
system” and “explicitly ties itself to the rate-of-return ratemaking rule.” Pai
Dissent at 114-15 (JA___-__); see 47 C.F.R. § 64.6020(a) (“[a] Provider’s rates are
presumptively in compliance with § 64.6010 (subject to rebuttal)”). Similarly, the
data collection rule, Rule § 64.6060, which requires detailed information from
providers concerning rates, fees, and calls, and a certification of compliance with
the cost-based-rate rule, makes sense only if the cost-based-rate rule survives.

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Vacatur of Rule 64.6010 therefore requires vacatur of Rules 64.6020 and 64.6060
as well.
II.

The “Interim” Rate Caps in § 64.6030 Are Unlawful
A.

The Order’s One-Size-Fits-All Approach to Rate Caps
Inexplicably Disregards Significant Differences Among
Institutions

1.

The Order’s rate caps should be vacated because, in setting uniform,

generally applicable caps, the FCC disregarded unrebutted evidence that
differences in facilities’ size and function warrant different rates. See Pai Dissent
at 116 (JA___) (the “record is replete with evidence” of significant cost differences
among facilities).31 Given that the majority of ICS costs are fixed, and do not vary
with the length or number of calls, average per-minute costs can be much higher in
smaller facilities than in larger ones.32 Moreover, ICS providers incur costs to set

31

See, e.g., Expert Report of Stephen E. Siwek for Securus at 3, 5 (Mar. 25,
2013) (“Siwek Rep.”) (JA___, ___); Letter from John E. Benedict, CenturyLink, to
Marlene H. Dortch, FCC, at 2-3 (Aug. 2, 2013) (“Aug. 2, 2013 CenturyLink
Letter”) (JA___-__) (costs of serving jails are almost 20% higher than costs of
serving state prisons); NCIC Comments at 3-4 (JA___-__); CenturyLink
Comments at 7 (JA___); GTL Comments at 6-7 (JA___-__); July 26, 2013
Telmate Letter (JA___-__); Don J. Wood, Inmate Calling Services – Interstate Call
Cost Study at 4-5, CC Docket No. 96-128 (Aug. 15, 2008) (“Wood Study”)
(JA___-__); Letter from Marcus W. Trathen, Counsel for Pay Tel, to Marlene H.
Dortch, FCC, Attach. at 4 (July 23, 2013) (“Pay Tel Rep.”) (JA___).
32

Wood Study at 5 (JA___); Pay Tel Report at 4 (JA___); CenturyLink
Comments at 7 (JA___); Siwek Rep. at 8 (JA___) (average length of interstate call

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up payment features and activate security features for each new inmate, increasing
costs in institutions with high inmate turnover.33
The record established not just that costs vary substantially, but also that
average per-minute ICS costs at some facilities far exceed the rate caps adopted in
the Order. According to data submitted by ICS providers, for example, costs of
service in 2008 ranged as high as $1.59 per minute for debit calls and $2.05 per
minute for collect calls, exclusive of site commissions.34 Securus submitted
evidence that, at many facilities it serves, ICS costs per minute average $1.39, not
counting site commissions. Siwek Rep. at 3, 5 (JA___, ___). CenturyLink
described costs at the smaller facilities it serves of up to 70 cents per minute. Aug.
2, 2013 CenturyLink Letter at 2 (JA___).

made in state prisons is 12.51 minutes compared to 7.10 minutes in city and county
jails).
33

See Letter from Marcus W. Trathen, Counsel for Pay Tel, to Marlene H.
Dortch, FCC, Attach. at 1 (Aug. 1, 2013) (JA___); Letter from Marcus W. Trathen,
Counsel for Pay Tel, to Marlene H. Dortch, FCC, at 1 (July 3, 2013) (JA___).
34

Pai Dissent at 118 (JA___) (citing Letter from Stephanie A. Joyce,
Counsel for Securus, to Marlene H. Dortch, Secretary, FCC, CC Docket No. 96128, Attach. (Aug. 22, 2008) (JA___-__); Report of Several Providers of Inmate
Telephone Service, CC Docket No. 96-128 (FCC filed Oct. 15, 2008) (JA___-__)).

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Although the FCC sought and obtained information about how rates, call
volumes, and costs vary at facilities across the country,35 it declined to account for
those differences in setting its rate caps. Order ¶ 17 (JA___-__). The Order does
not distinguish among the correctional institutions – private and public prisons,
jails, secure mental facilities, and juvenile detention centers of all sizes – to which
its rules apply. Nor does the Order seriously consider alternatives to a “one size
fits all” approach, even though the FCC was presented with alternatives. See, e.g.,
Pai Dissent at 111 (JA___) (describing proposal of tiered sets of rate caps tied to
facility type and size); Letter from Marcus W. Trathen, Counsel for Pay Tel, to
Marlene H. Dortch, FCC, CC Docket No. 96-128, at 6 (Dec. 9, 2008) (JA___)
(suggesting that the FCC “adopt a tiered rate structure[] using facility size as a
proxy for cost differentials”).36
The Order’s “tack[ed] on” waiver procedure does not blunt the impacts of
its one-size-fits-all rate caps for facilities with disparate costs, and does not

35

See NPRM ¶ 26 (JA___) (seeking such data); GTL Comments at 6-8
(JA___-__); NCIC Comments at 3-4 (JA___-__); CenturyLink Comments at 7
(JA___); Siwek Rep. at 3-4 (JA___-__); July 26, 2013 Telmate Letter at 2
(JA___); Aug. 2, 2013 CenturyLink Letter (JA___-__).
36

The FCC’s excuse for rejecting a more tailored regulatory scheme – that
there was too little information to draw more precise lines, Order ¶ 81 (JA___-__)
– was a reason to defer action, not to adopt “interim” regulations that are
unreasonable for a large percentage of correctional facilities. If the FCC had too
little information to act, it should have sought more information before acting.

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compensate for the FCC’s failure to craft more tailored rules. ALLTEL Corp. v.
FCC, 838 F.2d 551, 561 (D.C. Cir. 1988). As the Order takes pains to emphasize,
its waiver process is reserved for “unique circumstances,” Order ¶ 17 n.60
(JA___); accord id. ¶ 6 (JA___), and the “rare provider” that can make the
necessary showing, id. ¶ 74 (JA___), that rate caps at a given facility will preclude
recovery of costs at the holding-company level. Where, as here, the FCC “is on
record that it will not freely grant waivers,” the lawfulness of its “rules must be
assessed without reference to the waiver provisions.” Home Box Office, Inc. v.
FCC, 567 F.2d 9, 50 (D.C. Cir. 1977) (per curiam).
2.

In dismissing small, high-cost facilities where ICS costs far exceed

the rate caps, because those facilities “hold only a very small share of inmates
nationally,” Order ¶ 26 (JA___), the FCC ignores that these facilities constitute a
substantial proportion of the correctional institutions covered by the Order. See
Pai Dissent at 119 & n.67 (JA___). It was inexplicable for the FCC to subject
these many facilities to the same rate caps as much larger facilities with much
lower costs to provide ICS.37

37

The Wright petitioners’ own consultant acknowledged that, “[b]ecause of
the unavoidable inefficiencies of serving extremely small facilities, [petitioners’]
analysis may not apply to locally-administered jails and other low-capacity prison
facilities.” Wright Pet., Attach. A at 37 n.46 (JA___).

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The Order’s claim that ICS providers “typically use uniform rates when they
serve multiple correctional facilities with differing cost and demand characteristics
under a single contract,” Order ¶ 76 n.280 (JA___), similarly focuses on the wrong
evidence. There is no record evidence that ICS providers set uniform rates for
local jails across various counties, or for both statewide prisons and county jails.
Instead, the record reflects that ICS providers set different rates, pursuant to
different contracts, for facilities with such different costs of service. See, e.g.,
Comments of Securus at 1-2 (FCC filed Mar. 25, 2013) (“Securus Comments”)
(JA___-__); July 26, 2013 Telmate Letter at 2 (JA___); Affidavit of Richard A.
Smith ¶ 4, Nos. 13-1280, et al. (Nov. 25, 2013) (attached to Securus Emergency
Motion for Stay) (Securus serves 2,200 facilities and has approximately 1,800
contracts).
B.

The Order Ignores the Practical Consequences of Its Failure
To Account for High-Cost Facilities in Setting Rate Caps

The Order’s rate caps should also be vacated because the FCC failed to
grapple with the practical consequences – for inmates and facilities alike – of its
one-size-fits-all rules. The Order predicts that its rate caps will represent an
“upper limit of what can reasonably be expected to be cost-based rates.” Order ¶ 5
(JA___). As even the FCC now concedes, that prediction was not accurate.
Following the Order’s adoption of the rate caps, Pay Tel – the very same ICS
provider whose own cost study was used to set the Order’s $0.21/$0.25 per-minute
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rate caps – was forced to request a waiver because compliance with the caps would
“leave[] it in an ‘economically unsustainable situation.’” Order, Rates for
Interstate Inmate Calling Services, 29 FCC Rcd 1302, ¶ 6 (Wireline Comp. Bur.
2014) (“Waiver Order”) (JA___) (quoting Pay Tel Waiver Pet. at 2). The FCC
agreed, and granted Pay Tel a waiver that permits it to charge rates as high as
$0.46 per minute, or approximately double the rate caps. See id. ¶¶ 11, 17 (JA_____).
But the rate caps will put other providers in the position of charging rates
below their costs for many small, high-cost institutions.38 The caps are more than a
dollar per minute too low, for example, to permit recovery of costs for a substantial
proportion of the facilities Securus serves, and nearly 50 cents below costs for
small facilities where CenturyLink provides ICS. See supra p. 31.
The Order promises no relief for such facilities: providers can obtain a
waiver only in “extraordinary circumstances,” and only after proving that, at the
holding-company level, rate caps preclude recovery of costs. Order ¶ 73 n.270
38

Agency action predicated on unreasonable predictive judgments cannot
stand. See International Ladies’ Garment Workers’ Union v. Donovan, 722 F.2d
795, 821-22 & n.56 (D.C. Cir. 1983) (agency’s predictive judgment must be
reasonable and grounded in record evidence, and must not “ignore important
factors” or reach judgments that are “irrational given the relevant evidence in the
record”); see also Amoco Prod. Co. v. FERC, 158 F.3d 593, 595-96 (D.C. Cir.
1998) (refusing to defer to agency’s predictive judgment that was not adequately
explained and where evidence raised doubt about the reliability of the prediction).

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(JA___). Many providers with above-cap costs at some facilities (but below-cap
costs at others) thus have no hope of obtaining any waiver. Pay Tel was granted
one only after it demonstrated that, given facility and state regulatory requirements
applicable to intrastate calling rates, the Order’s rate caps would force the whole
company to “‘substantially curtail its operations’” or “go ‘out of business.’”
Waiver Order ¶ 6 (JA___) (quoting Pay Tel Waiver Pet. at 2).
With little hope of obtaining any waiver (and no assurance that a waiver
would offer more than fleeting relief), ICS providers may cease providing ICS
altogether at the highest-cost facilities they serve.39 Providers have no statutory
obligation to provide ICS at any particular correctional facility. At facilities where
costs run much higher than the rate caps, providers may make the business
judgment to stop providing ICS rather than take substantial losses on the service.
The Order shrugs off this concern, noting that “many state departments of
correction make ICS available to inmates at rates lower” than those the Order
adopts. Order ¶ 70 (JA___). That is beside the point. It is small facilities and
39

See Comments of Alabama Sherriffs Association at 1 (FCC filed Apr. 22,
2013) (JA___); Comments of Idaho Sheriff’s Association at 2-3 (FCC filed Apr.
22, 2013) (JA___-__); Comments of Oregon State Sheriffs’ Association at 2-3
(FCC filed Apr. 22, 2013) (JA___-__); Letter from Louisiana Sheriffs’
Association, CC Docket No. 96-128, at 1 (June 26, 2008) (JA___); Letter from
Louisiana Sheriffs’ Association, CC Docket No. 96-128, at 1 (July 14, 2008)
(JA___); Letter from Arkansas Sheriffs’ Association, CC Docket No. 96-128, at 1
(Aug. 18, 2008) (JA___).

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other high-cost institutions – not statewide departments of correction, which
generally have less challenging cost structures – where ICS is likely to cease.
Moreover, that ICS providers may occasionally provide service at facilities at rates
below costs40 hardly indicates that ICS providers will serve all high-cost
institutions with below-cost rates, or that they would be willing or able to continue
providing service at these institutions at any rate.
To the extent ICS providers continue serving these facilities, at rates below
costs, they will be able to do so only by using revenues from lower-cost facilities
to cross-subsidize those costs of service. Consequently, “long-term prison inmates
will be forced to subsidize the calls of short-term jail inmates.” Pai Dissent at 120
(JA___). The Order does not acknowledge this, let alone explain why it would be
reasonable to reduce rates for some inmates at the expense of others.
C.

The Order’s Rate Caps Are Tainted by Methodological Flaws

Finally, the FCC’s rate caps should be rejected because the FCC’s
methodology for arriving at the caps – using averaged cost data and ignoring
outliers – was flawed. Although “composite industry data or other averaging

40

See Order ¶ 80 n.301 (JA___) (one ICS provider has served small
facilities at a loss when it “represent[s] that community or . . . ha[s] a lot of
facilities in that area”); Bureau Denial ¶ 27 (JA___-__) (noting that, according to
the Siwek Report, Securus charges some below-cost rates at the highest-cost
facilities it serves).

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methods” may be appropriate where the data are sufficiently comparable, and
where the FCC is willing to “adjust[] and modif[y]” its approach for “varied” data
points, Southwestern Bell Tel. Co. v. FCC, 168 F.3d 1344, 1352-53 (D.C. Cir.
1999); see FCC Stay Opp. at 21, here the cost data varied widely, and the FCC was
unwilling to modify its averaging approach for high-cost facilities. Instead, the
FCC chose its debit rate cap based on Pay Tel cost data reflecting Pay Tel’s
average per-minute costs, Order ¶ 76 (JA___-__), and its collect rate cap based on
averaged 2008 cost data for several providers, id. ¶ 78 (JA___). Averaging
divergent data to arrive at across-the-board rate caps was not a reasonable
approach on this record.41
In setting a rate cap for collect calls, the FCC compounded its error by
excluding some data points before averaging, without explaining “why the outliers
were unreliable or their use inappropriate.” See United States Tel. Ass’n v. FCC,
188 F.3d 521, 525 (D.C. Cir. 1999) (“USTA I”). The study from which the collectcall rate cap was derived discussed two methodologies for arriving at average

41

See Petal Gas Storage, LLC v. FERC, 496 F.3d 695, 699-700 (D.C. Cir.
2007) (rejecting use of proxy groups comprised of companies with “highly
different risk profiles”); cf. Southwestern Bell, 168 F.3d at 1352-53 (approving use
of industry data where the FCC concluded “that the LECs generally use the same
assets and perform the same tasks in providing physical collocation service,” and
where the FCC made “adjustments and modifications to this general approach
where costs varied widely among carriers”) (internal quotation marks omitted).

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costs. The methodology chosen by the FCC reflected the costs of providing
service at 25 facilities, see Pai Dissent at 120 (JA___), but it excluded three other
facilities “whose traffic characteristics cause service providers to be unable to
recover their costs of serving that location,” Wood Study at 4-5 & n.10 (JA_____). The second methodology presented in the cost study included the three
locations deemed uneconomical to serve, and generated a per-minute average rate
of $0.283 – more than three cents per minute higher than the collect-call rate cap.
Pai Dissent at 120 (JA___). The FCC provides no reason – other than a desire to
push caps lower regardless of the evidence – to eliminate three facilities from the
data set it averaged to reach a collect-call rate cap. Moreover, prior agency
applications of the same methodology suggest that these facilities should have been
included in the analysis.42 And the FCC does not explain how its collect-call rate
cap can be described as “conservative,” Order ¶ 6 (JA___), when the study from
which the cap is derived warned that ignoring the three high-cost locations would
likely understate costs, Wood Study at 9 (JA___).
The FCC was also aware of, but ignored, record evidence that the study on
which its collect-call rate cap is based understated costs in other respects. See id.
42

See Report and Order, Request to Update Default Compensation Rate for
Dial-Around Calls from Payphones, 20 FCC Rcd 20231, ¶ 47 (2004) (including
payphones that “may not currently recoup all their costs” in a marginal location
analysis similar to the analysis on which the Order relies).

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at 15-16 (JA___-__). For instance, the study’s author reported that low-volume,
high-cost facilities were likely “statistically underrepresented.” Id. at 15 (JA___).
The FCC, by contrast, somehow concluded that “smaller, potentially higher-cost
facilities are over-represented in the data submission’s sample.” Order ¶ 80
(JA___). In addition, Securus reported that its cost data from the 2008 study were
no longer accurate and that its costs had since increased by more than 16%. See
Securus Comments, Ex. 5 (JA___). The FCC disregarded this information,
undermining its conclusion that the collect-call rate cap “presumably ensures fair
compensation to ICS providers.” Order ¶ 79 (JA___).
III.

The Safe Harbor Rates in § 64.6020 Are Independently Unlawful
The Order’s safe harbor rates should be invalidated not only because they

depend on the existence of the cost-based-rate rule – which already has been stayed
and now should be vacated, see supra Part I – but also because they suffer from the
same flaws as the rate caps. The FCC set safe harbor rates without regard to
differences in size, function, and cost of providing ICS at correctional facilities
across the country, and would deny the safe harbor to any ICS provider that
charges higher rates at even a single facility – despite the substantial and
unrebutted evidence that costs vary widely and in many cases far exceed even the
rate caps (not to mention the safe harbor rates, which are much lower). Moreover,
the safe harbor rates the FCC chose are indefensible on this record. The FCC

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derived these rates solely from rate data for seven state prisons that do not accept
site commissions. Order ¶¶ 61-62 (JA___-__). Even if site commissions were
properly considered not to be a cost of providing ICS and thus were properly
excluded from ICS rates (but see supra pp. 26-29), that methodology could not
withstand scrutiny.
First, the FCC excluded any cost data for jails – even though jails often cost
more to serve, and charging above-safe-harbor rates at even a single jail will
entirely disqualify a provider for the safe harbor. Pai Dissent at 121 (JA___). The
Order’s claim that safe harbors are set “at conservative levels to account for the
fact that there may be cost variances among correctional facilities,” Order ¶ 62
(JA___), is thus incorrect.43
Second, the FCC “decline[d] to base” its safe harbor rates – even in part – on
cost and revenue data submitted by two ICS providers, Securus and CenturyLink.
Order ¶ 68 (JA___). The FCC’s “concerns about relying entirely on these data to
calculate rates” because Securus and CenturyLink did not present disaggregated
data, id., could not justify that decision, given that the data on which the FCC

43

The Bureau was likewise wrong to describe the “data from state prisons”
as “more closely approximat[ing] actual costs.” Bureau Denial ¶ 26 (JA___).
That claim would be accurate only if the FCC ignored providers’ “actual costs” of
serving other types of facilities, which the FCC is not permitted to do. See USTA I,
188 F.3d at 525.

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relied likewise failed to disaggregate individual costs. See HRDC Comments,
Ex. A (JA___). Moreover, the FCC did not need granular data from ICS providers
distinguishing among collect, debit, or prepaid calls, to understand that its safe
harbor rates are far too low to provide service at many of the facilities Securus and
CenturyLink serve.
Third, the FCC calculated safe harbor rates by averaging rate data for the
seven prison systems, despite large rate variances among those seven states. Order
¶¶ 61-62 (JA___-__). As a result, per-minute rates in two of the seven states,
Michigan and Rhode Island, substantially exceed the safe harbor levels. In Rhode
Island, current per-minute rates exceed the Order’s rate caps, too – leaving ICS
providers serving Rhode Island state prisons prohibited from charging rates that the
FCC used to compute the safe harbor. Id. ¶ 63 n.235 (JA___-__). The FCC
dismisses these states – which comprise nearly 30% of the data set – as statistical
anomalies that did not warrant any increase in the safe harbor levels. Id. But that
assumes, without record support, that Michigan and Rhode Island prisons do not
have cost characteristics that would explain their higher rates.
Fourth, the FCC excluded California’s rates from the analysis, even though
California has also prohibited the payment of site commissions. The explanation
for this exclusion is wholly inadequate; the FCC merely notes that the rates in
California “recover the costs of significant in-kind contributions that, under the

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contract, the ICS provider is required to make,” id. ¶ 62 n.228 (JA___), without
describing what those in-kind contributions are, or evaluating whether the in-kind
contributions are directly attributable to California’s costs of providing
telecommunications service to inmates, which the FCC has told this Court would
be appropriately included in setting a provider’s rates, FCC Stay Opp. at 7 & n.1
(citing Order ¶ 54 n.203 (JA___)); id. at 8. Had California been included, the
resulting “safe harbor” for collect calls would have been $0.18/minute (28.5%
higher than the $0.14 actually adopted) and for debit and prepaid calls it would
have been $0.16/minute (25% higher than the $0.12 actually adopted). The lack of
analysis strongly suggests that the FCC excluded California simply because it did
not like the resulting rates.
Fifth, the FCC’s calculations were anything but “conservative,” Order ¶ 62
(JA___). After averaging the seven state prisons’ rate data, the FCC rounded down
to arrive at its safe harbor rates. Id. ¶¶ 63-64 (JA___-__). As noted, this left the
average interstate rate for two of the states’ prison systems – which do not accept
commissions – above the safe harbor levels. The safe harbor levels are thus
unreasonably low even in states that “have adopted the reforms the Order suggests
are necessary to correlate rates with costs.” Pai Dissent at 121 (JA___).

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The Commission’s Attempt To Regulate “Ancillary Fees” Is Contrary
to Law
Rules 64.6010 and 64.6060 also purport to regulate fees for financial

transactions and account management. These measures also should be vacated.
1.

The FCC gave no notice that it was considering regulation of ancillary

charges; the NPRM did not even mention the term. Months later, the Wireline
Competition Bureau issued a two-page Public Notice titled “More Data Sought on
Extra Fees Levied on Inmate Calling Services.”44 But the Order does “not
suggest[] that this Bureau-level request itself provided notice with respect to
ancillary charges.” Order ¶ 91 n.338 (JA___). The Bureau lacks power “to issue
notices of proposed rulemaking” and thus, as a matter of law, could not have
supplied notice here.45 And the “hodgepodge of comments strewn over several
years,” Pai Dissent at 115 n.33 (JA___), which included uninvited calls for the
regulation of ancillary fees, Order ¶ 91 n.338 (JA___), cannot excuse the FCC’s
failure to provide notice.46

44

28 FCC Rcd 9080 (Wireline Comp. Bur. 2013) (JA___-__).

45

47 C.F.R. § 0.291(e); see Sprint Corp. v. FCC, 315 F.3d 369, 376 (D.C.
Cir. 2003) (public notice by Common Carrier Bureau, “which lacks the authority
under the Commission’s regulations to issue notices of proposed rulemaking,”
could not have put Sprint on notice that the Commission was proposing to revise a
rule).
46

CSX Transp., 584 F.3d at 1082 (“Under the APA, . . . notice must come
from the NPRM.”); Shell Oil, 950 F.2d at 751 (“Even if the mixture and

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The FCC’s regulation of these fees must also be rejected because the

fees are outside of its jurisdiction.47 “Ancillary charges” are fees assessed on the
financial transactions, not the telecommunications services. “It is axiomatic that
administrative agencies may issue regulations only pursuant to authority delegated
to them by Congress.” American Library Ass’n v. FCC, 406 F.3d 689, 691 (D.C.
Cir. 2005) (vacating broadcast flag rules as outside Commission’s authority). The
FCC’s mandate is for “regulating interstate and foreign commerce in
communication by wire and radio.” 47 U.S.C. § 151. Fees related to payment
methods are entirely outside and independent of inmate “communication by wire
or radio.” For this reason, neither the Commission’s “ancillary authority” under 47
U.S.C. § 154(i) of the Act, or the reference to “any ancillary services” in § 276(d)
of the Act, gives the FCC jurisdiction. It is unreasonable to stretch the meaning of
these sources of authority to allow the Commission to regulate transactions fees
that are not charged in exchange for access to payphone equipment or
telecommunications services.

derived-from rules had been widely anticipated, comments by members of the
public would not in themselves constitute adequate notice.”).
47

Reply Comments of Securus at 16 (FCC filed Apr. 22, 2013) (JA___)
(citing 47 U.S.C. § 151 mandate “regulating interstate and foreign commerce in
communication by wire and radio”); see also Securus Reply Comments in
Response to DA-13-1445 at 1-3 (FCC filed July 24, 2013) (JA___-__).

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The “cost-based” rule for ancillary charges is also substantively

flawed. The FCC does not begin to explain how providers should determine
whether their ancillary charges are cost-based. But, because the Order establishes
no “safe harbor” or caps for ancillary charges, ICS providers must bear all the risk
as they try to predict whether their ancillary charges will meet the FCC’s approval
– based on metrics the FCC has not yet laid out, let alone tried to justify.
V.

The FCC’s Refusal To Exempt Existing Contract Rates from the
Order’s Cost-Based-Rate Rule and Rate Caps Was Arbitrary and
Capricious
In refusing to exempt interstate rates in existing ICS contracts from the

Order’s cost-based-rate requirement and rate caps, the FCC “ignore[d] the
practical effect of its order,” AT&T v. FCC, 978 F.2d 727, 734 (D.C. Cir. 1992),
namely, that ICS providers will be precluded from recovering substantial costs
built into their existing contracts. The FCC’s failure to grapple with this obvious
consequence was arbitrary and capricious. National Tel. Coop. Ass’n v. FCC, 563
F.3d 536, 540 (D.C. Cir. 2009) (“The APA’s arbitrary-and-capricious standard
requires that agency rules be reasonable and reasonably explained.”).
During the proceeding below, there was substantial consensus among
stakeholders that any new rate regulations should not apply to the rates in existing
ICS contracts for (at minimum) one year after the rules became effective. See
Order ¶¶ 98-102 (JA___-__); Alternative Wright Pet. at 28-29 (JA___-__); Reply

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Comments of Martha Wright, et al., at 17 (Apr. 22, 2013) (JA___) (“There is
simply no legitimate justification for the FCC not to adopt a one-year, fresh-look
period . . . .”). Numerous commenters, including both ICS providers and state
correctional authorities, went further, requesting that the FCC make any new ICS
rate regulations applicable only to contracts entered into after the regulations’
effective date. As those commenters explained, contracts obligate providers to
make “long-term capital commitments,” over a period of three or more years, and
those commitments are “made with a certain set of assumptions,” such as the rates
that ICS providers will be allowed to charge. CenturyLink Comments at 15
(JA___). Although ICS contracts may contain change-of-law provisions, those
provisions are individualized to specific contracts and do not all clearly permit
providers to renegotiate rates when the law changes. Id. at 15-16 (JA___-__); GTL
Comments at 29 (JA___).
Not only does the Order fail to create an exemption for existing ICS
contracts; it also denies the obvious implications of that choice. The Order states
that the FCC “do[es] not take a position” on whether its new rules will affect any
existing contracts, Order ¶ 101 (JA___), and that, in any case, ICS providers can
“renegotiate their contracts or terminate existing contracts so they can be rebid
based on revised terms,” id. ¶ 102 (JA___). The Order further concludes, without
explanation, that 90 days is a sufficient period of time for the parties “to

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renegotiate contracts or take other appropriate steps.” Id. (JA___). These claims
utterly “fail[] to consider an important aspect of the problem” providers have
identified – the economic and legal realities underlying ICS providers’ existing
contracts. State Farm, 463 U.S. at 43; see also Memorandum Opinion and Order,
Ryder Communications, Inc. v. AT&T Corp., 18 FCC Rcd 13603, ¶ 24 (2003) (“the
integrity of contracts . . . is vital to the proper functioning of any commercial
enterprise, including the communications market,” and “the long-term health of the
communications market depends on the certainty and stability that stems from the
predictable performance and enforcement of contracts”).
The Order addresses neither the possibility that prison and jail officials will
be unwilling to renegotiate their contracts with ICS providers nor the consequences
of their inability or refusal to do so. Nor does the Order contemplate the
possibility that officials in some states are required by state law to insist on the
payment of site commissions even where such commissions will make the ICS
contracts uneconomical. See, e.g., Tex. Gov’t Code Ann. § 495.027(a). The Order
does not address why ICS providers should bear the financial consequences of the
FCC’s decision to exclude site commissions from the costs of services provided
under existing contracts when facilities do not or cannot permit the modification of
existing contracts. The FCC’s failure to address any of these consequences of its
Order is arbitrary and capricious, and requires vacatur.

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CONCLUSION
The Order should be vacated in its entirety.
Dated: May 22, 2014

Respectfully submitted,
/s/ Stephanie A. Joyce
Stephanie A. Joyce
G. David Carter
ARENT FOX LLP
1717 K Street, N.W.
Washington, D.C. 20036-5342
(202) 857-6081

Michael K. Kellogg
Courtney Simmons Elwood
Aaron M. Panner
John B. Ward
KELLOGG, HUBER, HANSEN, TODD,
EVANS & FIGEL, P.L.L.C.
1615 M Street, N.W., Suite 400
Washington, D.C. 20036
(202) 326-7900

Counsel for Petitioner Securus
Technologies, Inc.

Counsel for Petitioner Global
Tel*Link Corporation

Adam Proujansky
Daniel A. Broderick
DICKSTEIN SHAPIRO LLP
1825 Eye Street, N.W.
Washington, D.C. 20006
(202) 420-2200

Robert A. Long, Jr.
Matthew J. Berns
COVINGTON & BURLING LLP
1201 Pennsylvania Avenue, N.W.
Washington, D.C. 20004-2401
(202) 662-6000

Counsel for Intervenor Telmate, LLC

John E. Benedict
Vice President, Federal Regulatory
Affairs & Regulatory Counsel
CENTURYLINK
1099 New York Avenue, N.W.
Washington, D.C. 20001
(202) 429-3114
Counsel for Petitioner CenturyLink
Public Communications, Inc.

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RULE ECF-3(B) ATTESTATION
In accordance with D.C. Circuit Rule ECF-3(B), I hereby attest that all other
parties on whose behalf this joint brief is submitted concur in the brief’s content.

/s/ Stephanie A. Joyce
Stephanie A. Joyce
May 22, 2014

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CERTIFICATE OF COMPLIANCE
Pursuant to Federal Rule of Appellate Procedure 32(a)(7)(C) and D.C.
Circuit Rule 32(a), as modified by the Court’s April 22, 2014 briefing order
granting the ICS Providers 11,900 words, the undersigned certifies that this brief
complies with the applicable type-volume limitations. This brief was prepared
using a proportionally spaced type (Times New Roman, 14 point). Exclusive of
the portions exempted by Federal Rule of Appellate Procedure 32(a)(7)(B)(iii) and
D.C. Circuit Rule 32(a)(1), this brief contains 11,710 words. This certificate was
prepared in reliance on the word-count function of the word-processing system
(Microsoft Word 2007) used to prepare this brief.

/s/ Stephanie A. Joyce
Stephanie A. Joyce
May 22, 2014

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TABLE OF CONTENTS
Page
47 U.S.C. § 201.................................................................................................Add. 1
47 U.S.C. § 276.................................................................................................Add. 2
47 C.F.R. § 64.6000 ..........................................................................................Add. 4
47 C.F.R. § 64.6010 ..........................................................................................Add. 6
47 C.F.R. § 64.6020 ..........................................................................................Add. 7
47 C.F.R. § 64.6030 ..........................................................................................Add. 8
47 C.F.R. § 64.6060 ..........................................................................................Add. 9

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47 U.S.C. § 201
§ 201. Service and charges
(a) It shall be the duty of every common carrier engaged in interstate or foreign
communication by wire or radio to furnish such communication service upon
reasonable request therefor; and, in accordance with the orders of the Commission,
in cases where the Commission, after opportunity for hearing, finds such action
necessary or desirable in the public interest, to establish physical connections with
other carriers, to establish through routes and charges applicable thereto and the
divisions of such charges, and to establish and provide facilities and regulations for
operating such through routes.
(b) All charges, practices, classifications, and regulations for and in connection
with such communication service, shall be just and reasonable, and any such
charge, practice, classification, or regulation that is unjust or unreasonable is
declared to be unlawful: Provided, That communications by wire or radio subject
to this chapter may be classified into day, night, repeated, unrepeated, letter,
commercial, press, Government, and such other classes as the Commission may
decide to be just and reasonable, and different charges may be made for the
different classes of communications: Provided further, That nothing in this chapter
or in any other provision of law shall be construed to prevent a common carrier
subject to this chapter from entering into or operating under any contract with any
common carrier not subject to this chapter, for the exchange of their services, if the
Commission is of the opinion that such contract is not contrary to the public
interest: Provided further, That nothing in this chapter or in any other provision of
law shall prevent a common carrier subject to this chapter from furnishing reports
of positions of ships at sea to newspapers of general circulation, either at a nominal
charge or without charge, provided the name of such common carrier is displayed
along with such ship position reports. The Commission may prescribe such rules
and regulations as may be necessary in the public interest to carry out the
provisions of this chapter.

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47 U.S.C. § 276
§ 276. Provision of payphone service
(a) Nondiscrimination safeguards
After the effective date of the rules prescribed pursuant to subsection (b) of this
section, any Bell operating company that provides payphone service-(1) shall not subsidize its payphone service directly or indirectly from its
telephone exchange service operations or its exchange access operations; and
(2) shall not prefer or discriminate in favor of its payphone service.
(b) Regulations
(1) Contents of regulations
In order to promote competition among payphone service providers and promote
the widespread deployment of payphone services to the benefit of the general
public, within 9 months after February 8, 1996, the Commission shall take all
actions necessary (including any reconsideration) to prescribe regulations that—
(A) establish a per call compensation plan to ensure that all payphone service
providers are fairly compensated for each and every completed intrastate and
interstate call using their payphone, except that emergency calls and
telecommunications relay service calls for hearing disabled individuals shall
not be subject to such compensation;
(B) discontinue the intrastate and interstate carrier access charge payphone
service elements and payments in effect on February 8, 1996, and all intrastate
and interstate payphone subsidies from basic exchange and exchange access
revenues, in favor of a compensation plan as specified in subparagraph (A);
(C) prescribe a set of nonstructural safeguards for Bell operating company
payphone service to implement the provisions of paragraphs (1) and (2) of
subsection (a) of this section, which safeguards shall, at a minimum, include
the nonstructural safeguards equal to those adopted in the Computer Inquiry-III
(CC Docket No. 90-623) proceeding;
(D) provide for Bell operating company payphone service providers to have the
same right that independent payphone providers have to negotiate with the
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location provider on the location provider’s selecting and contracting with, and,
subject to the terms of any agreement with the location provider, to select and
contract with, the carriers that carry interLATA calls from their payphones,
unless the Commission determines in the rulemaking pursuant to this section
that it is not in the public interest; and
(E) provide for all payphone service providers to have the right to negotiate
with the location provider on the location provider’s selecting and contracting
with, and, subject to the terms of any agreement with the location provider, to
select and contract with, the carriers that carry intraLATA calls from their
payphones.
(2) Public interest telephones
In the rulemaking conducted pursuant to paragraph (1), the Commission shall
determine whether public interest payphones, which are provided in the interest of
public health, safety, and welfare, in locations where there would otherwise not be
a payphone, should be maintained, and if so, ensure that such public interest
payphones are supported fairly and equitably.
(3) Existing contracts
Nothing in this section shall affect any existing contracts between location
providers and payphone service providers or interLATA or intraLATA carriers that
are in force and effect as of February 8, 1996.
(c) State preemption
To the extent that any State requirements are inconsistent with the Commission’s
regulations, the Commission’s regulations on such matters shall preempt such State
requirements.
(d) “Payphone service” defined
As used in this section, the term “payphone service” means the provision of public
or semi-public pay telephones, the provision of inmate telephone service in
correctional institutions, and any ancillary services.

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47 C.F.R. § 64.6000
§ 64.6000 Definitions.
As used in this subpart:
Ancillary charges mean any charges to Consumers not included in the charges
assessed for individual calls and that Consumers may be assessed for the use of
Inmate Calling Services. Ancillary Charges include, but are not limited to, fees to
create, maintain, or close an account with a Provider; fees in connection with
account balances, including fees to add money to an account; and fees for
obtaining refunds of outstanding funds in an account;
Collect calling means a calling arrangement whereby the called party agrees to pay
for charges associated with an Inmate Calling Services call originating from an
Inmate Telephone;
Consumer means the party paying a Provider of Inmate Calling Services;
Debit calling means a calling arrangement that allows a Consumer to pay for
Inmate Calling Services from an existing or established account;
Inmate means a person detained at a correctional institution, regardless of the
duration of the detention;
Inmate calling services means the offering of interstate calling capabilities from an
Inmate Telephone;
Inmate telephone means a telephone instrument or other device capable of
initiating telephone calls set aside by authorities of a correctional institution for use
by Inmates;
Prepaid calling means a calling arrangement that allows Consumers to pay in
advance for a specified amount of Inmate Calling Services;
Prepaid collect calling means a calling arrangement that allows an Inmate to
initiate an Inmate Calling Services call without having a pre-established billing
arrangement and also provides a means, within that call, for the called party to
establish an arrangement to be billed directly by the Provider of Inmate Calling
Services for future calls from the same Inmate;

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Provider of Inmate Calling Services, or Provider, means any communications
service provider that provides Inmate Calling Services, regardless of the
technology used.

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47 C.F.R. § 64.6010
§ 64.6010 Cost-based rates for inmate calling services.
All rates charged for Inmate Calling Services and all Ancillary Charges must be
based only on costs that are reasonably and directly related to the provision of ICS.

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47 C.F.R. § 64.6020
§ 64.6020 Interim safe harbor.
(a) A Provider’s rates are presumptively in compliance with § 64.6010 (subject to
rebuttal) if:
(1) None of the Provider’s rates for Collect Calling exceed $0.14 per minute at
any correctional institution, and
(2) None of the Provider’s rates for Debit Calling, Prepaid Calling, or Prepaid
Collect Calling exceed $0.12 per minute at any correctional institution.
(b) A Provider’s rates shall be considered consistent with paragraph (a) of this
section if the total charge for a 15–minute call, including any per-call or perconnection charges, does not exceed the appropriate rate in paragraph (a)(1) or (2)
of this section for a 15–minute call.
(c) A Provider’s rates that are consistent with paragraph (a) of this section will be
treated as lawful unless and until the Commission or the Wireline Competition
Bureau, acting under delegated authority, issues a decision finding otherwise.

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47 C.F.R. § 64.6030
§ 64.6030 Inmate calling services interim rate cap.
No provider shall charge a rate for Collect Calling in excess of $0.25 per minute,
or a rate for Debit Calling, Prepaid Calling, or Prepaid Collect Calling in excess of
$0.21 per minute. A Provider’s rates shall be considered consistent with this
section if the total charge for a 15-minute call, including any per-call or perconnection charges, does not exceed $3.75 for a 15-minute call using Collect
Calling, or $3.15 for a 15-minute call using Debit Calling, Prepaid Calling, or
Prepaid Collect Calling.

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47 C.F.R. § 64.6060
§ 64.6060 Annual reporting and certification requirement.
(a) All Providers must submit a report to the Commission, by April 1st of each
year, regarding their interstate and intrastate Inmate Calling Services for the prior
calendar year. The report shall contain:
(1) The following information broken out by correctional institution; by
jurisdictional nature to the extent that there are differences among interstate,
intrastate, and local calls; and by the nature of the billing arrangement to the
extent there are differences among Collect Calling, Debit Calling, Prepaid
Calling, Prepaid Collect Calling, or any other type of billing arrangement:
(i) Rates for Inmate Calling Services, reporting separately per-minute rates and
per-call or per-connection charges;
(ii) Ancillary charges;
(iii) Minutes of use;
(iv) The average duration of calls;
(v) The percentage of calls disconnected by the Provider for reasons other than
expiration of time;
(vi) The number of calls disconnected by the Provider for reasons other than
expiration of time;
(2) A certification that the Provider was in compliance during the entire prior
calendar year with the rates for Telecommunications Relay Service as required
by § 64.6040;
(3) A certification that the Provider was in compliance during the entire prior
calendar year with the requirement that all rates and charges be cost-based as
required by § 64.6010, including Ancillary Charges.
(b) An officer or director from each Provider must certify that the reported
information and data are accurate and complete to the best of his or her knowledge,
information, and belief.

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CERTIFICATE OF SERVICE
I hereby certify that, on May 22, 2014, I electronically filed the Joint Brief
for the ICS Provider Petitioners and Supporting Intervenor with the Clerk of the
Court for the United States Court of Appeals for the District of Columbia Circuit
using the appellate CM/ECF system. Participants in the case who are registered
CM/ECF users will be served by the appellate CM/ECF system.
I further certify that, on this date, two copies of the foregoing brief were
served by U.S. First Class mail on the following:
Donald B. Verrilli, Jr.
Solicitor General of the United States
United States Department of Justice
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530-0001

/s/ Stephanie A. Joyce
Stephanie A. Joyce