Prison Phone Justice

930 E. 50th Street
Chicago, Illinois 60615
VIA ECFS
December 10, 2012
Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554
Re: Meeting with Commissioner Mignon Clyburn on Ownership, Prison Phone Rate, and
Lifeline Issues
Dear Secretary Dortch:
On December 6, Rev. Jesse L. Jackson, Sr., Dr. George Korn, associate professor, Ohio
University School of Media Arts and Studies and advisor to Rev. Jackson, Dr. Sean MacMillan,
director of the Rainbow PUSH Coalition’s program for corporate responsibility, Bishop Tavis
Lane Grant, national field director for the Rainbow PUSH Coalition, and Steven Smith, director,
Rainbow PUSH Coalition Telecommunications Project, met with Commissioner Mignon
Clyburn and members of her staff, David Grimaldi, chief of staff and media legal advisor, and
Angela Kronenberg, wireline legal advisor, regarding a number of issues.
Rev. Jackson expressed his concern about predatory prison telephone rates and indicated that the
issue will be a major focus for the Rainbow PUSH Coalition in the months ahead. He asked
about steps that are being taken within the agency to address the problem and Commissioner
Clyburn and Ms. Kronenberg provided an update on the status of the Wright Petition and other
initiatives that are underway. It became clear that, while the FCC can have an impact on
interstate rates, it has very little jurisdiction on intrastate calling rates. Dr. MacMillan explained
that Rainbow PUSH will be focusing on predatory intrastate rates as it is currently doing in Cook
County, Illinois. The Rainbow delegation indicated plans to sponsor hearings on predatory prison
phone rates in Chicago and possibly New York and asked for the FCC’s participation.
Rev. Jackson expressed our organization’s ongoing support for the Lifeline program for lowincome Americans and our commitment to making it work as efficiently and effectively as
possible. Dr. Korn observed that, while compliance plan approval has been slow since the
requirement was implemented, there are signs that the pace of approvals will be picking up and
he expressed appreciation for that. He also expressed the hope that, as the mechanics of the
process continue to take shape, it will be marked by clarity of criteria, transparency and fairness.

Korn also addressed the Lifeline 10 federal state petition process. He indicated that the approval
process has been virtually frozen for the past 2 years, creating an anticompetitive situation in
these states. A competitive Lifeline situation in the 10 federal states will most likely offer lowincome citizens improved pricing, hardware, and other options that the current duopoly does not
provide. We urge the FCC to move forward on the 10 state approval process and allow qualified
companies to begin offering service. This will improve access and choice for the most needy
citizens in those states. Korn also asked about progress on the Lifeline database. He reminded the
Commissioner that the database is the best answer for problems of fraud, waste and abuse and
urged rapid action on its implementation.
Rev. Jackson and his colleagues expressed their concern regarding the ownership rule changes
that are currently under consideration at the agency. He made clear, as did the court, that
diversity issues must be addressed before there is any further relaxation of ownership rules.
The group also indicated their feeling that the current 30 day response period is not enough time
for meaningful input from those concerned about this important issue. New ownership data has
been released and appropriate analysis must be done regarding ways to address the diversity
issues that are apparent in the data. This will take some time.
At present, Rainbow PUSH does not support relaxation of any existing ownership rules—
including the newspaper rule. A full analysis must done on the effect of any possible changes on
minority ownership, and solutions to diversity issues must be offered, as the court mandated.
Media consolidation rules are inextricably linked to minority ownership. Allowing additional
media consolidation will harm minority owners. The FCC cannot split the two issues and it must
demonstrate a way to improve minority ownership before moving forward with any relaxation of
ownership rules.
If you have questions regarding this letter, please contact me directly.
Respectfully submitted,

George Korn, Ph.D.
Advisor to Rev. Jesse L. Jackson, Sr.
Cc:

Commissioner Mignon Clyburn, Mignon.Clyburn@fcc.gov
David Grimaldi, Dave.Grimaldi@fcc.gov
Angela Kronenberg, Angela.Kronenberg@fcc.gov