Regarding Prison Pay Phones, Comment urges FCC to:

1) establish a fair rate for all intra-state and inter-state prisoner telephone calls by eliminating commissions while allowing legitimate costs and providing a reasonable rate of return for service providers.

(2) Foreclose all opportunities to circumvent the elimination of commissions by ensuring that third party payment fees are passed through to families at cost with no mark-up or profit for prison phone service providers.

(3) Require debit calling and other calling options consistent with sound correctional practices and security concerns, including pre-paid, debit, and collect calls; and

(4) Defer to state utilities commissions to address a purported need for cost increases that arise from the provision of service in a particular state.