September 15, 2025
Chairman Brendan Carr
Commissioner Anna Gomez
Commissioner Olivia Trusty
Federal Communications Commission
50 L Street, NE
Washington, DC 20554
Re: Incarcerated People’s Communications Services, WC Docket Nos. 23-62, 12-375
Dear Chairman Carr, Commissioners Gomez and Trusty:
The ninety-five undersigned organizations write to request that the Commission rapidly
overturn the Wireline Competition Bureau Suspension Order1 that removes, for a period of
two years, essentially all the rules adopted last year to implement the Martha Wright Reed
Just and Reasonable Communications Act. 2 Specifically, we urge you to grant the
Application for Review filed by several public interest organizations. 3
As organizations that supported the Federal Communications Commission’s efforts to
promptly and correctly implement the Martha Wright-Reed Act, we are deeply
disappointed in this staff-level decision’s sudden abandonment of its rules and the
vulnerable consumers who are left without the protections mandated by Congress. In its
original decision, the Commission found:
overwhelming evidence of the substantial burden excessive communications rates
have on the ability of incarcerated people to stay connected and maintain the vital,
human bonds that sustain families and friends when a loved one is incarcerated. 4

In re Incarcerated People’s Communications Services; Implementation of the Martha
Wright-Reed Act, WC Docket Nos. 23- 62, 12-375, Order, DA 25-565 (WCB rel. June 30,
2025) (Suspension Order).
2
Martha Wright-Reed Just and Reasonable Communications Act of 2022, Pub. L. No. 117338, 136 Stat. 6156 (2023) (Martha Wright-Reed Act).
3
Benton Institute, Pennsylvania Prison Society, Criminal Justice Reform Clinic Lewis &
Clark Law School, National Consumer Law Center, Prison Policy Initiative, Public
Knowledge, United Church of Christ Media Justice Ministry and Worth Rises, Application
for Review, WC Docket Nos. 23-62, 12-375 (filed Jul. 20, 2025),
https://www.fcc.gov/ecfs/document/10731681711939/1.
4
In re Incarcerated People’s Communications Services; Implementation of the Martha
Wright-Reed Act, Report and Order, Order on Reconsideration, Clarification and Waiver,
and Further Notice of Proposed Rulemaking, 39 FCC Rcd 7647, ¶ 26 (2024).
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Not only is predatory pricing inhumane, but affordable communication lowers recidivism
and promotes successful reentry after release. For decades, providers of these
communications services have charged egregiously high rates and engaged in deceptive
practices because they face no competition to consider the interests of consumers, who
are a literally captive market.
Incarcerated people, their loved ones, clergy and all those supporting them have waited
decades for meaningful reform to the communications market. Congress acted, passing
the Martha Wright-Reed Act which addressed a long-standing gap in the FCC’s authority to
ensure that communications prices for incarcerated people are just and reasonable.
Congress required the FCC to address video calling and local rates for the first time. The
FCC implemented this directive with thorough and well-considered rules and rate caps for
local and video calls. The deadline for most of the prisons and jails in the country to
comply passed on April 1, 2025.5 Then, without warning, the Bureau suddenly removed all
the new protections a few months later, on June 30, flouting Congress’s directive.
The Suspension Order lacked reasonable facts to support its decision: no party even
sought the Bureau’s action. The companies that opposed the rules had already received
waivers to address specific, targeted implementation delays—and had indicated a need
for a waiver extension, not complete reversal of all the FCC’s rules. With a minor
exception, GTL—the main opponent of the FCC’s rules in prior years—had not opposed the
rules at all, either in court or at the FCC. The Suspension Order justified unilaterally
removing protections for the whole country by citing to one jail that had not filed at the FCC
but had announced (unjustifiably) that it would no longer permit calling because of the
FCC’s rule—and which has not restored service now that the rules have been suspended.
All the other reasons given are speculative and unsubstantiated.
The Suspension Order offered no notice and sought no public comment on its action
suspending federal rules, violating the Administrative Procedure Act. The Bureau staff do
not have authority to override a decision adopted by the FCC commissioners. Although the
Bureau called its decision a “waiver,” the Bureau disregarded the FCC’s waiver rules—in
fact, to fully suspend an entire set of rules for the whole industry does not even qualify as a
waiver.
The Commission should rapidly act to review the Bureau decision and return to
compliance with legislation that was adopted without a single no vote in Congress. People
who are incarcerated and their families deserve the protection of the law.

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47 CFR § 64.6010(d).
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Please take prompt action to address this matter and reverse the Bureau’s decision.
Sincerely,
914United
Advocates for Change
Aging Well Durham
American Humanist Association
Asian Americans Advancing Justice - AAJC
Boston Immigration Justice Accompaniment Network (BIJAN)
Bridgeway
Coalition for Social Justice
Coalition on Human Needs
Communications Workers of America (CWA)
Community Alliance on Prisons
Cooperative Baptist Fellowship
COYOTE RI
Cunningham Township Supervisor’s Office
CURE
CURE-SORT
Demand Progress
Electronic Privacy Information Center (EPIC)
Elephant Circle
EMIT (End Mass Incarceration Together)
Empowering Women Impacted by Incarceration
The Episcopal Church
EX-incarcerated People Organizing (EXPO) of Wisconsin
Faith Action for Community Equity
The Federal Prison Education and Reform Alliance-PERA
Fight for the Future
Fines & Fees Justice Center
FLORECER
Free Press
Freedom Force Florida
Georgia Resource Center
Hawai‘i Friends of Restorative Justice
Hawaii Conference United Church of Christ
HBCU International Innovation Media
Human Rights Defense Center
Illinois Alliance for Reentry and Justice
Incarcerated Workers Organizing Committee
Information for Change Washington
Instituto de Educacion Popular del Sur de California (IDEPSCA)
Iowa Justice Action Network
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Iowa Prison Perspectives
Jail Prison and Advocacy Project
Japanese American Citizens League
Jesse’s Place Organization
Just Future Project
JustLeadershipUSA
JustUS Coordinating Council
Latino Action Network
The Leadership Conference on Civil and Human Rights
Legal Services for Prisoners with Children
Living Beyond the Bars of Iowa
Maryland CURE
Media Alliance
MediaJustice
Mennonite Central Committee U.S.
MI-CURE
Minnesota Incarcerated Workers Organizing Committee
Missionary Oblates of Mary Immaculate
Minnesota Office of the Ombuds for Corrections
Multicultural Media, Telecom and Internet Counsel
Mystic Valley Action for Reproductive Justice
National Action Network
National Center for Law and Economic Justice
National Council of Churches
National Hispanic Media Coalition
National Urban League
NETWORK Lobby for Catholic Social Justice
No Cost Calls/Keeping Families Connect Coalition of MA
NTEN
Oregon CURE
Out for Justice, Inc.
Private Equity Stakeholder Project
The Promise of Justice Initiative
Public Justice
Public Justice Center
The Real Cost of Prisons Project
Returning Home Foundation
San Francisco Financial Justice Project
scaleLIT
Secure Justice
Skagit Legal Aid
Stand for Children Colorado
The STEM Alliance
Tallahassee Industrial Workers of the World, GMB
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TeamChild
Transition from Prison Ministry Team (Plymouth Church, Des Moines, IA)
Underground Ministries
Uptown People's Law Center
Utah Prisoner Advocate Network
The Utility Reform Network (TURN)
UV4SOR - United Voices for Sex Offense Reform
Voice of the Experienced (VOTE)
VT CURE
Washington Defender Association
Women & Incarceration Project, Center for Women’s Health & Human Rights, Suffolk
University

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