Comments in response to Securus’ Petition for Waiver of the Per-Minute Rate Requirement (“Petition”) as a coalition of organizations committed to securing just rates for people who are directly impacted by incarceration. In order to expand its subscriptions program, Securus requested a waiver of FCC rules 64.6030, 64.6080, and 64.6090 that require interstate incarcerated person calling services (“IPCS”) to be charged on a per-minute basis.1 In response, we echo Worth Rises’ Response to Securus’ Waiver Petition dated October 14, 2021 (“Response”), urging the Commission to request and carefully review more information about Securus’ subscription pilots before granting such a significant waiver.