Comment on FR Doc # 2012-12427

1. The ratios enumerated in the provision for minimum staffing should be 1:8, but add "with a minimum of two staff, not including the Control Room Operator". 2. No categories of juvenile detention facilities should be exempt from the staff to youth ratio. It should be 1:8, not including the Control Room Operator. 3. Costs of this provision will be substantial to states and counties. This is due not only to newly required policies/procedure implementation, but to include the cost of FTEs (hiring additional employees) and /or monitoring equipment. 4. The ratio of 8:1, not including the Control Room Operator, will be a major benefit to the safety and security of the children we care for due to increased staff interaction as the control room operator will not be counted in the ratio. 5. No further "studies" are needed...it is common sense that more staff and better procedures equals more prevention and better safety/security for the kids and staff, alike. 6. Video or other types of monitoring CAN NOT replace the 1:8 ratio of staff to youth, not counting the Control Room Operator. 7. The October 1, 2017 effective date gives a good amount of time to prepare, but funding is still going to be a major factor in whether these staff to youth ratios are actually put in place. In summary, provide funding !!!