Comment on FR Doc # 2012-12427

August 9, 2012 Attorney General Eric Holder, Jr. U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530-0001 RE: Docket No. OAG-131 National Standards to Prevent, Detect, and Respond to Prison Rape Minimum Staffing Ratios in Juvenile Facilities Dear Attorney General Holder, I am writing to submit these comments regarding the proposed minimum staffing ratios for secure juvenile facilities. As an individual with extensive experience working to remedy dangerous conditions of confinement for youth in the juvenile justice system, I urge you to retain minimum staffing ratios in the juvenile standards, to make the staffing requirements more stringent, and to narrow the range of situations under which agencies can exempt themselves from requirements because of exigent circumstances. I have firsthand knowledge of the importance of adequate levels of direct staff supervision to the safety of staff and youth. From May 2007 to May 2009, I directed the Office of the Independent Ombudsman for the Texas Youth Commission (TYC). As Chief Ombudsman, I investigated abuses and worked to protect the rights of children committed to TYC. I assumed my position at a time when the agency was in crisis, faced with hundreds of sexual abuse allegations against TYC employees in the agency’s secure facilities. In my role, I worked with agency officials to help take steps to address the problems that presented opportunities for sexual victimization. Since December 2010, I have served as the lead federal court monitor in S.H. v.. Stickrath, where I lead a team of experts supervising compliance with a federal court order requiring reforms in the treatment of youth held in custody by the Ohio Department of Youth Services. I have also served as public policy director of the Southern Policy Law Center, chair of the Texas Criminal Justice Coalition, and executive director of the American Civil Liberties Union of Texas. Based on my experience, the proposed standard