Comment on FR Doc # 2012-12427

In reference to Docket No. OAG-131 As the NM State Juvenile Detention Certification Manager, I oppose increasing staffing levels in our detention and juvenile facilities. 37106 and 37107 of the Federal Register/Vol. 77, No. 119 states "However the standards may not "impose substantial additional costs compared to the costs presently expended by Federal, State, and local prison authorities" Enacting the standards set minimum staffing levels of 1:8 during waking hours, and 1:16 during resident sleeping hours will impose a large financial burden on the Juvenile Detention Centers in the state of New Mexico. Many of the facilities in NM are in rural areas which already have issues meeting budgets for their current programs. Also recruiting and keeping quality staff in these areas is extremely difficult. The current NM Juvenile Detention Standards require staffing levels of 1:10 during waking hours, and 1:16 during resident sleeping hours. We have found that this is an effective level of staffing to ensure residents are kept safe and well supervised. Thank you for your consideration of these comments if you have any questions please contact me Sincerely Danny Martinez