I have been planning jails, prisons and juvenile halls since 1986 and was perplexed by W. B. Honeycutt’s opinion piece regarding jail standards (“We need affordable standards,” Nov. 3). While Honeycutt provides some factual information, he leaves out important information, and it is not clear to me that he has advanced the salient arguments in support of his thesis: that a revision to Title 15 of the California Administrative Code is needed to make jail costs more affordable.
It should be pointed out that Title 15 has the half of jail standards that pertain to jail operations. This includes requirements for inmate food, visitor access, medical care and so on. Title 24, Minimum Standards for Local Detention Facilities, has the requirements for the physical design of jails, such the minimum size of cells, how they are furnished and so on.
Most of the specific issues raised in Honeycutt’s piece are found in Title 24. The requirements in Title 15 most certainly affect jail costs, but Honeycutt focussed his discussion on issues addressed in Title 24.
Neither Title 15 nor Title 24 designates the proportions of jail housing allocated to less-expensive minimum-security housing versus more expensive medium- or maximum-security housing. Title 24 requires that all proposals for jail construction be accompanied by a needs assessment that examines the characteristics of the jail population and recommends the appropriate breakdown of housing types based on each jurisdiction’s inmate population.
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The jail standards and review of jail construction documents are administered by the Corrections Standards Authority (formerly the Board of Corrections).
While the needs assessment is supposed to indicate the appropriate mix of security levels in a jail, staff at the Corrections Standards Authority have from time to time developed agendas that tilt enforcement of the standards one way or the other. I would argue that these staff interpretations have had much more impact on the overbuilding of higher-security jail housing than either Title 15 or 24.
I know, for example, that Corrections Standards Authority staff have considered the San Luis Obispo juvenile hall “too soft” for more than a decade and have promoted every opportunity to increase its supply of higher-security beds.
I do not mean to imply that the juvenile hall would not actually benefit from higher-security beds, only that the Corrections Standards Authority staff’s attitudes are based more on their operational experience in adult institutions than any evidence of actual security breaches or changes in the characteristics of San Luis Obispo’s juvenile offenders.
Finally, minimum jail standards have, in practice, become maximum standards whenever the Corrections Standards Authority is administering bond or grant funds for the construction of new detention capacity.
In effect, every standard becomes a target that has to be hit spot on, because one cannot do less for the health and safety of inmates, nor can one spend the money to do any more. This makes it difficult for a jurisdiction to attempt innovative new approaches to dealing with offenders.
I won’t argue that Title 15 could not benefit from some revision. However, circumstances are more complex than suggested in Honeycutt’s Viewpoint. Delivering more within existing jail budgets will require an examination of Title 24 and the Corrections Standards Authority policy, as well as more flexibility to enable local jurisdictions to try innovative new ideas.
Greg Allen Barker is a registered architect with 25 years of experience. He has managed and contributed to numerous comprehensive criminal justice plans.