20160304Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:GRACE SEAMAN
DATE:MARCH2,2016
RE:2015 IDAHO TELECOMMUNICATIONS RELAY SERVICE ANNUAL
REPORT;CASE NO.GNR-T-16-02.
BACKGROUND
Each February the Administrator of the Idaho Telecommunications Relay Service (IRS
or relay)files a report detailing the activities and status of the program during the previous year.
The Administrator also determines the funding requirements for the following year and submits a
recommended budget with the annual report.
In 1992,the Idaho Legislature established the Telecommunications Relay Service Act
(TRS Act)in accordance with the federal Title IV of the American with Disabilities Act.The
TRS enables citizens who are hearing or speech-impaired to engage in telephone
communications “in a manner functionally equivalent to that of individuals without hearing or
speech impairments.”Idaho Code §61-1301.Under the Idaho TRS Act,all telephone
corporations providing local or long-distance service (not including wireless or VoIP services)
must provide TRS as set forth in the program and pay into the TRS Fund based upon an
allocation methodology adopted by the Commission.Idaho Code §6 1-1305.Pursuant to TRS
Rule 202,the Commission sets the IRS funding levels each year based upon the Administrator’s
Annual Report.IDAPA 3 1.46.02.202.
The Idaho TRS service provider,Hamilton Telecommunications (Hamilton),operates the
relay center where oral conversations are convened or “relayed”to text-type and vice versa.The
relay center also provides speech-to-speech,Spanish-to-Spanish,video,and Internet relay
services.
DECISION MEMORANDUM -1 -MARCH 2,2016
THE 2015 ANNUAL REPORT
On February 1,2016,the TRS Administrator,Mr.Dunbar,submitted the 2015 TRS
Annual Report and the 2016 TRS Budget for Commission approval.The Administrator reported
that the relay center handled 21,397 minutes of conversation (including out-of-state long distance
minutes)during calendar year 2015 compared to 32,254 minutes in 2014.This represents a 30%
decrease in billable minutes.During the year,the number of Captioned Telephone service
(Caplel)’telephones increased by 3%while the total CapTel usage decreased by 12%to 27,216
minutes.
Disbursements from the TRS fund to Hamilton decreased from $108,394 in 2014 to
$85,515 in 2015.In-state traditional relay and CapTel services are reimbursed by Idaho’s TRS
fund,while the firm of Rolka Loube Saltzer Associates,LLC reimburses 1-lamilton for out-of-
state relay calls as well as intrastate Internet relay and Internet video relay service usage.
Hamilton’s 2015 average answer time was 0.43 seconds;a very good response time.
1.2015 Expenses.The TRS expenses for the year totaled $124,566.The Administrator
reported that disbursements to 1-Iamilton were $85,515.The administrative fees and expenses for
the reporting year were $39,051,including the 2014 audit expense of $6,480.The end-of-year
fund balance was $291,611.
2.2015 Revenues and Allocations.The TRS fund is supported by assessments on local
exchange telephone service (residential and business)access lines and on billed intrastate long
distance minutes.The total number of intrastate long distance minutes reported by the telephone
companies increased by 17%from approximately 175,545,800 minutes in 2014 to approximately
205,405,200 minutes in 2015.The average monthly number of telephone lines reported
decreased by 1%from 382,843 in 2014 to 377,860 in 2015.The 2015 annual contribution to the
TRS fund was $116,656,a decrease of $9,770 (8%)from 2014.Local exchange services
contributed $75,575 (65%)and MTS/WATS contributed $41,081 (35%).In Commission Order
No.33256,the per-line and per-minute assessments for 2015 were maintained at $0.02 and
$00002,respectively.
3.Proposed 2016 Budget.The Administrator projects an annual operating budget of
$97,840.This budget reflects a continued decline in traditional relay usage.If assessment rates
CapTel allows hard-of-hearing users to hear the conversation as well as read the words on the phone’s built-in
screen.A trained operator “re-voices”the conversation from a caller into the voice recognition technology that
converts the words into a text message and provides the CapTel user with a more natural conversation.
DECISION MEMORANDUM -2-MARCH 2,2016
remain unchanged,the Administrator calculates the 2016 end-of-year fund balance will remain
near its current level.The Administrator also advises that Hamilton Communications relay
contract will expire this year.
4.Proposed 2016 TRS Funding Levels.Based on the proposed budget for 2016 and the
2105 end-of-year reserves,the Administrator recommends that the Commission maintain the
assessment rates at the current level for local exchange lines at $02 per month and 5.0002 per
intrastate MTS/WATS billed minute.This will maintain a cushion if unexpected expenses or
program changes occurs at the Federal Communications Commission (FCC).
TRS-Rclatcd FCC Activities
In the past two years,the FCC has issued Orders that may significantly impact the TRS
program and merit careful monitoring by the states.These are discussed below.
1.Internet Protocol Captioned Telephone Service (IP-CTS)Fund.The FCC oversees
and funds a nationwide TRS program,which compensates carriers that provide out-of-state TRS
calls over traditional wireline facilities,as well as Voice over Internet Protocol (V0IP)services.2
One form of relay service that uses VoIP is the IP CTS.At the 2015 National Association of
Relay Administrators (NASRA)conference last fall,an FCC representative,reiterated that the
FCC continues to reassess the transfer of fiscal and operational responsibility for IP-CTS from
the FCC to the states.3 Idaho does not administer IP-CTS and does not have funding nor
processes in place should the FCC transfer responsibility of this program to state jurisdictions.
2.TDM4-to-IP Transition Experiments.The FCC adopted a framework for approving
trials,or experiments for preserving traditional communications-related values,such as public
safety,consumer protection,competition and universal access,as communications networks
transition from legacy circuit-switched,copper technology to an IP-based packet-switched fiber
and wireless networks.These experiments will include changes to the TRS,which will have a
direct impact on the Idaho relay.Idaho’s traditional TDM relay system and the associated
equipment are not compatible with a IP-based,packet-switched network.Additionally,Idaho
2 Report and Order and Further Notice of Proposed Rulemaking,In the Matter ofMisuse ofInternet Protocol
Captioned Telephone Service and Telecommunications Relay Services and Speech-to-Speech Services for
Individuals with Hearing and Speech Disabilities,28 F.C.C.R.13,420 (August 26,2013).
Id.at ¶J 4.
Time-Division Multiplexing (TDM)is primarily used for digital signals,but can also accommodate analog
multiplexing.This is the technology generally considered when referencing the Public Switched Telephone
Network (PSIN),an aggregate of the world’s circuit-switched telephone networks.
DECISION MEMORANDUM -3 -MARCH 2,2016
has an aging population of TRS users that may not be comfortable or willing to switch to IP
compatible equipment.Thus,it is important for all state jurisdictions to monitor the results of
the experiments and provide performance feedback should the FCC require state TRS networks
to partially or fully transition to the IP TRS model.
STAFF’S RECOMMENDATION
Staff has reviewed the Administrator’s Annual Report and believes the expenses are
reasonable.Staff believes the Idaho citizens continue to be well served by Ehe Administrator and
the relay services provided by Hamilton Telecommunications.Staff also believes that the 2016
budget projection of S97.840 is acceptable based on the anticipated TRS expenses.The
projected revenue together with the current fund balance should be sufficient to meet 2016
expenses,including any unforeseen events.Staff,therefore,agrees with the Administrator’s
recommendation to maintain the IRS contributions at the current funding levels of 50.02 per
access line per month and 50.0002 per intrastate MTS/WATS minute.
COMMISSION DECISION
1.Does the Commission wish to accept the Administrator’s recommendation to
maintain the current TRS assessment rates adopted in Order No.33256?
2.Does the Commission wish to accept the annual report and adopt the Administrator’s
budget for 2016?
GraceS a n
Udmemus/irs reporl for 2015
DECISION MEMORANDUM -4-MARCH 2,2016