20170317Decision Memo.pdf

RE
DECISION MEMORANDT]M
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM: GRACE SEAMAN
DATE: MARCH l6,20n
2016 IDAHO TELECOMMI.'NICATIONS RELAY SERVICE ANNUAL
REPORT; CASE NO. GNR-T-L742
BACKGROUND
Each February the Administrator of the Idaho Telecommunications Relay Service (TRS
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.
ln 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 $ 5l-1301. Under the Idaho TRS Act, all telephone
corporations providing local or longdistance service (not including wireless or VoIP services)
must provide TRS as set forth in the pro$am and pay into the TRS Fund based upon an
allocation methodology adopted by the Commission. Idaho Code $ 6l-1305. Pursuant to TRS
Rule 202, the Commission sets the TRS funding levels each year based upon the Administrator's
Annual Report. IDAPA 31.46.02.202.
The ldaho TRS service provider, Hamilton Telecommunications (Hamilton), operates the
relay center where oral conversations are converted or "relayed" to text-type and vice versa. The
relay center also provides speech-to-speech, Spanish+o-Spanish, video, and Intemet relay
services.
IDECISION MEMORA}.IDUM MARCH 16,2017
THE 2016 ANNUAL REPORT
On February 10,2017, the TRS Administrator, Mr. Dturbar, submitted the 2016 TRS
Annual Report and the 2017 TRS Budget for Commission approval. During 2016, the
Administrator reported that the relay center handled 15,175 minutes of conversation (including
out-of-state long distance minutes) compared to21,397 minutes in 2015. This represents a29Yo
decrease in billable minutes. The number of Captioned Telephone (CapTel)l units increased by
6% while the total CapTel usage decreased by 6% to25,562 minutes.
Disbursements from the TRS fund to Hamilton decreased from $85,5t5 in 2015 to
$77,195 in 2016. In-state traditional relay and CapTel services are reimbursed by ldatro's TRS
fund, while the firm of Rolka Loube Saltzer Associates, LLC reimburses Hamilton for out-of-
state relay calls as well as intrastate Intemet relay and Internet video relay service uiage.
Hamilton's 2015 average answer time was 0.40 seconds; an excellent response time.
l. 2016 Expenses. The TRS expenses for the year totaled $l17,040. Disbusements to
Hamilton were $77,195. The administrative fees and expenses for the reporting year were
539,845, ineluding an expense of $12,675 for the service provider Request for Proposal that was
issued and awarded to Hamilton in 2016. The end-of-year fund balance was $284,569.
2. ?0-1,6 Revenues and Allosations. 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 decreased by 23% from approximately 205,535,000 minutes in 2015 to
approximately 158,535,000 minutes in 2016. The average monthly number of telephone lines
reported increased by 3% from 377,860 in 2015 to 391,132 in20l6. The 2015 annual
contribution to the TRS fund was $109,971, a decrease of $6,685 (6%) from 2015. Local
exchange services contributed 878,264 (71%) and MTSAMATS contributed $31,707 (29%). ln
Commission Order No. 3348 I , the per-line and per-minute assessments for 201 6 were
maintained at $0.02 and $0.0002, respectively.
3. Prooosed 2017 Budget. The Administrator projects an annual operating budget of
S101,840. This budget reflects a continued decline in traditional relay usage as well as a tri-
I CapTcl allows hard-of-hcaring users to hcar the conversation as well as read the words on the phone's built-in
screen. A traincd operator 'tre-voices" the conversation from a callcr into the voiee recognition technology that
converts the words into I text message and provides thc CapTe! user with a more natural conversation.
DECISION MEMORANDUM -2-MARCH t6,20t7
annual audit expense of approximately $7,000. If assessment rates remain unchanged, the
Administrator calculates the 2017 end-of-year fund balance will remain near its current level.
4, Proposed 2017 TRS Funding Levels. Based on the proposed budget for20l7 and the
2016 end-of-year reserues, the Administrator recommends that the Commission maintain the
assessment rates at the current level for local exchange lines at $.02 per month and $.0002 per
intrastate MTS/WATS billed minute. This will provide a cushion should unexpected expenses or
program changes occur at the Federal Communications Commission (FCC).
TRS-Rclated FCC Updates
In recent years, the FCC has issued Orders that directly impact the ldaho TRS programs.
In addition, FCC representatives have communicated that program funding changes are
periodically reviewed for altemative cost management options. Any changes to the program can
have a significant impact on service and funding, and therefore merit careful monitoring by the
states. Recent FCC actions are discussed below.
l. Ifrternet Protocol Captioned Telephone Service (lP-CT$J.Fund. The FCC oversees
and funds a nationwide TRS program, which compensates carriers that provide out-of-state TRS
calls over traditional wireline facitities, as well as Voice over lnternet Protocot (VoIP) services.2
One form of relay service that uses VolP is the IP-CTS. At the 2015 National Association of
Relay Administrators (NASRA) conference, 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 ldaho does not administer IP-CTS and does not have funding nor processes
in place to assume this responsibility if the FCC transfened this program to state jurisdictions.
2, TDMa+o-IP Transition Exoeriments. The FCC adopted a framework forapproving
trials, or experiments for preserving haditionalcommunications-related values, such as public
safety, consumer protection, competition and universal access, as comrnunications networks
transition from legacy circuit-switched, copper technology to an lP-based packet-switched fiber
and wireless networks. Idaho's traditional TDM relay system and the associated equipment are
2 Report and Order and Further Ndicc of Proposed Rulemaking, In the Matler of Misuse of lnternel Protocal
Coptioned Telephone Sen lce and Telecomnwnications Relty Services ond Speech-to-Speech Senices for
lndivlduals vith Hearlng and Speech Dkabilities, 28 F.C.C.R. I 3,420 (August 26, 20 l3).
' ld. atl4.
a Time-Division Multiplexing (TDM) is primarily used for digital signals, bul can also accommodate analog
multiplexing. This is the tcchnology generally considered when rcferencing thc Public Switchcd Tclephone
Network (PSTN), an aggregate ofthe world's circuit-swilched telephone networks.
DECISION MEMORANDUM -3-MARCH 16,2017
not compatiblc with a IP-based, packet-switched network. Additionally, Idaho has an aging
population of TRS users that may not be willing to switch to IP-compatible equipment, Thus, it
is important for all Sffi stakeholders 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 rnodcl.
3. Adootion of Real-Time Text Rules. In June 20I5,AT&T petitioned the FCC to
update its accessibility rules to allow Real-Time Text (RTT) to replace text telephone (TTY)5
technology over lP-based networks. In response, the FCC released the Report and Order and
Further Notice of Proposed Rulemaking (NPRM) on December 16, 2016. In the NPRM, the
FCC amends its rules to facilitate a transition from TTY to RTT technology and seeks comments
on a sunsct date for TTY support. RTT allows text characters to be sent as they are being
crealed, can be sent simultaneously with voice, and allows the use of off-the-shelf end user
devices to make text telephone calls, TTY is a traditional rclay scrvice that Hamilton continues
to provide to ldaho users. In 2016, Hamilton was reimbursed approximately $22,000 to facilitate
TTY communications in Idaho.
STAFF'S RECOMMENDATION
Staffhas reviewed the Administrator's AnnualReport and believes the expenses are
reasonable. Staffbelieves the Idaho citizens continue to be well served by the Administrator and
the relay scrvices provided by Hamilton Tclecommunications. Staffalso believes that the 2017
budget projection of $101,840 is acceptable based on the anticipated TRS expenses. The
projected revenue together with the curent fund balance should be sufficient to meet 2017
expenses, including any unforeseen events. Staff, therefore, agrecs with the Administrator's
recommendation to maintain the TRS contributions at the current funding levels of $0.02 per
access line per month and $0.0002 per intrastate MTSAIVATS minute.
t Since the 70s, TTY technologt has provided the only means for people with disabilities to send and receive lcxl
communications over the public switched telephone network esn$. To cnsurc that TTY users have comparablc
telephone network access as voice users, $e FCC rules have reguired providers and device manufacturers of
telecom services and advanced communications services (ACS) to support TTY technology. Changes to the
network{ngoing technology transitions from circuit switched to lP-based networks and from copper to wireless
and fiber infrastructure, have affected the qualiry and utility of TTY technology. .See Notice Proposed Rulemaking
para.2-3, FCC 16-169,
DECISION MEMORANDUM 4 MARCH 16,2017
COMMISSION DECISION
l. Does the Commission wish to accept the Administrator's recommendation to
maintain the cunent TRS assessment rates adopted in Order No. 33481?
2. Does the Commission wish to accept the annual report and adopt the Administmtor's
budget for2017?
, i, ,, , ,i, (c.ii t {r-rr*
Grace Seaman
Udmcmoc/tr rqrut for 2016 dcc mcmo
DECISTON MEMORANDUM -5-MARCH 16,2A17