20200403Final_Order_No_34615.pdf

ORDER NO. 34615 1
Office of the Secretary
Service Date
April 3, 2020
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF REVIEWING THE
ADMINISTRATOR’S 2019 ANNUAL REPORT
AND ESTABLISHING THE FUNDING
LEVELS TO SUPPORT THE
TELECOMMUNICATIONS RELAY SERVICE
(TRS) PROGRAM
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CASE NO. GNR-T-20-09

ORDER NO. 34615

On February 13, 2020, the Idaho Telecommunications Relay Service (TRS)
Administrator submitted the calendar year 2019 Annual Report and 2020 TRS Budget to the
Commission. Each year, the Commission reviews the Administrator’s Annual Report and
determines the funding levels needed to meet the TRS program’s future expenses. IDAPA
31.46.02.202 and .205. In this Order we accept the Administrator’s 2019 Report and 2020 Budget.
To ensure the longevity of the TRS fund, we increase the per-line assessment from $0.02 to $0.03,
and the per-minute assessment from $0.0002 to $0.0008—effective May 1, 2020.
BACKGROUND
The Idaho Legislature established the TRS Act in 1992 in accordance with Title IV of
the federal Americans with Disabilities Act. The TRS program allows 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. The Idaho
TRS service provider is Hamilton Telecommunications (Hamilton). 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-to-Spanish, video, and Internet relay services. On
October 15, 2019, the Commission authorized the Administrator to renew the relay contract with
Hamilton, and the contract now runs through November 30, 2022.
The Idaho TRS fund is supported by assessments on local telephone service (residential
and business) access lines and on billed intrastate long-distance minutes. In-state relay traffic and
captioned telephone (CapTel)1 services are reimbursed by Idaho’s TRS fund, while the firm of
Rolka Loube Saltzer Associates, LLC reimburses Hamilton for interstate calls (including intrastate
Internet relays and Internet video relay service).

1 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.
ORDER NO. 34615 2
THE 2019 ANNUAL REPORT
The Administrator reported that the relay center handled 7,125 minutes of traffic in
calendar year 2019. This represents a 34% decrease from calendar year 2018.2 The number of
CapTel units held steady, while usage decreased by 15% to 13,627 minutes from the previous year.
The renewal of Hamilton’s contract with the Administrator included an amendment which changed
the price per minute and compensation from conversation minutes3 to session minutes.4 The 2019
average answer time by Hamilton was 0.41 seconds.
1. 2019 Expenses. The TRS expenses for the year totaled $90,670. Disbursements to
Hamilton were $60,559. The administrative fees and expenses for the reporting year were
$30,111. The end-of-year fund balance was $263,731.
2. 2019 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. Telephone companies reported a 20% decrease in total intrastate long-
distance minutes, from about 125,050,000 minutes in 2018 to about 100,128,800 minutes in 2019.
Average monthly telephone lines decreased by 15%, from 253,004 in 2018 to 215,423 in 2019.
The 2019 annual total contribution to the TRS fund was $71,727, a decrease of $14,005
(16%) from 2018. Local exchange services contributed $51,701 (72%) and MTS/WATS
contributed $20,026 (28%). In Commission Order No. 34285, the per-line and per-minute
assessments for 2019 were maintained at $0.02 and $0.0002, respectively. The table below shows
2019 TRS contribution sources and amounts.

2019 Revenue Sources Amount Percentage of Total
Local Service Providers
($.02/month/line)

$51,701

72%
MTS/WATS Providers
($.0002/min)

20,026

28%
TOTAL $71,727 100%

2 By way of comparison, there were 12,135 minutes in 2017, and 10,698 minutes in 2018.
3 A conversation minute includes the time the calling party is connected to the called party or to an answering machine
at the called party’s number or to a recorded message or intercept for the called number. A conversation minute does
not include time in queue (i.e., call is ringing, waiting for a live answer), call set-up, or calls that have reached numbers
that are busy or received no answer.
4 A session minute is the time from the moment a Communications Assistant (CA) connects to an incoming relay call
until the moment the CA disconnects the last party. This includes incoming calls that do not reach the intended called
party ((busy, no answer, or wrong number) and includes call set-up and wrap-up.
ORDER NO. 34615 3

3. Proposed 2020 Budget. The Administrator projects an annual operating budget of
$158,500. This budget reflects increased administrative costs arising from changes to the contracts
for the Administrator and Hamilton. The budget also includes $8,000 for an audit of the TRS fund,
which is contractually required when a new person becomes the Administrator If assessment rates
remain unchanged, the Administrator calculates the 2020 end-of-year fund balance will continue
to have a reasonable reserve (2020 year-end balance is projected to be approximately $165,198).
4. Proposed 2019 TRS Funding Levels. Based on the proposed budget for 2020 and
the 2019 end-of-year reserves, the Administrator provided the following options:
Option 1: Continue the present compensation rates to the TRS fund at $0.02 per
line and $0.0002 per minute. Based on recent trends, there will be about 183,110 lines5 and
80,103,040 MTS/WATS minutes6 in 2020. Based on this estimation, revenue to the TRS fund will
be $59,967. With a 2020 budget of $158,500, the TRS fund’s balance will likely decrease. But the
2019 year-end balance is $263,731; so the TRS fund will remain viable in the short term if Option
1 is followed.
Option 2: Continue the $0.02 per-line rate but raise the per-minute rate from
$0.0002 to $0.0005. This option would make the ratio of the revenue coming from lines and
minutes closer to 50/50; the ratio in 2019 was about 72/28. See IDAPA 31.46.02.202.02. Assuming
there are about 183,110 lines and 80,103,040 MTS/WATS minutes in 2020 (see the calculations
in Option 1), Option 2 would result in a 2020 year-end balance of $189,229—a decrease from
2019’s $263,731 year-end balance.
Option 3: Raise the line charge from $0.02 per line to $0.03 per line, and the
MTS/WATS minute rate from $0.0002 per minute to $0.0008 per minute. This option would make
the revenue ratio between lines and minutes closer—approximately 51/49. The 2020 year-end
balance would be $235,234. Option 3 would ensure the longevity of the TRS fund balance, and
rates would not need to be raised as quickly as they would with other options.
STAFF RECOMMENDATION
Staff reviewed the Administrator’s Report and recommended that the Commission
adopt the Administrator’s Report and projected budget for 2020. Staff noted the Idaho citizens

5 2019’s line count of 215,423 x 85% = 183,110 due to 15% decrease.
6 2019’s MTS/WATS minutes of 100,128,800 x 80% = 80,103,040 due to 20% decrease.
ORDER NO. 34615 4
continue to be well served by the Administrator and the relay services provided by Hamilton. Staff
also noted that the 2020 budget projection of $158,500 is acceptable based on the anticipated TRS
expenses. The projected revenue, together with the current fund balance, should be enough to
meet 2020 expenses and any unforeseen events. However, Staff recommended the Commission
adopt Option 3, raising TRS contributions to $0.03 per access line and $0.0008 per MTS/WATS
minute. Staff believes this option will help ensure the TRS fund’s long-term viability.
DISCUSSION AND FINDINGS
In this Order, the Commission formally adopts the Administrator’s 2019 Annual
Report. We find the reported expenses for 2019 are reasonable. Idaho citizens continue to be well
served by the Administrator and the relay services provided by Hamilton Telecommunications.
The Commission also finds that the 2020 budget projection of $158,500 is reasonable based upon
the anticipated TRS expenses this year.
Based upon our review of the Annual Report and the Staff’s recommendations, we find
it is just and reasonable to raise the TRS contributions. Left unchanged, TRS contributions are
projected to generate $59,967 of revenue, but the 2020 budget we approve today is $158,500.
While the TRS fund’s balance should cover the difference, this is not a long-term solution.
The TRS contributions shall be set at $0.03 per access line per month and $0.0008 per
intrastate MTS/WATS minute. The costs of the TRS program have increased while revenue has
continued to decline—due largely to fewer Idahoans having local telephone service access lines.
Under Idaho Code § 61-1306(5) and IDAPA 31.46.02.000 et seq, the Commission must set the
formulas apportioning the costs of the TRS program among the telephone corporations that will
share the cost of the program. These formulas must provide the TRS fund with adequate revenue
for the Administrator and the Commission to fulfill their statutory duties. For the TRS fund to
remain viable, the access line and MTS/WATS minute rates must be increased. We remind those
telephone corporations required to make these remittances that they may not pass these remittances
to customers as a separate line item surcharge. See Order Nos. 24686 and 26541.
The Commission further finds that the projected 2020 allocation between local service
and toll service is just and reasonable given the estimated number of access lines and toll minutes.
O R D E R
IT IS HEREBY ORDERED that the Commission accepts the Administrator’s 2019
Annual Report and 2020 budget.
ORDER NO. 34615 5
IT IS FURTHER ORDERED that the 2020 TRS funding obligation of telephone
corporations providing local service in Idaho be raised from $0.02 per month per access line, to
$0.03 per month per access line—effective May 1, 2020.
IT IS FURTHER ORDERED that the 2020 TRS funding obligation for telephone
corporations providing intrastate MTS/WATS service be raised from its existing level of $0.0002
per intrastate billed minute, to $0.0008 per intrastate billed minute—effective May 1, 2020.
IT IS FURTHER ORDERED that the TRS Administrator continue to monitor
expenditures, revenues, and Federal Communications Commission actions. Any time it appears
that revenues will not cover expenditures, the TRS Administrator is to immediately notify the
Commission so it may evaluate whether TRS funding obligations should change.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order. Within seven (7)
days after any person has petitioned for reconsideration, any other person may cross-petition for
reconsideration. See Idaho Code § 61-626.
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ORDER NO. 34615 6
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 3rd
day of April 2020

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Diane M. Hanian
Commission Secretary

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