20210407Final_Order_No_34988.pdf

ORDER NO. 34988 1
Office of the Secretary
Service Date
April 7, 2021
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF REVIEWING THE
ADMINISTRATOR’S 2020 ANNUAL REPORT
AND ESTABLISHING THE FUNDING
LEVELS TO SUPPORT THE
TELECOMMUNICATIONS RELAY SERVICE
(TRS) PROGRAM
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CASE NO. GNR-T-21-02

ORDER NO. 34988

On February 16, 2021, the Idaho Telecommunications Relay Service (TRS)
Administrator submitted the calendar year 2020 Annual Report and 2021 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 2020 Report and 2021 Budget.
To ensure the longevity of the TRS fund, we increase the per-line assessment from $0.03 to $0.05,
and the per-minute assessment from $0.0008 to $0.001—effective May 1, 2021.
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 hearing- or speech-impaired
citizens 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. 34988 2
THE 2020 ANNUAL REPORT
The Administrator reported that the relay center handled 2,106 calls in calendar year
2020. This represents a 26% increase from calendar year 2019. The number of CapTel units held
steady. The 2020 average answer time by Hamilton was 0.85 seconds (compared to 0.41 seconds
in 2019). The increased average answer time was due to greater usage during the global pandemic.2
1. 2020 Expenses. The TRS expenses for the year totaled $163,040. Disbursements
to Hamilton were $123,082. The administrative fees and expenses for the reporting year were
$39,958. The end-of-year fund balance was $180,934.
2. 2020 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 18% decrease in total intrastate long-
distance minutes, from about 100,128,800 minutes in 2019 to about 82,015,033 minutes in 2020.
Average monthly telephone lines decreased by 41%, from 215,423 in 2019 to 126,760 in 2020.
The 2020 annual total contribution to the TRS fund was $66,838, a decrease of
$4,889.39 (7%) from 2019. Local exchange services contributed $32,751 (49%) and MTS/WATS
contributed $34,088 (51%). In Commission Order No. 34615, the per-line and per-minute
assessments for 2020 were increased to $0.03 and $0.0008, respectively. The table below shows
2020 TRS contribution sources and amounts.

2020 Revenue Sources Amount Percentage of Total
Local Service Providers
($.03/month/line)

$32,751

49%
MTS/WATS Providers
($.0008/min)

$34,088

51%
TOTAL $66,838 100%

3. Proposed 2021 Budget. The Administrator projects an annual operating budget of
$173,760. The budget includes $8,350 for a contractually required audit of the TRS fund. If
assessment rates remain unchanged, the Administrator calculates the 2021 end-of-year fund
balance will continue to have a reasonable reserve (2021 year-end balance is projected to be about
$95,529.83).

2 Hamilton was granted an FCC waiver for call answer times beginning March 16, 2020.
ORDER NO. 34988 3
4. Proposed 2021 TRS Funding Levels. Based on the proposed budget for 2021 and
the 2020 end-of-year reserves, the Administrator provided these options:
Option 1: Continue the present compensation rates to the TRS fund at $0.03 per
line and $0.0008 per minute. Based on recent trends, there will be about 101,408 lines3 and
64,811,226 MTS/WATS minutes4 in 2020. Based on this estimation, revenue to the TRS fund will
be $88,356. With a 2021 budget of $173,760, the TRS fund’s balance will likely decrease to
$95,529.
Option 2: raise the per-line rate from $0.03 to $0.05 but continue the per-minute
rate at $0.0008. This option would make the ratio of the revenue coming from lines and minutes
about 52/48; the ratio in 2020 was about 49/51. See IDAPA 31.46.02.202.02. Assuming there are
about 101,408 lines and 64,811,226 MTS/WATS minutes in 2021 (see the calculations in Option
1), Option 2 would result in a 2021 year-end balance of $119,867—a decrease from 2020’s
$180,934 year-end balance.
Option 3: Raise the line charge from $0.03 per line to $0.05 per line, and the
MTS/WATS minute rate from $0.0008 per minute to $0.001 per minute. This option would make
the revenue ratio between lines and minutes about 48/52. The 2021 year-end balance would be
$132,829. Option 3 would ensure the longevity of the TRS fund balance.
STAFF RECOMMENDATION
Staff reviewed the Administrator’s Report and recommended that the Commission
adopt the Administrator’s Report and projected budget for 2021. Staff noted the Idaho citizens
continue to be well served by the Administrator and the relay services provided by Hamilton. Staff
also noted that the 2021 budget projection of $173,760 is acceptable based on the anticipated TRS
expenses. The projected revenue, together with the current fund balance, should be enough to
meet 2021 expenses and any unforeseen events. However, Staff recommended the Commission
adopt Option 3, raising TRS contributions to $0.05 per access line and $0.001 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 2020 Annual
Report. We find the reported expenses for 2020 are reasonable. Idaho citizens continue to be well

3 2020’s line count of 126,760 x 80% = 101,408 due to 20% decrease.
4 2020’s MTS/WATS minutes of 80,811,226 x 80% = 64,811,226 due to 20% decrease.
ORDER NO. 34988 4
served by the Administrator and the relay services provided by Hamilton Telecommunications.
The Commission also finds that the 2021 budget projection of $173,760 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 $88,356 of revenue, but the 2021 budget we approve today is $173,760.
While the TRS fund’s balance should cover the difference, this is not a long-term solution.
The TRS contributions shall be set at $0.05 per access line per month and $0.001 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 2021 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 2020
Annual Report and 2021 budget.
IT IS FURTHER ORDERED that the 2021 TRS funding obligation of telephone
corporations providing local service in Idaho be raised from $0.03 per month per access line, to
$0.05 per month per access line—effective May 1, 2021.
IT IS FURTHER ORDERED that the 2021 TRS funding obligation for telephone
corporations providing intrastate MTS/WATS service be raised from its existing level of $0.0008
per intrastate billed minute, to $0.001 per intrastate billed minute—effective May 1, 2021.
IT IS FURTHER ORDERED that the TRS Administrator continue to monitor
expenditures, revenues, and Federal Communications Commission actions. Any time it appears
ORDER NO. 34988 5
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.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 7th day
of April 2021.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

I:\Legal\TELEPHONE\GNR-T-21-02\Orders\GNRT2102_mh_final.docx