20220422Final_Order_No_35378.pdf

ORDER NO. 35378 1
Office of the Secretary
Service Date
April 22, 2022
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF REVIEWING THE
ADMINISTRATOR’S 2021 ANNUAL REPORT
AND ESTABLISHING THE FUNDING
LEVELS TO SUPPORT THE
TELECOMMUNICATIONS RELAY SERVICE
(TRS) PROGRAM
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CASE NO. GNR-T-22-03

ORDER NO. 35378

On February 15, 2022, the Idaho Telecommunications Relay Service (“TRS”)
Administrator, Kathleen Toohill (“Administrator”), submitted the calendar year 2021 Annual
Report and 2022 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 2021 Report and 2022 Budget.
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.
The Idaho TRS fund is supported by assessments on local telephone service (residential
and business) access lines and on billed intrastate long-distance minutes. Idaho’s TRS fund
reimburses Hamilton for in-state relay traffic and captioned telephone (“CapTel”)1 services and
Rolka Loube Saltzer Associates, LLC reimburses Hamilton for interstate calls, including intrastate
Internet relays and Internet video relay service.
THE 2021 ANNUAL REPORT
The Administrator reported that the relay center handled 1,853 calls in calendar year
2021— a 12% decrease from calendar year 2020. The number of CapTel units held steady. The

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. 35378 2
average time it took Hamilton for a call to reach the relay switchboard and be answered by a
communication assistant in 2021 was 0.85 seconds. While this response time remained unchanged
from 2020, it continued to be 0.44 seconds slower than the average response time in 2019 due to
increased usage during the Covid-19 pandemic.
1. 2021 Expenses. The TRS expenses for the year totaled $145,780. Disbursements to
Hamilton were $97,052. The administrative fees and expenses for the reporting year were $40,068.
The end-of-year fund balance was $121,353.
2. 2021 Revenues and Allocations. Telephone companies reported a 21% decrease in
total intrastate long-distance minutes, from about 82,015,033 minutes in 2020 to about 65,058,266
minutes in 2021. Average monthly telephone lines decreased by 30%, from 126,760 in 2020 to
89,110 in 2021.
The 2021 annual total contribution to the TRS fund was $105,245 an increase of
$38,408 (57%) from 2020. Local exchange services contributed $41,687 (39%) and Message
Telecommunication Services (“MTS”) and Wide Area Telephone Service (“WATS”) collectively
contributed $64,418 (61%). In Commission Order No. 34988, the per-line and per long distance
minute assessments for 2021 were increased to $0.05 and $0.001, respectively, and went into effect
on May 1, 2021. The table below shows 2021 TRS contribution sources and amounts.

2021 Revenue Sources Amount Percentage of Total
Local Service Providers
($.05/month/line)

$41,687

39%
MTS/WATS Providers
($.001/min)

$64,418

61%
TOTAL $105,245 100%

3. Proposed 2022 Budget. The Administrator projects an annual operating budget of
$142,350. The budget includes administrative fees and expenses, travel and conference costs, the
Hamilton TRS payments, and NASRA annual membership dues.
4. Proposed 2022 TRS Funding Levels. Based on the proposed budget for 2022 and the
2021 end-of-year reserves, the Administrator provided these options:
Option 1: Continue the present compensation rates to the TRS fund that were
determined in Order No. 34988, at $0.05 per line and $0.001 per long distance minute.
ORDER NO. 35378 3
Option 2: Continue with the current long distance per minute rate of $0.001 while
raising the per line rate to a range somewhere between $0.06 or $0.10 per line to try and level out
the contributions to closer to 50% of LEC lines and MTS/WATS.
Option 3: Raise both rates.
STAFF RECOMMENDATION
After reviewing the information filed by the Administrator, Staff recommended the
Commission adopt the Administrator’s Report and projected 2022 budget. Staff noted that Idaho
citizens continue to be well served by the Administrator and the relay services provided by
Hamilton. Staff also noted that the 2022 budget projection of $142,350 is reasonable based on the
anticipated TRS expenses. Staff explained that the projected revenue—together with the current
fund balance—should be enough to meet 2022 expenses and any unforeseen events. Staff noted
the current rates approved in Order No. 34988 continued to be reasonable.
DISCUSSION AND FINDINGS
In this Order, the Commission formally adopts the Administrator’s 2021 Annual
Report. We find the reported expenses for 2021 reasonable. Idaho citizens continue to be well
served by the Administrator and the relay services provided by Hamilton. The Commission also
finds that the 2022 budget projection of $142,350 is reasonable based upon the anticipated TRS
expenses this year.
Based upon our review of the Annual Report and Staff’s recommendations, we find it
is just and reasonable to maintain the current rates approved in Order No. 34988.
O R D E R
IT IS HEREBY ORDERED that the Commission accepts the Administrator’s 2021
Annual Report and 2022 budget.
IT IS FURTHER ORDERED that the 2022 TRS funding level of telephone
corporations providing local service in Idaho remain unchanged at a rate of $0.05 per line.
IT IS FURTHER ORDERED that the 2022 TRS funding level for telephone
corporations providing intrastate MTS/WATS service remain unchanged at a rate of $0.001 per
long distance minute.
IT IS FURTHER ORDERED that the TRS Administrator continue to monitor
expenditures, revenues, and Federal Communications Commission actions. Any time it appears
ORDER NO. 35378 4
that revenues will not cover expenditures, the TRS Administrator is to immediately notify the
Commission so it may evaluate whether TRS funding levels 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 regarding any matter
decided in 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 22nd day
of April 2022.

ERIC ANDERSON, PRESIDENT

JOHN CHATBURN, COMMISSIONER

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JOHN R. HAMMOND JR., COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

I:\Legal\TELECOM\GNR-T-22-03\GNRT2203_rn_final.docx