20230425Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
LEGAL
FROM:JOHAN E.KALALA-KASANDA
DAYNE HARDIE
DATE:APRIL 25,2023
RE:2022 IDAHO TELECOMMUNICATIONS RELAY SERVICE ("TRS")
ANNUAL REPORT;CASE NO.GNR-T-23-02
BACKGROUND
Every year,in 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.
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 functionallyequivalent 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 includingwireless or VolP 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 §61-1305.Pursuant to TRS
Rule 204,the Commission sets the TRS funding levels each year based upon the Administrator's
Annual Report.IDAPA 31.46.02.204.
The Idaho 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-to-Spanish,video,and Internet relay
services.
DECISION MEMORANDUM -1 -APRIL 25,2023
The 2022 Annual Report
On February 15,2023,the TRS fund Administrator,Ms.Kathleen Toohill,submitted the
2022 Annual Report of the Idaho TRS Fund and the 2023 Idaho TRS Fund Budget for
Commission approval.The Administrator reported that the relay center handled 1102 completed
calls in 2022 compared to 1,853 calls in 2021,a decrease of 751 completed calls or 41%.
In 2022,there were 13,624.04 session minutes for TRS;3,154.71 session minutes
reported for Caption Telephone Service ("CTRS");and 176.44 session minutes for Advanced
Speech to Speech ("STS").The number of Captioned Telephone("CapTel")!units held steady.
The new contract with Hamilton Relay included a change in the price per minute and
compensation from conversation2 to session minutes.3
For the year 2022,as shown in Table No.1 herein below,total disbursements from the
TRS fund to Hamilton Relay amounted to $93,973.Including$60,000 for Outreach,$26,983 for
TRS,$6,309 for CTRS,and $681 for STS Relay Service.Compared to the $97,052
disbursement made in 2021,this represents a decrease of 3,079 or 3%.In-state traditional relay
and CapTel services are reimbursed by Idaho's TRS fund,while the firm of Rolka Loube Saltzer
Associates,LLC reimburses Hamilton for out-of-state relay calls as well as intrastate Internet
relay and Internet video relay service usage.
Table No.1:2022 DISBURSEMENTS TO HAMILTON
Outreach $60,000
Telecommunication Relay Service (TRS)$26,983
CapTel Relay Service (CTRS)$6,309
Speech to Speech (STS)$681
TOTAL $93,973
I 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.
2 A COOVCTSHIÍOR mÍnüÍC Shall include 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 call minute
does not include time in queue (call is ringing,waiting for a liveanswer),call set-up,call wrap-up,or calls that have
reached numbers that are busy or received no answer.
3 A session minute is defined as 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 (busy,no
answer,or wrong number)that do not reach the intended called party and includes call set-up and wrap-up.
DECISION MEMORANDUM -2 -APRIL 25,2023
A key performance indicator for TRS and CapTel is the average speed of answer
("ASA")for a call to reach the relay switchboard and to be answered by a communication
assistant.In 2022,Hamilton's average answer time was 0.39 seconds,which is closer to the 0.41
seconds recorded in previous years.At the height of the of the COVID-19 pandemic,the ASA
was reported closer to 0.85 seconds.This is a return to the normal ASA.
2022 Revenues and Allocations
The TRS fund is supported by assessments on local exchange telephoneservice
(residential and business)access lines and on billed intrastate long-distance minutes.The total
number of intrastate long-distance minutes reported by telephone companies in 2022 was
approximately 60,936,000 compared to 65,058,266.417in 2021,a 6.4%decrease.The average
monthlynumber of telephone lines reported decreased by 1.6%,from 89,110 in 2021 to 87,700
in 2022.
As illustrated in Table No.2 herein below,the 2022 total annual contributionto the TRS
fund was $112,741 compared to $105,245 in 2021,an increase of $7,496 or 6.6%.Local
exchange services contributed $51,805 (46%)and MTS/WATS contributed $60,936 (54%).In
Commission Order No.34988,the per-line and per-long-distanceminute assessments for 2022
were set to $0.05 and $0.001,respectively4
Table No.2:2022 Idaho TRS Revenue
Percentage of
2022 Revenue sources Amount Total
Local Service Providers
($0.05/month/line)$51,805 46%
MTS/WATSProviders
($0.001/min)$60,936 54%
TOTAL $112,741 100%
*The rates did not go into effect until May I,2022.
DECISION MEMORANDUM -3 -APRIL 25,2023
2022 Expenses
For 2022,TRS expenses amounted to $136,097,including $93,973 to Hamiltonand
$42,124 in administrative fees and expenses for the reporting year.The end-of-year TRS fund
balance was reported to be approximately $97,998.
Proposed 2023 Budget
As illustrated in Attachment D of the annual report,the Administrator projects an annual
operating budget of $141,550.This budget includes the anticipated administrative costs as
contracted,the travel/conference costs,the Hamilton TRS payments,NASRA membership dues,
and the bank charges.
2023 TRS Funding Levels
From Order No.34988,the rates of contributionfor ITRS were raised to $0.05 per line
and $0.001 per long-distanceminute and went into effect on May 1,2021.As illustrated in
Table No.3 herein below,for 2023 revenue for the fund can be estimated with the current
contributions and current rates to be approximately $90,194.The 2023 budget is estimated to be
$141,550.The 2022 year-end balance of approximately $97,998,is also the beginning balance
of 2023.Thus,the projection is that the fund will end the year 2023 with a positive balance of
$46,642.Therefore,for at least this year 2023,the current rates of contribution can sustain the
fund.However,a comprehensive review will need to be made next year.
Table No.3:2023 Fund Level Analysis
2023 Revenue Projection Amount
1/1/2023 Beginning Balance $97,998
Plus Estimated 2023 Revenue $90,194
Sub-Total $188,192
Minus Estimated 2023 Expenses $141,550
31/12/2023 Ending Balance $46,642
DECISION MEMORANDUM -4 -APRIL 25,2023
Idaho TRS went through a request for proposal process during 2022 and has entered year
1 of a 3-year contract which was mutuallyagreed upon with Hamilton Relay and the Advisory
Committee of the Telephone Industryas the statute requires.Idaho Relay will provide TRS,
CapTel,and Speech to Speech Services as in the past.Nationally,all states are experiencing a
drop-in traditional relay service and captioned telephonerelay service because of migration to
Internet Protocol ("IP")Relay and Video Relay Services.The focus of the Advisory Committee
of the Telephone Industryfor this next time period is to focus on the digital transition in
coordination with Hamilton Relay.
STAFF'S RECOMMENDATION
Staff has reviewed the Administrator's Annual Report.Staffbelieves the Idaho citizens
continue to be well served by the Administrator and the relay services provided by Hamilton
Telecommunications.Staffalso believes that the 2023 budget projection of $141,550 is
reasonable,based on the anticipated TRS expenses.The projected revenue,based on the current
rates,together with the current fund balance should be sufficientto meet 2023 expenses,
includingany unforeseen events.
COMMISSION DECISION
Does the Commission wish to accept the annual report and adopt the Administrator's
budget for 2023,and maintain the current rates?
ohan E.Kalala-Kasan
Udmemos/GNR-T-23-02 1daho TRS Fund 2022 Repon Decision Memo
DECISIONMEMORANDUM -5 -APRIL 25,2023