20240410TRS Administrators Annual Report 2023 (AMENDED).pdf

GNR-T-24-02
RECEIVED
2024 April 10,6:23PM
O IDAHO PUBLIC
UTILITIES COMMISSION
ReLay-
Telecommunications Relay Service (TRS) Administrator's Annual Report
Idaho TRS Fund
January 1 — December 31, 2023
Revenues
Revenues collected in all of 2023 totaled $112,149 with $53,006.45 being received from local
exchange services and $59,148.70 was received from MTS/WATS services. The starting
balance was $97,999.23 as of 1/1/2023, and the final balance was $68,872.15 as of
12/31/2023. The current rate is $.05 per local exchange line service and $0.001 for Message
Telecommunication Services (MTS) /Wide Area Telephone Service (WATS) services as of May
1, 2021.
2023 ITRS Revenue
Local Exchange
Quarter Services % MTS/WATS % Total
1 $13,991.80 48 15,157.84 52 $29,149.64
2 $13,070.25 45.3 15,782.36 54.7 $28,852.61
3 $12,924.95 47.3 14,418.18 52.7 $27,337.13
4 $13,019.45 48.6 13,790.32 51.4 $26,809.77
Total 53,006.45 47.3 59,148.70 52.7 $112,149.15
Call and Line Count
In 2023, providers and carriers reported the following to Idaho TRS:
Q1 - 279,836 lines 15,157,841 MTS/WATS
Q2 - 261,405 lines 15,782,360 MTS/WATS
Q3 - 258,499 lines 14,412,080 MTS/WATS
Q4 - 260,389 lines 13,790,320 MTS/WATS
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88,344 monthly average local exchange lines or 1,053,324 approximate total reported across
the entire year.
59,148,700 approximate long distance minutes (3.0 % decrease) reported throughout 2023.
Lines and Minutes Chart
Year Lines Reported Change from Minutes Change from
previous year previous year
2023 88,344 1.0 % increase 59,148,700 3.0 % decrease
2022 87,700 1.6 % decrease 60,936,000 6.4 % decrease
2021 89,110 30% decrease 65,058,266 21% decrease
2020 126,760 41% decrease 82,015,033 18% decrease
2019 215,423 15% decrease 100,128,800 20% decrease
2018 253,004 15% decrease 125,050,000 less than 1%
increase
2017 297,462 24% decrease 124,961,000 21% decrease
2016 391,132 3% increase 158,535,000 23% decrease
2015 377,860 1% decrease 205,405,200 17% increase
Attachment A—Zero Reporting
97 telecommunications companies filed $0/0 line reports in 2023 on a monthly, quarterly, or
annual basis.
Disbursements - Hamilton Relay
Total disbursements to Hamilton Relay for the provision of all services for 2023 were
$101,065.13. Expenses for TRS, CTS, and Speech to Speech were $36,065.09 and Digital
Transition Outreach was $65,000.04.
Attachment B — Hamilton Relay Disbursements by month, type and TRS/CTS minutes.
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Call Volume
Idaho Relay realized 1221 completed calls throughout 2023 which is an increase in the number
of calls from 1102 completed calls placed in 2022. TRS minutes usage decreased 17.6 percent
to 11,227.3 minutes. CTRS call volume decreased approximately 66% in 2023 from 2022.
Advanced Speech to Speech was discontinued, however standard Speech to Speech Services
generated 553 calls which was a decrease from 652 calls in 2022. There were also 533
Spanish calls through Idaho Relay for 2023 as opposed to 652 calls as well in 2022.
Average Speed of Answer
Average Speed of Answer (ASA) is a key performance indicator for TRS and CapTel which is
when a call reaches the relay switchboard and how long it takes to be answered by a
Communication Assistant. The ASA for 2023 was calculated as an average of 0.225 for TRS
and .475 for CTRS. 99.75% of CTRS calls were answered in 10 seconds or less while 99% of
TRS calls were answered in 10 seconds or less.
Administrative Fees and Expenses
Administrative Fees and Expenses totaled $39,880 for 2023 for consulting by TRS Administrator
Kathleen Toohil in addition to a $200 reimbursement for payment of NASRA annual
membership dues for 2023-2024 - resulting in $40,080 for the overall total.
Attachment C—Administrator Billing
Fund Balance
Starting Balance January 1, 2023 - $97,999.23
Q1 Balance (3/31) Q2 Balance (6/30) Q3 Balance (9/30) Q4 Balance (12/31)
$92,142.76 $84,949.91 $80,403.03 $68,872.15
Recommendations and Overview
Idaho TRS went through the Request for Proposal (RFP) process during 2022, and the agreed
upon service is in year 2 of the 3 year contract that is mutually agreed upon between Hamilton
Relay and the Advisory Committee of the Telephone Industry as statute requires. Idaho Relay
continues to provide TRS, CapTel, Spanish Relay, and Speech to Speech Services as in the
past. Nationally, all states are experiencing a drop in usage of traditional relay services and
captioned telephone relay service because of migration to some relay services available
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through the Internet and other wireless means. The focus by the Advisory Committee of the
Telephone Industry for this contract period was to continue providing TRS, CTRS, and STS
while also focusing on outreach of the analog to digital transition in coordination with Hamilton
Relay as decided upon by the Advisory Committee of the Telephone Industry which met during
the RFP process. This digital transition is troublesome to people dependent upon a text
telephone or caption telephone (TTY's) because those devices do not work when changed to a
wireless/digital line. Then add to that communication difficulties, and all of a sudden your text
telephone no longer is operational because of an analog to digital change, then it is difficult for
people to troubleshoot, communicate and figure out what is wrong with their equipment and
phone line. These individuals can literally have their means of communication cut off. This
resulted in the focus on Outreach for TRS by the Advisory Committee. Another goal is to
continue to share information about the service of Speech to Speech relay services. An
outreach toolkit has been developed and is being shared to explain the transition and/or assist
customers in finding solutions that work to best fit their needs. The Relay Friendly Business
Program is also still available for employers or businesses who have customers who are deaf
and use relay services to contact them.
Employees from the Disabilities Rights Office and Consumer and Government Affairs Bureau of
the Federal Communications Commission (FCC) held a meeting with the National Association
of State Relay Administration members February 13, 2024. Questions and answers were
discussed, but most importantly the FCC employees were receptive to issues brought up due to
the changing landscape of analog TRS services along with affordability and access to
Broadband. The Americans with Disabilities Act is 30+ years old, and a few states are working
on other options of relay services incorporating Real Time Text, but there are no ready-
replacements across the board for TRS services.
Attachment D -TRS Budget Worksheet
LEC and MTS/WATS
From Order# 34988 dated May 1, 2021, the rates of contribution to ITRS are currently
assessed at $0.05 per line and $0.001 per long distance minute.
The following are options in 2024:
Option 1 — Continue the present rates of contribution to ITRS at $0.05 per line and $0.001 per
minute.
With the trend of recent years of diminishing inventory of landlines, 2024 Local Exchange Lines
can potentially be estimated to be about 78,300-83,00 per month and long distance minutes
reported as 53,000,000-56,000,000. These forecasted numbers could be dramatically different
than estimated due to the digital transition. Revenue could be estimated with the current
contributions and current rates for ITRS to be approximately $100,000-107,000. With a 2024
budget estimate of$141,232, then the 2024 year-end fund balance would potentially fall in the
range of about $21,000-28,000.
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If the line assessment included wireless lines, then the income from the $.05 cents per line
(wireless and wireline) at about 278,000 monthly lines would more than cover the projected
2024 expenses with income at $167,194, not including MTS/WATS assessment..
Option 2— Continue with the current long distance per minute rate of$0.001 while raising the
per line rate. Raising the LEC rate to $0.07 would allow an end of year fund balance to come
out to about $45--50,000 due to incoming revenue of about $120,022 with the budget at
$141,232.
Please see Attachment E for the various rates and fund balance projections.
(Note: Rate change would occur part way through the calendar year which affects projection
due to delay in reporting and payments. There is a lag in reporting month by
telecommunications companies monthly but especially when the companies report quarterly.)
Option 3— If both rates are raised, the percentage of contributions are less balanced, however
the fund balance would increase. If further breakdown is desired, then this can be provided in
more detail and can be seen through Attachment E.
For further breakdowns of local exchange lines/long distance minute splits, fund balance
projections, and revenue breakdowns please see Attachment E.
Attachment E - ITRS Projections.
Option 4 -
An additional option for Idaho TRS would be to look at other creative means of funding beyond
landlines and MTS/WATS. According to the most recent data gathered by the National
Association of State Relay Administration (NASRA), 29 of 50 states have relay services that are
funded by wireless/VolP line surcharges in addition to landlines. While analyzing the data,
nationally the average rate of surcharge is $0.08 per line per month. These surcharges range
from one state (Kentucky) that receives from $0.01 on all lines - wireline and wireless - while at
the higher end Alaska receives $0.18 per wireless/wireline. In looking at regionally closer states,
Montana and Oregon are funded by a monthly $.10 wireless and Iandline surcharges while
Wyoming is funded by a $0.09 surcharge for all wireless and landlines.
In reviewing available relay services, 38 states offer Relay Conference Captioning (RCC)
providing equal access to all with the option to speak or type to communicate with other
attendees in a meeting of professional and larger group settings online which has been even
more essential since spring 2020 and virtual meetings. RCC provides people who are deaf or
hard of hearing the ability to read live captions (Communication Access Realtime Translation)
via a web browser on a computer, laptop, tablet, or mobile device. This service is extremely
helpful especially when a sign language interpreter may be unavailable and is accessible by
signing up at least 48 hours in advance during specified times. RCC offers a communication
method by which those with a hearing or speech disability can stay in the conversation and
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allows for inclusive and accessible means for all to participate. One avenue might be to embark
upon a pilot study of offering RCC to Idaho residents prior to committing to this service full-time.
Another service on the horizon is Real-Time Text (RTT) which is accessible primarily via mobile
telephone to use RTT with the relay service. The States of Maryland, Washington, California,
and Virginia are in the process of testing out such a pilot program (Universal
Telecommunications Access Platform) utilizing Real-Time Text in accordance with the FCC. If a
surcharge is assessed on wireless platforms, this could ensure sustainability of the fund as the
FCC still requires TRS and STS services nationally while the digital transition proceeds. TRS
services could be funded by a lower wireline and wireless surcharge.
Attachment F - TRS State Data
Administrator's recommendation is to follow Option 2 by raising the LEC line rate to $0.07 per
LEC line while keeping the MTS/WATS rate the same in order to preserve some of the fund
balance until more is known from the future regarding the changing landscape of analog TRS.
The Administrator, on behalf of the State of Idaho, will continue to provide yearly MARS data
reports (Multi-State Average Rate Structure) to the FCC via Rolka Loube, maintain TRS
Certification, submit annual Complaint Reports to the FCC, and submit quarterly and annual
reports to the Public Utilities Commission while monitoring all areas of relay with respect to
meeting standards for the FCC. I will continue to collaborate with the National Association of
State Relay Administrators and Hamilton Relay.
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