20240516Final_Order_No_36179.pdf

Office of the Secretary
Service Date
May 16,2024
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF REVIEWING THE )
ADMINISTRATOR'S 2023 ANNUAL REPORT ) CASE NO. GNR-T-24-02
AND ESTABLISHING THE FUNDING )
LEVELS TO SUPPORT THE )
TELECOMMUNICATIONS RELAY SERVICE ) ORDER NO. 36179
(TRS) PROGRAM )
On February 20, 2023, the Idaho Telecommunications Relay Service ("TRS")
Administrator, Kathleen Toohill ("Administrator"), submitted the calendar year 2023 Annual
Report and the proposed 2024 TRS Budget("Budget") to the Commission. On April 10, 2024, an
amended Report("Report")was filed in coordination with Commission Staff("Staff'). 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 31.46.02.204.
In this Order, we accept the Administrator's 2023 Report and the 2024 proposed 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")' services and
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. 36179 1

THE 2023 ANNUAL REPORT
The Administrator reported that the relay center handled 1,221 calls in 2023—representing
an approximately 11% increase from 2022. The average time it took Hamilton for a call to reach
the relay switchboard and be answered by a communication assistant in 2023 was 0.225 seconds
for TRS calls and .475 seconds for Caption Telephone Relay Service calls.
1. 2023 Expenses. The TRS expenses for the year totaled $141,274. Disbursements to
Hamilton were $101,065. The administrative fees and expenses for 2023 were $40,0802 The end-
of-year fund balance was $68,872.
2. 2023 Revenues and Allocations. Telephone companies reported a 3.0%decrease in total
intrastate long-distance minutes, from about 60,936,000 minutes in 2022 to about 59,148,700
minutes in 2023. Average monthly telephone lines increased by approximately 1.0%, from 87,700
in 2022 to 88,344 in 2023.
The 2023 annual total contribution to the TRS fund was $112,149 a decrease of $593
(0.5%) from 2022. In 2023, Local exchange services contributed $53,006 (47%) and Message
Telecommunication Services ("MTS") and Wide Area Telephone Service ("WATS") collectively
contributed $59,149 (53%). In Commission Order No. 34988, the per-line rate increased from
$0.03 to $0.05 effective May 1, 2021. In Order No. 35763,rates remained unchanged at$0.05 per
line and $0.001 per long-distance minute. The table below shows 2023 TRS contribution sources
and amounts.
Percentage of
2023 Revenue sources Amount Total
Local Service Providers
$0.05/month/line $53,006 47%
MTS/WATS Providers
$0.001/min $59,149 53%
TOTAL $112,149 100%
2 Staff stated that the administrative fees and expenses totaled$40,209. Staff Decision Memorandum at 4.This slight
difference is due to Staff including$129.00 in Bank Service Charges to the administrative fees and expenses total.
ORDER NO. 36179 2

3. Proposed 2024 Budget. The Administrator projects an annual operating budget of
$141,232 in 2024. The budget includes administrative fees and expenses, travel and conference
costs, the Hamilton TRS payments, and NASRA annual membership dues.
4. Proposed 2023 TRS Funding Levels. Based on the proposed budget for 2024 and the
2023 end-of-year reserves, the Administrator provided the following four options:
Option 1: Continue the present compensation rates to the TRS fund at $0.05 per line and
$0.001 per long-distance minute.
Option 2: Continue with the current long distance per minute rate of$0.001 while raising
the per line rate to a range somewhere around $0.07 per line to try and level out the contributions
to the fund. This would allow the 2024 end-of-year balance to come out to an estimated $45,000-
$50,000. Further information about how Option 2 would affect rates can be found in Attachment
E of the Report. The Administrator recommended this option.
Option 3: The Commission could raise both rates—additional details regarding this option
can be found in Attachment E of the Report.
Option 4: Staff noted that the Commissioner could "look at other creative means of
funding beyond landlines and MTS/WATS." Staff Decision Memorandum at 6. Staff noted what
other States have done stating:
According to the most recent data gathered by the NASRA, 29 of 50 states have
relay services that are funded by wirelessNoIP line surcharges in addition to
landlines. While analyzing the data, the national 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. Certain States in the Rocky Mountain Northwestern region,
Montana and Oregon, are funded by a monthly $0.10 wireless and landline
surcharges while Wyoming is funded by a $0.09 surcharge for all wireless and
landlines.
Id.
STAFF RECOMMENDATION
After reviewing the information filed by the Administrator (and the Administrator's
recommendation), Staff agreed with the Administrator and recommended the Commission adopt
Option 2 from Administrator's Report and projected 2024 budget. Staff believed Option 2—raising
only the TRS contributions to $0.07 per access line per month—was the best option to stabilize
the 2024 proposed 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 2024 budget
ORDER NO. 36179 3

projection of$141,232 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 2024
expenses and unforeseen events.
DISCUSSION AND FINDINGS
In this Order, the Commission formally adopts the Administrator's Report. We find the
reported expenses for 2023 reasonable. Idaho citizens continue to be well served by the
Administrator and the relay services provided by Hamilton. The Commission also finds that the
2024 budget projection of$141,232 is reasonable based upon the anticipated TRS expenses this
year.
Based upon our review of the Report and Staff s recommendations, we find it is just and
reasonable to adopt the Administrator's Option 2 in as discussed in Staffs comments. Based on
the information currently available, the Commission finds that Option 2 presents the best option
as it allows the per minute rate, which appears to be contributing to the fund in a sustainable
manner, to remain unchanged while taking a measured step towards sustainability by increasing
the per line rate. We find that these steps should provide a sustainable TRS Budget that provides
reliable services to Idaho customers.
ORDER
IT IS HEREBY ORDERED that the Commission accepts the Report and 2024 budget.
IT IS FURTHER ORDERED that the 2023 TRS funding level of telephone corporations
providing local service in Idaho increase to a rate of$0.07 per line.
IT IS FURTHER ORDERED that the 2023 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
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 about 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.Idaho Code §§ 61-626 and 62-619.
ORDER NO. 36179 4

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 161h day of
May 2024.
ERIC ANDERSON, PRESIDENT
9t",
J R. HAMMOND JR., COMMISSIONER
G
EDWARD LODG , C MISSIONER
ATTEST:
MWILa E arri c z
Commission Secretary
IALega1\TELEC0M\GNRT2402_Final_md.docx
ORDER NO. 36179 5