20250415Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: JOHAN E. KALALA-KASANDA, COMMISSION STAFF
CHRIS BURDIN,DEPUTY ATTORNEY GENERAL
DATE: APRIL 15, 2025
RE: 2024 IDAHO TELECOMMUNICATIONS RELAY SERVICE ("ITRS")
ANNUAL REPORT; CASE NO. GNR-T-25-03.
BACKGROUND
Annually, 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 of the program 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 American with Disabilities Act. TRS enables citizens with a
hearing or speech-impaired to engage in telephone communications "in a manner functionally
equivalent to that of individuals without hearing loss or speech impairments." Idaho Code § 61-
1301. Under the Idaho TRS Act, all telephone corporations providing local or long-distance
service (not including wireless or VoIP services) must provide TRS as stated in the program and
pay into the TRS Fund. Pursuant to TRS Rule 204, the Commission sets the TRS funding levels
each year based upon the Annual Report. IDAPA 31.46.02.204.
The 2024 Annual Report
On February 19, 2025, the TRS fund Administrator ("Administrator"), Ms. Kathleen
Toohill, submitted the 2024 Annual Report of the Idaho TRS Fund and the 2025 Idaho TRS Fund
Budget for Commission approval.
DECISION MEMORANDUM - 1 - APRIL 15, 2025

The Administrator reported that,during 2024,the relay center handled 976 calls,a decrease
from the 1221 completed calls placed in 2023. TRS session minutes usage decreased by 7% to
10,419.83 minutes compared to 11,227.3 session minutes in 2023. Caption Telephone Relay
Service ("CTRS")' call volume decreased by approximately 72% in 2024 from the 2023 level.
Advanced Speech to Speech ("STS") was discontinued, but the service was reinstated in late
2024/early 2025. Standard Speech to Speech Services generated 352 calls which was a decrease
from 553 calls in 2023. There were also 349 Spanish calls processed by Idaho Relay Center in
2024, which is a decrease from 533 calls in 2023.
For the year 2024, as shown in Table No. 1, total disbursements from the TRS fund to
Hamilton Relay for the provision of all services for 2024 were $100,004.04. This includes
$65,000.04 for digital transition outreach services and$35,004.00 for TRS, CTRS, and STS. In-
state traditional relay and CTRS are reimbursed by Idaho's TRS fund. 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: COMPARATIVE DISBURSEMENTS TO HAMILTON
2024 2023 2022
Outreach $ 65,000.04 $ 65,000.00 $ 60,000.00
TRS, CTRS, and STS $ 35,004.00 $ 36,065.00 $ 33,973.00
TOTAL $100,004.04 $ 101,065.00 $ 93,973.00
The Administrator reported that the Average Speed of Answer ("ASA") is a key
performance indicator for TRS and CapTel. This shows when a call reaches the relay switchboard
and how long it takes to be answered by a Communication Assistant. The ASA for 2024 was
calculated as an average of 0.633 for TRS and .47 for CTRS. 100% of CTRS calls were answered
in 10 seconds or less while 97.67 % of TRS calls were answered in 10 seconds or less. These
1 CTRS 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 captioned telephone user with a more natural conversation.
z The Hamilton contract extension changed the billing from conversation minutes to session minutes and created a
separate monthly charge for outreach services.
DECISION MEMORANDUM - 2 - APRIL 15, 2025

performance indicators may be a little slower for TRS than in 2023, however they are within the
contract requirements. CTRS ASA was slightly faster than 2023's ASA.
2024 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. The Administrator
reported that the total number of intrastate long-distance minutes reported by telephone companies
in 2024 was approximately 59,772,789 compared to 59,148,700 in 2023, a 1.0% increase. The
average monthly local exchange number of telephone lines reported decreased by 7.0%, from
88,344 in 2023 to 82,136 in 2024.
As illustrated in Table No. 2, below, the 2024 total annual contribution to the TRS fund
was $119,753.38 compared to $112,149 in 2023. Local exchange services contributed$59,211.65
and MTS/WATS contributed $60,541.73. In Commission Order No. 36179, the per-line and per-
long-distance minute assessments for 2024 were set to $0.07 and$0.001, respectively.3
Table No. 2: 2024 Idaho TRS Revenue
Percentage of
2024 Revenue sources Amount Total
Local Service Providers
$0.05/month/line $59,211.65 49%
MTS/WATS Providers
$0.001/min $60,541.73 51%
TOTAL $119,753.38 100%
2024 Expenses
For 2024, as shown in Attachment D of the Amended TRS Administrator's 2024 Annual
Report, actual TRS total expenses amounted to $140,300 compared to $141,274 in 2023. This
includes $100,004 disbursed to Hamilton and $40,296 in administrative fees and expenses for the
reporting year, compared to $40,209 in 2023. The end-of-year TRS fund balance was reported to
be approximately $48,345.49 compared to $68,872 in the prior year.
3 The rates went into effect on May 1,2024.
DECISION MEMORANDUM - 3 - APRIL 15, 2025

Proposed 2025 Budget
As illustrated in Attachment D of the TRS Administrator's 2024 Annual Report and Table
No. 3 below, the Administrator projected an annual operating budget of approximately $125,432.
The total amount includes the anticipated administrative costs as contracted, the Hamilton TRS
payments,National Association of State Relay Administration("NASRA")membership dues, and
bank charges.
Table No. 3: TRS Budget Analysis
2025 Projected
Total Revenue: $ 107,778.04
Expenses:
Administrator contract $ 24,000
Bank Service Charges $ 132
Hamilton TRS Payments $ 101,000
NASRA Dues $ 300
Total Expenses $ 125,432
Proposed 2024 TRS Funding Levels
Pursuant to Commission Order No. 36179, the rates of contribution for TRS were set at
$0.07 per line and $0.001 per long-distance minute and went into effect on May 1, 2024. As
illustrated in Table No. 4, below, the 2025 revenue for the fund can be estimated with the current
contributions and current rates of approximately$107,778.04. The 2025 budget is estimated to be
approximately$125,432. The 2024 year-end balance of approximately$48,345.49 is the beginning
balance of 2025. As a result, it is possible that the fund could end 2025 with a positive balance of
around $31,691.53.
DECISION MEMORANDUM - 4 - APRIL 15, 2025

Table No. 4: 2025 Fund-Level Analysis
2025 Revenue Projection Amount
l/l/2025 Beginning Balance $48,345.49
Plus 2025 Estimated Revenue $107,778.04
Sub-Total $156,123.53
Minus Estimated 2025 Expenses $125,432
31/12/2025 Ending Balance $30,691.53
Based on the proposed budget for 2025 and the 2024 end-of-year reserves, the
Administrator recommends maintaining the current rates of contribution to ITRS at $0.07 per
line per access line per month and $0.001 per minute per intrastate MTS/WATS minute. This is
Option 1 out of the three options recommended for consideration by the Administrator. The three
options are listed herein below as follows:
Option 1—Continue the present rates of contribution to ITRS at$0.07 per line and$0.001
per minute. The trend in recent years of a shrinking inventory of landlines, the 2025 Local
Exchange Lines can be estimated to be about 78,000-82,000 per month and long-distance minutes
around 54,000,000-50,000,000 per month. The forecasted numbers could dramatically change
from the estimates due to the digital transition. The annual revenue of the ITRS for 2025 could be
estimated at approximately $107,000, with a projected 2025 budget of$125,432. The 2025 year-
end fund balance could potentially fall between$28,000-30,000.
Option 24 — Continue with the current long-distance per-minute rate of $0.001 while
raising the per-line rate to$0.10. By raising this rate,it would provide a revenue of about$120,022
and an end-of-year fund balance between$45,000 and$50,000.
Option 3 - In this option the Idaho TRS would look for other creative means of funding
outside of landlines and MTS/WATS. Based on data gathered by the NASRA,29 of 50 states have
relay services that are funded by wirelessNolP line surcharges in addition to landlines.
4 Note. There is a lag in reporting months by telecommunications companies'monthly reporting but especially when
the companies report quarterly.
DECISION MEMORANDUM - 5 - APRIL 15, 2025

STAFF'S RECOMMENDATION
Staff has reviewed the Administrator's 2024 Annual Report. Staff agrees with the
Administrator's recommendation in Option 1 to maintain the LEC line rate at $0.07 per LEC line
and the MTS/WATS rate at $0.001 per long-distance minute. This option will help to preserve a
portion of the fund's balance until more is known in the future regarding the changing landscape
of analog TRS.
Staff believes that the 2025 budget projection of$125,432 is acceptable based on the
anticipated 2025 TRS expenses. The projected revenue generated from the current rates, together
with the current fund balance, should be sufficient to meet 2025 expenses and unforeseen events,
as shown in Table 4 above. Staff will be working very closely with the Administrator during the
year in monitoring the fund level. Staff believes the Idaho citizens continue to be well served by
the Administrator and the relay services provided by Hamilton Telecommunications.
COMMISSION DECISION
1. Does the Commission wish to accept the Administrator's recommendation to maintain
the present rates of contribution to Idaho TRS at $0.07 per access line per month and the current
long-distance rate at $0.001 per intrastate MTS/WATS minute unchanged?
2. Does the Commission wish to accept the Administrator's Annual Report and adopt the
Administrator's budget for 2025?
3. Anything else?
3A alkm_14
Johan E. Kalala-Kasanda
Commission Staff
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DECISION MEMORANDUM - 6 - APRIL 15, 2025