20250502Final_Order_No_36590.pdf

Office of the Secretary
Service Date
May 2,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF REVIEWING THE )
ADMINISTRATOR'S 2024 ANNUAL REPORT ) CASE NO. GNR-T-25-03
AND ESTABLISHING THE FUNDING )
LEVELS TO SUPPORT THE )
TELECOMMUNICATIONS RELAY SERVICE ) ORDER NO. 36590
(TRS) PROGRAM )
On February 19, 2025, the Administrator of the Idaho Telecommunication Relay Service
("TRS" or "Relay") filed the 2024 Annual Report and 2025 TRS Budget recommendations with
the Idaho Public Utilities Commission ("Commission"). Each year, the Commission reviews the
Administrator's Annual Report and determines the funding needed to meet the TRS program's
future expenses.
BACKGROUND
In 1992, the Idaho Legislature established the Telecommunications Relay Service Act
("Idaho TRS Act") in accordance with the American with Disabilities Act. Staff Memo at 1. TRS
enables citizens with hearing or speech impairments to engage in telephone communications "in a
manner functionally equivalent to that of individuals without hearing loss or speech impairments."
Idaho Code § 61-1301. The TRS service provider is Hamilton Telecommunications("Hamilton").
Order No. 35378. Hamilton operates the relay center where oral conversations are converted or
"relayed" to text-type and vice versa. Id. The relay center also provides Advance and Standard
speech-to-speech ("STS"), Spanish-to-Spanish, video, and Internet relay services. Id.
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. Staff Memo at 1. 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
The Administrator reported that there was a decrease in the amount of calls from 2023 to
2024. 2024 Annual Report at 2. The relay center handled 976 calls in 2024, compared to the 1,221
calls handled in 2023. Id. at 3. TRS session minutes usage decreased by 7%to 10,419.83 minutes
ORDER NO. 36590 1

compared to 11,227.3 session minutes in 2023. Id. Caption Telephone Relay Service ("CTRS")'
call volume decreased by approximately 72%in 2024 from the 2023 level.Id. Advanced STS was
discontinued, but the service was reinstated in late 2024/early 2025. Id. Standard STS Services
generated 352 calls in 2024, down from 553 calls in 2023. Id. There were also 349 Spanish calls
processed by the Idaho Relay Center in 2024, down from 533 calls in 2023. Id.
The average time it took for a call to reach the relay switchboard and be answered by a
communication assistant in 2024 was 0.663 seconds for TRS calls and.47 seconds for CTRS calls.
Id.
1. 2024 Expenses. The TRS expenses for the year totaled$140,300. Staff Decision Memo
at 3. The total included $100,004 disbursed to Hamilton and $40,296 in administrative fees and
expenses. 2024 Annual Report at 2. The end-of-year TRS fund balance was reported to be
approximately $48,345.49. Id. at 4.
2. 2024 Revenues and Allocations. The total number of intrastate long-distance minutes
reported by telephone companies in 2024 increased 1% to approximately 59,772,789. Id. at 1-2.
The average monthly local exchange number of telephone lines reported decreased by 7% to
82,136 in 2024. Id. at 2.
The 2024 annual total contribution to the TRS fund was $119,753.38, an increase of
approximately $7,604.38 from 2023. Id. at 1. In 2024, Local Exchange Services contributed
$59,211.65 (49%) and Message Telecommunication Services ("MTS") and Wide Area Telephone
Service ("WATS") collectively contributed $60,541.73 (51%). Id. 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. Proposed 2025 Budget. The Administrator projects an annual operating budget of
$125,4322 in 2025. Id. at 5. The budget includes administrative fees and expenses, bank service
fees,the Hamilton payments,and National Association of State Relay Administration("NASRA")
annual membership dues. Id.
'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.
2 The total proposed annual operating budget provided by the Administrator was $124,432. In Staff s review of the
proposed TRS budget, Staff found the Administrator's value contained a typographical error and calculated the total
value of the proposed expense costs to be$125,432.
ORDER NO. 36590 2

4. Proposed 2025 TRS Funding Levels. Based on the proposed budget for 2025 and the
2024 end-of-year balance, the Administrator provided the following four options:
Option 1: Continue the present rates of contribution to TRS at $0.07 per line and $0.001
per minute.Id. Because of 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 50,000,000-54,000,000 per month.Id. The forecasted numbers could dramatically
change from the estimates due to the digital transition.Id. The annual revenue of the TRS for 2025
is estimated at approximately $107,000, with a projected 2025 budget of$125,432. Id. The 2025
year-end fund balance could potentially fall between $28,000 and $30,000. Id.
Option 2: Continue with the current long-distance per-minute rate of$0.001 while raising
the per-line rate to $0.10. Id. 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.Id.
Option 3: In this option the TRS would look for other creative means of funding outside
of landlines and MTS/WATS.Id. Based on data gathered by the NASRA,29 of 50 states have relay
services that are funded by wirelessNVoIP line surcharges in addition to landlines. Id.
STAFF RECOMMENDATION
Commission Staff ("Staff') agreed with the Administrator and recommended the
Commission adopt Option 1 to maintain the line rate at $0.07 per line and the MTS/WATS rate at
$0.001 per long-distance minute. Staff Decision Memo at 6. Staff believed this option would help
to preserve a portion of the fund's balance until more is known about the changing landscape of
analog TRS. Id.
Staff agreed that the 2025 budget projection of $125,432 was acceptable based on the
anticipated 2025 TRS expenses. Id. Staff reasoned that the projected revenue generated from the
current rates, together with the 2024 carry-over balance, should be sufficient to meet 2025
expenses and unforeseen events. Id. Staff agreed to continue working with the Administrator
during the year to monitor the fund level.Id. Staff believed that Idaho citizens continued to be well
served by the Administrator and the relay services provided by Hamilton. Id.
DISCUSSION AND FINDINGS
In this Order, the Commission formally adopts the Administrator's Report. We find the
reported expenses for 2024 reasonable. Idaho citizens continue to be well served by the
Administrator and the relay services provided by Hamilton. The Commission also finds that the
ORDER NO. 36590 3

2025 budget projection of$125,432 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 1 for 2025 as discussed in Staff s comments.Based
on the information available, the Commission finds that Option 1 presents the best option because
it maintains the current per line and per minute rates, while still contributing to the fund
sustainably. These steps maintain a viable TRS budget to provide reliable services to Idaho
customers.
ORDER
IT IS HEREBY ORDERED that the Commission accepts the Administrator's Annual
Report and adopts the Administrator's budget for 2025.
IT IS FURTHER ORDERED that the present rates of contribution to TRS at $0.07 per
access line per month and the current long-distance rate at $0.001 per intrastate MTS/WATS
minute remain unchanged.
IT IS FURTHER ORDERED that the TRS Administrator shall continue to monitor
expenditures, revenues, and Federal Communications Commission actions. If it appears that
revenues will not cover expenditures, the TRS Administrator shall 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. 36590 4

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 2nd day of
May 2025.
EDWARD LODGE, SIDENT
kL ;?fal�
J R. HAMMOND JR., COMMISSIONER
DAMN HA/RDIk, COMMISSIONER
ATTEST:
Aa6i8s<5hez
Commission Secretary
IALegal\TELECOM\GNRT2503_Final_em.docx
ORDER NO. 36590 5