20210323_dk5jn.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:DANIEL KLEIN
DATE:MARCH 19,2021
RE:2020 IDAHO TELECOMMUNICATIONS RELAY SERVICE ANNUALREPORT;CASE NO.GNR-T-21-02
BACKGROUND
Each 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 including wireless or VoIP 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 202,the Commission sets the TRS funding levels each year based upon the Administrator's
Annual Report.IDAPA 31.46.02.202.
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 -MARCH 19,2021
THE 2020 ANNUAL REPORT
On February 16,2021,the TRS Administrator,Ms.Kathleen Toohill,submitted the 2020
TRS Annual Report and the 2021 TRS Budget for Commission approval.During 2020,the
Administrator reported that the relay center handled 2,106 calls in 2020 an overall increase of
26%.There was 11,847.98 session minutes reported for Caption Telephone Service,18,761.19
Session Minutes for TRS,and 1365.07 Session minutes for Speech to Speech in 2020.The
increase has been attributed to the global pandemic and relay users relyingon the service more as
opposed to making in person visits.The number of Captioned Telephone (CapTel)!units held
steady.An amendment was made with Hamilton's contract which changed the price per minute
and compensation from conversation2 to session minutes.3
Disbursements from the TRS fund to Hamilton increased from $60,558.62 in 2019 to
$123,081.74in 2020,an increase of 103%.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.Hamilton's 2020 average answer time was .85 seconds.This was an
increase from past years due to the increased usage due to the global pandemic.Hamilton was
granted a FCC waiver for call answer times starting March 16,2020 which is still in affect
currently.Communications Assistants were also granted permission to work from home due to
the pandemic.
2020 Expenses
The TRS expenses for the year totaled $163,039.94.Disbursements to Hamilton were
$123,08 1.74.The administrative fees and expenses for the reporting year were $39,958.20.The
end-of-year fund balance was $180,933.83.
'CapTel allows hard-of-hearingusers 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 CORVersation minute 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,waitingfor a live answer),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 -MARCH 19,2021
2020 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 total
number of intrastate long-distance minutes reported by the telephone companies decreased by
18%from approximately 100,128,800 minutes in 2019 to approximately 82,015,033 minutes in
2020.The average monthlynumber of telephone lines reported decreased by 41%from 215,423
in 2019 to 126,760 in 2020.The 2020 annual contribution to the TRS fund was $66,837.81,a
decrease of $4,889.39 (7%)from 2019.Local exchange services contributed $32,750.55 (49%)
and MTS/WATS contributed $34,087.77 (51%).In Commission Order No.34615,the per-line
and per-minute assessments for 2020 were increased to $0.03 and $0.0008,respectively.4
Proposed 2021 Budget
The Administrator projects an annual operating budget of $173,760.This budget reflects
a change in administrative costs due to the change in the administrators contract as well as the
higher costs of the Hamilton contract extension."The budget also includes $8,350 for a
contractual audit of the fund.If assessment rates remain unchanged,the Administrator calculates
the 2021 end-of-year fund balance will continue to have a reasonable reserve (2021 year-end
balance is projected to be approximately $95,529.83).
Proposed 2021 TRS Funding Levels
Based on the proposed budget for 2021 and the 2020 end-of-year reserves,the
Administrator presents the followingoptions:
1.Continue the present rates of contribution to ITRS at $0.03 per line and $0.0008 per
minute.With the trends of recent years of diminishing inventoryof landlines,2021
Local Exchange Lines can be estimated to be approximately 101,408 (2020's count of
126,760 x 80%=101,408 due to 20%decrease).2021's Long Distance Minutes can
be estimated at 64,811,226 (2020 Long Distance Minutes 80,811,226x 80%=
64,811,226 due to 20%decrease).Therefore,revenue can be estimated with the
current contributions to ITRS at $88,356.With a 2021 budget of $173,760 and a
4 The new rates did not go into effect until May 1,2020,before that it was $0.02 per line and $0.0002 per min.
6 The Hamilton contract extension changed the billing from conversation minutes to session minutes and created a
separate monthly charge for outreach services.
DECISION MEMORANDUM -3 -MARCH 19,2021
2020 year-end balance of $180,933.83,with the projected contributions,that could
reduce the fund balance to $95,529;
2.Continue with the current $0.0008 long distance per minute rate and raise the per line
rate (currentlyassessed at $0.03)to $0.05.If the lines reported are 101,408 (80%of
126,760 -2020's assessed lines),and the split were 52/48 for 0.02 and 0.0005 then
the fund balance would be reduced to $119,867;and
3.Raise both rates,the $0.03 line charge and the $0.0008 rate,and find rates that will
result in more of a 48/52 split,by raising the rates to $0.05 per line and $0.001 per
minute which would result in a fund balance of $132,829.These rate changes
ensuring longevityof the fund balance.
STAFF'S RECOMMENDATION
Staff has reviewed the Administrator's Annual Report.Staff believes the Idaho citizens
continue to be well served by the Administrator and the relay services provided by Hamilton
Telecommunications.Staff also believes that the 2021 budget projection of $173,760 is
acceptable based on the anticipated TRS expenses.The projected revenue together with the
current fund balance should be sufficient to meet 2021 expenses,including any unforeseen
events.Staff,therefore,agrees with the Administrator's recommendationin option 3 to raise the
TRS contributions to $0.05 per access line per month and $0.001 per intrastate MTS/WATS
mmute.
COMMISSION DECISION
1.Does the Commission wish to accept the Administrator's recommendation to
raise the current TRS assessment rates$0.05 per access line per month and $0.001 per intrastate
MTS/WATS minute?
2.Does the Commission wish to accept the annual report and adopt the Administrator's
budget for 2021?
Daniel Klein
Udmemos/trs report for 2019 dec memo
DECISION MEMORANDUM -4 -MARCH 19,2021