20220405_jk2rq.pdf

DECISION MEMORANDUM
TO:COMMISSIONER ANDERSON
COMMISSIONER CHATBURN
COMMISSIONER HAMMOND
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:JOHAN E.KALALA-KASANDA
DAYN HARDIE
DATE:APRIL 1,2022
RE:2021 IDAHO TELECOMMUNICATIONS RELAY SERVICE ANNUAL
REPORT;CASE NO.GNR-T-22-03
BACKGROUND
Every year,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 also determines the fundingrequirements 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 includingwireless or VolP 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 fundinglevels 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
DECISION MEMORANDUM -1 -APRIL 1,2022
relay center also provides speech-to-speech,Spanish-to-Spanish,video,and Internet relay
services.
The 2021 Annual Report
On February 15,2022,the TRS fund Administrator,Ms.Kathleen Toohill,submitted the
2021 Annual Report of the Idaho TRS Fund and the 2022 Idaho TRS Fund Budget for
Commission approval.The Administrator reported that the relay center handled 1,853 calls in
2021.This was a decrease of 253 completed calls (12%)compared to the 2,106 reported in
2020.
In 2021,there were 7,489.57 session minutes reported for Caption Telephone Service
(37%decrease),15,081.03 Session Minutes for TRS (19%decrease),and 812 Session minutes
for Speech to Speech (41%decrease).The number of CaptionedTelephone (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
For the year 2021,total disbursements from the TRS fund to Hamilton amounted to
$97,051.70.Including$60,000 for Outreach and $37,051.70for TRS,CapTel Relay Service
(CTRS),and Speech to Speech (STS)Relay Service.This is less than the $123,081.74
reimbursed in 2020--a 21%decrease.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.
A key performance indicator for TRS and CapTel is the average speed of answer (ASA)
for a call to reach the relay switchboard and to be answered by a communication assistant.In
2021,Hamilton's average answer time was 0.85 seconds-a significant increase as compared to
the 0.41 seconds of previous years.This increase from past years was caused by the increased
i 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 conversation minute shall include the time the calling party is connected to the called pany 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,waiting for a liveanswer),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 -APRIL 1,2022
usage due to the pandemic.Hamilton was granted an FCC waiver for call answer times starting
March 16,2020,which is still effective.Communications Assistants were also granted
permission to work from home due to the pandemic.
2021 Expenses
For 2021,TRS expenses totaled $145,780.10.-including$97,051.70 to Hamiltonand
$40,068.00 in administrative fees and expenses for the reporting year.The end-of-year TRS
fund balance was reported to be $121,352.80.
2021 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 telephonecompanies in 2021 was
65,058,266compared to 82,015,033 in 2020,a 21%decrease.The average monthlynumber of
telephonelines reported decreased by 30%from 126,760 in 2020 to 89,110 in 2021.
As illustrated in Table No.1,below,the 2021 total annual contribution to the TRS fund
was $105,245,an increase of $38,408.19 (57%)from 2020 annual contributions.Local
exchange services contributed $41,687 (39.23%)and MTS/WATS contributed $64,418
(60.77%).In Commission Order No.34988,the per-line and per-minute assessments for 2021
were increased to $0.05 and $0.001,respectively4
Table No.1:2021 ITRS Revenue
2021 Revenue sources Amount Percentage of Total
Local Service Providers
($0.05/month/line)$41,687 39.23%
MTS/WATS Providers
($0.001/min)$64,418 60.77%
TOTAL $105,245 100%
The new rates did not go into effect until May 1,2021,before that it was $0.03 per line and $0.0008 per min.
DECISION MEMORANDUM -3 -APRIL 1,2022
Proposed 2022 Budget
As illustrated in Attachment D of the annual report,the administrator projects an annual
operating budget of $142,350.This budget includes the anticipated administrative costs as
contracted,the travel/conference costs,the Hamilton TRS payments,and NASRA membership
dues.
2022 TRS Funding Levels
From Order No.34988,the rates of contribution for ITRS were raised to $0.05 per line
and $0.001 per long distance minute and were effective May 1,2021.Revenue for the fund can
be estimated with the current contributions and current rates to be approximately $92,146.The
2022 budget is estimated to be $142,350and a 2021 year-end balance of $121,352.80.For,at
least this year,the current rates can sustain the fund.However,a review will need to be made
next year.
Idaho TRS is now entering year 3 of an amended 3-year contract which was mutually
agreed upon with Hamilton Relay and the Idaho PUC in 2019.Monies were allocated for
Outreach services as a result of that contract,in addition to the provision of TRS,CapTel,and
Speech-to-Speech Services.Idaho Relay also contracts to provide Advanced Speech-to-Speech
Services.From the year 2020 and in early 2021,there was higher than average TRS and CapTel
usage.However,this stabilized later in 2021 returning to typical usage.Budget needs for TRS
and CapTel do not appear to be as great as expected in 2021.A new Request for Proposal has
been sent out and responses are due by May 2,20225.The current contract sunsets November
30,2022.
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 2022 budget projection of $142,350 is
reasonable,based on the anticipated TRS expenses.The projected revenue,based on the current
rates,together with the current fund balance should be sufTicient to meet 2022 expenses,
Hamilton Relay and T-Mobile are the only two companies providingstate relay service.
DECISION MEMORANDUM -4 -APRIL 1,2022
includingany unforeseen events.The current rates approved in Order No.34988 continue to be
reasonable.
COMMISSION DECISION
Does the Commission wish to accept the annual report,adopt the Administrator'sbudget
for 2022,and maintain current TRS rates?
Johan E.Kalala-Kasanda
Udmemos/GNR-T-22·03 TRS 2021 Decision Memo
DECISIONMEMORANDUM -5 -APRIL 1,2022
Id a o
Rel.ay-
Telecommunications Relay Service (TRS)Administrator's Annual Report
idaho TRS Fund
January 1 -December 31,2021
Revenues
Revenues collected in all of 2021 totaled $105,245 with $41,687 being received from local
exchange services and $64,418 was received from MTS/WATS services.The staiting balance
was $180,933.83 as of 1/1/2021,and the final balance was $121,352.80 as of 12/31/2021.The
current rate is $.05 per local exchange line service and $0.001 for Message Telecommunication
Services (MTS)I Wide Area Telephone Service (WATS)services as of May 1,2021.
2021 ITRS Revenue
Local Exchange
Quarter Services %MTSIWATS %Total
1 $9,508 39 14,871 61 $24,378
2 $8,049 35 14,949 65 $22,998
3 $11,616 44.6 14,429 55.4 $26,046
4 $12,514 38.3 20,169 61.7 $32,683
Total $41,687 39.23 $64,418 60.77 100%
Call and Line Count
In 2021,providers and carriers reported the following to Idaho TRS:
89,110 monthly average local exchange lines (a 30%decrease in monthly line count from 2020)
or 1,069,321 total reported across the entire year.
65,058,266.417 long distance minutes (a 21 %decrease)reported throughout2021.
Lines and Minutes Chart
Year Lines Change from Minutes Change frompreviousyearpreviousyear
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
90 telecommunications companies filed $0 reports in 2021 on a monthly,quarterly,or annual
basis.
Attachment A -Zero Reporting
Disbursements -Hamilton Relay
Total disbursements to Hamilton Relay for the provision of all-encompassing
telecommunications relay services (TRS)for the year were $97,051.70.TRS,CapTel Relay
Service (CTRS),and Speech to Speech (STS)Relay Senrice totaled $37,051.70 while Outreach
totaled $60,000.00.
Attachment B -Hamilton Relay Disbursements
A total 1853 completed calls were placed throughoutthe year while 2021 saw decreases in
usage as the numbers were higher in 2020 due to the beginning of the Covid-19 pandemic.TRS
decreased by about 24 %,CTRS decreased by about 40%and Advanced STS decreased by
80%.
Session Minutes
In 2021,7,489.57 Session Minutes were reported for Captioned Telephone Relay Sentice,
15,081.03 Session Minutes for TRS,and 812 Session Minutes for Speech to Speech for 2021.
Average Speed of Answer
A key performance indicator for TRS and CapTel is typically the average speed of answer (ASA)
for a call to reach the relay switchboard and to be answered by a Communication Assistant,and
that was calculated as an average of 0.85 seconds for the entire year as opposed to 2019 which
was 0.41 seconds.Because of the COVID-19 pandemic during 2020 and 2021,the FCC has
extended Hamilton's waivers since March 16,2020 which have been extended a couple of times
through the most recent of March 31,2022 due to being unable to meet standards.The ongoing
pandemic also grants permission to Communication Assistants to be able to work from home.
Administrative Fees and Expenses
Administrative Fees and Expenses totaled $40,068 for 2021 for TRS Administrator Kathleen
Toohill consulting and reimbursement for payment of NASRA annual membership dues for
2021-2022.
Attachment C -Administrator Billing
Funds
Starting Balance January 1,2021 -$180,933.83
Q1 Balance (3/31)Q2 Balance (6/30)Q3 Balance (9/30)Q4 Balance (12/31)
$145,735.07 5132,740.32 $122,374.94 $121,352.80
Recommendations and Overview
Idaho TRS is now entering year 3 of an amended 3 year contract which was mutually agreed
upon with Hamilton Relay and the Idaho PUC in 2019.Monies were allocated for Outreach
services as a result of that contract,in addition to the provision of TRS,CapTel,and
Speech-to-Speech Services.Idaho Relay also contracts to provide Advanced Speech to
Speech Senrices.2020 and into early 2021 saw higher than average TRS and CapTel usage
however later in 2021 realized more typical usage.Budget needs for TRS and CapTel do not
appear to be as high as expected in 2021.A new Request for Proposalwill soon be sent out for
bids for a new TRS contract as the current contract sunsets November 30,2022.
2021 tumed out to be a year of primarily continued virtual outreach events,however Idaho's
Outreach Specialist has begun to schedule in-person outreach training and events in 2022.
Nationally the trend of other states are experiencing a drop in traditional relay service and
captioned telephone relay service because of migration to Intemet Protocol (IP)Relay and
Video Relay Senrices.
Attachment D -TRS BudgetWorksheet
LEC and MTSIWATS
From Order #34988 dated May 1,2021,the rates of contribution to ITRS were raised to $0.05
per line and $0.001 per long distance minute.
The following are options in 2022:
Option1 -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,2022 Local Exchange Lines
can potentially be estimated to be 74,000 and that same year's Long Distance Minutes can
potentially be estimated at 52,000,000.Revenue can be estimated with the current contributions
and current rates for ITRS to be approximately $92,146.With a 2022 budget estimate of
$142,350 and a 2021 year-end balance of $121,352.80 with the proJected contributions,the end
of year balance for 2022 could conceivably fall around $73,775.
Option2 -Continue with the current long distance per minute rate of $0.001 while raising the
per line rate to a range somewhere between $0.06 or $0.10 per line to try and level out the
contributions to closer to 50%of LEC lines and MTS/WATS.Raising the LEC rate to $0.07 or
$0.08 would balance the contributions and should allow a fund balance of at least
$85,000-$95,000.
(Note:rate change would occur almost halfway through the year which affects how much is
projected 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.)
With a long distance per minute rate (currently assessed at $0.001):
Option3-If both rates were raised,the contributions would be less balanced,however the
fund balance would end up higher.When the MTS/WATS rate is raised the payments seem to
fall on just a few companies,resulting in very high payments from justa few companies.If
further breakdown is desired,then I would be able to provide this in more detail.
For further breakdowns of local exchange lines/long distance minute splits,fund balance
projections,and revenue breakdowns,please see Attachment E -ITRS Projections.
The Administrator will continue to monitor all areas of relay with respect to meeting standards
for the FCC,NASRA,and Hamilton Relay while continuing to work closely with the Idaho Public
Utilities Commission.