Substantive Proposed Regulatory Changes Emergency

Substantive Proposed Regulatory Changes Emergency Telephone Systems Act

Section Concern Response

General

DuPage: On the proportional allowable costs – how will that be measured? If we want to motivate consolidation, then stand alone consolidated PSAPs should have not have to worry about proportional allowable costs. Also how would you measure that in terms of a 9-1-1 system.

Proportionate means - the correct or suitable amount when considered in relation to the other uses. There isn’t a really good way to spell this out as it is not exact and must rather be determined on a case by case basis.

General

DuPage: I’d also like to see some sort of support/preference towards STARCOM21 for interoperability purposes. It’s a state-wide system and a state contract. The more users on it the cheaper and more stable it becomes. It should also be the baseline for grant reimbursement for radio console equipment. If a 9-1-1 system is using STARCOM21, portables should be an allowable cost (green). It also would make consolidations more seamless.

This is a legislative issue requiring further discussion.

Definitions

Many of the comments pertaining to definitions are not actually about the definition but rather the rules.

Definitions are not rules or requirements. To the extent there are concerns with application of a term that has been defined, those should be addressed within the rule. Only concerns about the definition itself would be addressed within the definition.

9-1-1 Network

Definition amended in response to concerns regarding P.01 and i3 Grade of Service requirements.

"9-1-1 Network" means the network used for the delivery of 9-1-1 calls, data, and messages over dedicated and redundant facilities to a primary or backup 9-1-1 PSAP that meets the appropriate Grade of Service. The following definition currently exists: Grade of Service means P.01 for Basic 9-1-1 or Enhanced 9-1-1 services or the NENA i3 Solution standard for NG9-1-1.

9-1-1 System Provider

INENA/ILAPCO: CLEC requirement behind the SSP, ICC requirement but should it be in this document also?

This is a definition rather than the rules regarding how the 9-1-1 System is built. The Department does not regulate carriers. The ICC has authority over these issues.


9-1-1 Telecommunicator

New definition to be added to clarify application of Subpart F of Part 1325.

“9-1-1 Telecommunicator” means any person employed in a full-time or part-time capacity at a PSAP, SAP, VAP, or Backup PSAP whose duties or responsibilities include answering, receiving, or transferring an emergency call for dispatch to the appropriate first responder(s).

Aid Outside Jurisdictional Boundaries Agreement

Counties < 50,000: What does this mean for all of the individual agreements? Would all of the individual agreements go away and there would just be agreements between the 911 Authorities and all of the public safety agencies would just be expected to fall in line under those agreements? Saline, Gallatin, & Hamilton: The 911 Authority alone doesn't have the authority to require another 911 authority to require a public safety agency to render aid outside their response area, without some sort of additional agreement in place between the 911 authority and all public safety entities, that allows for the one 911 authority to have control of county or municipal or private safety agencies.

Yes, sort of. Each 9-1-1 Authority is responsible for obtaining call handling agreements with its participating agencies. These agreements should include aid outside jurisdictional boundaries provisions. So, what is left is for the 9-1-1 Authority to have an agreement with the adjacent 9-1-1 System(s). There should be no need for a 9-1-1 Authority to have individual agreements with all of the public safety agencies making up the adjacent 9-1-1 System(s). We have further clarified this below. "Aid Outside Normal Jurisdictional Boundaries Agreement" means a written cooperative agreement entered into by all participating and adjacent agencies 9-1-1 Authorities with each participating agency and adjacent 9-1-1 system, and public safety agenciesproviding that, once an emergency unit is dispatched to a request through a 9-1-1 system, that unit shall render its services to the requesting party without regard to whether the unit is operating outside its normal jurisdictional boundaries. Additionally, the redundant (definitional) language should be removed on pages 13 and 17 in Part 1324 and on pages 21 and 25 in Part 1325:

The Call Handling and Aid Outside Jurisdictional Boundaries Agreements with each Participating Agency and with each Adjacent 9-1-1 Authority which contains a primary and secondary means of dispatch (i.e. radio frequency/talk group, 10- digit transfer telephone number etc.). Such agreements must also provide that,


once an emergency unit is dispatched in response to a request through the system, such unit shall render its services to the requesting party without regard to whether the unit is operating outside its normal jurisdictional boundaries. Certified notification of the continuation of call handling and aid outside jurisdictional boundaries agreements shall be made among the involved parties on an annual basis.

Auditor Verification Form

Counties < 50,000: Audits performed by the County, 911 is included in this audit. Will agency need to have a separate audit? Will this basically require the ETSB’s to pay for their own audit? Most county fiscal years do not coincide with the calendar year AFR reports. This is excessive oversight. INENA/ILAPCO: Need to discuss this more. Auditors do not know our ETSB requirements. The auditors are there to audit the accounting function not the ETSA. This is going to cause a lot of difficulty and extra expense to systems. Many systems operate on a cash basis and the auditors use an accrual basis

This is a definition rather than the rules regarding how or when audits will be conducted – for additional see 1329.605. The 9-1-1 Systems collectively receive approximately $165M in surcharge money collected by the state. Additionally, approximately 75 of the 9-1-1 Authorities will receive $500,000 or more. Oversight of the expenditure of such taxpayer money is appropriate. Additional discussion regarding the audits will be had during the review of Part 1329.

Automatic Alarm or Automatic Alerting

Device

INENA/ILAPCO: Maybe add comment about mechanical dialer. It is covered in another document but since alarm is listed may want to make a comment as well

There are definitions for both. A mechanical dialer is not an automatic alarm - for additional see 1325.510.

Backup PSAP

INENA/ILAPCO: Costs will be an issue, needs more discussion

This is a definition rather than the rules regarding Backup PSAPs – for additional see 1325.415. "Backup PSAP" means a public safety answering point that serves as an alternate to the PSAP operating independently from the PSAP at a different location, which has the capability to directly dispatch for the PSAP or otherwise transfer emergency calls directly to all participating agencies within the 9-1-1 Authority for whom they are acting as a backup, is at a different location, and operates


independently from the PSAP. A backup PSAP may accept overflow calls from the PSAP or be activated in the event that the PSAP is disabled.

Busy Day and Busy Hour

DuPage: Busy Day and Busy hour should specify “greatest volume of 9-1-1 traffic” because that stat in 9-1-1 Net doesn’t measure 10 digit dial, unless the central office does measure everything going into the PSAP.

"Busy Day" means a consecutive 24-hour period during which the greatest volume of 9-1-1 traffic is handled in the central office. "Busy Hour" means the two consecutive half-hours each day during which the greatest volume of 9-1-1 traffic is handled in the central office.

Call Referral Call Relay

Call Transfer Definitions

DuPage: Call Referral, Relay and Transfer are strike outs – is it your intent to use the language in the chart? It’s a little unclear. St. Clair: These rule changes eliminate the ability to transfer calls to private ambulance services for dispatching their resources and also the ability to provide calls to the Illinois State Police. Saline, Gallatin, & Hamilton: Why remove this definition? Again there are some cases that a transfer is what is needed. What happens when the person calls 911 for their relative states away or at the other end of the state? This is why we have a state wide phone book to make those transfers. INENA/ILAPCO: This is only listed in 1326, but we still do this in PSAP's today. Should this be listed in the other rules as well and not deleted.

The terms - Call Referral, Call Relay, or Call Transfer do not appear in Parts 1324 and 1325; accordingly, the definitions have been removed. The terms - Call Referral, Call Relay, or Call Transfer have been amended in Part 1326. We are eliminating definitions because the terms are not used in the rule. The removal of terms not used does not eliminate the ability to do anything. We have been mindful of this issue as we reviewed the specific regulatory provisions that impact dispatch methods. Accordingly, a definition of Transfer has been added to Parts 1324 and 1325.

COOP INENA/ILAPCO: Will there be a template so all are covering the same information and achieving the same goal of uniformity?

Yes, however, this is a definition so to the extent there will be a template or guidelines, they will be discussed within the rules not the definition – for additional see 1325.400.


Decommissioned

DuPage: Why would we suggest that they transition from a PSAP to a dispatch center? It should just mean the closing of a PSAP. I’m afraid of fighting funding for things like RMS that are proportional/slippery slope if we are acknowledging a link/transition between the two. When you close a PSAP in a PD you basically have records personnel answering phones (some talk on the radio and have access to the CAD system for service requests).

Neither the ETSA nor the Administrative rules regulate a police department’s non-emergency dispatching and many police departments throughout the state continue to serve in this capacity. Local and county police departments are regulated by the Illinois Municipal Code (65 ILCS 5/11 and Illinois Counties Code 55 ILCS 5/3) respectively and their non-emergency dispatch activities are within this jurisdiction rather than the ETSA. We need a term defined to describe the circumstance that exists when a PD closes a PSAP but continues to dispatch non-emergency calls to its officers to make clear the decommissioned entity may no longer receive 9-1-1 calls or funding.

Direct Dispatch

Counties < 50,000: This could cause a conflict with contracts between private ambulance providers and a primary PSAP, which also serves as dispatch. How would this be addressed? For example if we an ambulance call comes into one primary PSAP in the local system, they may have to transfer it to another primary PSAP for dispatch based on requirements of the contract. Saline, Gallatin, & Hamilton: By this rule, if you were to receive a 911 call from another state, then my 911 Authority would have to direct dispatch this call? There needs to be some reasonable approach to this definition and requirement.

This is a definition rather than the rules regarding dispatch methods – for additional 1325.415. We have been mindful of this issue as we reviewed the specific regulatory provisions that impact dispatch methods. Accordingly, a definition of Transfer has been added to Parts 1324 and 1325.

Dispatch Center

Will: Use of term is "Dispatch" inconsistent with common public understanding, common industry usage, and is not consistent with terminology used in associated terms defined in the NENA Master Glossary.

This topic is open for discussion and suggestion. If there is a term other than Dispatch Center to describe a location that does not receive 9-1-1 emergency calls but does perform other non-emergency dispatching and administrative responsibilities, another term could be considered.


Distinct Location Identification

INENA/ILAPCO: This is not a NENA definition, is there a NENA definition that could be used? Maybe Subaddress? Consistency.

This is a definition from 1326 regarding private business switch. This is a legislative issue.

Emergency Call

DuPage: Emergency call – so I’m fine with where we are going – do we need to think about “approved device (as in by the ICC or other form of approval) and is it subject to surcharge. I also think there is a lot in this one definition. You might want to think about having an Emergency call or 9-1-1 Call Duration definition. St.Clair: Now that the timeline of an emergency call has be clearly defined, does this mean we are no longer required to record radio traffic after dispatch or any follow up related calls, as they might not be handled by a PSAP. Will: The two "ands" make the sentence wordy and imply three distinct conditions to be satisfied. In fact, there are two conditions, as call disconnection is dependent upon the TC determination that no further information is required. Reword sentence to read "An emergency call ends when a first responder has been dispatch and the telecommunicator disconnects the call having determined that no further information is required." Counties < 50,000: So do only 9-1-1 Calls qualify as an Emergency? What if a citizen has an emergency and calls the 10-digit line, is it any less of an emergency? A 911 call can come in on a non-emergency line, walk-in, etc. Does not necessarily have to come in through 911 to be an emergency call. INENA/ILAPCO: RTT needs to be added to this as new technology. Or do we just need to say any types of media

We would not define call duration. We would within rules indicate what duration is permissible if this is deemed necessary. Definitions clarify what is meant by a term. They do not create guidelines. The rule requires that “each answering point will have the capability of logging/recording 9-1-1 requests for service including voice, data, video and other media used and must be of adequate capacity to record both sides of a conversation of each incoming emergency call and any radio transmissions relating to the emergency call and its disposition for each answering point.” Accordingly, any radio transmission involving a PSAP, Backup PSAP, Unmanned Backup PSAP, SAP, or VAP that relate to the emergency call and its disposition must be recorded. Radio transmissions that do not involve an entity regulated by 1325.415 are not covered by this rule. ETSA only regulates calls received within the 9-1-1 System. Calls made to a ten digit line are not regulated by ETSA even if they relate to an emergency. Attempting to regulate calls made to a ten digit line could become quite complicated. "Emergency Call" or “9-1-1 Call” means any type of request for emergency assistance through a 9 1-1 network. An emergency call is not limited to a voice telephone call. It could be a two way video call, an interactive text, Teletypewriter (TTY), an SMS, an Instant Message, Real Time Text (RTT), or any new mechanism for communications available in the future. An emergency call


that have the availability to contact 9-1-1? Needs more discussion

begins when the request for emergency assistance is received by a 9-1-1 Telecommunicator. An emergency call ends when a first responder has been dispatched and the 9-1-1 Telecommunicator disconnects the call has having determined no further information is required and disconnects the call.

ETSB Definition

DuPage: My only comment about combining ETSB and Joint ETSB is that they are slightly different animals and have different board requirements. I’m concerned that this may cause confusion later. Maybe we could add “unless otherwise specified” or something like that.

For purposes of our rules the distinction is irrelevant. The definitions within rules does not change the statutory difference in board requirements.

Grade of Service Definition amended in response to concerns regarding P.01 and i3 Grade of Service requirements.

Grade of Service means P.01 for Basic 9-1-1 or Enhanced 9-1-1 services or the NENA i3 Solution standard for NG9-1-1.

Grant Program INENA/ILAPCO: Does the law need to be addressed for NG Grants after 2020?

This is not a regulatory issue. This is a legislative issue.

Network Connections

INENA/ILAPCO: Look at this closely as it discusses surcharge application for payment.

This definition was changed to be consistent with ETSA.

Network Costs

INENA Region 7: Network costs has been modified changing “including” to “which may include”. Will this reflect in the State Administrators Office authority to pay some cost? INENA/ILAPCO: No detailed costs of NG listed and they should be as there will be one time costs installing the network, and recurring costs. The money set aside for the state network will probably include the one time charges so that should be allowed for the systems that are currently working or up and running

The change was made for consistency and is non-substantive. It does not impact the application of the definition. NG-911 Costs are included and the term is defined. Payment of one-time costs for installation are expressly prohibited – network costs must be recurring pursuant to ETSA.

NG9-1-1 Costs

INENA/ILAPCO: Removed from Part 1325. Where is this covered in detail if this is removed?

This was in error. It will be replaced. "NG9-1-1 costs" means those recurring costs that directly relate to the Next Generation 9-1-1 service as determined by the Statewide 9-1-1 Administrator with the advice of the


Statewide 9-1-1 Advisory Board, includingwhich may include, but need not be limited to, costs for NENA i3 Core Components (Border Control Function (BCF), Emergency Call Routing Function (ECRF), Location Validation Function (LVF), Emergency Services Routing Proxy (ESRP), Policy Store/Policy Routing Functions (PSPRF) and Location Information Servers (LIS)), Emergency System Routing Proxy (ESRP), Emergency Call Routing Function/Location Validation Function (ECRF/LVF), Spatial Information Function (SIF), the Border Control Function (BCF), and the Emergency Services Internet Protocol networks Statewide ESInet, software external to the PSAP (data collection, identity management, aggregation, and GIS functionality), and Gateways (legacy 911 tandems and/or gateways)s), legacy network gateways, and all associated fees, taxes, and surcharges on each invoice.

P.01 INENA/ILAPCO: Why are there no discussions about NG but we are leaving old legacy requirements in? This will go away with NG

This is a definition rather than the rules regarding standards of service – for additional 1324.200 and 1325.205.

Pseudo Automatic Number

Identification or “pANI”

ITA: The definition of pANI should be revised as follows to reflect the fact that in some cases pANI is used to support VoIP, as well as wireless, 9-1-1 calls: “Pseudo Automatic Number Identification” or “pANI” means a telephone number used to support routing of wireless and in some cases VoIP 9-1-1 calls. It may identify a wireless cell, cell sector or PSAP to which the call should be routed, also known as a routing number. INENA/ILAPCO: Add Pani definition from NENA glossary?

This is the definition from the NENA glossary; however, we agree the addition of VoIP would be beneficial. "Pseudo Automatic Number Identification" or "pANI" means a telephone number used to support routing of wireless and in some cases VoIP 9-1-1 calls. It may identify a wireless cell, cell sector or PSAP to which the call should be routed, also known as routing number.

SAP DuPage: Are they required to have ANI/ALI, it’s not clear. If it’s unclear because of ISP, then just include ISP as existing.

This is a definition rather than the rules regarding SAPs. This could/should be addressed in 1325.415.


INENA/ILAPCO: Can these be added after the legislation from 2016 and who pays for the network?

"Secondary Answering Point" or "SAP" means a location, other than a PSAP, that is able to receive the voice, data ALI and call back number ANI of emergency calls transferred from a PSAP and completes the call taking process by dispatching the appropriate public safety agencies.

Transfer

Adding a definition to clarify methods remaining in response to concerns raised.

"Transfer" means a 9-1-1 service in which the 9-1-1 Telecommunicator, who receives an emergency call, transmits or conferences the incoming call to the appropriate authorized entity. Transfer shall not include a relay or referral of the information or caller.

Unmanned Backup PSAP

INENA/ILAPCO: Can an unmanned PSAP be added? Again, this is a definition rather than rules regarding unmanned backups. This could/should be addressed in 1325.415. “Unmanned Backup PSAP” means a public safety answering point that serves as an alternate to the PSAP, is typically unmanned but can be activated if the primary PSAP is disabled, and is at a different location and operates independently from the PSAP.

Waiver

INENA/ILAPCO: Why was SAB dropped from this? The legislation does not include the SAB in the waiver process, the change was made to make the rules consistent with the statute. Currently, waivers are within the purview of the Administrator and not the Board. Section 15.4a (c) provides “A waiver from a consolidation required under subsection (a) of this Section may be granted if the Administrator finds that the consolidation will result in a substantial threat to public safety, is economically unreasonable, or is technically infeasible.” Adding the SAB to this process will need to done legislatively.



1324.200(b)(3)

DuPage: Why are we adding language for dispatch center? If it’s not 9-1-1 or an emergency from a required 10 digit dial, then it’s a call for service. Its front counter. We have records personnel that can talk on the radio and ask officers to respond to the station or a bank run – that doesn’t make it a dispatch center. St.Clair: The intent of this legislation was previously verified by members of the advisory board, NENA and APCO and approved by the original legislation. This change is now taking us backwards and presenting additional challenges for 911 authorities and PSAPS. Counties <50,000: I am looking for further clarification. In our case the PSAP is at the PD we currently verify the information, and transfer the call either the Sheriff’s Office or the State Police depending on the situation. I believe there needs to be local control on how an agency wants to receive the call. What happens when an emergency call comes in on a non-emergency line to a Dispatch Center that is not authorized to directly dispatch emergency calls?

We are not adding language for dispatch centers. The term was previously used inconsistent with its application in the industry. Dispatch Centers exist and accordingly must be addressed through rules to ensure uniformity – emergency calls are not to be transferred to them and 9-1-1 monies cannot be used to support them. We are formalizing their separation from the statewide 9-1-1 system. While various members of the advisory board have commented on their understanding of the intent of the legislation, these comments do not control. Legislative intent would apply if the plain language of the statute is in conflict or is otherwise ambiguous. In this instance, it is not. Legislative amendments would be needed to address this issue. A call to a non-emergency line is not a 9-1-1 call and is not regulated by ETSA or our rules. (b) Counties and 9-1-1 Authorities:

(3) May not convert PSAPs to SAPs, or VAPs to avoid the requirements for consolidation in ETSA Section 15.4(a); however, PSAPs that are closed may continue to function as a Dispatch Center. The authorized PSAPs remaining after consolidation shall directly dispatch all emergency calls and shall not transfer, refer, or relay those calls to an a Dispatch Center. Nothing in this subsection (b)(3) shall be construed to mean a PSAP, SAP, or VAP cannot also perform its Police, Fire or EMS administrative and non-emergency responsibilities.

The authorized PSAPs remaining after consolidation shall direct dispatch all emergency calls and shall not transfer, refer, or relay those calls to a Dispatch Center. Only transfers to the Department, the SAPs shown on a network


diagram, or private emergency providers listed as a participating agency are permitted and must be documented as the dispatch method to be used in the applicable call handling agreements. Nothing in this subsection (b) shall be construed to mean one PSAP cannot transfer emergency calls to another PSAP.

1324.200(c)(1)(D)

DuPage: “which ones will be decommissioned, and which ones will be closed” – redundant, how agencies that were decommissioned or closed will now be dispatched for emergency calls and non-emergency calls. So – the agency is not decommissioned or closed, the PSAP will be so maybe it should read: “how agencies of the decommissioned or closed PSAP will now be . . . “ Also, if we open the door to non-emergency calls, we are getting into the more public perception of what the PSAP does and this then lends itself to expanding the role of the PSAP and (in the future) of a “dispatch center”.

As part of a consolidation, the 9-1-1 Authority has to identify which PSAPS will remain operational, be decommissioned, and be closed. We need to know about all three… because if they are still dispatching non-emergency calls, they are not closed, but they cannot be considered part of the system. This information is directly relevant to the use of surcharge.

1324.200(c)(1)(I)

Counties <50,000: We never did know what VoIP providers were on our system unless we received a revenue check from them, which some were once a year for under $20. Does State have a system for tracking VoIP providers?

The State does not regulate or have any ability to track VoIP providers. The rule specifically states the applicant is to provide a list of providers who are known by the applicant. Further, the State cannot track carriers (other than wireless) by system.

1324.200(c)(1)(J)(ii)

DuPage: The language regarding wireline – auditing of surcharge money as it relates to wireline surcharge monies pursuant to ETSA Section 30 … and wireless – okay perhaps we should just include an agreement check box or something that is incorporated into the form. 1 for consistency, 2 to make sure that money is moved at the time the application is approved.

The money is not treated the same under ETSA. As entities continue to move from one jurisdiction to another, which we have no authority to prohibit, we have to have rules to regulate it.

1324.200(c)(1)(J)(iv)

Amended based on Direct Dispatch concern raised. iv) The backup PSAP Agreement that establishes backup and overflow services between 9-1-1 authorities or PSAPs within those authorities, which must detail and confirm the backup PSAP’s capability to directly dispatch or otherwise


transfer emergency calls directly to all participating agencies within the 9-1-1 Authority for whom they are acting as a backup;

1324.200 (c)(1)(J)(v)

DuPage: I think it would be helpful if it stated that the providers were responsible to submit this. ITA: This subsection imposes a requirement to include as an attachment to an application for a long form 9-1-1 consolidation plan, a network diagram provided by the 9-1-1 system provider. The language of the proposed modification of this subsection should be revised to remove the reference to “P.01.” The ITA provides several reasons for deleting the reference. Counties <50,000: Language should also include i3 components. INENA/ILAPCO: More explanation is needed in order for the systems to understand. Talking NG language, but not talking about NG requirements just legacy P.01

We don’t regulate providers. We regulate the 9-1-1 Authorities. We agree with the ITA this could be removed as it is a grade of service standard for carriers. (v) A network diagram that is provided by the 9-1-1 system provider showing a list of all interconnecting carriers transporting all 9-1-1 traffic from the end user to the PSAP and all system components including ingress and egress. It should provide the P.01 trunking, interconnection points, routing and backup configuration for the 9-1-1 system, as well as SAPs and Unmanned Backup PSAPs; Additionally, the following will remain and not be deleted. 1324.200 (d) The consolidation plan must meet the applicable Grade of Service.

1324.200(c)(1)(J)(vi)

Amended based on Aid Outside Jurisdictional Boundaries Agreement discussion in definitions.

The Call Handling and Aid Outside Jurisdictional Boundaries Agreements with each Participating Agency and with each Adjacent 9-1-1 Authority which contains a primary and secondary means of dispatch (i.e. radio frequency/talk group, 10- digit transfer telephone number etc.). Such agreements must also provide that, once an emergency unit is dispatched in response to a request through the system, such unit shall render its services to the requesting party without regard to whether the unit is operating outside its normal jurisdictional boundaries. Certified notification of the continuation of call handling and aid outside jurisdictional boundaries agreements shall be made among the involved parties on an annual basis.


1324.200(c)(1)(K)

Counties <50,000: Test plan requires testing with VoIP providers. We never did know for sure what VoIP Providers were in our County unless we received a check from them. Does State have a way to track VoIP providers? INENA/ILAPCO: How are we going to measure these? Will there be a template? Are all the voice loggers able to measure this and prove this? Many times the phone calling is poor quality and the systems don't have control over that.

The State does not regulate or have any ability to track VoIP providers. Testing is to determine if there are problems within the system. It is in the 9-1-1 Authorities best interest to test as thoroughly as possible. The rule is to ensure the networks are tested appropriately. Test plans are not new, and there is guidance within the application. (K) A Test Plan, which is the 9-1-1 system's overall plan detailing testing with all wireline and wireless carriers and VoIP providers, who are known, including but not limited to, the 9-1-1 database, network trunking, system overflow, system backup, default routing and transfers. A test plan for NG911 should address components and functionality of the NG911 System’s implementation including but not limited to call testing, SMS, API Integration, measurement tools and reporting solution as well as voice and speech quality.

1324.200(c)(2)(E)(i)

Amended based on Direct Dispatch concern raised. (i) An updated backup PSAP Agreement that establishes backup and overflow services between 9-1-1 authorities or PSAPs within those authorities, which must detail and confirm the backup PSAP’s capability to directly dispatch or otherwise transfer emergency calls directly to all participating agencies within the 9-1-1 Authority for whom they are acting as a backup;

1324.200(c)(2)(F)

INENA/ILAPCO: Explain how does the 911 system get this information as required in this statement.

When converting to a new network, the 9-1-1 Authorities must have a means of communicating the switch with Businesses within their 9-1-1 System to ensure their calls do not continue to go to the old network.


This requirement is that the 9-1-1 Authority document how they intend to communicate the change of network to Businesses within their 9-1-1 System.

1324.200(c)(2)(H)

INENA/ILAPCO: This is a major item that needs to be explained to the systems what this means to provide this information.

Cindy will address this in greater detail at the Board Meeting; however, for further information, please refer to: • NENA 04-503, NENA Technical Information Document

Network/System Access Security Issue 1, December 1, 2005

• DoIT’s Cybersecurity Guidelines • NENA Security for Next-Generation 9-1-1 Standard

(NG-SEC) NENA 75-001, Version 1, February 6, 2010 • NENA Next Generation 9-1-1 (NG-SEC) Audit Checklist

NENA 75-502, Version 1, December 14, 2011 • NENA NG9-1-1 Security Information Document NENA-

INF-015.1-2016 12/08/2016

1324.200(c)(3) INENA/ILAPCO: Isn't this the verification form and do we need the definition?

Yes, it is the verification form. We only need to define it if there is confusion regarding what is required.

1324.200(c)(3)(D)

Counties <50,000: Why would we dispatch non-emergency calls? Why couldn’t we relay non-emergency calls by telephone or other means. INENA/ILAPCO: Does everyone agree with this? More discussion needed.

Each ETSB does it differently. This is what we are trying to determine. This is seeking information and does not prohibit any particular method of dispatch. If the method of dispatching non-emergency calls is transfer, that is what will be included in the narrative.

1324.200(c)(3)(E)(i)

Counties <50,000: As mentioned in other comments concerning direct dispatching multiple backup agencies like firefighters, medics, officers would be very complicated, cost prohibitive for radio setup, and would greatly interfere with the original agency’s flow of handling incident. INENA/ILAPCO: New requirement. Are all systems aware of this?

The rule requires the ability to direct dispatch but does not prohibit any particular method of dispatch. For example, in a rollover or overflow situation, it may be appropriate to transfer.

i) An updated backup PSAP Agreement that establishes backup and overflow services between 9-1-1 authorities or PSAPs within those authorities, which must detail and confirm the backup PSAP’s capability to directly dispatch


or otherwise transfer emergency calls directly to all participating agencies within the 9-1-1 Authority for whom they are acting as a backup

1324.200(c)(3)(E)(ii)

Counties <50,000: This has P.01 trunking, but also needs “i3 components” added for Next Gen. INENA/ILAPCO: Talking NG language but only talk P.01 and not NG Requirements

We agree the reference to P.01 will be removed. Both enhanced and NG service will continue to exist. A network diagram that is provided by the 9-1-1 system provider showing a list of all interconnecting carriers transporting all 9-1-1 traffic from the end user to the PSAP and all system components including ingress and egress. It should provide the P.01 trunking, interconnection points, routing and backup configuration for the 9-1-1 system, as well as SAPs, and Unmanned Backup PSAPs; Additionally, the following will remain and not be deleted. 1324.200 (d) The consolidation plan must meet the applicable Grade of Service.

1324.200(c)(3)(E)(iii)

INENA/ILAPCO: Are these required if the consolidation is a consolidation within a county and agreements do not change?

Yes. Anytime a new plan is filed, the call handling agreements need to be included. New Call Handling and Aid Outside Jurisdictional Boundaries Agreements with each Participating Agency and with each Adjacent 9-1-1 Authority pursuant to Section 1324.200, J), vi), if applicable. This rule will be changed in 1325 as well to make clear that every plan filing must include all call handling agreements to ensure there is a complete and accurate record in the file upon which an order of authority is based.

1324.200(f)

St.Clair: How can we have previously made all the 911 authorities present their waivers to the 911 advisory board and now we are going to allow single person to be responsible for the decision with no oversight.

The change is specifically proposed because it is consistent with the legislation. Waivers are within the purview of the Administrator and not the Board. Section 15.4a (c) provides “A waiver from a consolidation required under subsection


INENA/ILAPCO: Why do the vendors need to review? A technical review by the commission, the governing body, should suffice. This information is giving them a look at what the system is doing and they may not be a part of the plan, giving away possible network plans etc.

(a) of this Section may be granted if the Administrator finds that the consolidation will result in a substantial threat to public safety, is economically unreasonable, or is technically infeasible.” Carriers should have the ability to review the network architecture to ensure they have no issues with the plan prior to approval. Because not all carriers are regulated by the State, it is possible there is information included in the plan that is of concern but the State will not know without Carrier input.

1324.200(g)(3)(A)

Counties <50,000: Why has language been removed for posting waivers, consolidation plans and Department’s review on its website? These were helpful for SAB Hearings on consolidation and possibly other upcoming situations.

The plans and waivers are posted under 1324.200(f) and 1324.200(i) so this was redundant. They will still be posted.

1324.200(i) INENA/ILAPCO: What about the SAB? The legislation does not include the SAB in the waiver

process, the change was made to make the rules consistent with the statute.

1324.210(d)

Counties <50,000: Why is a 2 day notice required to speak at public hearing? This would possibly exclude potential valuable input if unusual circumstances were to arise. INENA/ILAPCO: This is new. Why not staying with the way it has been handled as it has worked very well.

To provide structure to the Board hearing process as we attempt to move away from ALJ hearings in non-contested situations.

1324.220 Counties <50,000: Language was deleted from this draft that previously gave SABs the opportunity to provide input for waivers.

The legislation does not include the SAB in the waiver process, the change was made to make the rules consistent with the statute.


Part 1325

DuPage: What is with the limitation on the ETS Board make up. Overall we have worked hard to standardize and consolidate, DuPage specifically has spent years working through a model that works for DuPage. That was accomplished by creating a balance of power – this would severely limit a county’s ability to effectively manage the surcharge which is their fiduciary responsibility. Instead of limiting the board in this manner, make the boards an even number, require a consensus of a super majority.

To the extent this comment pertains to 1325.305, this is from the statute and was added to help people understand what the language meant. Nothing changes even if we remove it as these are the requirements of Section 15.4 of ETSA.

Part 1325

DuPage: How do you define a public safety agency? This is directly from the ETSA and is included in Part 1325: "Public Safety Agency" means a functional division of a public agency that provides police, firefighting, medical or other emergency services to respond to and manage emergency incidents.

1325.105

INENA/ILAPCO: Review this and discussion needed. When 9-1-1 Authorities do not comply with the requisite standard of service, there needs to be a framework for gaining compliance without going directly to revoking an order of authority. As we move toward Statewide NG911, this framework becomes even more important.

1325.200(c)

Counties <50,000: What is “proportionate” expense formula for outbound notification systems? 50/50, 95/5? INENA/ILAPCO: How is this going to be determined and what are the criteria, needs to be spelled out.

Proportionate means - the correct or suitable amount when considered in relation to the other uses. There is no way to spell this out. It is not exact and must rather be determined on a case by case basis between the ETSB and public agency that would share in the use of equipment and expense.

1325.200(h)(1) INENA/ILAPCO: Explain the difference between long form for the network.

Network Configuration refers to things like call routing and trunking.

1325.200(h)(3)

Saline, Gallatin, & Hamilton: Why is there a need to send adjacent agreements? These agreements are on file numerous times and in the current form, do not have a relationship with the back-up center. But in 1325.205 (page 25 letter B) the rule states here of they have already been filed?

The rule is being changed consistent with Part 1324 to make clear that every plan filing must include all call handling agreements to ensure there is a complete and accurate record in the file upon which an order of authority is based.


1325.205

Counties <50,000: Will the state have a minimum guideline for cyber security? I can foresee some systems using a “free” virus protection, and others using an expansive service. I would like to see a minimum level set.

Yes, the State will follow DoIT’s Cybersecurity Guidelines and NENA Security for Next-Generation 9-1-1 Standard (NG-SEC) NENA 75-001, Version 1, February 6, 2010, which will be available on the 9-1-1 website. See discussion regarding 1325.515 below.

1325.205(b)(9)

INENA/ILAPCO: We have no way of knowing this information as the state receives the checks now and that is how the systems knew who was providing service in their county/system. The state will have to provide this information to the systems.

The State does not regulate or have any ability to track VoIP providers. The rule specifically states the applicant is to provide a list of providers who are known by the applicant. Every effort should be made to ensure that all interconnected VoIP providers who are advertising and offering service in your 9-1-1 jurisdiction are sending their 9-1-1 calls through the 9-1-1 network.

1325.205(b)(10)(D)

Amended based on Direct Dispatch concern raised. The backup PSAP Agreement that establishes backup and overflow services between 9-1-1 Authorities or PSAPs within those Authorities, which must detail and confirm the backup PSAP’s capability to directly dispatch or otherwise transfer emergency calls directly to all participating agencies within the 9-1-1 Authority for whom they are acting as a backup;

1325.205(b)(10)(E)

INENA/ILAPCO: Show the data centers for the provider but not providers name. Again referencing to P.01 grade of service.

We agree the reference to P.01 will be removed. Both enhanced and NG service will continue to exist. (E) A network diagram that is provided by the 9-1-1 system provider showing a list of all interconnecting carriers transporting all 9-1-1 traffic from the end user to the PSAP and all system components including ingress and egress. It should provide the P.01 trunking, routing and backup configuration for the 9-1-1 system as well as SAPs and Unmanned Backup PSAPs; Additionally, the following will be added. 1325.205(d) The initial or modification plan must meet the applicable Grade of Service.


1325.205(b)(10)(F)

INENA/ILAPCO: Should this statement be in consolidation plan also?

No. In fact, this rule is being changed consistent with Part 1324 to make clear that every plan filing must include all call handling agreements to ensure there is a complete and accurate record in the file upon which an order of authority is based. (F) The Call Handling and Aid Outside Jurisdictional Boundaries Agreements with each Participating Agency and with each Adjacent 9-1-1 Authority which contains a primary and secondary means of dispatch (i.e. radio frequency/talk group, 10 digit transfer telephone number etc.). Such agreements must also provide that, once an emergency unit is dispatched in response to a request through the system, such unit shall render its services to the requesting party without regard to whether the unit is operating outside its normal jurisdictional boundaries. Certified notification of the continuation of call handling and aid outside jurisdictional boundaries agreements shall be made among the involved parties on an annual basis. If filing a Modification Plan or NG9-1-1 Plan, pursuant to this section whereby these agreements have already been provided in a previous plan, only agreements that are impacted by a change will be required as a part of the plan.

1325.205(b)(11)

INENA/ILAPCO: Again we will not know the providers. The State does not regulate or have any ability to track VoIP providers. Testing is to determine if there are problems within the system. It is in the 9-1-1 Authorities best interest to test as thoroughly as possible. The rule is to ensure the networks are tested appropriately. A Test Plan, which is the 9-1-1 system's overall plan detailing testing with all wireline and wireless carriers and


VoIP providers, who are known, including, but not limited to, the 9-1-1 database, network trunking, system overflow, system backup, default routing, and call transfers

1325.205(b)(12)(E) INENA/ILAPCO: What if this doesn't changed? what will be needed to explain?

Even if it does not change, there will be a new provider so the split exchanges have to addressed to ensure the order of routing has been determined.

1325.205(b)(12)(F)

INENA/ILAPCO: Again, more detail needed as the systems don't have access to this data.

When converting to a new network, the 9-1-1 Authorities must have a means of communicating the switch with Businesses within their 9-1-1 System to ensure their calls do not continue to go to the old network. This requirement is that the 9-1-1 Authority document how they intend to communicate the change of network to Businesses within their 9-1-1 System.

1325.205(b)(12)(G) INENA/ILAPCO: What kind of detail? Example or form needed if to be completed.

Cindy will discuss at the Advisory Board Meeting.

1325.205(c)(2) INENA/ILAPCO: Is this not the verification form? Yes, it is the verification form. We only need to define it if there is confusion regarding what is required.

1325.205(c)(5)(A)

INENA/ILAPCO: More discussion as who will fund the costs?

The backup PSAP Agreement that establishes backup and overflow services between 9-1-1 Authorities or PSAPs within those Authorities, which must detail and confirm the backup PSAP’s capability to directly dispatch or otherwise transfer emergency calls directly to all participating agencies within the 9-1-1 Authority for whom they are acting as a backup;

1325.205(c)(5)(B)

INENA/ILAPCO: Again, P.01 but not NG requirements mentioned.

We agree the reference to P.01 will be removed. Both enhanced and NG service will continue to exist. A network diagram that is provided by the 9-1-1 system provider showing a list of all interconnecting carriers transporting all 9-1-1 traffic from the end user to the PSAP and all system components including ingress and egress. It should provide the P.01 trunking, routing and backup


configuration for the 9-1-1 system as well as SAPs and Unmanned Backup PSAPs;

1325.205(c)(5)(C)

This rule is being changed consistent with Part 1324 to make clear that every plan filing must include all call handling agreements to ensure there is a complete and accurate record in the file upon which an order of authority is based.

The Call Handling and Aid Outside Jurisdictional Boundaries Agreements with each Participating Agency and with each Adjacent 9-1-1 Authority required pursuant to Section 1325.210(b)(10)(F). If existing agreements have already been provided in a previous plan, only agreements that are impacted by a change will be required as a part of the plan.

1325.205(c)(6)

INENA/ILAPCO: Voip carriers unknown, data centers will be the only known item.

The State does not regulate or have any ability to track VoIP providers. A test plan, which is the 9-1-1 system's overall plan detailing testing with all wireline and wireless carriers and VoIP providers, who are known, including, but not limited to, the 9-1-1 database, network trunking, system overflow, system backup, default routing, and transfers

1325.205(d)

Added regarding Grade of Service requirements (d) The initial or modification plan must meet the applicable Grade of Service. Cindy can speak to this in greater detail during the Board Meeting.

1325.215 (a)(1)

Saline, Gallatin, & Hamilton: Requires a log of major system activities? Define Activities? What activities should be logged?? INENA/ILAPCO: Need an example of what data you are seeking or wanting.

This is not new. Each PSAP should log equipment failures/outages, 9-1-1 System outages and major events that occur (natural disaster, fire, fatal accidents). A log can be maintained by each shift, daily or monthly.

1325.220

Amended to make clear the participating agencies are subject to site visits to verify compliance with all standards, including but not limited to training standards.

The Department and Administrator shall have the authority to conduct a site visit with 9-1-1 systems Authorities, including but not limited to its PSAPs and participating agencies, to verify compliance with technical and operational standards set forth in the Act and in this Part.


1325.305

Saline, Gallatin, & Hamilton: The word “shall” should be reconsidered for some positions – i.e. a requirement for a county board member being shall should be changed to may. Most ETSB's are appointed by a county board and the rules allow for an elected official. In addition some ETSB's are municipal, why should a county board member have a direct seat on a municipal board? Joint ETSB's could have a board made up multiple county board members, which then become an issue as is it a county board meeting or a 911 meeting? In letter d. A PSAP representative should be may and not shall as well as an option. Not mandated Norcomm: Is the change in (a)(2) for County ETSBs? If yes, IMHO this is not made clear. I realize 15.4 of ETSA describes in great detail the make-up of the Board, but I think the rule needs to be more clear and concise. Unless the intent is to have a County Board Member on every ETSB, then the rule is very clear. However, if it is the intent to the have a County Board Member on every ETSB throughout the State, I would be opposed to this rule.

There is no requirement within the rule or statute that requires a County Board member… the rule says not more than 1, which means equal to or less than one (i.e. one or zero). With respect to the PSAP representative, this is mandated by ETSA. No more than 1 means equal to or less than 1 (or 0). The following language is proposed to clarify since there still appears to be confusion.

a) Pursuant to Section 15.4 of ETSA, each ETSB shall consist of not fewer than five members and shall be comprised as follows: 1) Not fewer than 5 members; 2) At least 1, who is a member of the public and a

resident of the 9-1-1 System; and 3) No more than 1, who is a member of the county

board within the 9-1-1 System; and 3) At least 3, who are representatives of the 9-1-1 public

safety agencies within the 9-1-1 System. While a member of the county board within the 9-1-1 System is not required, if a county board member is appointed to the ETSB, there shall be no more than 1.

b) Any of the members of the ETSB, including but not

limited to the county board member may be elected officials so long as they meet the provisions established in paragraph a).


c) The ETSB may consist of more than five members so long

as the additional members do not cause the ETSB to exceed the limitation established in paragraph a)2).

d) Joint Emergency Telephone System Boards shall include

as member(s) at least 1 PSAP representative from the 9-1-1 System.

1325.400(h) INENA/ILAPCO: Again a standard form for all systems in order to provide consistency.

The Administrator intends to provide a template for the COOP and make it available on the website.

1325.400(n) INENA Region 7: How will 911 management ensure SSP’s are in compliance?

Can you explain to be clear what is meant by your question?

1325.415

St. Clair: This says that in the event of a roll over we would be required to answer and directly dispatch an emergency call at a backup PSAP. This would create an extremely unsafe situation as the Primary PSAP could be handling something such as an active shooter or burglary in progress in which their radio traffic is restricted and the backup PSAP is unaware and ultimately interrupts the ongoing incident.

I do not find where it says this. The issue regarding Direct Dispatch have been addressed in subsections (g) and (i) below.

1325.415(e)

Saline, Gallatin, & Hamilton: CPE shall be designed to achieve transfers...... You have deleted the term transfer, but here it is a requirement to receive a transfer? Looks like the transfer issue needs to be left in the definitions.

We deleted the term “Call Transfer” because it is not used within the rule. A definition for Transfer has been added as discussed in the Definitions section.

1325.415(f)

INENA Region 7: Will the training requirement be monitored at a State Directors level? Many 911 authorities cannot mandate telecommunicator training.

The training requirements for 9-1-1 telecommunicators will be spelled out in the Rules. These are mandates from the State of Illinois by law. In order to be part of the Statewide 9-1-1 System, PSAPs will have to meet the standards. Employers will be required to track the training of 9-1-1 Telecommunicators as compliance will be subject to review during site visits.

1325.415(g) INENA Region 7: Does “fully equipped” answering positions mean all positions shall be manned? Does this mean that all Counties of Southern Illinois (CSI) PSAP’s must have

Fully equipped was not intended to mean that all answering positions must be manned.


capability to “direct dispatch” to all 11 Counties? Many telecommunicators are not under the authority of 911 ETSB’s, making compliance with this rule difficult and in some cases impossible. Counties <50,000: It’s already required that PSAPs have a Backup PSAP, which would be a given that two telecommunicators are currently available to take the 9-1-1 call, so why is this seemingly unnecessary language included in the rules? Saline, Gallatin, & Hamilton: Two telecommunciators on duty will be funded how? There are very few 911 only dispatch centers and call volumes at times do not allow for two telecommunciators on a shift without additional compensation for them occupying a chair. Even then they have to be paid, and using a formula of how much times a telecommunciator was answering a call is not valid as you have to be ready for a call. Which is time waiting on a 911 call and requires compensation. INENA/ILAPCO: This section is using descriptions that were dropped from the definitions.

Again, we deleted the term “Call Transfer” because it is not used within the rule. (g) At a minimum, each PSAP and SAP shall have at least

two fully equipped answering positions. Emergency calls shall be directly dispatched, or transferred, relayed, or referred to an authorized answering point. Overflow emergency calls shall be routed to a backup PSAP as provided for in subsection (i). (1) A minimum of two 9-1-1 Telecommunicators must

be on duty and available to receive and process calls at all times. The Backup PSAP fulfills this obligation insofar as the Backup PSAP can directly dispatch or otherwise transfer emergency calls directly to all participating agencies within the 9-1-1 Authority for whom they are acting as a backup.

1325.415(g)(1)

INENA/ILAPCO: These paragraphs are putting requirements on agencies that goes beyond the 91-1- law responsibility. These are decisions on the people running the PSAP.

See language immediately above.

1325.415(g) and(i)

Counties <50,000: As it relates to directly dispatching for primary and backup PSAP’s… I agree with keeping the number of transfers to a minimum, but, especially in rural areas, it is operationally and cost prohibitive to be able to directly dispatch each and every agency. This may be well

(i) Each 9-1-1 system shall have a Backup PSAP that must operate independently from the PSAP to provide call answering in the event of overflow and/or an emergency. The Backup PSAP must have the capability to directly dispatch or otherwise transfer emergency calls directly to all participating agencies within the 9-1-1


intentioned in large metro areas, but in rural areas is not feasible. I have a number of objections to this. INENA/ILAPCO: Costs will be an issues, needs further discussion.

Authority for whom they are acting as a backup the appropriate public safety agencies for that 9-1-1 system. A Backup PSAP shall meet the same standards as the primary PSAP

1325.415(i)(2) INENA/ILAPCO: Can they be added and does a plan need to be filed to add?

The issue for discussion is who will pay for them.

1325.415(m)

INENA/ILAPCO: Why not under load? This was amended in an effort to address concerns raised in front of the SAB previously. All PSAP’s should follow Section 2.1 – Infrastructure from the NENA Drills and Exercises Information Document NENA-INF-026.2-2018, April 5, 2018.

1325.415(o)

INENA/ILAPCO: Maybe instead of the word secrecy, use the word confidentiality instead, especially in a government document?

This is not a new provision. Answering point employees shall be instructed to be efficient and courteous in the handling of all emergency calls and to comply with the provisions of all applicable federal and State laws in maintaining secrecy confidentiality of communications.

1325.415(t)

INENA/ILAPCO: Do we need to add NG terms also? These are examples, it is not intended to be all-inclusive. (t) All data essential to the operation of the answering point should have a backup available. Examples of data essential to the operation of the answering point include the Master Street Address Guide (MSAG), automatic location identification (ALI), GIS Layers in support of geospatial routing, computer aided dispatch (CAD), call detail activity and customer premise equipment (CPE) data. The 9-1-1 Authority is responsible for insuring that periodic backups are executed and logged. At least one backup should be stored off-site. Any off-site storage should comply with all security requirements.


1325.415(w)

INENA Region 7: Data analysis reports are not available to many 911 PSAPs at this time to track administrative calls, non-emergency calls, roll over count, abandoned calls. Counties <50,000: The answering point employee’s do not report to the 911 Coordinator; they are not my employees. Saline, Gallatin, & Hamilton: Reporting of such calls is not available for all these records from either the audio recordings, or CPE equipment at this time. Or is not broken down by category as in 1 / 2 / 3. How do u capture the transfers to? Why does the Administrator need to know the number of Administrative calls, that don’t come through the CPE? Non-Emergency calls are subjective, as to what is an emergency to one person or agency is not an emergency to another person or agency. INENA/ILAPCO: All these wants will depend on the vendor of the CPE or the voice logger. If all required then there will be costs involved upgrading these, it they are even available. This needs more explanation as this can be interpreted many ways.

This does not refer to multimedia recordings. The 9-1-1 System’s MIS tracks call data. Refer to Section 5.19 Management Information System (MIS) from NENA-STA-027.3-2018 ANSI Approved: 07/02/2018

It is desirable that the PSAP incorporate a Management Information System (MIS). At a minimum, the MIS SHALL be capable of tracking incoming calls and provide PSAP management personnel with real-time information and strategic management reports. It is desirable that the MIS also be capable of tracking outgoing calls and provide the same level of reporting capabilities as the incoming calls described above. It is desirable that the MIS include a summary report that provides the following information: • Number of total calls received • Number of abandoned calls • Number of calls per trunk • Number of calls per call type • Number of calls transferred • Number of calls per position • Average time to answer • Average length of call • Average hold time • ACD Queue call statistics, if ACD system is used It is desirable that the MIS be flexible to allow a PSAP manager to produce reports on an as-needed basis or scheduled for various time periods (per shift, operator, hour, day, week, month, etc.). It should be noted that if multiple, independent MIS reporting systems are deployed at a PSAP, the information from each system may not be consistent in comparison with each other.


(w) Each answering point shall comply with any data request received from the Administrator and will at a minimum collect, analyze and report the following statistics, to the extent they are available:

1325.420(a) INENA/ILAPCO: Does everyone agree with this, needs more discussion.

This is open for discussion.

1325.425

St.Clair: How can you expect the 911 authority to submit readiness to connect to the statewide NG 911 network, when the state has not selected a vendor nor a technology that will carry the data

These rules are specifically contingent upon the implementation of the Statewide NG9-1-1 Network. Before there can be implementation, the state will have selected a vendor and technology.

1325.425(a) INENA/ILAPCO: What is a readiness plan? is it the NG plan filing?

No, it is a checklist, which came from the FCC working groups on NG911. There will be a form for this that will be made available.

1325.425(a)(2)

INENA/ILAPCO: What is PSAP readiness? It is a state of preparedness to ensure the PSAPs are actually ready to connect to the statewide system and includes i3 capable call handling equipment, multimedia recording system, and the required GIS layers to support geospatial routing.

1325.425(a)(3) INENA/ILAPCO: All systems need to know this as it is a new item.

These are NG9-1-1 Standards and are all new.

1325.425(h)(1)

INENA/ILAPCO: When will these start being required? Where will the courses/testing be offered? Is there a particular vendor that will be used? This will be an additional cost to ETSB for these certifications.

All 9-1-1 Authorities have already been asked to and have designated Stewards and Maintainers. Training is ongoing. Cindy will provide further explanation at the Board meeting.

1325.500(c) INENA/ILAPCO: Does the current MSAG to ALI compare for VoIP/Interconnected carriers that are not housed in their database of the SSP

We need further clarification.

1325.505(c)

Counties <50,000: If it is the Sheriff’s department call is left to them to fill out, the Telecommunicators in the 911 center / Flora Police Dept employees do not put dispositions on their calls.

The reference to disposition means how the call was handled not what the law enforcement disposition was.


1325.505(e)(2)

Counties <50,000: The 911 dispatchers are city employees and the 911 authority has no control over the dispatchers.

This is required by statute. Further, Section 1325.100 Application of Part, provides that “this Part shall apply to all public agencies, public safety agencies, public safety answering points and 9-1-1 Authorities. This Part also pertains to 9-1-1 service regardless of the technology provisioned by the 9-1-1 system provider and 9-1-1 Authority for the delivery of 9-1-1 service.”

1325.515

Will: EOP is not defined in the definitions, and the definition of COOP is very vague. Recommend consulting SMEs and relevant standards to establish more descriptive guidance on planning standards on what should be addressed in these plans. Counties <50,000: Will the state have a minimum guideline for cyber security? I can foresee some systems using a “free” virus protection, and others using an expansive service. I would like to see a minimum level set.

The Administrator intends to provide a template for the COOP and make it available on the website. The State will follow DoIT’s Cybersecurity Guidelines and NENA Security for Next-Generation 9-1-1 Standard (NG-SEC) NENA 75-001, Version 1, February 6, 2010, which will be available on the 9-1-1 website.

1325.515(a)

INENA/ILAPCO: Does everyone agree with this? Needs more discussion as systems do things differently

Cindy will address this in greater detail at the Board Meeting; however, for further information, please refer to: • NENA PSAP Site Characteristics Information Document

NENA-INF-024.2-2018 (originally 04-502) 02/14/2018 • NENA E9-1-1 PSAP Equipment Standards NENA-STA-

027.3-2018 (Originally 04-001) 06/16/2018 • NENA PSAP Survivability Information Document NENA-

INF-020.2-2017 (originally 53-503) 01/12/2017 • FEMA Emergency Operations Center Facility and

Technology Maintenance Guide December 2016

1325.515(a)(3) Saline, Gallatin, & Hamilton: Define Fire Suppression Devices. The term devices has been used twice in this section, without defining the term device.

Use of the term devices or systems was intended to allow each 9-1-1 Authority to determine what the most appropriate option is for them.


1325.520(g)(1)(G)

INENA/ILAPCO: These abbreviations are an ever changing list. Maybe be best to just refer to the NENA document that deals with these?

The Department will provide further explanation at the Board meeting. type of service − for example, RESD, BUSN, PBXR, PBXB, CNTX, PAY$, COIN, MOBL, WRLS, RSDX, RESX, BSNX, BUSX, VRES, VBUS, VPAY, OMBL, WPH1, WPH2, P2P1, WPH1, VNOM, VENT, TEXT, TLMA, TELM, VOIP, CELL, etc.;

1325.525

St.Clair: Does this eliminate the previous requirement to notify the ICC or is this in addition to that requirement? Counties <50,000: What is an outage? Is it a loss of “dial tone”, or a lighting strike that takes out one console, leave others to function properly? What exactly constitutes a reportable outage event? Saline, Gallatin, & Hamilton: The statement that Notification shall be made to the PSAPs within 30 minutes and to the Administrator within two hours. Is this by the CARRIER? When does the clock start on this? Carrier understand that the clock starts once they have identified the problem. PSAPs understand this as when the issue has been reported to the CARRIER. INENA/ILAPCO: What types of outages PSAP, carrier customers. Carriers are to notify the ICC and do they notify ISP also?

The ICC regulates providers while the Department regulates 9-1-1 Authorities and ETSBs. They are separate requirements and obligations. Once a 9-1-1 Authority becomes aware the 9-1-1 service is not available, these obligations become applicable.

1325.600

INENA Region 7: Should Domestic Violence standards be considered as well? Counties <50,000: The Telecommunicators are City Employees and the 911 Board has no authority over the dispatchers. Is there a vehicle set in place to require refresher training with the Sexual Assault training?

As we flesh out the rules for 9-1-1 Telecommunicator Certification, we can consider whether domestic violence standards are or should be included. These are mandates from the State of Illinois. In order to be part of the Statewide 9-1-1 System, PSAPs will have to meet the standards. See Below.


1325.605

Counties <50,000: The Telecommunicators are City Employees and the 911 Board has no authority over the dispatchers. Who is to pay for the 80 hrs training? What are the guidelines for the training. INENA/ILAPCO: Do all of these bullets match with what the joint training committee provided, need to make sure. Should there also be a statement that the funding of this will come from the state directly not the systems? Is this training only once? If not, how often and will it be updated regularly?

Cindy will provide further explanation at the Board meeting. Refer to APCO/NENA Recommended Minimum Training Guidelines for the Telecommunicator (e) Each 9-1-1 Authority, as well as its PSAPs and participating agencies that employ 9-1-1 Telecommunicators and 9-1-1 Telecommunicator Supervisors, is responsible for ensuring such personnel are trained consistent with Section 53 of the Department of State Police Law [20 ILCS 2605/2605-53], Section 7.1 of ETSA [50 ILCS 750/7.1], and this section.


Part 1326

Counties <50,000: Most smaller counties strongly oppose the “Direct Dispatch” definition and requirements as referenced in various comments throughout this document.

Changes recommended to Part 1326 are to correct the NENA Standards citations and update to current terminology. No substantive changes are recommended to this standard. Part 1326 pertains to Private Business Switch and PEAPs only.

Part 1327

DuPage: Most of the language looks like updates based on the states requirements. I’d like to see an end date for consolidation grants. If you haven’t done it by now . . . $5M back into the system for the state wide network and 9-1-1 systems would help offset any change in revenue distribution from the costs of the new network.

The Department will have a legislative discussion at the Board meeting.

1327.120(c) INENA/ILAPCO: What happens to NG 911 Grants after 06/30/20?

The Department will have a legislative discussion at the Board meeting.

1327.200(b)(1)(H)

Saline, Gallatin, & Hamilton: A proposed section should be inserted to include: Scoring results of the administrator shall be made public or at a minimum of back to the applicant, so the applicant knows how they scored in their applications. In addition all grant awards shall be posted on the department's web site within 48 hours of the awards being awarded.

Information regarding grants that is publicly available is posted on the GATA website. At the Board meeting, Cindy will further explain the information provided to recipients.

1327.200(g)

INENA/ILAPCO: Why was this deleted? Again removing the SAB from the process and giving all decision making to State

GATA did not exist when the original provisions were written. We have proposed deletions consistent with Department’s requirements under GATA. Further explanation will be provided at the Board Meeting. The SAB will continue to determine the amount to be made available for consolidation grants.

Part 1328 DuPage: Are we striking the whole thing? Yes, WETSA was repealed and pertinent wireless sections

were incorporated into ETSA. 1328 will be repealed and pertinent rules are to be incorporated in 1324 and 1325.


Part 1329

DuPage: AFR It should probably spell out Annual Financial Report

“Annual Financial Report” or “AFR” means the financial report due annually pursuant to Section 40 of the Emergency Telephone System Act [50 ILCS 750/40] to the Department from every 9-1-1 Authority receiving Surcharge funds.

Part 1329 DuPage: Commission are we going to use ICC anywhere then include ICC

The term ICC is not used within the rule.

Part 1329

DuPage: Why is MSAG struck from this section I didn’t see any reference in the chart but I could have missed it

MSAG is not used within Part 1329 so it is being removed from the definition. MSAG was at point relied upon to resolve wireless zip code disputes; that is no longer the case. Now, postal points are used instead.

1329.100 Added for clarification. This Part shall apply to all carriers, VoIP providers, and 9-1-1

Authorities, except that it shall not apply to the City of Chicago.

1329.210(c)

Counties <50,000: New language was added which could potentially take the Advisory Board completely out of the discussion. I suggest “and Administrator” so that all key players are included in the discussion.

In a prior instance, the Board indicated a preference to stay out of the network cost dispute. Although they cannot be taken out of the process, this was a concession to allow them to weigh in where they deemed it appropriate.

1329.210(e)

DuPage: I think this is a good idea. You might want to consider language like “ if a 9-1-1 authority does not have a project plan in place with a definite completion date for migration to” You want to motivate people to comply. We have run into this with 9-1-1 systems that think it is not financially feasible to consolidate. If we don’t push them to provide a plan with a timeline they can linger for years without any way to get to the finish line. You could also consider a specific sliding scale. INENA/ILAPCO: More discussion and need to make sure everyone understands this

This will be discussed at the Board meeting. Network costs are determined by the Administrator with the advice of the Board. Costs are either included or not. The language does not allow for a sliding scale of eligibility in this situation.

1329.300 DuPage: do you want to be specific? I realize that we probably are not moving away from the website in the near

Terminology like “in the manner determined by the ISP” has not been permitted in the past by JCAR.


future but would it be easier to add “or in the manner determined by the ISP” to give yourself some wiggle room. Saline, Gallatin, & Hamilton: A summary total of subscribers shall be submitted to the agencies either annually or every six months, for accountability purposes.

This information is provided as requested in aggregate. It is not available by carrier.

1329.310

Counties <50,000: Carriers should have to show the number of landlines, VoIP and wireless customers to the State as well as the PSAP. Carriers states that there is no way to show numbers but we see bills broken out sent to PSAPs for payment, they did show numbers when billing the PSAP directly. It’s a matter of programming and may cost the carriers, but they do get the 3% for accounting and collecting of the surcharge.

This is open for discussion; however, legislation would likely be required.

1329.310(b) INENA/ILAPCO: Should 1.74 be mentioned here? Law needs to be addressed in this section. 3% is high for billing on the current $1.50

See the CTC comments below. The statute allows for up to 3%.

1329.310(c)

DuPage: I’d like to see something that says % of actual surcharge collected. CTC: The proposed rule goes beyond the statute to permit the Department to request additional supporting documentation if a Telecom/VoIP Provider retains greater than 1.74% of the gross amount for expenses. No such requirement exists or is authorized in the statute. Accordingly, CTC submits that the proposed requirement for Telecom/VoIP Providers to document its collection expenses above 1.74% of the collected funds should be deleted.

The ETSA make the Department responsible for oversight of the surcharge funds collected and expended and is expressly granted rulemaking authority in Section 10 so that the Department may implement the provisions of the Act for which it is responsible.

1329.340 Counties <50,000: Some systems audit is completed as part of the County’s annual audit and most do not correlate with Calendar year based AFR, will those systems have to

The requirements of this Section are based upon Section 40 of ETSA. These requirements are not new and exist independent of the auditing provisions in Section 1329.605.


independent calendar year based audit conducted for the ETSB?

1329.340(b) INENA/ILAPCO: More discussion. Do all the systems agree with all these statements?

This is open for discussion; however, the rule is written in line with Sections 30 and 40 of ETSA so these are not new requirements just a more thorough explanation.

1329.340

Amendment to make more consistent with language in Section 30 of ETSA.

9-1-1 Authorities must ensure and be able to demonstrate that surcharge disbursements received pursuant to the Act were used only for reasonably necessary costs directly attributable to that enhance, operate or maintain the implementation, enhancement, operation, or maintenance of a 9-1-1 system in accordance with Section 1329.600 of this Part.

1329.340(b)(2)

Saline, Gallatin, & Hamilton: Co-mingle of funds. Is this a requirement to have multiple accounts? This is problematic for some ETSB's. In addition does this mean an audit of these separate accounts will be required to the AFR? Please explain the reasoning behind this language as proposed??

Co-mingling is expressly prohibited by ETSA (15.4(c)), this is not new.

1329.340(b)(3)

DuPage: Just say “9-1-1 authorities must document their budget annual revenue and expenditures including costs that are not allowable uses of surcharge.” Will: New Requirement. Agree that this capability must exist so that expenses may be categorized as surcharge allowable or non-allowable, but reporting of other local expenses to the Department is inappropriate, perhaps beyond a specific figure. Clarify language accordingly.

DuPage Counties language is agreeable if we eliminate the word budget. 9-1-1 authorities must document their budget annual revenue and expenditures including costs that are not allowable uses of surcharge. Other local expenses are not required to be reported.

1329.340(b)(4) Saline, Gallatin, & Hamilton: Define what questions. This is an open ended request.

It is open ended on purpose. What is included as a certification question could change from year to year… depending for example on federal grant opportunities.

1329.340(c) Will: New Requirement. Again, detailed documentation of expenses that are not covered by 911 funds should be of no concern to the Department. This is additional

This is open for discussion; however, the documentation required is consistent with the statutory requirement that the reports be audited financial statements.


administrative burden on both sides that yields no specific benefit. Clarify language accordingly.

1329.400

DuPage: I’m assuming that this is clean up. If we are going this route, is it possible to know what is unclaimed so that 9-1-1 system that maybe servicing these areas can stake a claim? St. Clair: Why the need to change from the past practice and what happens if these agreements are not created? Counties <50,000: 911 Entities should be given the number of monthly wireless subscribers in their geographic area (defined by zip code)

This is not new. The language is being cleaned up based upon the repeal of WETSA. The practice has not changed. The street sign language is redundant. It is addressed in 600 and is in the statute. St.Clair: I cannot find a reference to any type of agreements in Section 1329.400. This information is provided as requested in aggregate. It is not available by carrier.

1329.405(a)

INENA/ILAPCO: Why only yearly? They receive a percent of the surcharge to do this service. That is holding money from the systems

We are not withholding money from the systems pending submission from the Vendors. We have a few Vendors that submit network cost invoices quarterly. We only pay the network costs when we get an invoice.

1329.405(e)(1)(D) INENA/ILAPCO: Does everyone agree with this? If the bill breakdown is only received yearly, how does the 30 days apply if done prior to the 30 days of the billing they receive?

This was intended to protect everyone. Karl can speak to this in more depth at the Board meeting.

1329.510(a)

INENA/ILAPCO: This section changed from be applied to the carrier to now the authority. What happens to the requirements on the carriers?

This section has never applied to carriers. The word providers was used incorrectly as the Section has always been applicable to the audited financial reporting required of 9-1-1 Authorities.

1329.510(d)(3)

INENA/ILAPCO: Systems need to know this. Timeframe is not stated for the audit for repayment and will this need to be a special audit since we only do external audits once a year?

This section was added to protect the State’s ability to remain eligible for federal grant funding and is consistent with ETSA.

1329.600 DuPage: I thought the purchase of property was prohibited under an AG opinion. Unless you specify for the PSAP structure specifically this is a slippery slope (and probably

The 9-1-1 Authority may not own property, but a unit of local government may do so. These expenses may be paid by the 9-1-1 Authority through a lease agreement or


why it was prohibited by the AG based on someone buying something). Other than the chart and if it was incorporated somewhere I missed it – how are these defined or referenced 1329.900(a)(2) I’m assuming that if in good faith I entered into a contract that is now not an allowable cost the ETSB would be able to finish the contract to term using surcharge. Folks are going to need time to transition. INENA Region 7: “Guidance” is vague when followed by “priority expenditures”, “allowable expenditures”, “permissible expenditures.” Counties <50,000: Prioritization of expenditures should be left to local control. Something that may appear in tier 1, while worthy, may not be of a priority in another area. INENA/ILAPCO: Does everyone agree with this? Needs much more discussion.

reimbursement for usage to the unit of local government. The unit of local government purchases and owns the property in this scenario. This is open for discussion.

a) Grants and surcharge disbursements may be used only for the purposes set forth in the ETSA for reasonably necessary costs that enhance operate or maintain have a direct relationship to the implementation, upgrade, maintenance, operation or support of the 9-1-1 system.

1329.600(a)(2)

Will: "reviewed annually by the Administrator" causes concern in how vague the language is. 911 Authorities need protection from the State Administrator having the ability to change reimbursement guidelines in a way that may apply rules or limitations that were not in place when a budget was prepared. Expand language to add more clarity. Saline, Gallatin, & Hamilton: Define the term “should be met”?

Section 35 of the Statute provides limitations on what surcharge money can be used for. Guidance was requested and is provided; however, the guidance is not intended to undermine the 9-1-1 Authorities ability to make decisions regarding its expenses. This is open for discussion. (2)(A) Tier 1 - Priority Expenditures, which should shall be met before surcharge disbursements are directed to Tier 2 and Tier 3 Expenditures.

1329.600(b)(1) Will: For many, many years, the Will County 9-1-1 System has operated and maintained central law enforcement, fire,

There is an AG’s opinion on point.


and EMS records systems for agencies within the system. Disallowing these expenses would fundamentally change how our System operates, and have a significant and detrimental impact on our participating agencies and in the delivery of public safety services to the public. We agree that Jail and Court Records Management Systems should be ineligible, as these are not core 9-1-1 / emergency response functions. LE, Fire, and EMS records systems should not be included in this prohibition.

1329.600(b)(8)

Will: How do we have an integrated LEADS connection into the CAD system if we cannot pay for it? If the intent is that 9-1-1 funds are not used to provide individual participating agencies with LEADS service, hardware, etc, then word this section that way. Do not prohibit 9-1-1 authorities from purchasing LEADS connectivity for use in the PSAP. This is unreasonable from a practical standpoint. Add corresponding language to Surcharge Table.


1329.600(b)(9)

Will: "not directly attributable to 9-1-1" is vague and open to a wide range of interpretation. It is not clear who makes this determination, or what criteria is used. Language may also need to be expanded to be more descriptive. Counties <50,000: Does this ref to CAD, Mapping, AVL, Policy vendor’s?

Again, this (directly attributable) is language that comes from Section 35 in ETSA. The terminology “costs that are directly attributable” has a commonly understood use in the practice of accounting. It is used to distinguish direct costs from indirect costs.

1329.600(b)(10)

Will: This wording is too narrow. This is detrimental to our work and the services we provide to the public, and are examples of the very narrow "view of the world" used to craft these rules.

Again, expenditures must be directly attributable to implement, upgrade, maintain, operate or support the 9-1-1 system - See Section 35 in ETSA.

1329.600(b)(12)

DuPage: Retention of a private attorney by a county ETSB. So if the SAO appoints special counsel and there is a fee for service is that allowed? We sued to do that and there have been instances when one was considered for certain legal matters. What’s the basis of this one?

Only those professional services directly attributable to the support of the 9-1-1 system are permitted. If there is a conflict of interest and the 9-1-1 Authority requires legal representation directly related to its operation of the 9-1-1 system, this would be a Tier 1 expense.


INENA Region 7: There are cases in which using the County SA is not practical or can potentially be a conflict of interest between the County and the 9-1-1 Authority. Is it just the retaining fee we can’t pay, or legal services? Will: Not directly attributable to 9-1-1 is vague and open to a wide range of interpretation. It is not clear who makes this determination, or what criteria is used. Are I.T. vendor services, cybersecurity monitoring services, and the like considered directly attributable or not? Clarify language and ensure it is consistent with the Surcharge Table. Counties <50,000: Having an outside attorney is often required in our field. Often the States Attorney has a conflict of interest in any topic involving both the County and ETSB. Also any legal requirements for a group that includes more than one county, like CSI, requires an outside lawyer.

The clarifying language could be removed since it appears to be creating confusion. 12) Professional services not directly attributable to the delivery of 9-1-1 service, including but not limited to the retention of a private attorney by a County ETSB; and

1329.600(b)(13)

DuPage: examples? Does Smart911 fit into the delivery of 9-1-1? Will: Not directly attributable to 9-1-1 is vague and open to a wide range of interpretation. It is not clear who makes this determination, or what criteria is used. This is another determination that should be made at the local level by the 9-1-1 Authority, and not micromanaged by ISP in Springfield.

Special language was added to the ETSA regarding Smart911 and can be found under the more generic definition of hosted supplemental 911 service. Section 35(9) of ETSA – includes hosted supplemental 911 service.

1329.600(c)

Will: Our concern here is dependent upon the interpretation of "eligible use" criteria in the Surcharge Table. If the eligible use category is meant to be taken literally as all-inclusive, this could be a burden for ETSBs for the next few years as this list is comprehensively

The table is intended to be all-inclusive. If there are other expenses that should be added, now is the time to have that conversation. If there are things unforeseen, this paragraph provides a mechanism to add things to the list, which will change over time.


determined-+. If the eligible use column simply gives illustrative examples of the cost categories are not expected to be all-inclusive, we do not have a concern. Add language, preferably as front matter to the Surcharge Table, to indicate that the eligible use list is intended to be illustrative but not necessarily all inclusive.

1329.600(d) INENA/ILAPCO: Details needed. This is really just a reiteration of ETSA. The ETSB is receiving money and is responsible for it.

1329.605

DuPage: The county completes an annual audit based on its fiscal year. A second would be an unnecessary expense and expenditure of surcharge. Other than the calendar year, it doesn’t fit into the state or a 9-1-1 system (although a few may have a calendar year) fiscal year. This would also be a special expense to have an auditor audit against the state statute. Also June 30 for large counties is a tight time frame. What are we trying to accomplish here? I’m waiting to hear what the county CFO says. St.Clair: This new audit procedure is duplicating processes that are already in place. The county has an annual audit done of all accounts and that is a publicly available document. Would that document suffice, or would this be a requirement to have an additional audit done to provide? We already provide the AFR and any requested supporting documentation. To now require a separate audit is overstep of the role of the Statewide 911 administrator. INENA Region 7: Is this an additional audit, separate from a general county audit? Concerns if Auditors will know The depth of the 911 law in order to conduct and produce such extensive records and reports.

The county audit is not an audit of 9-1-1 revenues and expenses against ETSA and its rules. The statute requires each ETSB “shall report to the Department audited financial statements.” See 50 ILCS 750/40. The Department has determined this language creates a fiduciary responsibility for the Department to ensure 9-1-1 funds are appropriately audited against ETSA and its rules. This is a good faith effort to ensure the Department is a good steward of the money as envisioned by the statute. The 9-1-1 Systems collectively receive approximately $165M in surcharge money collected by the state. Additionally, approximately 75 of the 9-1-1 Authorities will receive $500,000 or more. Oversight of the expenditure of such taxpayer money is appropriate; however, the Department is receptive to discussing best practices to minimize the impact of these requirements on the 9-1-1 Authorities. This will be discussed in greater detail at the Board Meeting.


Will: Given that the County's normal comprehensive audit process is usually completed in May, this timeline is acheivable but tight. This would realistically depend on the cooperation of County finance and auditor to meet successfully, which creates a dependency that the ETSB does not control. Counties <50,000: Dates should be after the rules have been accepted and implemented. Having it be a requirement for an outside auditor to sign off on whether the 911 charges are legitimate is ridiculous. No auditor knows anything about 911. Excessive Oversight. For my entity we mostly do everything listed here already except for D which is not an issue. The issue here is that our auditors conduct audits on our fiscal year and not on the calendar year. Our fiscal year is Dec 1 to Nov 30. I think a language change to allow 911 Authorities to do this on their fiscal year, or a mechanism to allow 911 Authorities to submit their fiscal year audits would be better. I don’t think the intent here should lead to a 911 Authority to have to pay for and submit to a separate audit when one is already being done. Saline, Gallatin, & Hamilton: Define the term audit. Should be an insertion that the 911 funds received by the State of Illinois shall be audited in the same means and that audit made available to the 911 Authorities within 30 days of the completion of the audit. INENA/ILAPCO: Auditors are not familiar with ETSB rules. How will this impact our audits and costs? Whole section needs to be discussed more.


1329.605(a)(2)

ITA: While this subsection is not clearly drafted, it appears to require all carriers and interconnected VoIP providers to engage outside auditors to audit 9-1-1 surcharge funds collected. This subsection should be deleted. The statute does not authorize the ISP, through rule or otherwise, to require carriers and interconnected VoIP providers hire outside auditors to audit their own books and records. The statutes referenced in this section (50 ILCS 750/12 or 50 ILCS 750/20) do not impose such an audit requirement. CTC: This Part proposes to require Telecom/VoIP Providers to audit the 9-1-1 surcharge funds that they collect. While the statute explicitly provides for audited statements of the ETSB/qualified governmental agency/unit of local government receiving surcharge money for audits of the Statewide 9-1-1 Fund and the Wireless carrier Reimbursement Fund, no statutory requirement exists for Telecom/VoIP Providers to initiate audits regarding the surcharges they collect. CTC submits that the proposed requirement for a Telecom/VoIP Provider’s audit of 9-1-1 surcharges collected be deleted. INENA/ILAPCO: Needs much more discussion.

The ETSA make the Department responsible for oversight of the surcharge funds collected and expended and is expressly granted rulemaking authority in Section 10 so that the Department may implement the provisions of the Act for which it is responsible.

1329.620

DuPage: Did we define “books and records” and why wouldn’t 9-1-1 systems just follow the state statute on records retention?

The records retention statute allows each entity to set records retention schedules. The rules provide guidance to 9-1-1 Authorities on our expectation regarding these records.

1329.620(e)

ITA: The proposed rule changes the minimum record retention period from 5 to 7 years. This change will add cost and burden. It is not at all clear why such a change is necessary or what purpose it serves.

This change was recommended to ensure 9-1-1 Authorities and System Providers meet the same minimum records retention requirement as that of the Department. Seven years is the commonly recommended records retention period for any records related to the collection or payment of a tax or surcharge.


CTC: The proposed regulation would extend that obligation an additional two years and require records retention for seven (7) years. This represents a forty percent (40%) increase in the length of time to retain records. CTC submits that the current records retention provision of five (5) years should not be changed. Saline, Gallatin, & Hamilton: First off why was d deleted and e added when there is no d? Why the change of five years to seven years? Storage can be an issue and may be different than what is on file with the Illinois Secretary of State records retention.


Allowable Expenses Chart

Counties <50,000: Concerned that this could be seen as an open book of funds for local jurisdictions who have agreements with the ETSB’s to serve as PSAP’s and take 9-1-1 calls. We have included a number of questions and concerns for consideration.a

Section 35 of the Statute provides limitations on what surcharge money can be used for. Guidance was requested and is provided; however, the guidance is not intended to undermine the 9-1-1 Authorities ability to make decisions regarding its expenses. The chart is intended to provide guidance regarding what is allowable rather than what is required. The chart will be discussed in detail during the Board Meeting.

Surcharge Table CAD

CAD Hardware / Software /

Workstations.

Will: The intent seems to be for 9-1-1, however the language could be construed to include workstations in participating agency facilities or apparatus which connect to CAD and allow for interaction by responders in the field. This is a concern. More narrowly focus the language.

The Department will more narrowly focus the language and consider language to be included in 1329.600(b) expressly prohibiting the purchase of such items for responders in the field.

Surcharge Table CAD

RMS Interface

Will: In section b) Grants and surcharge disbursements may not be used for the following expenses:

1. Law Enforcement, Fire, Jail, ETMS, and court records management systems, connectivity, software licensing maintenance and service agreement.

CAD interface that populate RMS with CAD data, but can’t supply the RMS that goes with the CAD system to be able to track reports of people who misuse 911, reports of those 911 calls for domestic violence, DUI’s, etc.


Surcharge Table Contracted Services

Professional Services.

Will: Unclear as to whether this is a conflict with the limitation specified in 1329.600 b) 12) which prohibits retention of private attorneys by ETSBs. Clarify between these two items.

A conflict is not intended. Only those professional services directly attributable to the support of the 9-1-1 system are permitted. 1329.600(b)(12) will be amended to make this clear.

Surcharge Table Mass Notification

System Public Alerting

System

Will: Appears to exclude such systems which are used for emergency responder alerting and dispatch. Again, Will County uses a common system which promotes seamless integration across our PSAPs and agencies, including a current project to perform this function automatically as a result of CAD call creation. Placing us in the position of


having to integrate with potentially 58 different local systems to perform this function would be a nightmarish waste of resources on the part of the ETSB. Add language to include "emergency responder notification" to mass notification and public alerts.

Surcharge Table Personnel

Salaries/Benefits for 9-1-1 Staff

Counties <50,000: What percentage? Amount? What is that call worth? Some Municipalities would like $80,000 for a TC, but only handle 3,500 911 calls per year. Put a cap on the 911 calls of $2.25 each (or other amount as decided by board) this way it would be consistent across all counties – 3,500 X $2.25 = $7,875.00 per year per call. Quite a difference from the $80,000 a municipality would want.

Surcharge Table Radio Systems

Communication Equipment & Maintenance

Will: Will County 9-1-1 has great concerns and objects to the permissibility of using 9-1-1 funds to purchase emergency responder (participating agency) radio equipment and MDT equipment. We are aware of ETSBs that do this, and to the extent that we would not want those ETSBs dictating to us how to meet our local needs we would take the same view. But, as these rules seek a 'one size fits all' approach to ETSB needs, we must object in the strongest terms that this is not an appropriate use of 9-1-1 surcharge funds, and seems inconsistent particularly in light of many of the limitations that ISP is seeking to impose elsewhere in this table. Delete this provision.

Surcharge Table Radio Systems Radio System Maintenance

INENA/ILAPCO: Land for tower sites. Absolutely makes no sense to own radio towers, generators, etc for the tower site but not land. It adds extra issues for the ETSB

The 9-1-1 Authority may not own property, but a unit of local government may do so. These expenses may be paid by the 9-1-1 Authority through a lease agreement or reimbursement for usage to the unit of local government. The unit of local government purchases and owns the property in this scenario.

a How can the Salary of a Coordinator/Director not be a Tier 1 expense? We are a pretty important piece to the day to day operations of the system.


Allowable communications based expenditures are inconsistent. The ability to respond to an emergency is only as good as the communications network that is used to notify the responding first responders. Hardware/Software is a Tier 1 expense, yet tower sites are a Tier 3, your base radio system is only as effective as the tower network that is used to effectively transmit the notification of an emergency, especially in rural counties.

I also have an issue with Pre/Post Employment costs for 911. This only makes sense for those who have call centers that only answer 911 calls.

A lot of PSAPs already have most of the Tier 1 expenses satisfied by the local Sheriff, Police and 9-1-1. Making these items Tier 1 allowable use of 9-1-1 funds would open a wide door for County Board and local agencies to now “expect” 9-1-1 to cover these expenses.

Radio Sys Hardware/software, Radio System Maint - Our ETSB is not in the radio business, and we don’t want to be. The local police and sheriff currently provide this component. If anything, radios should be a proportionate share only.

Our local telecommunicators are not 9-1-1 employees, we don’t sit in on interviews and we are not included in the hiring process . . . so it would not make sense that we pay for pre-employment costs/post employment costs.

Cost to Provision Connectivity like fiber optic, circuits and radio circuits . . . . is this related to “direct dispatch” setup?

Headsets – Our county TCs already have headsets, but no one wears them. Maybe this should be a proportionate share since they dispatch for non-emergency situations too.

Emergency Generator & UPS – Our PSAP is inside Sheriff’s Office/Jail and they already have a generator and UPS. If anything, these should be aTier 3 proportionate share expense.

Office supplies/equipment – Joint Dispatch PSAP already has copiers, shredders, etc. for the Sheriff’s Office that they use.

Console furniture, chairs, and chair mats should also be an proportionate share as it is used by Sheriff’s Office employees while also performing Sheriff Office duties. This would be a more appropriate Tier 3 shared expense.

Documents

Substantive Proposed Regulatory Changes Emergency