I St. Clair County 4, a Emergency Telephone Systems Board I 00.9, I St. Clair County E911 Administrative Offices 101 South 1?tSt Belleville,lL 62220-2014 (618) 825-2160 Fax: (618) 277?7668 Sheriff Richard Watson CHAIRMAN Fire Chief Donald R. Feher VICE-CHAIRMAN Former Mayor George Chance Mr. Michael E. Sullivan Mr. Kevin Elbe Chief Steven Brown Mr. Ken Easterly Mr. Herbert Simmons EXECUTIVE DIRECTOR r. Kevin Ka ufhold EY April 17, 2018 Cindy Barbera?Brelle Statewide 9-1-1 Administrator 801 South 7th St. Springfield, IL 62703 Ms. Barbera-Brelle, St. Clair County observed the posting of the Madison County Illinois Consolidation Plan on the Statewide 9-1-1 Administrator website on effective March 8, 2018. In accordance with Section 1324.200- G-2-A, below you will find St. Clair Counties written objections to the filing and request for an administrative hearing in this matter. St. Ciair County is of the belief, this plan is identical to a previous request made by St. Clair County which was subsequently denied by the Statewide 9?1-1 Advisory Board and sanctions were written into the current Administrative Rules barring such activity. Please see our comments below: a Page 3 indicates a Date of 07/19/2017, however, this plan was not posted until March 8, 2018. Why the significant delay in the posting of this plan, or if it has been revised this plan needs to be updated to reflect accurate dates as objections, approvals and sanctions are outlined in the administrative ruies with date deadlines. 0 Also on page 3 it is noted that the current PSAPs of Bethalto, East Alton, Highland, Madison, SIUE, Troy and Venice will ?Decommission/Close,? however a thorough review of the plan shows that is not accurate. 0 On page 5, a letter addressed to indicating the intent of Madison County to consolidate is also dated 07/20/17, however there is a significant delay from this time period. Additionally, their letter indicates their consolidation plan ?to be filed,? and their plan cover page is showing 07/19/17 which indicates this was written after the filing with the Department. a Page 6 under question 2 does not accurately reflect the types of radio systems in use in Madison County. Additionally, it makes no mention of the Trunked VHF system owned and operated by Highland which will be required for direct dispatch from Collinsville. Page 6 under question 3 states "will all PSAPs remaining after consolidation direct dispatch all emergency calls pursuant to section 1324.200b(3) and they indicate "yes.? Upon review of 1324.200b (3), it states ?May not convert PSAPs to SAPs, VAPs, or Dispatch Centers to avoid the requirements for consolidation in ETSA Section The authorized PSAPs remaining after consolidation shall directly dispatch all emergency calls and shall not transfer or relay those calls to an unauthorized entity." As we will provide multiple references of evidence below of the clear violation of the above quoted Administrative Rule. 0 Page 6 under question 8 it states ?have you included financial information?? The answer by Madison County is ?No? and the bolded text here states ?Plans submitted without this documentation will be rejected.? Therefore this plan should be rejected based solely on this failure to comply. On page 8 under Plan Narrative, it states "this consolidation plan in compliance with applicable law and conditions of the previous waiver request order.? Which is not accurate because as indicated above and below there are clear violation of On page 9 it lists the backup plan for the remaining PSAPS which does not match the lists provided later in the documents. On page 9 in the narrative plan, Madison County indicates ?Madison County ETSB has identified a need to maintain a training facility that would require direct use of 9-1-1 training workstations in a classroom setting. Madison County ETSB plans to keep training positions and 9?1-1 system administrator workstations (which require direct access to the 9?1-1 network) at the Wood River Training Facility. Factors in this decision include the lack of an adequate facility (physical space) at any of the remaining PSAPs and the need to provide ongoing training and administrative access to the system. Furthermore, Madison County ETSB will pay for the Wood River Training facility (Admin/Training ONLY site) connectivity to the system from local revenue sources AND IT WILL NOT BE INCLUED IN ANY INVOICE PAID DIRECTLY BY the State of Illinois.? This would actually create a 9th PSAP and would not comply with the consolidation requirements. Edwardsville PSAP was recently built and has a large training facility which would be adequate and already be connected to the 9-1-1 connectivity. Additionally, the ETSB should not be able to pay for an additional PSAP location out of surcharge funds regardless if it is being paid directly by the state because this is just another method to circumvent the process. St. Clair County inquired early on that if a PSAP was willing to pay for their own equipment and connectivity could they avoid consolidation and we were told ?no? as that was outside of the intent of the law. Additionally on page 9, Madison County indicates ?it should be noted that each PSAP listed as ?closing? will continue to function as a dispatch center for their respective jurisdictions.? This is a direct violation of 1324.200b(3) which states ?May not convert PSAPs to SAPs, VAPs, or Dispatch Centers to avoid the requirements for consolidation in ETSA Section The authorized PSAPs remaining after consolidation shall directly dispatch all emergency calls and shall not transfer or relay those calls to an unauthorized entity.? Also on page 9, they indicate a 911 call will be received by a PSAP and a CAD incident created. Forthe duration of the 911 call. Does this mean until the call is hung up or until the call is completed by the First Responder? Additionally on page 9 they state directly dispatches appropriate agency via Primary Method (if Primary Method is not available, Secondary Method will be utilized as outlined in each call handling agreement attached to this plan.? As we will point out on multiple instances below, some primary and a large amount of secondary methods results in phones calls either using the Call Relay or Call Transfer format both of which are illegal under administrative rule Additionally there is now intent to use a new Starcom 21 talkgroup as a secondary method, however, a great majority of these agencies do not use Starcom 21 and it would be unlawful to place a radio in a "dispatch center? rather than a Starcom 21 radio in the hands of every first responder. Furthermore on page 9 they state ?if PSAP does not provide full dispatch services for the agency, dispatch center assumes call handling (all radio traffic, CAD Updates, request for additional resources, for the remainder of the incident.? How does the "Dispatch Center? receive the information from the call (ie, Name, call back number, location, This method presents an inherent risk to the safety of the public and the first responder. Additionally if the PSAP and the Dispatch Center are both dispatching the same officers to different calls, how does each know who is available, etc.. If this is being done by the CAD system, who is paying for the CAD and connectivity to a non? Also on page 9, they state ?Currently, logging recorders are located at each of the sixteen PSAPs for call and radio traffic. These recorders are funded locally by each municipality. The eight remaining PSAPs and eight PSAPs designated as ?closing? will continue to maintain (at their own expense) recording devices for call and radio traffic." However in the administrative rules Section 1325.415-L it indicates the 911 Authority shall provide for the installation of a master logging recorder 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. To require non?PSAPs to maintain their own recordings and then be reliant upon retrieving information from them does not comply with the rules. Page 17 is an lnteragency Agreement with the State Park FD and it states the primary method is Madison County would alert them via St. Clair County Fire Department 154.190 which Madison County DOES NOT have authorization to page on. The secondary method would be the appropriate and a new secondary needs to be added. Page 24 includes a PSAP boundary map as required by the Consolidation plan submittal, however, this is a map of their current 16 PSAPs and does not reflect the consolidation. Page 25 is the document that shows a proposed Consolidation Diagram with the backup plans not matching earlier documents. Page 27 shows a projected switch to an ASE circuit which as explained previously cannot be completed without multi-county collaboration. Additionally it shows 9 PSAPs each with a 100m circuit which as has been proven recently by the Statewide 9?1?1 Administrator in her ruling with St. Clair County is far beyond the needs of 9-1?1 call delivery and processing. Therefore, as we were required to these circuits need to be greatly reduced and the PSAP needs to be removed. Page 29 lists StarCom?MCE911 as the secondary method of call delivery. If this were the case the department would be required to purchase Starcom 21 radios for all of their First Responders as this cannot be relayed to a dispatch center for rebroadcast it must be directly to the first responder. Page 30 lists StarCom?MCE911 as the secondary method of call delivery. If this were the case the department would be required to purchase Sta rcom 21 radios for all of their First Responders as this cannot be relayed to a dispatch center for rebroadcast it must be directly to the first responder. Page 35 lists StarCom-MCE911 as the secondary method of call delivery. If this were the case the department would be required to purchase Starcom 21 radios for all of their First Responders as this cannot be relayed to a dispatch center for rebroadcast it must be directly to the first responder. Page 36 lists StarCom-MCE911 as the secondary method of call delivery. If this were the case the department would be required to purchase Starcom 21 radios for all of their First Responders as this cannot be relayed to a dispatch center for rebroadcast it must be directly to the first responder. Page 37 lists Sta as the secondary method of call delivery. If this were the case the department would be required to purchase Starcom 21 radios for all of their First Responders as this cannot be relayed to a dispatch center for rebroadcast it must be directly to the first responder. Page 39 lists StarCom-MCE911 as the secondary method of call delivery. if this were the case the department would be required to purchase Starcom 21 radios for all of their First Responders as this cannot be relayed to a dispatch center for rebroadcast it must be directly to the first responder. Page 42 has changed the secondary method of the Highland Volunteer Fire and EMS to an emergency text paging based on the objections submitted by St. Clair County on January 25, 2018. This agreement has been crossed out and new information written into the dated December 18, 2017 document and it is concerning whether the department is even aware of this change. Page 43 has changed the secondary method of the Highland Pierron Volunteer Fire Department to an emergency text paging based on the objections submitted by St. Clair County on January 25, 2018. This agreement has been crossed out and new information written into the dated December 18, 2017 document and it is concerning whether the department is even aware of this change. Page 44 has changed the secondary method of the Grantfork Fire Department to an emergency text paging based on the objections submitted by St. Clair County on January 25, 2018. This agreement has been crossed out and new information written into the dated December 18, 2017 document and it is concerning whether the department is even aware of this change. Additionally a later document shows the secondary method for Gra ntfork is a phone call to the Collinsville Police Department which provides conflicting information. Page 45 has changed the secondary method of the Marine Fire Dept to an emergency text paging based on the objections submitted by St. Clair County on January 25, 2018. This agreement has been crossed out and new information written into the dated December 18, 2017 document and it is concerning whether the department is even aware of this change. Page 46 has changed the secondary method of the St Jacob Fire Department to an emergency text paging based on the objections submitted by St. Clair County on January 25, 2018. This agreement has been crossed out and new information written into the dated December 18, 2017 document and it is concerning whether the department is even aware of this change. Page 47 has changed the secondary method of the St Rose Fire Department to an emergency text paging based on the objections submitted by St. Clair County on January 25, 2018. This agreement has been crossed out and new information written into the dated December 18, 2017 document and it is concerning whether the department is even aware of this change. Page 48 lists the primary method for notification to the Police as a phone call to 618-650-3324 which is the phone number of their dispatch center. This would be a call relay not direct dispatch. Page 49 lists the primary method for notification to the SIUE Police as a phone call to 618?650-3324 which is the phone number of their dispatch center. This would be a call relay not direct dispatch. Page 52 lists the primary method for notification to the SIUE Police as a phone call to 618-650-3324 which is the phone number of their dispatch center. This would be a call relay not direct dispatch. Page 54 lists the secondary method for notification to the Maryville Police, Fire and EMS as a phone call to the Maryville Police Department seven digit non-emergency number which would be a call relay not a direct dispatch. Page 55 lists the secondary method of dispatch for the Troy Fire Department to be a phone call to the Troy Fire Department. However, later documents lists the secondary method as an emergency text page. Page 55 indicates the Troy Fire Department will be dispatched by the Glen Carbon PSAP while the Troy Police Department will be dispatched by the Madison County Sheriff PSAP and both have the potential to divert back to the ?Troy Dispatch Center.? This represents a risk for the residents of that community as their 911 calls will be routed to one PSAP and if the need for exists they have to be transferred to a different PSAP. Page 58 lists the secondary method for notification to the Maryville Police as a phone call to the Maryville Police Department seven digit non-emergency number which would be a call relay not a direct dispatch. Page 61 lists the secondary method for notification to the Maryville Fire as a phone call to the Maryville Police Department seven digit non?emergency number which would be a call relay not a direct dispatch. Page 62 lists the secondary method for notification to the Troy Fire Dept as an emergency text notification in contradiction to that listed in the interagency agreement on page 55. Page 63 lists the Primary method for Granite City as Sta rcom but with a radio frequency of 153.845 which is VHF in which Sta rcom is 800m hz. Page 64 lists the Primary method for Granite City as Starcom but with a radio frequency of 153.845 which is VHF in which Sta rcom is 800mhz. Page 65 lists the Primary method for Granite City as Starcom but with a radio frequency of 153.845 which is VHF in which Sta rcom is 800m hz. Page 68 lists the secondary method for Venice Police and Fire as Starcom MCE911, however, this agency does not have Starcom Radios and would require them to be placed in the hands of all first responders not just a single radio in the ?dispatch center.? Page 69 lists the secondary method for Venice Police as Starcom MCE911, however, this agency does not have Starcom Radios and would require them to be placed in the hands of all first responders not just a single radio in the ?dispatch center.? Page 74 lists the secondary method for Venice Police as Starcom MCE911, however, this agency does not have Starcom Radios and would require them to be placed in the hands of all first responders not just a single radio in the ?dispatch center." Page 77 lists the secondary method for Venice Fire as Starcom MCE911, however, this agency does not have Starcom Radios and would require them to be placed in the hands of all first responders not just a single radio in the "dispatch center.? Page 82 lists the secondary method of the Grantfork FD to be a phone call to the Collinsville PD which is in contradiction to their earlier agreement from the Highland Interagency Agreement and would also represent a call relay not direct dispatch. Page 98 lists the secondary method of the Grantfork FD to be a phone call to the Collinsville PD which is in contradiction to their earlier agreement from the Highland Interagency Agreement and would also represent a call relay not direct dispatch. Page 117 lists Starcom MCE911 as the secondary method for Bethalto and East Alton Police Departments when they are not Starcom Agencies. This would require them to purchase Starcom Radios for all of their first responders and not just placing a single radio in the "dispatch center? which would result in a Call Relay and not direct dispatch. Page 118 lists Starcom MCE911 as the secondary method for Bethalto and East Alton Police Departments when they are not Starcom Agencies. This would require them to purchase Starcom Radios for all of their first responders and not just placing a single radio in the ?dispatch center? which would result in a Call Relay and not direct dispatch. As an example is shown on Page 120, there are multiple places in where problems noted in the St. Clair County objection filed January 25, 2018 were crossed out and changed to new information without updating the involved agencies and having new signatures obtained. It is unknown if these agencies are aware of the changes or of the impact in which they would be responsible for purchasing multiple radios to comply with their new secondary method as indicated by the Madison County ETSB. No documents were actually updated and changed to involve the agencies they were simply crossed out, or pages without signatures were re? ?ty.ped Page 121 lists Starcom MCE911 as the secondary method for Bethalto Police Department when they are not Starcom Agencies. This would require them to purchase Sta rcom Radios for all of their first responders and not just placing a single radio in the ?dispatch center? which would result in a Call Relay and not direct dispatch Page 122 lists Sta rcom MCE911 as the secondary method for East Alton Police Department when they are not Sta rcom Agencies. This would require them to purchase Starcom Radios for all of their first responders and not just placing a single radio in the ?dispatch center? which would result in a Call Relay and not direct dispatch. Page 127 lists Starcom MCE911 as the secondary method for Bethalto Fire Department when they are not Starcom Agencies. This would require them to purchase Starcom Radios for all of their first responders and not just placing a single radio in the ?dispatch center? which would result in a Call Relay and not direct dispatch. Page 133 is an Interagency Agreement with the State Park FD and it states the primary method is Madison County would alert them via St. Clair County Fire Department 154.190 which Madison County DOES NOT have authorization to page on. The secondary method would be the appropriate and a new secondary needs to be added. Page 139 lists adjacent agencies and includes the St. Clair County Sheriff, however, the attached agreement signed by the Sheriff is for the St. Clair County ETSB. Page 150 improperly lists the secondary method for St. Clair County ETSB to notify Madison County via Radio Talk group which does not exist in St. Clair County. This document is not accurate of the capabilities of the system and the chairman who signed along with Madison County have been provided with written notice of the inability to comply with this interagency agreement. While section 1324.200-3 indicates ?notwithstanding this subsection any 9-1?1 Authority required to consolidate pursuant to ETSA Section 15.4a(a) that is only reducing the number of PSAPs in order to comply with the Act need not formally submit a consolidation plan to the Administrator for approval. While Administrator approval is not necessary for these consolidations, the 9-1-1 Authority must provide written notification documenting the change 10 business days prior to making the change. However, since Madison County elected to file for a waiver, was subsequently denied and then provided with requirements from the Statewide 911 Administrator, 9?1-1 Advisory Board and the Administrative Law Judge, they are no longer filing a simple consolidation and thus are subject to all the requirements of a Consolidation Plan to include a public hearing in front of the statewide 9?1-1 advisory board. As we have taken the opportunity to thoroughly review and document our objections we now file our formal request for a hearing to have our objections publically hea rd, unless, you find this document enough to immediately deem this consolidation plan a violation of the administrative rules and deny it in its entirety. Furthermore, the legislations itself states ?The Statewide 9-1-1 Advisory Board shall: (1) advise the Department of State Police and the Statewide 9?1?1 Administrator on the oversight of 9-1?1 systems and the development and implementation of a uniform statewide 9-1?1 system.? To allow for an intentional violation of the administrative rules and multiple attempts to circumvent the legislation does not uphold the intent or comply with the intent to create a ?uniform? system by allowing a one-off of this magnitude. Very Respectfully, Herb Simmons Executive Director