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State of Illinois

Next Generation 9-1-1 Feasibility Study

Report

PREPARED DECEMBER 2017 FOR ILLINOIS STATE POLICE,

OFFICE OF THE STATEWIDE 9-1-1 ADMINISTRATOR

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Table of Contents

Executive Summary ....................................................................................................................... 1 Vision 1 Current Environment ........................................................................................................................ 2 NG9-1-1 Assessment, Considerations, and Implications .................................................................. 3 Conclusion ....................................................................................................................................... 4

1 Background ............................................................................................................................. 5

2 Methods .................................................................................................................................. 5 2.1 Town Halls / Interviews .......................................................................................................... 5 2.2 Survey ................................................................................................................................... 6 2.3 Research ............................................................................................................................... 6

3 Current Environment ............................................................................................................... 7 3.1 Statutory, Regulatory, and Political Environment ................................................................... 7 3.2 Stakeholders .......................................................................................................................... 8

3.2.1 Stakeholder-identified Challenges to NG9-1-1 Implementation .......................................................... 9 3.2.1.1 Funding ..................................................................................................................................... 10 3.2.1.2 Comprehensive Planning .......................................................................................................... 10 3.2.1.3 Statewide Collaboration and Technical Standards / Assistance ............................................... 11

3.3 Technology Environment ..................................................................................................... 13 3.3.1 PSAP Call Handling .......................................................................................................................... 13 3.3.2 Geographic Information System / Mapping ....................................................................................... 14 3.3.3 9-1-1 Providers .................................................................................................................................. 16 3.3.4 Originating Service / Infrastructure Providers ................................................................................... 17 3.3.5 Automated Information Systems ....................................................................................................... 18

3.4 Operational Environment ..................................................................................................... 19 3.4.1 Emergency Telephone System Boards ............................................................................................ 20 3.4.2 Geographic, Populations, and Resource Availability ........................................................................ 20 3.4.3 Economic / Funding Environment ..................................................................................................... 21 3.5.1 Indiana ............................................................................................................................................... 24

3.5.1.1 Governance ............................................................................................................................... 24 3.5.1.2 Technology ................................................................................................................................ 24 3.5.1.3 Operations ................................................................................................................................. 25 3.5.1.4 Funding ..................................................................................................................................... 25

3.5.2 Iowa ................................................................................................................................................... 25 3.5.2.1 Governance ............................................................................................................................... 25 3.5.2.2 Technology ................................................................................................................................ 26 3.5.2.3 Operations ................................................................................................................................. 27 3.5.2.4 Funding ..................................................................................................................................... 27

3.5.3 Kentucky ............................................................................................................................................ 28 3.5.3.1 Governance ............................................................................................................................... 28 3.5.3.2 Technology ................................................................................................................................ 28

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3.5.3.3 Operations ................................................................................................................................. 28 3.5.3.4 Funding ..................................................................................................................................... 29

3.5.4 Missouri ............................................................................................................................................. 29 3.5.4.1 Governance ............................................................................................................................... 29 3.5.4.2 Technology ................................................................................................................................ 31 3.5.4.3 Operations ................................................................................................................................. 31 3.5.4.4 Funding ..................................................................................................................................... 32

3.5.5 Ohio ................................................................................................................................................... 33 3.5.5.1 Governance ............................................................................................................................... 33 3.5.5.2 Technology ................................................................................................................................ 34 3.5.5.3 Operations ................................................................................................................................. 34 3.5.5.4 Funding ..................................................................................................................................... 35

3.5.6 Wisconsin .......................................................................................................................................... 35 3.5.6.1 Governance ............................................................................................................................... 35 3.5.6.2 Technology ................................................................................................................................ 36 3.5.6.3 Operations ................................................................................................................................. 36 3.5.6.4 Funding ..................................................................................................................................... 36

3.6 National Considerations ....................................................................................................... 36 3.6.1 NG911 NOW Coalition ...................................................................................................................... 36 3.6.2 National 911 Program NG9-1-1 Interstate Playbook ........................................................................ 38

4 NG9-1-1 Considerations and Implications ............................................................................. 39 4.1 Statutory, Regulatory, and Political Considerations and Implications ................................... 39

4.1.1 Provider Liability Protection ............................................................................................................... 39 4.1.2 Regulatory Environment .................................................................................................................... 41

4.1.2.1 Department Administrative Rules .............................................................................................. 41 4.1.2.2 ICC Rules for Service Providers ............................................................................................... 41

4.1.3 Political Environment ......................................................................................................................... 42 4.1.3.1 FirstNet Integration .................................................................................................................... 43 4.1.3.2 Governor’s Competitiveness Council ........................................................................................ 44 4.1.3.3 Government Affairs Liaison to Legislature ................................................................................ 45

4.2 Stakeholders ........................................................................................................................ 46 4.3 Technology Requirements and Considerations .................................................................... 48

4.3.1 PSAP Call Handling .......................................................................................................................... 48 4.3.2 GIS / Mapping ................................................................................................................................... 50 4.3.3 9-1-1 Providers .................................................................................................................................. 51 4.3.4 Service Providers .............................................................................................................................. 52 4.3.5 Standards .......................................................................................................................................... 52 4.3.6 Automated Information Systems ....................................................................................................... 52 4.3.7 Interfaces to Other Systems .............................................................................................................. 53 4.3.8 Security / Backup / Resiliency Considerations .................................................................................. 54

4.4 Operational Considerations and Implications ....................................................................... 54 4.5 Economic / Funding Considerations and Implications .......................................................... 55

4.5.1 Grants and Potential Funding Sources ............................................................................................. 55 4.5.1.1 Next Generation 9-1-1 Advancement Act Grants ..................................................................... 55 4.5.1.2 Other Federal Grant Funding .................................................................................................... 56

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4.5.2 Federal Grant Guidance .................................................................................................................... 57 4.5.2.1 Emergency Communications Preparedness Center Reference Guide .................................... 57 4.5.2.2 SAFECOM Grant Guidance ...................................................................................................... 57

4.5.3 Public–Private Partnerships .............................................................................................................. 58 4.5.4 Fund Diversion .................................................................................................................................. 59

5 Recommendations / Options ................................................................................................. 60 5.1 NG9-1-1 Guiding Principles ................................................................................................. 60

5.1.1 Themes ............................................................................................................................................. 60 5.1.2 Guiding Principles ............................................................................................................................. 61 5.1.3 Desired Outcomes............................................................................................................................. 62 5.1.4 Vision ................................................................................................................................................. 62

5.2 Illinois NG9-1-1 Operational Vision ...................................................................................... 63 5.2.1 Consolidation ..................................................................................................................................... 63 5.2.2 Staffing .............................................................................................................................................. 63 5.2.3 Mutual Aid Agreements and Memoranda of Understanding ............................................................. 64 5.2.4 Multimedia ......................................................................................................................................... 64 5.2.5 Training ............................................................................................................................................. 64 5.2.6 Consistent Level of Service ............................................................................................................... 64 5.2.7 Policies and Procedures ................................................................................................................... 64

5.3 Illinois NG9-1-1 Technical Vision ......................................................................................... 64 5.3.1 ESInet ................................................................................................................................................ 65

5.3.1.1 Carrier-based Network .............................................................................................................. 65 5.3.1.2 Public-provided Network ........................................................................................................... 66 5.3.1.3 NG9-1-1 Core Services ............................................................................................................. 67 5.3.1.4 Access ....................................................................................................................................... 70 5.3.1.5 Diversity and Redundancy ........................................................................................................ 70 5.3.1.6 Quality of Service ...................................................................................................................... 71 5.3.1.7 Security ..................................................................................................................................... 71 5.3.1.8 Interstate / Intrastate Operability ............................................................................................... 71

5.3.2 Next Generation Core Services ........................................................................................................ 71 5.3.2.1 Spatial Interface ........................................................................................................................ 72 5.3.2.2 Location Validation Function and Location Information Server ................................................ 72 5.3.2.3 Border Control Function ............................................................................................................ 72 5.3.2.4 Legacy Network and PSAP Gateways ...................................................................................... 72 5.3.2.5 Call Routing Functions .............................................................................................................. 72 5.3.2.6 Additional Data Repositories ..................................................................................................... 73 5.3.2.7 Hosted Call Handling ................................................................................................................ 73 5.3.2.8 Text-to-9-1-1 and Video ............................................................................................................ 73

5.4 Implementation Vision .......................................................................................................... 73 5.4.1 NGCS Buildout .................................................................................................................................. 74 5.4.2 GIS Development .............................................................................................................................. 74 5.4.3 ESInet Buildout.................................................................................................................................. 74 5.4.4 PSAP Connections ............................................................................................................................ 75 5.4.5 Geospatial Routing ............................................................................................................................ 75

5.5 Statutory, Regulatory, and Political Environment ................................................................. 75

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5.5.1 Statutory Environment ....................................................................................................................... 75 5.5.2 Regulatory Environment .................................................................................................................... 76

5.5.2.1 Department Administrative Rules .............................................................................................. 76 5.5.2.2 ICC Rules for Service Providers ............................................................................................... 76

5.6 Illinois NG9-1-1 Economic / Funding Vision ......................................................................... 77 5.6.1 State-level Procurement .................................................................................................................... 77 5.6.2 Funding ............................................................................................................................................. 78

5.6.2.1 Current Revenue ....................................................................................................................... 78

Appendix A – Summary of Town Hall Meetings ........................................................................... 80 State of Illinois – NG9-1-1 Town Hall Meeting Themes .................................................................. 80 DuPage County .............................................................................................................................. 83 DeKalb County ............................................................................................................................... 87 Peoria County ................................................................................................................................ 89 Sangamon County ......................................................................................................................... 91 Effingham County .......................................................................................................................... 93 Williamson County ......................................................................................................................... 95 Chicago .......................................................................................................................................... 99

Appendix B – Survey Details ..................................................................................................... 101

Appendix C – Detailed Statutory and Regulatory Gaps and Considerations .............................. 102 Definitions and Terms .................................................................................................................. 102 GIS Conversion ............................................................................................................................ 104 Data Collection ............................................................................................................................. 105 Integrated Governance Policy Suite ............................................................................................. 106 Security ........................................................................................................................................ 107

Appendix D – Statutory Alignment ............................................................................................. 109 Public Act 100-0020 ..................................................................................................................... 109

Appendix E – ICC Rules Review and Assessment .................................................................... 167

Appendix F – Department Administrative Rules......................................................................... 243

Appendix G – Cooperative Agreements..................................................................................... 306 Cooperative Agreements or Memorandum of Understanding ....................................................... 306 The Need for an ICA/MOU ........................................................................................................... 306 Writing an ICA/MOU ..................................................................................................................... 307 What an ICA/MOU Should Include ............................................................................................... 308

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Table of Figures

Figure 1: Stakeholder Composition ................................................................................................................. 9 Figure 2: NG9-1-1 Challenges ....................................................................................................................... 10 Figure 3: Priority Needs ................................................................................................................................. 11 Figure 4: Priority Three and Four Needs ....................................................................................................... 12 Figure 5: CPE Status ..................................................................................................................................... 14 Figure 6: Missouri 911 Funding Map ............................................................................................................. 32 Figure 7: Gap Analysis and Next Steps ......................................................................................................... 38 Figure 8: NG9-1-1 Stakeholders .................................................................................................................... 48 Figure 9: Potential CPE Upgrade Needs ....................................................................................................... 49 Figure 10: NG9-1-1 Themes .......................................................................................................................... 61 Figure 11: Guiding Principles ......................................................................................................................... 62 Figure 12: General Timeline .......................................................................................................................... 74

Table of Tables

Table 1: Stakeholders ...................................................................................................................................... 9 Table 2: 9-1-1 Service Providers in Illinois .................................................................................................... 16 Table 3: Disbursement of Funds .................................................................................................................... 21 Table 4: Total Revenue Received / Distributed FY2017 ............................................................................... 23 Table 5: NG9-1-1 Stakeholder Needs ........................................................................................................... 46 Table 6: Advantages and Concerns of Public-Private Partnerships ............................................................. 58 Table 7: Carrier-based Networks ................................................................................................................... 66 Table 8: Public-provided Network .................................................................................................................. 66 Table 9: Hosted NGCS .................................................................................................................................. 67 Table 10: In-network NGCS ........................................................................................................................... 68 Table 11: Single-Source NGCS ..................................................................................................................... 69 Table 12: Multi-vendor NGCS ........................................................................................................................ 69 Table 13: Rough Order of Magnitude Cost Estimation .................................................................................. 70

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Executive Summary

Mission Critical Partners, Inc. (MCP) is pleased to present the Next Generation 9-1-1 (NG9-1-1) Feasibility Study to the Illinois State Police (ISP) Statewide 9-1-1 Bureau and the Statewide 9-1-1 Administrator. The Statewide 9-1-1 Administrator, with the advice and recommendation of the Statewide 9-1-1 Advisory Board, has been directed, by legislation, to develop and implement a statewide NG9-1-1 network by July 1, 2020. The State mandate for NG9-1-1 transition is intended to improve 9-1-1 call delivery, enhance interoperability, improve communications between 9-1-1 service providers, and support additional caller information, photos and other data. The 9-1-1 infrastructure and public safety industry as a whole are in a state of transition. The legacy 9-1-1 infrastructure utilizes aging technology and systems that are nearing end-of-life. Wireless and voice over Internet Protocol (VoIP) technology today is required to be modified to access the legacy infrastructure. The infrastructure today is unable to support new and emerging technology such as text messaging, image and video sharing. Because of the need to advance the legacy 9-1-1 infrastructure, NG9-1-1 technology and standards have been developed. NG9-1-1 is being adopted by states and jurisdictions and many are in some phase of evaluation, planning, or implementing an NG9-1-1 infrastructure. Transition to NG9-1-1 is not an easy task and requires a phased approach, including review of current state, desired future state, and steps for achieving the desired outcome. This document addresses each phase by focusing on regulation and policies, funding, technology, and operational environments in the state of Illinois. Vision MCP completed research via surveys, town hall meetings, interviews, and legislative document review to establish an understanding of the current state of the 9-1-1 environment and infrastructure in Illinois and identify recommendations for moving forward. Stakeholders and participants in the town hall meetings helped develop a vision for NG9-1-1:

To have a ubiquitous NG9-1-1 service and to provide each 9-1-1 caller with the same level of service for all residents and visitors in the state, regardless of location or device.

This vision was set to help define what a successful implementation of a statewide NG9-1-1 network would look like. In addition to the vision, guiding principles were developed to set benchmarks for achievement of the overall objective.

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These principles will help guide the State and decision-makers as they plan and implement NG9-1-1. In addition to establishing an overall vision for providing ubiquitous 9-1-1 service across the state, MCP identified priorities within the different stakeholder groups to ensure successful deployment of NG9-1-1. Those identified in sequential order were 1) funding; 2) comprehensive planning; 3) statewide collaboration; and 4) technical standards and technical assistance. Current Environment The research and identification of priorities provided valuable insight into the current 9-1-1 infrastructure within Illinois and helped establish an understanding of the current environment. It also formed the framework for the next steps recommended for successful execution of the milestones needed to achieve the vision and objectives set for NG9-1-1 in the state of Illinois. This section of the study provides an overview of the Illinois statutory and regulatory, stakeholder, technical, operational, and funding environments.

GUIDING PRINCIPLES

Strategic vision must address ALL of 9-1-1 needs, not just NG9-1-1

Broad stakeholder engagement is desired at all levels

Robust functionality is of paramount importance

Services must be improved, not degraded

Sustainable funding is essential to carry out the mission

Reliability, resiliency and sustainability is critical to success

Regional capabilities/initiatives must be leveraged

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NG9-1-1 Assessment, Considerations, and Implications This section of the study provides an assessment of the considerations related to transitioning to an NG9-1-1 environment. Statutory, Regulatory, and Political Assessment and Considerations Some Illinois service providers have expressed concern with the lack of or limited provider liability in Public Act 99-0006. Department administrative rules and Illinois Commerce Commission (ICC) rules have been reviewed and evaluated after Public Act 99-0006 was introduced, and is currently being revisited for 100-0020. The State should conduct a thorough and extensive review of existing statutes and supporting ICC rules along with the Department administrative rules to ensure consistency in language and references and that no language exists that could hinder the adoption of NG9-1-1 technology statewide. The primary objective of the Department is to improve 9-1-1 service in Illinois. With this, there are many steps that need to be achieved to support this objective and funding is integral to successfully completing the steps. As such, the Department should quickly establish program priorities to help ensure funds and milestones are set to meet the objectives of the Department. Stakeholders In an NG9-1-1 environment there is a need for greater stakeholder engagement. Operational, Political, Technical, Fiscal, and Community stakeholders will all need to remain abreast of changes with the transition to NG9-1-1 and ensure proper training, procedures, policies, and communication efforts are developed and maintained throughout implementation efforts and beyond project completion. Technology Assessment, Requirements, and Considerations NG9-1-1 is based upon i3 standards and, as such, i3 capabilities are an important consideration with each technology component recommended in preparing for a successful implementation of a statewide NG9-1-1 network. Numerous standards have been documented to support the transition to i3, and these standards should be considered when developing Request for Proposal (RFP) requirements in support of procuring new equipment and building an Emergency Services Internet Protocol (IP) network (ESInet) and Next Generation Core Services (NGCS) solutions. Establishment of a statewide geographic information system (GIS) initiative to provide definitive guidance on the requirements, frequency for updates, and quality standards for GIS data for public safety use in NG9-1-1 should begin as early as possible. Operational Assessment and Considerations Each Emergency Telephone System Board (ETSB) is best placed to determine the operational needs of their respective public safety answering points (PSAPs). Each ETSB should develop plans for their PSAPs

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to address the minimum level of service determined by the State. This would include alternate media, routing, and call processing. Economic / Funding Assessment and Considerations There are numerous grants and potential funding sources that support the planning and implementation of a statewide NG9-1-1 plan. As such, the State may consider several different sources outlined in this section to help support the efforts being planned. Fund diversion has become a significant topic and a point of contention among state and local authorities. Every effort should be made to ensure that funds collected for 9-1-1 purposes are not used for non-9-1-1-related activities or programs if the Department intends to apply for any federal grants. There is concern that the potential for the governor to designate a 5 percent “reserve” of funds appropriated to the Department, as called for in Public Act 100-0023, could jeopardize Illinois’ ability to receive federal funding in the future. Conclusion The State of Illinois is in a position to successfully plan, transition, and implement a statewide NG9-1-1 network. This will not be an easy task and requires detailed planning, prioritization, and collaboration across multiple groups and organizations. The Department should consider undertaking strategic planning activities that will help guide all aspects of 9-1-1 and NG9-1-1 implementation, management, administration, and funding. All parts of the Department’s responsibilities need to be cohesive and coordinated. MCP recommends development of an Illinois NG9-1-1 strategic plan to tie goals, desired outcomes, and financial structures into a comprehensive path forward for the state. MCP recommends the Department finalize the strategic plan for the future of NG9-1-1 in Illinois.

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1 Background

The State of Illinois (State) 9-1-1 Administrator, with the advice and recommendation of the Statewide 9-1-1 Advisory Board, has been directed by legislation to develop and implement a statewide Next Generation 9-1-1 (NG9-1-1) network by July 1, 2020. This direction came with the adoption of Public Act 99-0006, which amended the Emergency Telephone System Act and repealed the Wireless Emergency Telephone Safety Act. This was done, as a first step, to encourage the consolidation of the state’s 253 public safety answering points (PSAPs) in preparation of the next generation migration. The state mandate is that the next generation implementation should be a hosted solution that meets National Emergency Number Association (NENA) requirements and standards and, at a minimum, provides improved 9-1-1 call delivery, enhanced interoperability, increased ease of communication between 9-1-1 service providers, and allows immediate transfer of 9-1-1 calls, caller information, photos, and other data. In 2016, the Illinois State Police (ISP), Office of the Statewide 9-1-1 Administrator, sought proposals for consulting services to complete an NG9-1-1 feasibility study for the state of Illinois. Being uniquely positioned to conduct a study of the implications, costs, and considerations of next generation emergency telephone communications, Mission Critical Partners (MCP) was awarded the contract to support the State on December 21, 2016. The three phases of the project are as follows: • Phase 1: Feasibility study and procurement recommendation • Phase 2: Development of a Request for Proposal (RFP) for an NG9-1-1 system network provider,

assistance with contract negotiations, and technical discussions with the prospective provider • Phase 3: NG9-1-1 system network implementation oversight and system acceptance testing During Phase I, the feasibility of NG9-1-1 was assessed and a procurement recommendation is being made. This phase focuses on the current 9-1-1 system in Illinois, including the regulatory and funding framework and the technical and operational environments.

2 Methods

To gather the extensive amount of data that is necessary to truly assess the current system, several different methods of data collection were used. Surveys were sent to the PSAPs, town hall meetings were held across the state, interviews were conducted, and vast research efforts were performed so the current environment could be fully understood, and assessments made. 2.1 Town Halls / Interviews Town hall meetings were scheduled and conducted throughout the state. The locations for the town hall meetings were chosen based on geographical location to ensure representatives from each PSAP had

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access to at least one. Meetings were held in DuPage, DeKalb, Peoria, Sangamon, Effingham, and Williamson counties and the city of Chicago. Each meeting was slated for three hours and focused on discussing the project, which included system requirements, keys to successful implementation, barriers to success, transitional needs, and desired features and functions. A full overview of themes derived from the town hall meetings can be found in Appendix A–Summary of Town Hall Meetings. 2.2 Survey In April 2017, an online survey tool was distributed to all PSAPs in Illinois via the Statewide 9-1-1 Administrator. The survey was broken down into six sections: • General Information • Customer Premise Equipment (CPE) • Computer Aided Dispatch (CAD) • Geographic Information System (GIS) • Facilities • Policy, Governance, and Fees The survey was designed to take approximately 20 minutes and allowed each PSAP to share information regarding their current environment and needs to be successful in an NG9-1-1 environment. The survey was disseminated to all Emergency Telephone System Boards (ETSBs) to coordinate with their PSAPs throughout the state; however, only those PSAPs that knew they would be in operation in the year 2020 were asked to complete and submit the survey. PSAPs that are part of or will be part of consolidation efforts did not have to respond. A total of 182 responses to the survey were received; 176 primary PSAPs and 6 secondary or backup PSAPs. A full overview of survey data can be found in Appendix B–Survey Details. 2.3 Research While the town hall meetings and surveys provided an insight to the PSAPs throughout the state and their day-to-day operations, concerns, and visions, there was data on a state-level that needed to be obtained to provide a wholistic picture of today’s environment and what future success looks like. Research was conducted by meeting with State officials involved in emergency communications and information technology (IT). Legislation and regulations documents were reviewed. Documents, provided on the Office of the Statewide 9-1-1 Administrator1 website, were referenced and used to draw conclusions on the current environment and were used to develop the future visions. Documents included: Statewide 9-1-1 Advisory Board Meeting Minutes; the 2016 and 2017 Advisory Board’s Report to the General Assembly;

1 http://www.isp.state.il.us/statewide911/statewide911.cfm

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the Illinois Administrative Code, Section 83, and the “Agency-specific Content for the Notice of Funding Opportunity” form. Access to these and other documents provided by the Statewide 9-1-1 Administrator were extremely helpful in the development of this study.

3 Current Environment

3.1 Statutory, Regulatory, and Political Environment The previous legislative session initiated dramatic changes to the 9-1-1 landscape in Illinois. Public Act 99-0006 merged the requirements of the wireline 9-1-1 law known as the Emergency Telephone Safety Act (50 ILCS 750) and the wireless 9-1-1 law known as the Wireless Emergency Telephone Safety Act (50 ILCS 751) into the Emergency Telephone System Act (ETSA) (50 ILCS 750), and amended the Department of State Police Act. The pre-paid 9-1-1 law known as the Prepaid Wireless Surcharge Act (50 ILCS 753) still remains standalone. Many of the changes in Public Act 99-0006 created new requirements for the State and 9-1-1 community. The Office of the Statewide 9-1-1 Administrator was created within the Department of State Police (Department) and is responsible for developing, implementing, and overseeing a uniform statewide 9-1-1 system for all areas of the state outside of jurisdictions having a population of more than 500,000. The statewide 9-1-1 program was transferred from the Illinois Commerce Commission (ICC) to the Department effective January 1, 2016. The 9-1-1 Services Advisory Board duties transitioned to the Statewide 9-1-1 Advisory Board, whose members were appointed by the governor and work under purview of the Department. In July 2017, Public Act 99-0006 was replaced by Public Act 100-0020 (100-0020), which amended the ETSA. The latest legislative activity extended the repeal date of the existing ETSA to 2020, and updated the funding for 9-1-1 and NG9-1-1. In Chicago, the Office of Emergency Management and Communications (OEMC) is the City’s lead agency for managing large, complex events and emergency situations. OEMC coordinates local, state, federal, and non-government organizations; operates communications systems; and provides technological services to support the City of Chicago. OEMC operates the 9-1-1 center and the 3-1-1 call center for City services, coordinates traffic management, manages major incidents, and provides primary planning and direction for emergency and non-emergency events in support of other City departments. OEMC provides and maintains a number of IT systems to support the 9-1-1 emergency communications operation, including CAD and associated mapping, camera media, and mobile data communications systems. These systems are used in the processing, dispatching, and tracking of all emergency calls received by the 9-1-1 center. These systems are the primary tools used by call takers, dispatchers, and supervisors; they are also used by emergency responders in the Chicago Police and Fire Departments, and by management of OEMC, police, and fire resources.

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3.1.1 Regulatory Environment 3.1.1.1 Department Administrative Rules Administrative rules are in place for the previous legislation. These rules have been guiding operational and functional elements of the program since the passage of the recent changes to the ETSA over the past two years. Appendix F–Department Administrative Rules provides the administrative rules, references for standards and industry best practices, and recommendations to align current administrative rules. 3.1.1.2 ICC Rules for Service Providers Oversight of the telecommunications and 9-1-1 service providers was left with the ICC in Public Act 100-0020. A high-level assessment of the current ICC rules was conducted. MCP reviewed current language in Title 83: Public Utilities, Chapter I: Illinois Commerce Commission; Subchapter f: Telephone Utilities, Parts 725, 730, and 735; determined whether a federal guideline, standard, or best practice could be referenced; and assessed whether the current ICC rule text was in alignment with those guidelines or standards. The rules were reviewed to evaluate the current text to determine whether changes might be warranted as Illinois moves toward NG9-1-1. Appendix E–ICC Rules Review and Assessment provides a review of the current statute and regulations related to 9-1-1 and the Department’s authority. The review contains statute text, the legislative reference number, a summary statement about what the section discusses, national standards or best practices references that support or address what the statute text accomplishes, and MCP’s interpretation of whether the statute text poses any issues for NG9-1-1 feasibility. It may also include any considerations that MCP feels the Department should contemplate as the state moves forward to NG9-1-1 implementation. Any statute change can potentially impact these rules, which will require update and revision. The ICC, as the authority for administration and monitoring of the technical requirements for 9-1-1 service providers in the state, will need to work with the Department as the rules are revised to ensure continuity and seamless integration between rules for providers and the vision for statewide services. As with the Department’s 9-1-1 administrative rules, ICC has done an excellent job of establishing telecommunications-related regulations that apply to the current legacy systems and, to some extent, help to transition 9-1-1 systems to NG9-1-1 services. The rules provide direction for telecommunications service providers (with some minor exceptions) and establish lines of responsibility, demarcation, and authority. Interviews with the ICC reveal that more is needed in this area when a specific NG9-1-1 comprehensive plan is completed and the direction is well understood. 3.2 Stakeholders Currently several stakeholders throughout the state are involved in 9-1-1 operations and decisions. These stakeholders fall into five categories: operational, political, technical, fiscal, and community. Each group of stakeholders represents a different role in the 9-1-1 system.

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Table 1: Stakeholders

Stakeholder Category Responsibilities

Operational Deal with the day-to-day operations in a center, both on a local and state level

Political Are responsible for the legislation decisions affecting the operations of

9-1-1; approve budgets to ensure emergency communications are properly funded

Technical Are responsible for the technical aspects of the 9-1-1 systems

Fiscal Help prepare budgets and ensure that procurements are done with the best interest of the operational aspects

Community Expect and rely on the services of the PSAP

Figure 1: Stakeholder Composition

Stakeholders in the City of Chicago include residents, tourists, and visitors; businesses that operate in the city; OEMC and PSAP staff; 9-1-1 equipment and infrastructure providers; and first responders. 3.2.1 Stakeholder-identified Challenges to NG9-1-1 Implementation The survey and town hall meetings sought to identify the three biggest challenges (priorities) for NG9-1-1 implementation for local agencies.

Operational

•Call Takers / Dispatchers

•PSAP Leadership•First Responders•Statewide 9-1-1 Administrator

•Statewide 9-1-1 Bureau

• ISP Leadership

Political

•Governor •State Legislators•Local Elected Officials

•ETSBs

Technical

• ICC •Statewide 9-1-1 Administrator

•Statewide 9-1-1 Bureau

•Service Providers•Vendors•Chief Information Officers (CIOs)

• IT Staff•Local Network Staff

Fiscal

• ICC•Statewide 9-1-1 Administrator

•Statewide 9-1-1 Bureau

•Procurement Officers

•Budget Personnel

•ETSBs

Community

•Statewide 9-1-1 Advisory Board

•Citizens•Civic Organizations

•Special Needs Community

•Tribal Community

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3.2.1.1 Funding When asked to identify the top priority, the response was overwhelmingly focused on one key area that plagues most 9-1-1 authorities across the country—funding. Of the PSAPs responding, nearly two-thirds of the 9-1-1 authorities (62 percent) identified funding as their most significant hindrance.

Figure 2: NG9-1-1 Challenges

3.2.1.2 Comprehensive Planning When asked to identify the second highest priority for achieving NG9-1-1 implementation, the responses were more balanced, but comprehensive planning emerged as the most common response. However, the responses as a whole appear to demonstrate that 9-1-1 authorities within the state are cognizant of the need to conduct fundamental planning on a level greater than their own jurisdictions. While individual planning within their own authority is necessary, it must be done in collaboration with the State and neighboring PSAP jurisdictions for the results of the planning to be successful.

Common radio system

0%

Communication and involvement from the State

6%Comprehensive

planning9%

Funding support62%

Operational standards

1%

Other0%

State Mandated Consolidation

1%

Statewide collaboration

7%

Technical assistance8%

Technical standards5%

Traning1%

NG9-1-1 Challenges

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Figure 3: Priority Needs

Comprehensive planning is especially important in NG9-1-1, and these survey results reflect a mature attitude and high level of understanding among 9-1-1 authorities in Illinois. The significance of this finding illustrates a strong desire on the part of 9-1-1 authorities responding to this survey to participate in comprehensive planning and demonstrates their keen sense of the need to look at a bigger picture to achieve the most effective 9-1-1 program in Illinois. 3.2.1.3 Statewide Collaboration and Technical Standards / Assistance When asked to identify the third and fourth highest priorities for successful NG9-1-1 implementation in Illinois, statewide collaboration and technical standards/technical assistance were cited most often. These needs are seen by the respondents as being linked, and speak to the 9-1-1 jurisdictions’ expectations and reliance on a strong statewide 9-1-1 program. • Statewide Collaboration: While the 9-1-1 Program only has been in existence in its present form for two

years, and many of the activities assigned to the Department have not yet stood the test of time, the Department has made a significant impact on coordinating 9-1-1 service throughout the state and fulfilling the requirements of the current legislation. This progress is obviously felt by survey respondents and is encouraging to note. Statewide collaborative efforts can be truly successful only if

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the other key stakeholders, i.e., the local 9-1-1 authorities, are receptive of the direction and guidance offered by that statewide collaboration. Today, the 9-1-1 authorities are working in concert with their neighboring jurisdictions and the State. Collaboration is seen as a key to successful NG9-1-1 implementation.

• Technical Standards and Assistance: As part of the statewide guidance and collaboration

demonstrated by the Department and desired by the local 9-1-1 authorities, the value of technical standards and technical assistance is noted in the survey results. Local 9-1-1 authorities generally are willing to follow the State’s guidance, primarily because ongoing funding hinges on the inter-relationships and cohesive implementation that NG9-1-1 requires, but also because, as educated providers of the service in their local communities, they understand this methodology is the most productive and cost effective. 9-1-1 authorities look to the State to continue to provide and even expand its role of supplying the technical requirements, standards, overarching design and vision for the interconnecting of local systems. Local 9-1-1 authorities also rely on the State to provide the technical assistance necessary to assure the effectiveness of those interconnections, and expect (and accept) that as a necessary role of the Department.

Figure 4: Priority Three and Four Needs

Communication and involvement

from the State12%

Comprehensive Planning

17%

Connectivity0%

Funding Support

8%

PSAP Interoperability

0%

Operational Standards

10%

Benefits Use Cases0%

Statewide Collaboration

16%Interop Policies

3%

Technical Assistance

14%

Technical Standards

15%

Training 4%

Other (Future Maintenance & Replacement)

1%

Priority Three and Four Needs

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3.3 Technology Environment 3.3.1 PSAP Call Handling In 2016, 202 Illinois PSAPs answered over 9.7 million 9-1-1 calls from wireless, wireline, and voice over Internet Protocol (VoIP) phone subscribers. In the same period, over 4,100 text messages were delivered to 40 PSAPs that currently support text-to-9-1-1 service. An analysis of the agencies served by PSAPs in Illinois found the following: 100 percent handle law enforcement calls, 92 percent handle fire calls, 87 percent handle calls for emergency medical services (EMS) assistance, and 20 percent handle calls for other agencies. The Illinois PSAP community ranges in size from single seat PSAPs to areas with 200 call taking workstations, demonstrating the diversity in population centers and confirming the need to ensure flexibility of future solutions. While a significant effort to consolidate PSAPs is underway, it is notable to report a sizeable majority of the PSAPs in Illinois have five positions or less, and the benefit of further consolidations exist. Not only are PSAPs diverse in size, but also in technology. A representative sample of 182 PSAPs surveyed by MCP in 2017 reported 1,201 positions currently in operation, supported by 11 different equipment manufacturers. The 9-1-1 Operations Unit of OEMC serves as the City’s PSAP for fire, EMS and law enforcement incidents within the City. The 9-1-1 center is a consolidated 24-hours a day, 7-days a week, 365-days a year operation that functions in a split operational model; communications staff are assigned to either police operations or fire operations. Annually, the 9-1-1 center averages approximately 5 million emergency calls via 9-1-1 and approximately 100,000 non-emergency calls. Annually, the 9-1-1 center processes approximately 2.5 million incidents per year for police; approximately 90,000 incidents for fire; and approximately 300,000 incidents for EMS. The 9-1-1 center currently operates in a horizontal dispatch configuration for both fire and police; that is, there is a division of responsibilities between the call take and dispatch functions. Incoming 9-1-1 calls are answered by a call taker and then processed from that position. Dedicated dispatchers then assign field units to the calls for service and are responsible for all tasks associated with a respective incident. There are 136 call taker/dispatcher workstations within the OEMC 9-1-1 center. All call take positions have the critical technology necessary to receive and process incoming 9-1-1 calls; telephony CPE, CAD, and mapping. All dispatch positions have telephony CPE, CAD, mapping, and radio consoles. In Chicago, police is the primary PSAP for all incoming 9-1-1 calls; fire is a secondary PSAP. All incoming 9-1-1 calls into the 9-1-1 center are answered by a police call taker; if the event is police-related, the call taker processes the event, which is then sent via CAD to the appropriate police dispatcher. All calls for service that require a fire or medical response are transferred to a fire call taker. The 9-1-1 center dispatches all law enforcement resources within the City, with the exception of officers assigned to the

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Chicago Department of Aviation’s (CDA’s) O’Hare International Airport (O’Hare). Emergency calls from O’Hare airport property that hit the local exchange carrier’s public switch are received at the OEMC’s 9-1-1 center and are transferred to the Airport’s communications center. This includes all wireless 9-1-1 calls placed from within the airport property. Police call takers transfer all fire-related callers to a fire call taker if the event requires fire or EMS resources. The OEMC’s 9-1-1 center dispatches all City police and fire units assigned to CDA’s Midway International Airport. The CDA operates its own dispatch centers known as “Emergency Control Centers” at both O’Hare and Midway. The primary purpose of these centers is to support general airport operations and provide emergency response for both airports. The communications center at O’Hare is referred to as the O’Hare Communications Center (OCC) and the Control Center at Midway is referred to as MCC. The current CPE environment in the state suggests that 59 percent of the PSAPs do not have adequate technology, or may require additional licensing to support i3 call handling at the local level; the equivalent of 600 positions. Thus, requiring additional equipment to convert legacy analog to NG9-1-1 Session Initiation Protocol (SIP), using IP/centralized automatic message accounting (CAMA) gateways, until technology upgrades can be made.

Figure 5: CPE Status

3.3.2 Geographic Information System / Mapping In the current 9-1-1 PSAP environment, GIS data is used for mapping a caller’s location and supporting dispatch functions. Eighty-four percent of the PSAPs use this data within their CAD system, CPE, or both to support their operations. With the introduction of the NG9-1-1 environment, GIS takes on the additional role of supporting call routing functions. As such, GIS is a foundational data element for the overall operation of an NG9-1-1 solution, and requires an appropriate level of leadership attention. In Chicago, the current CAD system does not utilize GIS address maps. Location validation within its current CAD system utilizes a table-based geo-file for address verification. The geo-file is currently

0 10 20 30 40 50 60 70

1 to 56 to 10

11 to 2021 to 3031 to 4041 to 50

200+

CPE Status by Capability

i3 Compliant Upgrade/Potential Upgrade

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populated utilizing GIS mapping data (Esri 10.4.1) provided by the OEMC GIS department. The CAD mapping displays the location of wireline calls, Phase I wireless tower locations, and Phase II wireless caller locations. For wireless Phase II calls, the CAD system converts the caller’s location to the closest available street segment, providing the call takers with a range of addresses and the street name. The system enables users to zoom in and out and pan using mouse operation. Maps maintain centerline and boundary polygon data. There is an in-place Identity feature that displays information such as district, beat, area, and zone about a location. There is also an address find feature that centers the map on a location entered. The operator can locate units with operational global positioning system (GPS) devices and track the unit as it moves. GIS data meets the levels described in NENA 02-014, GIS Data Collection and Maintenance, and NENA 02-010, Data Formats for ALI Related Data Exchange, MSAG & GIS. At present, there is no mobile mapping integrated with OEMC’s CAD system in police or fire mobile computers. Police use Caboodle Mobile, a home-grown mapping application. GIS data is managed either directly by PSAPs or through local agency sources. In addition, both the Illinois Department of Transportation (IDOT) and the Illinois Department of Innovation and Technology (DoIT) have data sharing initiatives underway to foster collaboration at a statewide level. The HERE initiative managed by IDOT seeks to offer roadway data to create a single roadway or centerline data source at the state level. The Illinois First IT Strategy outlined by DoIT also includes a topic of focus for GIS by establishing a working group proposed to accomplish four initiatives: create a state agency spatial data catalog, establish collaboration and a knowledge portal, establish a cloud-based strategy and procurement channel, and build an enterprise Geocoding service. Any valuable data element, when allowed to lapse over time, will become inaccurate. Currently the GIS data is maintained at varying frequencies across the state, ranging from as needed to daily, and in several reported cases as infrequently as bi-annually and annually. Esri or Esri-based solutions account for over 60 percent of the GIS platforms used in Illinois. Within this group, only three users remain on 9.x versions of the software. Compliance with standards are important for planning and implementation. Currently 76 percent of the PSAPs self-report compliance with standards. While overall this percentage is high, efforts should be taken to verify independently to ensure an appropriate baseline from which to build upon. As reported by PSAPs, the overwhelming majority utilize three primary GIS data layers required for NG9-1-1: centerlines, address points, and boundary polygons. The maintenance of these layers is performed at the local level at varying frequencies; 75 percent of the PSAPs update their data either within a month or less, or on an as-needed basis. GIS quality should reach 98 percent or higher accuracy for use within an NG9-1-1 environment, more specifically geospatial call routing and for use with subscriber address validation. Many agencies in Illinois have undertaken initial steps to validate existing GIS data to legacy Master Street Address Guides

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(MSAGs) and automatic location identification (ALI) data to verify accuracy. Exercises such as the GIS/MSAG comparison are valuable in that it provides a starting point for GIS data accuracy improvement efforts as well as helping to shape quality assurance processes. For example, in Illinois, currently the average GIS centerline to MSAG match rate is 54 percent; a slightly lower 50 percent match rate when comparing the GIS address points to MSAG was observed. Each percentage, to be compliant with NG9-1-1 standards should be 98 percent or above. When considering a similar comparison of GIS to ALI data, the percentage of PSAPs who have undertaken the effort, as well as the data quality, is below 50 percent in each category. Leveraging GIS data in support of geospatial routing also requires seamless or contiguous boundaries. When disparate data sets are combined into a statewide data set, this requirement is critical to avoid gaps in coverage for routing and/or lack of clarity for call delivery. In regional and/or statewide NG9-1-1 deployment initiatives observed to date, programs have been developed and staffed, either by agency resources or third-party vendors early in the transition process. These programs are designed to work through source data agencies to consolidate disparate data, coalesce to a master data set owned by the authority, and perform quality assurance to achieve geospatial data of the quality and frequency necessary for NG9-1-1 use at the state or regional level. Currently there is no program in place to ensure gaps, overlaps, and quality metrics are met from a statewide data set. 3.3.3 9-1-1 Providers Nine 9-1-1 service providers currently operate in Illinois per ICC data, providing both legacy 9-1-1 services/solutions and regional NG9-1-1 services/solutions.

Table 2: 9-1-1 Service Providers in Illinois

9-1-1 Service Providers

Communications Venture Corporation d/b/a INdigital Telecom Illinois Bell Telephone Company

Consolidated Communications of Illinois Company NextGen Communications, Inc.

Frontier North Inc. NG-911, Inc.

Gallatin River Communications L.L.C. West Safety Communications Inc.

Geneseo Telephone Company

Today, the majority of ETSBs are supported by legacy 9-1-1 service providers; accounting for roughly 75 percent of Illinois’ active PSAPs. However, in the recent past, two notable regional groups have formed to forge ahead with NG9-1-1 solutions: the Counties of Southern Illinois (CSI) and the Northern Illinois NG

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Alliance (NINGA). Both solutions offer Emergency Services IP networks (ESInets)2, and some of Next Generation Core Services (NGCS) features, including: Emergency Call Routing Function (ECRF), Emergency Services Routing Proxy (ESRP), Legacy Selective Router Gateway (LSRG), Border Control Function (BCF), and integrated GIS for call routing. • CSI – Thirteen counties, serving 17 PSAPs, are supported by a next generation call routing solution

offered by NG-911 Inc. The solution has been in operation since June 2015. The solution leverages fiber network infrastructure to deliver an IP-based broadband network hosting NGCS while retaining the ability to interface with the legacy network supporting adjacent counties and agencies.

• NINGA – Eleven counties, serving 19 PSAPs, in a similar solution to the CSI network, offering an IP-based ESInet and next generation call routing solution delivered by NG-911 Inc.

9-1-1 service providers, through open forum discussions, have suggested it is imperative to ensure that the solution for NG9-1-1 in Illinois be i3 standards-based, and retain flexibility to support both time division multiplex (TDM) and IP egress to originating service providers (OSPs), as the majority still rely on TDM and Signaling System 7 (SS7)-based origination. 3.3.4 Originating Service / Infrastructure Providers Per ICC reports, the Illinois OSP landscape comprises 56 local exchange carriers (LECs) and 199 VoIP, competitive LECs (CLECs) and cellular providers. There are 39 selective routing solutions dispersed in 14 local access and transport areas (LATAs) across the state. These routing solutions include both legacy TDM and i3-capable technologies. Over 2,150 CAMA trunks, and 1,828 administrative lines are installed across all PSAPs that responded to the recent survey. In many PSAPs, CAMA trunks groups are separated for wireless and wireline classes of service, which is a product of legacy methods of operation at the introduction of wireless calls to PSAPs; this varies regionally across the United States. This method of trunk capacity management is no longer required in NG9-1-1. OSPs currently interface with selective routers by TDM. In some cases, OSPs may have the capability to establish IP connective ingress to the 9-1-1 call routing solutions; however, the capability is not enabled or in use. The Illinois Century Network (ICN), operated by DoIT, provides over 2,000 miles of owned/leased fiber throughout the state with the ability to reach all sites with a high-availability redundant backbone. In

2 NENA defines an ESInet as a managed IP network that is used for emergency services communications, and that can be shared by all public safety agencies. It provides the IP transport infrastructure upon which independent application platforms and core functional processes can be deployed, including, at a minimum, those necessary for providing NG9-1-1 services. ESInets may be constructed from a mix of dedicated and shared facilities, and may be interconnected at local, regional, state, federal, national, and international levels to form an IP-based internetwork (network of networks).

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addition to layer 1 support, ICN services include SIP trunking and multi-protocol label switching (MPLS) cloud services. DoIT also provides many existing direct connections to law enforcement agencies in support of the LEADs program. Initially connections were provided as T1, but a recent project has been initiated to convert connections to Metro-Ethernet (Metro-E). The current project is planned for completion in June 2018. Broadband connectivity was reported from 162 PSAPs with over 45 providers; this accounts for 90 percent of the PSAPs. Secondary broadband service was reported by 62 percent, while 33 percent reported tertiary connectivity ranging from 1.5 megabits (mb) to 10 gigabits (gb). 3.3.5 Automated Information Systems With the exception of five agencies, all Illinois PSAPs report the use of CAD solutions in their dispatch operations. Thirty-three different providers were reported by the responding agencies. Sixty-three percent of the CAD solutions in use have been installed within the last seven years, indicating a potential future need to focus on enhancements for PSAPs with aging infrastructure. Of the CAD solutions in place, 138 have interconnected or built-in management information system (MIS) capabilities; however, over three-quarters of the PSAPs do not share MIS data as part of normal operations. This may be due to the lack of emphasis on information sharing currently in the industry and the wide array of CAD and MIS solutions in place across the state. This also corresponds to the number of PSAPs that reported no existing CAD-to-CAD interface, indicating an opportunity to increase awareness and encourage collaboration. Information sharing can be a powerful tool to assist neighboring agencies and State 9-1-1 authorities in ensuring continuity and service as NG9-1-1 solutions take hold in the 9-1-1 environment, and is encouraged for systems and process improvements. Many of the same agencies reported the use of mobile and handheld devices provided by the agency as opposed to user-provided devices. User-provided devices have the potential to become more prevalent as the First Responder Network Authority (FirstNet) integration progresses nationally. In Chicago, the critical technology installed at the workstations is Northrop Grumman Altaris Gold 2.0 CAD, mapping, and Airbus DS VESTA 911 answering equipment with automated call distribution (ACD) capabilities. There are no radio consoles at the call take positions. The VESTA equipment, installed in 2012, is routinely updated by AT&T, the support and maintenance vendor. The call take positions are used to answer all incoming 9-1-1 and ten-digit calls, place outgoing calls, maintain speed dials, and place one-button transfer calls. The 9-1-1 answering equipment is capable of receiving Enhanced 9-1-1 (E9-1-1) call data. An interface to the CAD system allows the location of wireline calls, Phase I wireless tower locations, and Phase II wireless caller locations to be transferred to the CAD and displayed on the map. For wireless Phase II calls, the CAD system converts the caller’s location to the closest available street segment, providing the call takers with a range of addresses and the street name. The VESTA answering positions provide instant recall recording (IRR) for all phone calls.

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The City of Chicago originally purchased the existing CAD system in April 1993; deployment and go-live occurred in September 1995. The system was originally developed and purchased as a PRC Public Sector, Inc. system, which eventually was sold and is currently doing business as Northrop Grumman Information Technology based out of McLean, Virginia. The current Northrop Grumman CAD system software in use by Chicago is multi-discipline; the City uses the police (PCAD) and fire (FCAD) modules, and the Communications Front-End Computer System (CFCS). The logging recorder is connected to audio at each position. OEMC uses AURORA 2.2 HF2.2 as the MIS connected to the CPE to collect and analyze call data. In addition, all police call data is sent to a police-owned data warehouse that is integrated with many police applications to analyze the data. The OEMC provides data updates to the Chicago Police Department, Chicago Department of Transportation, Chicago Department of Innovation and Technology, Federal Bureau of Investigation, and Federal Bureau of Alcohol, Tobacco, Firearms and Explosives. Chicago’s first responders are equipped with in-vehicle computers and have wireless connectivity using a combination of private and commercial wireless networks with coverage available throughout most of the city. All emergency responder disciplines use CAD Mobile developed by Northrop Grumman from the Altaris Gold CAD software. Police also use a version of CAD Mobile that has been adapted for use on BlackBerry and Android smartphones by Northrop Grumman. Police personnel integrate CAD Mobile into secure images for both BlackBerry and Android devices. Police laptops and SmartPhones use commercial wireless networks. There are approximately 500 CAD handheld devices and 3,000 CAD mobile data computers in vehicles. Both Chicago airports use Airbus DC Sentinel 911 ES1000 answering equipment (Version 5.07); however, airport officials are considering replacing this system in the near future. The airports use a shared Intergraph CAD system (Version 9.2). O’Hare Airport uses Motorola Gold Elite radio dispatch consoles. The airports do not have a mobile data system. 3.4 Operational Environment Oversight of the statewide 9-1-1 system falls under the ISP, Office of the Statewide 9-1-1 Administrator, in accordance with ETSA, updated by Public Act 100-0020. The Office has been responsible since January 2016 for the development, implementation, and oversight of a uniform 9-1-1 system for all areas of the state outside of municipalities having a population over 500,000 people3. Therefore, the Statewide 9-1-1 Administrator is responsible for all 9-1-1 operations throughout the state, except for the City of Chicago.

3 http://www.isp.state.il.us/statewide911/statewide911.cfm

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3.4.1 Emergency Telephone System Boards Currently in Illinois there are several hundred ETSBs. These ETSBs are defined, by legislation, as “a board appointed by the corporate authorities of any county or municipality that provides for the management and operation of a 9-1-1 system within the scope of the duties and powers prescribed by Emergency Telephone System Act (ETSA)”.4 ETSBs throughout the state oversee the day-to-day operations of the 9-1-1 systems at PSAPs in their jurisdiction and provide fiscal, operational, and technological oversight. Title 83: Public Utilities, Chapter IV: Department of State Police, Part 1324: Consolidation of 9-1-1 Emergency Services5, effective January 1, 2016, directed consolidation throughout the state. There were three categories of consolidation that could be opted into during the consolidation application period: • Consolidation of an unserved county with an existing 9-1-1 authority and the creation of a Joint ETSB • Consolidation of either paper ETSBs or multiple ETSBs, resulting in the creation of a Joint ETSB and

consolidation of individual PSAPs • Consolidation of PSAPs within an ETSB

In Chicago, OEMC’s 9-1-1 center operates under the authority of the Chicago ETSB, which has five members appointed by the mayor. The State is now mainstreaming ETSBs and processing consolidation applications and requests. There are still ETSBs in the process of deciding how many PSAPs they will consolidate to. The State is actively working to help those areas where there are roadblocks or challenges in the review and decision process. 3.4.2 Geographic, Populations, and Resource Availability Illinois is the fifth most populous state in the United States, with a population of nearly 12.8 million6 residents, covering a total area of 57,914 square miles. Illinois’ largest city is Chicago, with a population of 2.7 million of the 102 counties in Illinois, when assessing population, Cook County is the largest with a population of 5.2 million; Hardin County is the smallest with a population of just over 4,000. When assessing by land mass, McLean County is the largest, 1,186 square miles; Putnam County is the smallest with 172 square miles. According to the surveys submitted, the smallest PSAPs in the state have only one position in their center, while the largest system has over 200 positions. With such a mix of urban, suburban, and rural communities in Illinois, there are anomalies that make it difficult to ensure the same level of service throughout the state for 9-1-1 access and care. 4 http://www.isp.state.il.us/docs/83IAC1325.pdf 5 http://www.ilga.gov/commission/jcar/admincode/083/08301324sections.html 6 https://www.census.gov/quickfacts/IL

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3.4.3 Economic / Funding Environment Public Act 99-0006 changed the method of funding 9-1-1 in Illinois. Beginning January 2016, the State began collecting the 9-1-1 surcharge for wireline, VoIP, and prepaid and postpaid wireless for all areas of the state except Chicago. Previously only the prepaid and postpaid wireless surcharge was remitted to the State and local authorities were responsible for setting and collecting the wireline and VoIP surcharges. In July 2017, Public Act 100-0020, which replaced Public Act 99-0006, increased the fee beginning in 2018 from $0.87 to $1.50 for wireline, wireless, and VoIP and 3 percent per transaction for prepaid wireless.7 As a 9-1-1 authority in a municipality with a population in excess of 500,000, per Public Act 100-0020, the City of Chicago collects its own 9-1-1 fee, which is set at $5.00 for wireline, wireless, and VoIP and 9 percent per transaction for prepaid wireless. The fee collected in Chicago is not part of the Statewide 9-1-1 Fund. Public Act 100-0020 permits landline, VoIP and LEC-type service providers to deduct and retain an amount not to exceed 3 percent of the surcharge collected each month as reimbursement for collecting and remitting the fee. After 2021, wireless carriers will also be permitted to deduct and retain an amount not to exceed 3 percent. All funds collected are kept in a dedicated account known as the Statewide 9-1-1 Fund. Funds are distributed from this account each month according to priority levels established in Public Act 100-0020. The priority distributions detailed under Section 30 (b) (1) are listed in order in Table 3 below.

Table 3: Disbursement of Funds

Disbursements under Section 30 (b) (1)

(A) Portion for Counties Under 100k $0.013

(B) To Wireless Carrier Reimbursement Fund $0.026

(C) Department Administration ($0.007 until December 31, 2017) $0.017

(D) NEW: Wireless Fixed (12 cents Through 7/1/2020) $0.012

(E) NEW: Grants for NG9-1-1 Expenses (5 Cents Through 6/30/2020) $0.05

(F) NEW: NG9-1-1 Expenses (13 cents after 7/1/2020) $0.13

As displayed in the table above, $0.013 is distributed monthly to each County ETSB with a population under 100,000 according to the most recent census data, which is authorized to serve as a primary

7 Assessed per Section 15 of the Prepaid Wireless 9-1-1 Surcharge Act PA 97-463.

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wireless 9-1-1 PSAP. $0.026 is deposited into the Wireless Carrier Reimbursement Fund. It should be noted that the amount deposited in this fund decreases each year and is scheduled to end in July 2021. Until December 31, 2017, $0.007 and on and after January 1, 2018, $0.017, shall be used to cover the Department's administrative costs. $0.12 is distributed as a proportional grant based upon zip code to the 9-1-1 authority taking wireless calls. After June 30, 2020 this amount drops to $0.04. In some areas of Illinois wireless calls are handled by the state police. $0.05 is set aside for NG9-1-1 grants through June 30, 2020, for those areas within the territory of a large electing provider. Finally, after 2020, $0.13 is set aside for NG9-1-1 expenses. After these disbursements detailed in Section 30 (b) (1) have been calculated, the money remaining is distributed according to the priorities set in Section 30 (b) (2), as detailed below. • (A) Wireline/ VoIP; Hold Harmless Level • (B) 9-1-1 Network Costs • (C) ISP for RFI / RFP / Administrator / Advisory Board Costs • (D) Portion set aside for 9-1-1 Grants / NG9-1-1 • (E) Remaining surcharge to all 9-1-1 systems Public Act 100-0020 calls for funds to be distributed to the 9-1-1 authorities that imposed local surcharges prior to Public Act 99-0006; this is referred to as the “hold harmless level.” These 9-1-1 authorities are to receive an amount equal to the average monthly wireline and VoIP surcharge revenue attributable to the most recent 12-month period reported to the Department for the October 1, 2014, filing. Counties that did not impose a surcharge receive an amount equal to their population multiplied by 0.37, multiplied by the rate of $0.69. Counties without 9-1-1 service that had a surcharge in place receive an amount equal to their population multiplied by 0.37 and then multiplied by the amount of their surcharge. Public Act 100-0020 allows the Department to hold funds in reserve for grants, as described in Section 15.4b of the Act, and NG9-1-1 expenses up to $12.5 million in both 2016 and 2017, up to $20 million in 2018, and $20.9 million in 2019. Beginning in 2020, the Act provides a cap on the amount held in reserve through 2023 when it stays at $17 million per year. In addition, the Act requires a minimum of $6.5 million to be held in reserve for fiscal years (FYs) 2018 and 2019. MCP interprets this to mean that there is no financial limit on the amount the Department can expend each month to implement NG9-1-1 by 2020; and, the Department may also hold in reserve the amounts detailed in Public Act 100-0020 Section 30 (b) (2) (D) each year. This would reduce the amount of funds available for distribution under Section 30 (b) (2) (E). All remaining funds are to be distributed as monthly proportional grants to the 9-1-1 authorities taking wireless calls. In 2016, all revenue received was expended without any funds being set aside for future NG9-1-1 expenditures. Table 4 below illustrates the percentage of the total revenue received and distributed in FY2017 for each line item.

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Table 4: Total Revenue Received / Distributed FY2017

Disbursements under Section 30 (b) (1) Percentage of Revenue

(A) Portion for Counties Under 100k 1.31%

(B) Wireless Carrier Reimbursement Fund 3.33%

(C) Department Administration 0.71%

NEW: (D) Wireless Fixed (12 cents Through 7/1/2020) 0

NEW: (E) Grants for NG9-1-1 Expenses (5 Cents Through 6/30/2020) 0

NEW: (F) NG9-1-1 Expenses (13 cents after 7/1/2020) 0

Disbursements under Section 30 (b) (2) Percentage of Revenue

(A) Wireline/ VoIP; Hold Harmless Level 30.75%

(B) 9-1-1 Network Costs 8.77%

(C) ISP for RFI / RFP / Administrator / Advisory Board Costs 0.45%

(D) Portion Set Aside for 9-1-1 Grants / NG9-1-1 6.03%

(E) Remaining Surcharge to All 9-1-1 Systems 48.64%

3.5 Neighboring Jurisdictions Illinois is bordered by five states (Wisconsin, Iowa, Missouri, Kentucky, and Indiana) and shares a water border, Lake Michigan, with the state of Michigan. Thirty-nine counties in Illinois border the five states. PSAPs in 39 counties not only have to transfer calls to other PSAPs in Illinois, but also to the six states (including Michigan) from which they may receive wireless calls.

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3.5.1 Indiana 3.5.1.1 Governance8 The Indiana Statewide 911 Board (Board), a quasi-state government agency established by IC 36-8-16.7, Statewide 911 Services, operates under the Indiana Treasurer’s Office. It has statewide jurisdiction over 9-1-1 services. The Board’s two primary responsibilities include collecting surcharges from all communication service providers and distributing the funds to local units of government, as well as to support operation of a statewide public safety ESInet for 9-1-1 calls. The Board, in partnership with the Indiana Department of Administration, initiated a Request for Services (RFS) procurement (RFS15-12) in summer 2014. The RFS document sought a vendor(s) to build out an IP-based NG9-1-1 network for part or all of Indiana to provide an equal level of service to all PSAPs. The RFS required the selected vendor(s) to meet or exceed the level of service offered today by the IN911 network, which is a statewide, private E9-1-1 network provisioned by the Board to handle 9-1-1 calls from cellular phones. In December 2014, the Board awarded bids to three vendors. Those vendors included INdigital and AT&T for network call delivery services for wireless 9-1-1 traffic, and Emergency Call Tracking System (ECaTS) for a statewide comprehensive data analytics system. Implementation began in summer 2015 and will take an estimated 18 to 24 months to have AT&T's secondary network completed and all PSAPs transitioned to the ESInet. This project will result in all PSAPs operating in an NG9-1-1 environment. 3.5.1.2 Technology9 A self-healing Synchronous Optical Network (SONET) serves as the transport network for a diverse IP-based mesh network that delivers 9-1-1 voice and ALI data. IP signaling is converted to analog voice and traditional RS-232 data communications to serve legacy equipment in the back room of a local PSAP. The IN911 network is fully redundant at all levels, with redundant, paired selective router tandems, multiple IP-based selective routing services, and redundant ALI links and controllers. The underlying IP transport is fully redundant to each PSAP, and the connections to all legacy LEC network elements used for 9-1-1 service are redundant as well. The IN911 network is a fully private network that makes extensive use of IP security protocols and procedures. In addition to the redundant nature of the IN911 network design, the Board implemented tertiary connections from third-party service providers. Tertiary connections are added to the 9-1-1 network as high-speed broadband networks are established PSAP communities. These connections, where available, are used to connect multiple providers’ networks for improved delivery of wireless 9-1-1 calls. They also are being added at critical network points where the unreliability of legacy circuits has been observed.

8 https://www.in911.net/network.html 9 Ibid.

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The network is evolving to support additional agencies to promote public safety for Indiana residents and visitors. The Board has extended the IN911 network across state boundaries into Michigan, Ohio, and Kentucky to enable wireless call transfers across state lines along with the location information associated with the call; interconnectivity with Illinois is in progress. 3.5.1.3 Operations Indiana reports in the 2016 National 911 Progress Report, published by the National 911 Program, that 100 percent of its primary PSAPs have call handling equipment processing IP calls from an ESInet. Specifically, this percentage reflects the total 9-1-1 authorities in a state that have implemented NG9-1-1 systems for all service types. Indiana further reported that 100 percent of the addressing authorities within the state have geocoded addresses in GIS-ready format. This means that 100 percent of the PSAPs are capable of processing emergency calls for service from all devices—wireline, wireless, and VoIP—using NG9-1-1-capable infrastructure and locating callers using GIS data. 3.5.1.4 Funding The State collects end-user surcharges. This funding operates the statewide 9-1-1 network and is an aid to funding 9-1-1 service within the 92 counties. 9-1-1 is a local service, provided by the counties, cities, and towns (who provide mutual funding assistance through cooperative interlocal agreements). Effective, July 1, 2015, all communication service providers in Indiana that provide wireless, landline, lifeline, and VoIP services must collect a monthly statewide 9-1-1 fee of $1.00 per device. This is an increase from $0.90 per device for wireless, landline, and VoIP, and from $0.50 per device for lifeline, which has been in effect since July 1, 2012. The fee, known as the Statewide 911 Fee, will ensure Indiana complies with 9-1-1 requirements established by the Indiana General Assembly. This is the result of an Indiana law (IC 36-8-16.7-32) passed during the 2015 legislative session. Effective, July 1, 2015, all retail merchants in Indiana that sell prepaid wireless telephone services (through the sale of a prepaid phone or prepaid phone card) now must collect $1.00 per sales transaction. This is an increase from $0.50 per sales transaction, which has been in effect since July 1, 2012. The fee, known as the Prepaid 911 Enhancement Fee, will ensure that Indiana complies with 9-1-1 requirements established by the Indiana General Assembly. This is the result of a State law (IC 36-8-16.6-12) passed during the 2015 legislative session. 3.5.2 Iowa 3.5.2.1 Governance The 911 program in Iowa is governed by the Code of Iowa, Chapter 34A, and the Iowa Administrative Code, Section 605, Chapter 10. The State is required to appoint a program manager for the 911 program in Iowa who reports to the director of Iowa Homeland Security and Emergency Management (HSEM). The program manager acts under the supervisory control of the HSEM director and in consultation with the 911 Communications Council (Council). The Council advises and provides recommendations to the director

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and program manager regarding the implementation of the requirements of the statutes. Such advice and recommendations is provided on issues at the request of the director or program manager, or as deemed necessary by the Council. The Council also may provide grants, subject to available money in the E911 emergency communications fund, to PSAPs agreeing to consolidate pursuant to Chapter 34A, Section 7A, subsection 2, paragraph “h.” The Council’s authority is limited to the issues specifically identified in the statute and does not preempt the authority of the utilities board, created in Section 474.1, to act on issues within the jurisdiction of the utilities board. Under current statute, the 911 program only has authority for wireless 911 service. All 99 Iowa counties have the capability of accepting wireless E911 Phase II service, which provides the call taker at the PSAP with latitude and longitude coordinates so they can more readily locate the person who has placed the 911 call. This year, Senate File (SF) 500 passed both chambers of the Iowa legislature and was signed into law by the governor on May 11, 2017. Changes to the existing statute are scheduled to go into effect on July 1, 2017. They include adoption of the State’s “consolidation plan” that seeks to combine the wireless and wireline 911 networks and to create a shared environment for PSAP call processing; updates the definitions of 911; and adds Iowa Geographic Information Council and the Emergency Management Agency (EMA) to membership on the 911 Communications Council. Currently and before the 2017 statute changes, 911 phone service for wireline was managed at a local level. Each 911 authority (PSAP jurisdiction) determined policy, practices, 911 fees for their wireline subscribers, and call answering and dispatch standards for its jurisdiction. Wireless and VoIP was managed by the State 911 program. 3.5.2.2 Technology The first phase of a multi-phase effort to upgrade the NG911 network sought to convert analog/copper trunking to the local PSAPs to a statewide, IP-based, Ethernet network backbone, and was completed in November 2012. The second phase of the NG911 network upgrade is currently in progress and was expected to be completed in July 2017. This phase includes updating individual PSAPs to IP-enabled call handling equipment and logging recorders. When completed, this upgrade ultimately will allow PSAPs to receive IP-based signaling for the delivery of emergency calls. Thirteen of the largest PSAPs were identified to develop a secondary ESInet. Completely diverse fiber, circuits, and state systems were used to build this network, which is separate from the primary Iowa ESInet backbone. The secondary ESInet is able to automatically route calls during an outage to the 13 PSAPs, which would answer calls on behalf of the area(s) experiencing the outage. There is an ongoing cost for managing this network of approximately $259,000 annually, and the secondary ESInet has been built at a cost of $101,355. Iowa reports that two PSAPs are yet to be added, which will complete the network. In the 2016 National 911 Progress Report, Iowa reports that of the 911 authorities in the state 100 of 144 have awarded a contract for NG911 system components and/or functions procured in 2016.

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3.5.2.3 Operations The state’s E911 system consists of 113 PSAPs across 99 counties. These PSAPs handle both wireline and wireless 911 calls for service. Fifty percent of primary PSAPs have CPE processing IP calls from an ESInet, while 11 PSAPs currently can receive text-to-911 calls. Ninety-three percent of addressing authorities within the state have geocoded their addresses to a GIS-ready format, and 100 percent of the NG911 authority systems are capable of processing and interpreting location and call information. This data element reflects the percentage of 911 authority systems in Iowa that are capable of processing NG911 emergency calls for all service types (wireline, wireless, VoIP) using NG911 infrastructure. (NG911-capable means infrastructure and GIS). 3.5.2.4 Funding The bulk of E911 revenue is obtained through the wireless 911 surcharge. Under Iowa Code §34A.7A (2), the collected surcharge fees must be distributed in the following order:

1. To HSEM for 911 program administration, an amount equal to that appropriated by the General Assembly. In 2016, this amount was $250,000.

2. To joint E911 service boards, 46 percent of the total surcharge funds generated for

communications equipment utilized in the implementation and maintenance of E911 services within the local PSAP. Iowa Code §34A.7A (2) (e) and (2) (a) – (c) establishes how these funds are to be distributed among the 113 PSAPs in the state. For the 12 months ending September 30, 2016, this amount was $14,284,715, an increase of $1,405,603 from the previous 12 months. This percentage has been changed to 60 percent. The first distribution payments at the new rate were received by local service boards in October 2016, representing the months of July–September 2016. This one quarter distribution with the higher surcharge rate is included in the totals from October 1, 2015, through September 30, 2016.

3. To wireless service providers, 10 percent of surcharge funds generated for the three-year period of

July 1, 2013, through June 30, 2016, to recover their costs of providing E911 wireless Phase I services. For the 12 months ending September 30, 2016, this amount was $522,294, a decrease of $31,056 from the previous 12 months.

4. To communication service providers, i.e., wireline carriers, for eligible expenses for transport costs

of calls between the E911 network routers and the local PSAPs. For the 12 months ending September 30, 2016, this amount was $2,982,225, an increase of $546,865.

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3.5.3 Kentucky 3.5.3.1 Governance The 2016 session of the General Assembly adopted House Bill (HB) 58510, which made numerous changes to 911 statutes in Kentucky, including changing the name of the State Board, which has jurisdiction over wireless 911 services. Effective July 15, 2016, the Commercial Mobile Radio Service (CMRS) Board was renamed the Kentucky 911 Services Board (Board). On May 17, 2017, Governor Matt Bevin issued an executive order to reorganize the Kentucky 911 Services Board. The executive order reduces the Board’s membership from 15 to 5 members, and creates an advisory council made up of 13 members appointed by the governor. The reorganization transitions daily management and oversight of the Board to the Kentucky Office of Homeland Security (KOHS). The Board administratively is attached to KOHS per Kentucky Revised Statute (KRS) 39G.040, and KOHS maintains a robust grants department that administers millions of dollars annually in federal grants. Membership of the newly constituted 911 Services Board includes: • The secretary of the Public Protection Cabinet • The executive director of the Office of Homeland Security • The director of the Division of Emergency Management • The commissioner of the Department of Local Government • One citizen appointed by the governor who is an attorney or accountant and who is not an employee of

the state or a local government 3.5.3.2 Technology The Commonwealth’s NG911 Plan for statewide deployment of an ESInet was developed in 2009. There are two ESInets deployed and operational within the state that deliver IP calls to primary PSAPs. A request for proposals (RFP) for a statewide ESInet was pulled after initial responses received were deemed inadequate. This RFP has not been reissued. In the 2016 National 911 Progress Report, Kentucky reported that 44 911 authorities have awarded a contract for NG911 system components and/or functions. 3.5.3.3 Operations No CPE within the state handles IP calls according to the 2016 National 911 Progress Report, which leverages state-reported data. 10 http://www.lrc.ky.gov/record/16RS/HB585/bill.pdf

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3.5.3.4 Funding HB 585 also amended Section 7, KRS 65.7627 to create more uniformity in funding for wireless 911. The commercial mobile radio service emergency telecommunications fund (CMRS fund) is an insured, interest-bearing account administered and maintained by the Kentucky 911 Services Board. The CMRS service charges levied generate revenue equitably from prepaid and postpaid CMRS connections within the commonwealth. No charges other than the CMRS services charges levied under the Act are authorized to be levied for providing wireless 911 service. The Board is required to deposit all revenues collected directly into the fund, and the Board directs disbursements from the fund according to the provisions of KRS 65.7631, allowable expenses. Monies in the fund are not considered the property of the Commonwealth and are not subject to appropriation by the General Assembly to prevent diversion.11 Local governments have broad latitude in raising 911 revenues on landline connections separate from the wireless fees noted above. KRS 65.760(3) permits cities, counties, and urban-county governments to levy any special tax, license, or fee for 911 emergency phone service that does not conflict with the Kentucky Constitution and statutes. The statute specifically authorizes a fee on landline phone accounts, and most Kentucky counties levy such a fee. Where there are landline fees, they range from $0.50 to $4.25 a month. Two counties assess a percentage tax on phone rates; Boyd County charges 17 percent of the base phone rate, while Wolfe County assesses a 3 percent tax on all local phone charges and long-distance tolls. 3.5.4 Missouri 3.5.4.1 Governance Missouri 650.325, enacted in 1997, established within the Department of Public Safety the Advisory Committee for 911 Service Oversight, “which was charged with assisting and advising the state in ensuring the availability, implementation, and enhancement of a statewide emergency telephone number common to all jurisdictions through research, planning, training and education.”12 The Committee represented “all entities and jurisdictions before appropriate policy-making authorities and the general assembly, and shall strive toward the immediate access to emergency services for all citizens of this state.”13 Each Committee member was appointed by the governor, with the advice and consent of the senate, for a term of four years. In 2017, the duties previously outlined in the 1997 legislation were repealed and replaced in SB503. Nothing changed in the mission as outlined in the 1997 Act, but additional directives for the Board including responsibilities for the Department of Public Safety were added to:

11 http://www.lrc.ky.gov/record/16RS/HB585/bill.pdf 12 http://revisor.mo.gov/main/OneSection.aspx?section=650.325&bid=31367&hl 13 Ibid.

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• Complete a study by December 31, 2017, of the number of PSAPs necessary to provide the best possible 911 technology and service to all areas of the state in the most efficient and economical manner possible, and

• Issue a state PSAP consolidation plan based on the study, and provide such plan to the Missouri 911 Service Board.

The name of the previously established Advisory Committee was changed to the Missouri 911 Service Board which is charged with carrying out the mission as defined in statute.14 The composition of the Board was changed slightly to remove the public service commission representative and replace that position with a representative from the 911 Directors Association, and adding representation from VoIP and a representative of the governor’s council on disability. The new composition no longer dictates that the chair shall be chosen from the Department of Public Safety, and combines county and municipality representation. The Board defined duties changed little with the 2017 legislation and include responsibility to: • Organize and adopt standards governing the Board’s formal and informal procedures • Provide recommendations for primary and secondary PSAPs on technical and operational standards

for 911 services • Provide recommendations to public agencies concerning model systems to be considered in preparing

a 911 service plan • Provide requested mediation services to political subdivisions involved in jurisdictional disputes

regarding the provisioning of 911 services, except that the Board shall not supersede decision-making authority of local political subdivisions regarding 911 services

• Provide assistance to the governor and the general assembly regarding 911 services • Review existing and proposed legislation and making recommendations regarding changes that would

improve such legislation • Aid and assist in the timely collection and dissemination of information relating to the use of a universal

emergency telephone number • Perform other duties as necessary to promote successful development, implementation and operation

of 911 systems across the state including monitoring federal and industry standards being developed for next generation 911 systems

• Promulgate rules and regulations that are reasonable and necessary to implement and administer its responsibilities15

The most significant governance change in the 2017 legislation is the designation of a State 911 Coordinator who is to be responsible for overseeing statewide 911 operations and ensuring compliance with federal grants for 911 funding; apply for and receive grants from federal, private, and other sources; report to the governor and the general assembly at least every three years on the status of 911 services statewide, as well as specific efforts to improve efficiency, cost-effectiveness, and levels of service. 14 http://revisor.mo.gov/main/OneSection.aspx?section=650.325&bid=34613 15 http://revisor.mo.gov/main/OneSection.aspx?section=650.330&bid=34614

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The new Missouri State 911 Coordinator is also expected to conduct and review an annual survey of PSAPs in Missouri to evaluate potential for improved services, coordination, and feasibility of consolidation; make and execute contracts or any other instruments and agreements necessary or convenient for the exercise of its powers and functions; and develop a plan and timeline of target dates for the testing, implementation, and operation of an NG911 system throughout Missouri. The Department of Public Safety provides staff assistance to the Board. 3.5.4.2 Technology Without a statewide collection mechanism, it is virtually impossible to provide valid data on technology employed in PSAPs in Missouri. Now that a Statewide 911 Coordinator is authorized, information may be more readily available in the future. 3.5.4.3 Operations In addition to Missouri Statute, Chapter 650-340, 911 Training and Standards Act16, designates training for public safety telecommunicators. This law has been in effect since 1999. The initial training requirement for all law enforcement, fire, and EMS telecommunicators is 16 hours. Telecommunicators at joint communications centers must complete 40 total hours of training. Law enforcement, fire, and EMS telecommunicators can complete an approved 40-hour course as well. All initial training must be completed within 12 months of employment. After initial training, all telecommunicators are required to complete 24 hours of ongoing training every three years. The Missouri 911 Service Board issues the training certification and determines which organizations are authorized to conduct training. A list of approved training courses is available online, which includes the Association for Public-Safety Communications Officials International (APCO) Institute courses, as well as courses offered by the University of Central Missouri Safety Center, Chariton County Enhanced 911 Service, The Public Safety Group, International Academies of Emergency Dispatch (IAED) and National Emergency Communications Institute (NECI). Emergency Medical Dispatch (EMD) certification is mandated by the state’s Department of Health and Senior Services in Missouri Statute, Chapter 190. According to the law, telecommunicators must successfully complete an EMD program that meets or exceeds the U.S. Department of Transportation’s curriculum. In statute, an emergency medical dispatcher is “a person who receives emergency calls from the public and has successfully completed an emergency medical dispatcher course, meeting or exceeding

16 http://revisor.mo.gov/main/OneSection.aspx?section=650.340&bid=34615

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the national curriculum of the United States Department of Transportation and any modifications to such curricula specified by the department through rules adopted pursuant to sections 190.001 to 190.245.”17 3.5.4.4 Funding Missouri is the only state not collecting a wireless 911 surcharge. Some counties rely on wireline surcharges, property taxes, and sales taxes to fund 911, while others simply do not provide service. Forty-five counties assess a fee of anywhere from 2 percent to 15 percent of the base tax rate for 911. Fifty-one counties assess from 0.125 percent to 1 percent of sales tax for emergency services, and nineteen counties are unfunded. Missouri does not collect wireless, prepaid cellular or VoIP fees for 911.

Figure 6: Missouri 911 Funding Map

Missouri statute Section 650.396 makes a special provision for St. Louis County and authorizes a tax under certain conditions where, in the case of St. Louis, an emergency communications system commission has been established. They may levy, and have, a tax on the taxable real property in the county, not to exceed $0.06 per $100 of assessed valuation to accomplish any of the following purposes:

17 http://revisor.mo.gov/main/OneSection.aspx?section=190.100&bid=9443&hl

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• The provision of necessary funds to establish, operate and maintain an emergency communications system to serve the county in which the commission is located; and

• The provision of funds to supplement existing funds for the operation and maintenance of an existing emergency communications system in the county in which the commission is located.18

The 2017 legislation also established that the state auditor has the authority to conduct performance and fiscal audits of any board, dispatch center, joint emergency communications entity, or trust fund established under the statute. 3.5.5 Ohio 3.5.5.1 Governance Recognizing the need to prepare Ohio for NG9-1-1, the legislature passed House Bill (HB) 360 in December 2012 creating the Ohio ESInet Steering Committee. The Committee was tasked with: • Addressing the development of a statewide ESInet, including a review of the current funding model for

the state's 9-1-1 systems • Examining the readiness of the state's current technology infrastructure to support NG9-1-1 • Researching legislative authority regarding governance and funding • Making recommendations for consolidation of PSAP operations, accommodating NG9-1-1 technology

and facilitating an efficient and effective emergency services system • Recommending policies, procedures, and statutory or regulatory authority to effectively govern a

statewide emergency services IP network • Coordinating with statewide initiatives and associations The initial ESInet report was submitted in 2013 with recommendations to establish a statewide 9-1-1 governing body; establish a state authority for an NG9-1-1 Coordinator; modify statutory language to eliminate impediments to the implementation and operation of a statewide ESInet; modify existing funding model language to support implementation and operations of a statewide NG9-1-1 system; establish a uniform 9-1-1 access fee for the transition and ongoing operations of an NG9-1-1 system; and develop a PSAP consolidation plan to promote reductions of the number of PSAPs to an optimal level for an NG9-1-1 system. The Public Safety Answering Point (PSAP) Operations Rules mandated by Ohio Revised Code (ORC) 128.021 were passed and adopted by the State in 2016. The 2016 rules met the ESInet 2013 report recommendations including establishment of a statewide coordinator and administrative body known as the Statewide ESInet Steering Committee, consisting of ten members, with five appointed by the governor from the County Commissioner’s Association of Ohio, or a successor organization, four appointed from the Ohio Municipal League or a successor organization, and one appointed from the Ohio Township

18 http://revisor.mo.gov/main/OneSection.aspx?section=650.396

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Association or a successor organization. The state CIO or the officer's designee serves as the chairperson of the Steering Committee and is a nonvoting member. All other members are voting members. The Steering Committee has permanent technical standards and PSAP operations subcommittees to advise and assist based on their respective areas of expertise. The membership of the subcommittees is determined by the Steering Committee. The technical standards subcommittee includes one member representing a wireline or wireless service provider that participates in the state's 9-1-1 system, one representative of the Ohio Academic Resources Network, one representative of the Ohio Multi-Agency Radio Communications Trunking System (MARCS) steering committee, one representative of the Ohio Geographically Referenced Information Program (OGRIP), and one member each from the Ohio chapters of APCO and NENA. The State is extensively reviewing existing statutes to ensure that they contain nothing that could hinder the adoption of NG9-1-1 technology statewide. 3.5.5.2 Technology The majority of Ohio PSAPs leverage analog circuit-switched telephony designed to enable voice calls to 9-1-1, with very little associated data. While the counties of Morgan and Monroe have been the test bed and showcase of NG9-1-1 technology in the state, ESInets exist in only a few counties, and no regional ESInets currently exist. The Ohio 9-1-1 Administrator stated in interviews that the agency is hoping for a legislative funding package this year that will enable the State to expand NG9-1-1 implementations. Each PSAP is encouraged to drive action towards the development of a statewide NG9-1-1 system, and facilitating communication and cooperation among the various levels of government involved in 9-1-1 along with the release of an RFP for the development of a statewide NG9-1-1 system. 3.5.5.3 Operations Until 2009, more than five PSAPs could exist in each county. In 2009, state law mandated the reduction of PSAPs to no more than five per county, and in 2016 the maximum number of PSAPs was reduced to no more than four per county. This number is further reduced to three beginning in 2018. New PSAP operation rules became effective in the state in May 201619, with all PSAPs needing to achieve compliance by May 2018. Compliance includes staffing with a minimum of two telecommunicators always on duty and available to receive and process calls; each PSAP must have standard operating procedures (SOPs) that ensure telecommunicators prioritize emergency functions over non-emergency functions.

19 http://codes.ohio.gov/oac/5507-1

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In addition, each telecommunicator must meet minimum training standards and be tested annually, demonstrating knowledge of, and expertise in, the following: • Local demographics and geography • First responder agencies and their jurisdictions • National Incident Management System (NIMS) and Incident command system (ICS) • Local and state interoperability plans and operations • Stress management • Customer service • Ability to effectively operate agency radio, computer, records management, and telecommunications

systems • Ability to understand and follow policy and procedures • Ability to recognize gaps in policies and procedures, and recommend changes • Ability to classify and prioritize requests for service • Ability to document all call details accurately • Ability to verify and relay initial dispatch information • Ability to handle calls and obtain necessary information from hostile, hysterical, or difficult callers Each PSAP is required to provide emergency dispatching by establishing an internal EMD protocol, including pre-arrival instructions, through training or establishing an EMD protocol through the local medical authority or by agreement with a third-party medical dispatch provider. 3.5.5.4 Funding Ohio collects wireless 9-1-1 fees at rates of $0.25 per month per phone number for billed cellular service and 0.05 percent (five-tenths of one percent) of the sale price for prepaid cellular phones. 3.5.6 Wisconsin 3.5.6.1 Governance Wisconsin has begun to develop statewide oversight or governance for 911 and has structured it under the Department of Military Affairs. The Statewide emergency services number statute, Wisconsin § 256.35(3)(i)20, requires that participating LECs submit a new 911 contract, or an amendment to an existing 911 contract, to the Public Service Commission (PSC) for review. The PSC may disapprove a submitted contract or contract amendment if it finds the contract is not compensatory, is excessive, or is not in the public interest.

20 https://docs.legis.wisconsin.gov/statutes/statutes/256/35

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The PSC has limited authority to authorize a telecommunications service provider to impose a 911 surcharge if the service provider presents proof that it has entered into a contract with a county to provide 911 service. 3.5.6.2 Technology Technology varies throughout the state. In Wisconsin, the installation and maintenance of the 911 network in a given county is authorized by a contract that the county enters into with participating LECs. This contract specifies in detail the network design for the county’s 911 service, sets the amount of the 911 surcharge, and identifies the obligations of the parties to operate, maintain, and repair the 911 network, per Wisconsin § 256.35(3)(b)(3).21 The National Profile Database data collection survey regarding statewide components for procurement provides detail on what parts, functions, or components for NG9-1-1 are being procured statewide. Wisconsin responded that “none are being deployed in Wisconsin.” 3.5.6.3 Operations 911 operations are handled at a local level. Local 911 authorities rely on past practice, national-level standards, and locally-crafted operating procedures. 3.5.6.4 Funding 911 surcharges in Wisconsin are unique in that they only are used for reimbursing landline service providers – not wireless – and no portion of the funds goes to the local 911 systems (which are funded through county or municipal budgets). In Wisconsin, no portion of the amount collected from the 911 surcharge that appears on monthly telephone bills is shared with State, county, or municipal governments. The 911 surcharge is limited to the recovery of telecommunications network expenses for the 911 service. The proceeds from the 911 surcharge collection are retained in full by the participating LECs. The amount of the collection is not reported to the State. 3.6 National Considerations 3.6.1 NG911 NOW Coalition22 In 2016, NENA, the National Association of State 911 Administrators (NASNA), and the Industry Council for Emergency Response Technologies (iCERT) joined together to create a coalition focused on rapidly accelerating the deployment of NG9-1-1. In conjunction with the NG9-1-1 Institute and experts in

21 Ibid. 22 www.911NOW.org

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government and academia, the NG911 NOW Coalition is working to address various challenges that have stalled rapid NG9-1-1 implementation. These national public safety and industry leaders have committed to work together to achieve the following national goal:

By the end of the year 2020, all 911 systems and centers in all 56 states and territories will have sufficiently funded, standards-based, end-to-end, IP-based 911 capabilities,

and will have retired legacy 911 systems, without any degradation in service to the public.

The Coalition believes that an accelerated implementation of NG9-1-1 will provide improved emergency services for the public, 9-1-1 professionals and first responders alike. The benefits of NG9-1-1 include increased compatibility with emerging communications trends, enhanced reliability and resiliency of the nation’s 9-1-1 systems, improved emergency response for the public, and the opportunity for greater cost efficiencies. Conversely, the Coalition believes a delay in NG9-1-1 implementation would create technological obsolescence and increased security risks, and result in missed opportunities for improved emergency response.

There is little question that Next Generation 9-1-1 (NG9-1-1) will forever change how emergency services are provided in the United States. The capabilities of NG9-1-1 technology will provide the nation’s public safety answering points (PSAPs) and first

responders with vitally important information that was inconceivable in an environment dominated by legacy technology. The result will be a dramatic improvement in both lives

and property saved, as well as the safety of our nation’s first responders.

However, many challenges will need to be resolved—in the areas of Governance, Funding, Technology, Operations and Education—before NG9-1-1 not only comes to fruition, but more importantly becomes ubiquitous across the U.S. In order to promote

more effective and timely NG9-1-1 deployment, the NG9-1-1 NOW Coalition has analyzed each of the challenges (or “gaps”) to timely deployment, has identified

potential strategies to address them, and seeks input from the public safety community, industry, and other affected stakeholders on where to place the highest priorities.23

The NG9-1-1 Gap Analysis and Next Steps report24 is an examination of these major areas of concern and includes recommendations for addressing the gaps and challenges. They include:

23 http://www.ng911now.org/blog/2016/6/13/report-ng9-1-1-gap-analyses-and-next-steps 24 https://static1.squarespace.com/static/56bb58608a65e27aeda89c9c/t/575eadd4746fb9dbf86f7d76/1465822676753/NG911NOW+National+Gap+Analysis+and+Strategy+Document+Draft+6-13-16+Final%5B1%5D.pdf

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Figure 7: Gap Analysis and Next Steps

While the NG911 NOW Coalition efforts have been focused on national-level initiatives, the five areas of research and analysis can be of guidance to the Department and the state of Illinois as NG9-1-1 is pursued. Governance and funding supporting state-level initiatives and direction along with adequate funding for those initiatives including cost estimates, technology and operational planning that address the needs of local operations while guiding statewide NG9-1-1 transitional and functional elements, and education of the policy-makers focusing on the benefits of NG9-1-1 and the importance of sufficient and sustainable funding are clearly the responsibility of the Illinois Statewide 9-1-1 Administrator and the statewide program. 3.6.2 National 911 Program NG9-1-1 Interstate Playbook Forging new efforts in the transitional implementation of NG9-1-1, such as the interconnection of statewide systems for improved 9-1-1 service across state borders, has been without a roadmap, which is typical when one is among the first to accomplish the initiatives. Consequently, states need a process to follow to smooth the transition to NG9-1-1. That need was the genesis for development of the Next Generation 911 (NG9-1-1) Interstate Playbook (Playbook) produced under the guidance of the National 911 Program. The

Governance: Develop legislation to support increased national and state-level NG9-1-1 leadership and support including a model regulatory framework to facilitate coordination between the local 9-1-1 authorities, state executive and legislative leadership and state regulators. This legislative effort would be closely tied to strategies focused on obtaining additional NG9-1-1 funding resources.

Funding: Complete a high-level cost estimate for deploying NG9-1-1 across the country and secure additional funding for NG9-1-1 through federal legislation.

Technology: Develop a comprehensive national NG9-1-1 implementation plan that addresses both state and regional deployment models, identify an entity to lead the development of a National Forest Guide, establish an entity to ensure consistent implementation of NG9-1-1 standards, and publish NG9-1-1 GIS standards.

Operations: Develop a model that describes roles and responsibilities of all stakeholders for NG9-1-1 functional elements. Develop operational procedures to be used for interconnecting ESInets.

Education: Educate the public safety community, the general public and policy makers on what NG9-1-1 can offer to improve public safety and national security, focusing on the benefits of NG9-1-1, the consequences of delayed NG9-1-1 deployment and the importance of sufficient and sustainable funding

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Playbook observes and documents the interconnection and integration of Iowa, Minnesota, North Dakota and South Dakota, which are all at different stages of transition to full NG9-1-1 implementation. States in similar stages of NG9-1-1 transition, and those just beginning, such as Illinois, may benefit from the Playbook as a guidebook to integrate systems with neighboring deployments of NG9-1-1. The ultimate goal of NG9-1-1 is to provide an effective, interconnected system of systems for the processing of emergency 9-1-1 calls across the nation. The Playbook describes the methods the four states followed. No doubt there will be a variety of methods implemented before end-state NG9-1-1 capabilities are fully realized. However, by recounting the processes these states used, discussing the issues, identifying the challenges and recommending methods to overcome and deal with these situations, Illinois or regional systems within Illinois may achieve more effective planning and more successful outcomes. Efficient 9-1-1 systems that seamlessly interconnect and distribute calls and caller data without regard to jurisdictional boundaries is the operational goal of the Playbook. The “plays” outlined in the Playbook help step an agency, region, or state through the myriad of challenges interconnecting neighboring states or regions. The Playbook recognizes the need for a formal agreement with partners, identifies who should be involved in the planning and execution of the interoperable connection, suggests how vendors and service providers should be engaged to assist, notes the importance of the testing process and communication with involved PSAPs, and helps avoid pitfalls and challenges that might be faced along the way. The Playbook sections are designed to inform and assist in an easy to digest format of background information, considerations, and best practices to follow, key focus points that will aid in a smooth transition, followed up by support references for additional information and understanding.

4 NG9-1-1 Considerations and Implications

4.1 Statutory, Regulatory, and Political Considerations and Implications 4.1.1 Provider Liability Protection Some current Illinois service providers expressed concerns over the lack of NG9-1-1-specific language or limited provider liability in the revised statute. Review of the section related to provider liability does not lead MCP to the same conclusions (underline emphasis added).

(50 ILCS 750/15.1) (from Ch. 134, par. 45.1)

Sec. 15.1. Public body; exemption from civil liability for developing or operating emergency telephone system.

(a) In no event shall a public agency, the Commission, the Statewide 9-1-1 Advisory Board, the Administrator, the Department of State Police, public safety agency, public

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safety answering point, emergency telephone system board, or unit of local government assuming the duties of an emergency telephone system board, or carrier, or its officers, employees, assigns, or agents be liable for any civil damages or criminal liability that directly or indirectly results from, or is caused by, any act or omission in the development, design, installation, operation, maintenance, performance, or provision of 9-1-1 service required by this Act, unless the act or omission constitutes gross negligence, recklessness, or intentional misconduct.

A unit of local government, the Commission, the Statewide 9-1-1 Advisory Board, the Administrator, the Department of State Police, public safety agency, public safety answering point, emergency telephone system board, or carrier, or its officers, employees, assigns, or agents, shall not be liable for any form of civil damages or criminal liability that directly or indirectly results from, or is caused by, the release of subscriber information to any governmental entity as required under the provisions of this Act, unless the release constitutes gross negligence, recklessness, or intentional misconduct.25

While, this is typical legislative language seen in other state’s 9-1-1 statutes and, in fact, is not different from the previous legislation in Illinois, there was a concern raised about the adequate liability protection it provides for the carrier due to the lack of NG9-1-1-specific language. While it appears to provide adequate protection, the Department’s legal support may be consulted for further interpretation and comparison to Illinois state law. MCP expects that this issue may continue to be raised by some carriers. While the recently revised statute is an improvement to the previous statute, gaps in legislative language still exist and may need to be addressed in administrative rules or in future legislative changes. These recommendations include considerations for: • Legacy Terminology: Legacy references and terminology should be transitioned out of current

legislation and replaced with technology- and vendor-neutral text that permits the Department sufficient flexibility and nimbleness going forward.

• GIS: GIS is still missing as an essential element of NG9-1-1 and the transition from legacy databases to geo-spatial data used to route and process a 9-1-1 call in an NG9-1-1 environment.

• Consolidation Grants: Specifics on consolidation grants still need to be defined. The Department can use the influence of program priorities to help guide consolidation efforts and assist local communities in fulfilling legislative requirements.

• Program Priorities: A specific network design and forward momentum towards NG9-1-1 in the state is needed so that program priorities can be clearly delineated and program resources appropriately assigned.

• Call Handling Agreements/Memoranda of Understanding (MOUs): The need for clear and cohesive call handling agreements and/or MOUs have always been significant, but become even more important in

25 http://www.ilga.gov/legislation/ilcs/ilcs3.asp?ActID=741&ChapterID=11

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an NG9-1-1 ecosystem with many regional 9-1-1 authorities. Many of the consolidated 9-1-1 jurisdictions have been previously independent and now must operate effectively in a shared environment. An MOU allows the various entities a direction and documented understanding of how decision-making will be shared, defines cost allocation responsibilities, outlines operational procedure changes, and codifies agreed upon technology sharing requirements.

4.1.2 Regulatory Environment 4.1.2.1 Department Administrative Rules Administrative rules, which guide operational and functional elements of the program, are in place for the ETSA as amended by Public Act 99-0006. The Department’s administrative rules need to be reviewed and updated to reflect the changes from Public Act 100-0020, effective July 1, 2017. Each time the statute changes, administrative rules should be reviewed and updated, with the changes to continue the effective work of the Department. These changes need to be done in concert with other governmental entities within the state, such as the ICC, to ensure a comprehensive system and plan for both 9-1-1 authorities and service providers. The areas where gaps still exist can be a starting point for the Department. Areas that are hampered by legacy terminology or vendor-specific references can be defined more broadly in administrative rules. A greater emphasis on GIS and the associated data that will be necessary in NG9-1-1 can be encouraged, funded, and identified among the Department priorities. In addition to Department Administrative Rules, the Department should encourage and work in concert with the ICC as their rules for technology and service providers need to be updated as well. 4.1.2.2 ICC Rules for Service Providers As with the Department’s 9-1-1 administrative rules, ICC has done an excellent job of establishing telecommunications-related regulations that apply to the current legacy systems and, to some extent, help to transition 9-1-1 systems to NG9-1-1 services. The rules provide overall direction for telecommunications service providers and establish lines of responsibility, demarcation, and authority. Interviews with the ICC disclose an understanding by the ICC that more is needed in this area and will be undertaken when a specific NG9-1-1 comprehensive plan design is completed and the vision and direction for NG9-1-1 in Illinois is defined. During the assessment process, MCP identified that some modifications or deletions in terms may not be appropriate until a full legacy-to-NG9-1-1 transition is completed. In these cases, the changes are not necessary immediately and the current ICC rule text may be adequate until all legacy technology is transitioned out of service and is no longer part of the Illinois 9-1-1 system. Currently, legacy terminology is too prevalent and needs to be supplanted with more current, relevant terms that refer to NG9-1-1 or generic technology. In some cases, the modification is more urgent and should be considered immediately as it impacts what the Department and the legislature want to achieve

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regarding NG9-1-1 implementation, as the current statutes and/or rules may not provide clear direction to the service providers in the state. Not addressing recommended changes may impact the State’s ability to move NG9-1-1 forward on the preferred deployment schedule. In other cases, the terminology or definitions in the statute may be prohibitive or limiting, which also would affect the State’s ability to implement the needed system changes on the desired implementation schedule. 4.1.3 Political Environment The arguments surrounding the last legislative session and the recent need to pursue legislative override of a Gubernatorial veto initially strained relationships between the Executive and Legislative branches of Illinois government. While the mission of 9-1-1 should rise above politics, these actions have impact and their significance should not be oversimplified. It is hoped that with the continued good work of the Department to advance the mission and intent of the legislation, all parties will regain confidence in their decisions to set aside differences and move the initiative forward for improved 9-1-1 service in Illinois. The State’s budget concerns are widely reported in the local and national press and illustrate that the state finances are severely constrained. While recent action by the legislature may have ended the budget impasse, the Democratic-led legislature and the Republican governor have often found themselves in political gridlock, as reported by the State Journal Register on July 30, 2017.26 The fact that 9-1-1 receives funds partially outside of the State budget process is advantageous, but also introduces risk. The 9-1-1 surcharge and fund balance represents a ready source of funds both to local ETSBs and to the Department that is vulnerable to raiding. Statute language prevents this to a significant degree, but what the legislature created, the legislature can also change, as demonstrated with the passing of Public Act 100-0023. The threat of losing potential federal support is only a threat, while the State’s need for cash that is readily available in the State coffers may be considered more necessary by the legislature than the promise of funds in the future. It is imperative that the Department remain vigilant to responsible accounting and spending policies that will demonstrate fiduciary responsibility. Tension over state finances issues can impact 9-1-1 even with its own funding source and legislative requirements. While the mission of 9-1-1 should transcend such political tensions, the Department and the Statewide 9-1-1 Advisory Board should continue to be prudent with the funds entrusted to them. MCP’s experience often demonstrates that in large states with many local authorities, such as Illinois, there may be a level of animosity that exists between large cities and rural areas. Smaller and more rural areas often are compelled to advocate harder for state funding dollars; if there are typical budget or financial constraints, these tensions may be exacerbated. Disparity in funding, real or perceived, is always a concern and the Department and the Statewide 9-1-1 Advisory Board should be mindful that part of their role is to remain neutral and fair in their policies and practices. 26 http://www.sj-r.com/news/20170730/look-at-political-gridlock-over-state-school-funding

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Many local 9-1-1 authorities are concentrating on consolidation in accordance with requirements of the statute. The local ETSBs may deem their focus cannot be distracted by other major efforts such as NG9-1-1 until their governance structure is in place and stabilized. Their need for significant direction, guidance, and assistance (planning and oversight) from the State is increased under these circumstances. The Department should establish program priorities at the earliest possible time and should link those program priorities with the grant guidance it should also establish. All 9-1-1 funds collected and expended should be advancing NG9-1-1 initiatives to meet the intent of the legislation. The Department has the authority and, indeed, the responsibility to clarify the direction and guide the local 9-1-1 authorities in this way. Both programmatic guidance and funding should work in parallel and support the direction as defined by the Department. 4.1.3.1 FirstNet Integration The Department is also encouraged to ensure that NG9-1-1 and the Illinois FirstNet (National Public Safety Broadband Network [NPSBN]) implementations are in concert with one another. While these are two separate network implementations whose functions address different aspects of the emergency response continuum, they are intrinsically linked and politically they should be viewed as integrated efforts.

The benefits of integrating NG9-1-1 and FirstNet are significant to both systems. Technology is most valuable when it improves the user experience. In the case of the technologies that will be leveraged by FirstNet and NG9-1-1, they ultimately will be measured by their ability to enhance emergency response and to keep first responders safer and better informed. Again, this ability will be enhanced by developing a unified communications platform by interconnecting FirstNet and NG9-1-1 at the core. The possibilities for leveraging the synergies between the NPSBN and NG9-1-1 are virtually endless if they are interconnected properly. One example is that workgroups could be created in a unified platform, similar to the talkgroups that exist today in 800 megahertz (MHz) trunking systems. Various data files could be dropped into such workgroups, and accessed by members—law enforcement, fire, EMS, 9-1-1, and more—on an as-needed basis. That will not be possible if the NPSBN and NG9-1-1 are implemented as standalone networks. Yet another benefit of integrating the NPSBN and NG9-1-1 at the core of a unified communications platform is that a single set of cybersecurity policies can be developed. An enormous amount of data will pass between these two networks, so it is imperative that they operate under the same requirements to reduce the likelihood of a cybersecurity breach.

For decades, public safety communications networks and systems have been implemented as standalone entities, with little if any thought given to how those networks and systems will interoperate with other networks and systems, both inside and outside an agency. Too frequently the same mistake can be made regarding FirstNet and NG9-1-1, which currently are on parallel implementation paths, mostly because they are viewed as related, but separate and different networks.

The public safety community needs to stop thinking and talking about FirstNet and NG9-1-1 as individual entities. Instead, MCP encourages Illinois to start talking about a unified public safety communications platform with two vital, interconnected components, one that serves the needs of first responders in the

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field (FirstNet) and the other (NG9-1-1) that serves the needs of the first responders in the Illinois 9-1-1 centers.

The Department should consult with the NPSBN/FirstNet implementation team in Illinois to further coordinate efforts on both systems. The integration of the state’s NPSBN/FirstNet implementation along with NG9-1-1 will be a critical component to fully enhanced and coordinated systems of emergency communications from the public’s access to the NG9-1-1 network to the responders in the field. The Department should continue to coordinate effort with the State’s FirstNet implementation and help to ensure a collaborative and integrated approach to designing and implementing the two communications network infrastructures.

4.1.3.2 Governor’s Competitiveness Council On October 17, 2016, the governor issued Executive Order 2016-13, which instructed all state agencies to undertake a comprehensive review of existing rules and regulations. The concern expressed by the executive branch of Illinois legislature is that the state is overburdened with rules and regulations and the governor has identified a need to simplify the regulatory environment. The Executive Order established the Illinois Competitiveness Council (Council) to oversee this review. The goal of the Council is to determine which regulations are outdated, repetitive, confusing, unnecessary, or harmful to the state’s economy. The governor’s office has challenged state agencies to consider: • What regulations or policies are confusing, outdated, or repetitive? • Are regulations consistent across different agencies? • How can the process of interacting with State agencies, including reductions in paperwork

requirements be streamlined? • Is there is a clear need (public health, safety, or welfare) for the rule? • What processes can agencies put in place to save taxpayers’ time and money? The Council is comprised of representatives from over 40 state agencies, boards, and commissions. The ICC and the ISP both are represented on the Council. The review process aims to make meaningful changes that will encourage simplified government. There are seven guidelines in the Executive Order for agencies to consider when reviewing regulations. These guidelines may offer the Department opportunities to enhance current regulations to strengthen NG9-1-1 implementation effectiveness. The Council asks that all agency/department guidelines are reviewed to ensure that:

1. Regulation is up to date and reflective of current Agency functions and programs. 2. Regulation is drafted in such a way as to be understood by the general public.

Regulations should be clear, concise and drafted in readily understood language. Regulations should not create legal uncertainty.

3. Regulation is consistent with other rules across Agencies. Agencies should coordinate to ensure rules are not conflicting or have duplicative requirements.

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4. Regulation should not cause an undue administrative delay or backlog in processing necessary paperwork for businesses or citizens.

5. Regulation does not impose unduly burdensome requirements on business, whether through time or cost, or have a negative effect on the State’s overall job growth. In considering this criterion, the Agency should consider whether there are less burdensome alternatives to achieve the Regulation’s purpose.

6. Regulation does not impose unnecessary burden on social service providers or recipients, whether though [sic] time or cost. In considering this criterion, the Agency should consider whether there are ways to revise the Regulation to make it easier for social service providers and recipients to provide or receive services.

7. There is a clear need and statutory authority for the Regulation. Regulation should not exceed the Agency’s statutory authority and should be drafted so as to impose statutory requirements in the least restrictive way possible. In considering these criteria, the Agency should also consider whether the Regulation exceeds federal requirements or duplicates local regulations or procedures.27

MCP urges continued coordination on rules and administrative regulation changes between the Department and the ICC so that there is no duplication of regulation and that terminology used by each agency is consistent and clear, and updated for NG9-1-1 elements. This coordination is essential to help ensure efficient use of resources and a coordinated approach to NG9-1-1 implementation at the state and local level. A thorough and strategic review of all regulations and rules related to 9-1-1 might be beneficial so that as priorities are established, any potential barriers are mitigated, and the Department’s authority to fund NG9-1-1 components is clearly defined. The Department is encouraged to collaborate as much as possible with the ICC and to work toward rule simplification, while updating terms, establishing priorities that help the Department and 9-1-1 authorities move forward to NG9-1-1 implementation. 4.1.3.3 Government Affairs Liaison to Legislature As a department within the Illinois state office, the Department has the benefit of a government affairs or legislative liaison to the legislature. Questions from legislators, caucus members, and legislative staff, may and do come to the ISP and, in particular the Department, regarding the NG9-1-1 implementation and the status of the initiative. Currently, the Department reacts to a question, but is not proactive. The Department might want to consider using the Government Affairs Liaison as a vehicle to push the Department’s agenda forward. The Department should continue to educate and inform through the annual report to the legislature that is required by statute. The annual report should be used as an opportunity to inform and gain support for the work that the Department does and the Statewide 9-1-1 Advisory Board oversees so that when issues are

27 https://www2.illinois.gov/Pages/government/execorders/2016_13.aspx

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brought to the legislature they have built an understanding and a relationship that shows confidence and support for the mission. The Department and the Statewide 9-1-1 Advisory Board might also consider briefings to the legislature on a periodic basis to enhance communication and understanding. As transitional elements of implementation to NG9-1-1 progress, such transitions may require press releases or announcements from the Department; these are additional opportunities to keep both the community and the decision-makers informed and increase awareness. Such awareness building can help bridge understanding and provide background to legislators who may get questions from local constituents on the activities of the Department. Providing briefings to legislators and their staff can go a long way to build trust and confidence in the Department. The Department should consider use of the Competitiveness Council, government affairs liaison and the annual report to the legislature to enhance communication with the legislature and other state departments as well as local authorities regarding the NG9-1-1 initiatives. 4.2 Stakeholders In an NG9-1-1 environment, there are minor changes to the stakeholder groups that exist today in the legacy environment. Though a majority of the stakeholders that have active roles in the day-to-day operations and decisions in the PSAPs remain the same, there is a need for greater stakeholder engagement; especially surrounding education of NG9-1-1 and what it means for the communities. The needs of stakeholders in an NG9-1-1 environment differ from that in a legacy environment.

Table 5: NG9-1-1 Stakeholder Needs

Stakeholder Category Needs

Operational

Stakeholders in this group will need to be educated on what NG9-1-1 is and how it works, and what is needed day-to-day to make sure there is a standard level of care that is expected when reaching 9-1-1. There

will need to be a focus on educating telecommunicators (call takers and dispatchers), supervisors, and management on how messages reach

the center (text, data, live video). There is also concern among the industry on how telecommunicators will handle the more dynamic and

visual methods; in a setting where they have only been used to handling emergencies via voice, they may now be faced with handling

them visually. Operationally, there will also need to be a plan for FirstNet convergence and getting the information that is received in the

PSAP to the first responders.

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Stakeholder Category Needs

Political

In times where many states, like Illinois, are struggling with budget constraints, stakeholders in this group will have to be educated on what

NG9-1-1 is, why it is important to make the transition now, and how stifling the process of migrating could be detrimental to public safety.

Technical

In a legacy environment, the expectation of the technical stakeholders is different than in an NG9-1-1 environment. GIS staff plays a very fundamental role in the success of implementing and sustaining

NG9-1-1. As in NG9-1-1 there is the presence of an ESInet, there must be more emphasis and understanding by local network staff to

understand how that works. Cybersecurity to protect the various interconnected networks while still providing interoperability becomes

more complicated and requires coordination between IT staffs. Education of the NG9-1-1 infrastructure is important to maintaining

success.

Fiscal

During these economic times, it is important to have the fiscal stakeholders understand the industry best practices in developing

requirements and procuring an NG9-1-1 solution. Education is also key to this group of stakeholders for them to understand that this is not an

upgrade to the system, but a shift to a new system.

Community

The community needs to be educated on what their interaction with 9-1-1 in their community will look like in a next generation environment. As there is an increase in their taxes to help cover the cost of migration, there is an onus on the state and localities to educate them on the why.

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Figure 8: NG9-1-1 Stakeholders

The State should establish a prolonged education and engagement series throughout the next few years to not only educate the stakeholders about what NG9-1-1 is, but what it will offer citizens in the state. As the dependency on technology shifts, there is an expectation set by stakeholders for what services, such as 9-1-1, are impacted and provided. Education about the importance, cost, and next steps helps to allow stakeholders to champion for the change. The development of a communications plan to ensure messaging is accurate and consistent may be necessary. 4.3 Technology Requirements and Considerations

4.3.1 PSAP Call Handling As outlined in the assessment of the current PSAP call handling environment, a significant percentage, 59 percent, of the call handling equipment in use today does not support i3 standards, either requiring upgrades to existing equipment or new complete systems to comply. Therefore, an effort to increase the speed at which investment in i3-capable call handling solutions is recommended moving forward. Estimated at $36,000 per position would equate to a rough order of magnitude investment of $21.6 million over the next two to three years to bring call handling equipment in alignment with NG9-1-1 needs.

Operational

•Call Takers / Dispatchers

•PSAP Leadership

•First Responders

•Statewide 9-1-1 Bureau

•Statewide 9-1-1 Administrator

• ISP Leadership•FirstNet

Political

•Governor •State Legislators•County Leadership

•City and Town Leadership

•OtherElected Officials

•ETSBs

Technical

• ICC •Statewide 9-1-1 Bureau

•Statewide 9-1-1 Administrator

•Service Providers

•Vendors•CIOs•IT Staff•Local Network Staff

•GIS Staff

Fiscal

• ICC •Statewide 9-1-1 Bureau

•Statewide 9-1-1 Administrator

•Procurement Officers

•Budget Personnel

•ETSBs

Community

•Statewide 9-1-1 Advisory Board

•Citizens•Civic Organizations

•Special Needs Community

•Tribal Community

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Figure 9: Potential CPE Upgrade Needs

It is important to note that while the technology deficiency is not deemed a barrier to establishing an interface with an IP network, outdated technology does prevent the introduction of many desirable features that NG9-1-1 promises to deliver to the state of Illinois. Furthermore, the need for additional equipment required to interface with IP-based networks for SIP signaling will require an additional cost of integration at the onset, and follow-on cost for removal of equipment as technology upgrades occur. While many PSAPs with outdated technology do have plans to upgrade in the next three years, this will be dependent on funding, implementation timelines, and setting policy requirements for technology to interface with the ESInet. It should be noted that given the significant cost to bring lagging technology up-to-date with i3 standards, options do exist for leveraging economies of scale to provide high-level service at a lower cost. Hosted controller solutions have increased in popularity in recent years, and can be leveraged as an option to support PSAPs of varying sizes that need new technology but are challenged with technical resources and funding. As part of the RFP to be developed, vendors will be asked to provide proposals for hosted call handling solutions and to verify which call handling platforms have been successfully integrated to their NG9-1-1 solutions. Given the significant effort required to address the 59 percent of current solutions that will require upgrades or replacement to become i3-compliant, consideration should be given to the hosted call handling solution as a means to speed replacement and reduce cost. Smaller PSAPs with one to 5 seats benefit most from the economies-of-scale approach that hosted solutions provide by sharing core components as opposed to procuring capital assets that require maintenance and support. A hosted call handling solution in Illinois could be hosted in diverse locations to provide redundancy, much like the hosted call routing solution for NGCS, with remote stations extended from the core to the PSAP utilizing the same ESInet interface. All future call handling equipment purchases should be validated as i3- and selected vendor-compliant before funds are dispersed to ensure that PSAPs are making progress in the right direction for feature capability. The selected ESInet/NGCS provider should have a test lab available for pre-production testing of CPE.

0 10 20 30 40 50 60 70

1 to 56 to 10

11 to 2021 to 3031 to 40

200+

CPE Potential Upgrade Needs by PSAP/Position Counts

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If PSAPs choose to procure new CPE solutions prior to or during the transition to NG9-1-1, it is critical that i3-compliant solutions are procured. For PSAPs wishing to procure CPE equipment, RFPs should include language to ensure that CPE and CPE-related equipment are both legacy and i3-compliant for all future purchases. Several examples include the following:

1. Must be capable of supporting: a. Legacy ALI database and HTTP-Enabled Location Delivery (HELD) queries b. Emergency service number (ESN) and geospatial routing c. i3 SIP and legacy connections

2. Respondents should describe their level of HELD implementation as defined in Section 4.2 of NENA-STA-010.2-2016.

3. Respondents should describe their level of Location-to-Service Translation (LoST) protocol implementation at the CPE for interacting with the Emergency Call Routing Function (ECRF) and Location Validation Function (LVF) elements of i3, as defined in Sections 4.4.2 and 4.4.3 of NENA-STA-010.2-2016.

4.3.2 GIS / Mapping GIS is a foundational element for NG9-1-1 and, as such, the development of a strong standards-based GIS program is of the upmost importance. The establishment of such a program is no small undertaking and requires a significant leadership investment of time. Both the states of Kansas and Tennessee have excellent models from which to draw upon. The GIS program should focus on four key elements: standards, quality, frequency, and contiguous. All GIS should comply with the NENA Next Generation 9-1-1 (NG9-1-1) United States Civic Location Data Exchange Format (CLDXF) Standard for required layers and attributes. The State should outline the minimum standards for GIS data for use with NG9-1-1 and require agencies to adhere to same. GIS data for use with geospatial call routing and location validation functions requires a high level of accuracy. While many agencies within the state have taken the initiative to perform analysis of their data to existing MSAG/ALI data, to fully prepare for the transition to NG9-1-1, much more work is needed. Analysis alone will not suffice, changes to the data will be required, and in many cases changes at the local level data schema may also be needed. All PSAPs should conduct analysis of current GIS data to MSAG/ALI data to determine baseline readiness for NG9-1-1, either independently or by a third-party, but against the same standard. Once complete, a coordinated effort at the state level should be undertaken to ensure quality metrics are in place and progress to correct erroneous data is tracked against the master implementation schedule. Automated quality assurance and quality control (QA/QC) measures will provide a significant benefit in the form of time savings in the effort to clean data and prevent errors from entering the spatial interface and call routing solutions. Gaps and overlaps must be addressed to ensure that once all agency data is compiled into a single data set the data is seamless for use by the NG9-1-1 service provider(s). Failure to address these can result in misroutes of 9-1-1 callers and potentially delay first responder dispatch. This effort will require close

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coordination at the local level to resolve. Strong QA/QC measures should be established to prevent gaps and overlaps from being introduced at the state level and ingested by the NGCS provider. Update frequency must be addressed across the state; this is key to ensuring that current data is available for subscriber validation and call routing. NENA Standards for the Provisioning and Maintenance of GIS data to ECRFs and LVFs (NENA-STA-005.1.1-2017) recommends GIS data layers be updated from minutes in some cases to hours or days depending on layer. A one-size-fits-all approach may not be appropriate for the state of Illinois, given the disparity in size between largest and smallest PSAPs. Therefore, good judgment and flexibility should be built into any process defined. A PSAP that supports a community with minimal growth may require less frequent changes to GIS, where as a large metropolitan area with significant growth may require daily changes. The State should consider the use of automation where appropriate to support those characteristics. Automation will not preclude the need for direct support at the local level for managing the upkeep of the data; however, it will improve the consistency and flow of information from the local agency to the spatial interface function. Two options for achieving GIS readiness are available: a State organized and operated program or a vendor-provided SI. Industry working groups are currently organized and actively in the process of further defining the spatial interface function and roles and responsibilities; however, early feedback indicates that the spatial interface function and provider will have broad responsibility of collecting the data from disparate agencies and coalescing into a single statewide data set in compliance with data standards and schema requirements. To accomplish the legislative goal of delivering NG9-1-1 by 2020, the State should establish a statewide GIS initiative to provide definitive guidance on the requirements, frequency for updates, and quality standards for GIS data for public safety use in NG9-1-1. Given the scope of the effort, work on this element for the transition to NG9-1-1 should begin as early as possible to prevent delays in feature implementation in future steps of the transition. The State should either identify a lead agency or contract with a vendor to begin the collection and analysis of data from ETSBs for the performance of QA/QC and aggregation to a statewide data set. This work can be performed in parallel with efforts to develop the program to oversee the effort so that definitive guidance can be issued to resolve errors and discrepancies at the completion of data collection and analysis. The RFP to be developed should include provisions for a GIS vendor (separate or subcontracted to the prime) to perform the spatial interface function to support NCGS. Furthermore, provisions for this requirement will require the GIS data set to remain the property of the State of Illinois. 4.3.3 9-1-1 Providers During the June 2017 meeting with the 9-1-1 service providers, the providers highlighted the need for ubiquitous, standardized NG9-1-1 solutions for the state of Illinois, and recognized that TDM network infrastructure changes would play a role and requested that the solution remain flexible for carriers needing network access. Other notable issues raised during the meeting centered on liability, cost recovery, and GIS quality to support geospatial routing.

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The existence of ESInet and NGCS providers operating within the state will require any NG9-1-1 solution offered by the State to be capable of interfacing to support the ability to transfer 9-1-1 calls for service and the future potential to support policy routing functions. The selected solutions provider must take this into consideration. It is recommended that the Playbook serve as a model for integrating ESInets. The selected NGCS solutions provider should be a licensed and certified 9-1-1 solutions service provider in Illinois to avoid potential delays in project implementation. The State will need to ensure that the NGCS provider deploys an i3 standards-based solution that ensures flexibility for OSPs’ connectivity to the ESInet. 4.3.4 Service Providers OSPs will be required to interconnect with the State of Illinois ESInet and, as such, will need to have multiple Points of Presence (POP) to ensure geo-diverse egress. The selected solutions provider should be capable of supporting multiple geo-diverse meet-me points to reduce the cost of transport between LATA boundaries where feasible. In addition to diverse POP for OSP interconnections, the ESInet provider must be able to ensure last mile connectivity to all PSAPs within the state, either through owned or leasing agreements. Furthermore, the selected ESInet provider must be capable of supporting minimum bandwidth needs for trunking capacity to carry both voice and media at equivalent existing CAMA trunk capacity to each PSAP with a marginal capacity for future growth as deemed sufficient. Consideration must be given to the broad range of PSAP needs when planning bandwidth for an ESInet in Illinois. The majority of PSAPs have five positions, yet the network will also be required to support the City of Chicago, which staffs over 200 positions (as a whole) and requires a significant network investment. 4.3.5 Standards The State requires the implementation of a standards-based solution that complies with nationally accepted standards and requirements applicable to IP network architecture, security, and interface functionality. The RFP to be developed will encompass standards-based requirements for vendors to deliver IP network design, deployment, operation, and security in full compliance with recognized standards. 4.3.6 Automated Information Systems NG9-1-1 brings a significant improvement in the ability to transfer and route calls through the Policy Routing function (PRF). In cases where phone systems outages prevent callers from arriving at the desired destination and PRF has chosen a second route option, CAD-to-CAD interfaces provide the ability to get the information needed for dispatch to the appropriate agency for first response. For CAD-to-CAD to be technically feasible, system upgrades will be required to PSAP CAD equipment in areas where solutions have reached end-of-life, and should be looked to as a future enhancement to operational readiness. As current CAD solutions are replaced and/or upgraded, it is important to ensure the ability to support the XML protocol is present. This will allow the Presence Information Data Format – Location Object (PIDF-

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LO) to convey location information and support the functionality to exchange data with adjacent agencies by supporting National Information Exchange Model (NIEM) standards. This need for further systems integration will become more apparent as FirstNet begins implementation. The information available and the flow of information between agencies should, over time, continue to become more interwoven and could potentially lead to opportunities to introduce hosted CAD solutions, much like those considered for call handling equipment, where solutions will be architected as cloud-based host/remote and/or be interconnected through an ESInet interface. MIS is a valuable tool to support QA and operational excellence. Not only should voice recording be leveraged to evaluate operational metrics, but call data information should also be leveraged to ensure a robust QA/QC process and to assist in the process of trend identification for staffing and technology needs. As the operational support model shifts from the standard legacy operations model, the State of Illinois should ensure that a core call routing solution is supported with a robust MIS and reporting system, to ensure that data is available to manage the system. This data can be used as standalone or in tandem with MIS data at the local PSAP level to assist operational staff in making data-driven decisions for system optimization. Therefore, Illinois should include as a function of the RFP that potential solution providers are required to identify their available reporting suites developed internally or provided by a third-party solution. Voice recording should also be considered when planning for i3 systems integration. Systems should have the ability to record either at the call handling equipment position or IP port for call traffic. PSAPs should plan to review their existing solutions with vendors and prepare an upgrade plan, if necessary, prior to integrating with the ESInet. Any future recording purchases should be required to support native SIP interfaces. For PSAPs wishing to procure CAD equipment, RFPs should include language to ensure that CAD and CAD-related equipment is both legacy and i3-compliant for all future purchase. For example, an RFP should include the following:

1. Must be capable of supporting i3 location data such as XML protocol for PIDF-LO. Respondents should describe their level of compliance to National Information Exchange Model (NIEM) standards.

4.3.7 Interfaces to Other Systems The vision of NG9-1-1 is a network of networks, an interconnected landscape that allows for new data sources, more redundancy, flexibility, and reach than ever before. Whether establishing interconnectivity with regional or interstate agencies, the State should ensure the NG9-1-1 solutions provider plans accordingly. With six bordering states and two regional intrastate ESInets, there will be a necessity to transfer calls between agencies served by external ESInets and NGCS. The Playbook can serve as a foundation for building requirements, and establishing operating agreements with other agencies. Along with this vision comes interconnectivity with new devices and new solution providers that have never been able to access 9-1-1 networks to provide enhanced information. The Internet of Things (IoT) will bring

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information from smart devices for improved location accuracy and caller data. Additional data repository providers will be able to supplement caller information to provide more detailed information to first responders. Many of these technologies are only now beginning to see trials in the 9-1-1 call environments as innovators in the industry strive to encourage early adoption. There is more future work to be done as an industry to reach the point of mainstream market adoption; however, Illinois, with its NG9-1-1 solution, must be prepared to support interfacing with standards-compliant third-party solutions for additional data. Even more to consider is the introduction of FirstNet into the public safety market, with many parallels to the NG9-1-1 core of an IP-based broadband network, FirstNet focuses on the communication between dispatching and first responder as well as intra-first responder communications. While much of the proposed FirstNet solution and implementation is still unknown, the integration between the two solutions does not have to be parallel; convergence should be the goal. The ability to get information seamlessly from a caller to the responder should be a priority. 4.3.8 Security / Backup / Resiliency Considerations Cyber security is a critical function of any IP network, and must be a high priority for any ESInet implementation. The transition from legacy TDM network to IP networks introduces new security challenges; in addition to Total Denial of Service (TDOS), cyberattacks including malware, virus, and ransomware must now be considered and prevented. The selected provider must comply with the National Institute of Standards and Technology (NIST) Framework for Improving Critical Infrastructure Cybersecurity and the NENA Security for Next-Generation 9-1-1 Standard (NG-SEC) for security. The ESInet and local PSAP networks are recommended to perform regular network asset inventory audits. In addition, local PSAP networks should undergo an initial cybersecurity assessment to establish a baseline from which improvements to security can be made prior to interfacing with the ESInet. Defining minimum requirements for network and physical security for PSAPs connecting to the ESInet for service is also recommended. Facilities for the ESInet and NGCS should be geo-redundant, and have redundant architecture and dual entrance facilities. Power and cooling at core networking sites should have redundant systems. Physical security and access control, in addition to network security, should be a minimum requirement. Where available, PSAPs should leverage network path diversity for facility entrance. Continuity of Operations Plans (COOP) for network and core services providers should be in place and reviewed and exercised at annual intervals. Local PSAPs are recommended to have a complementary COOP, which is reviewed annually. Network monitoring and network and security operations centers should have 24-hours a day, 7-days a week, 365-days a year operations. 4.4 Operational Considerations and Implications The feature-rich capabilities of NG9-1-1 will create a new operating environment for PSAPs. As was discussed in the town hall meetings, not all PSAPs may be ready or able to use all these features. To provide ubiquitous service across Illinois, the State could develop requirements for the PSAPs or ETSBs.

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As the ETSBs have a better understanding of the resources and abilities of the PSAPs in their jurisdictions, the ETSBs should develop plans for the following: • Minimum of two levels of alternate call routing for each PSAP • Minimum of two PSAPs designated to receive and process calls with media other than voice (text,

video, etc.) • Minimum of two PSAPs designated to handle calls in the event of a PSAP failure/evacuation. • Training for PSAPs on NG9-1-1 procedures 4.5 Economic / Funding Considerations and Implications 4.5.1 Grants and Potential Funding Sources 4.5.1.1 Next Generation 9-1-1 Advancement Act Grants The Next Generation 9-1-1 Advancement Act of 2012, Title VI, Subtitle E of the Middle Class Tax Relief and Job Creation Act of 2012, amended section 158 of the National Telecommunications and Information Administration (NTIA) Organization Act, 47 U.S.C. § 942, to direct the administrator of the National Highway Traffic Safety Administration (NHTSA) and the Assistant Secretary for Communications and Information and NTIA Administrator to establish and jointly administer a matching 9-1-1 grant program. The Act also required the NHTSA Administrator and the NTIA Assistant Secretary to develop and submit to Congress a plan for the management of the program. The matching grant program provides financial assistance to eligible entities for:

(A) the implementation and operation of 9-1-1 services, E9-1-1 services, migration to an IP-enabled emergency network, and adoption and operation of Next Generation 9-1-1 services and applications;

(B) the implementation of IP-enabled emergency services and applications enabled by Next Generation 9-1-1 services, including the establishment of IP backbone networks and the application layer software infrastructure needed to interconnect the multitude of emergency response organizations; and

(C) training public safety personnel, including call-takers, first responders, and other individuals and organizations who are part of the emergency response chain in 9-1-1 services.28

28 https://www.gpo.gov/fdsys/pkg/PLAW-112publ96/html/PLAW-112publ96.htm

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The coordination plan between NHTSA and NTIA facilitates communication between federal, state, and local emergency communications systems, emergency personnel, public safety organizations, telecommunications carriers, and telecommunications equipment manufacturers and vendors involved in the implementation of NG9-1-1 services. The Tax Relief Act made $115 million available for the program from the Public Safety Trust Fund. To carry out the tasks outlined in the Act, NHTSA and NTIA signed an MOU in September 2016 establishing each party’s roles and responsibilities. The MOU provided for the transfer of $112 million to NHTSA, of which $109,250,000 is estimated to be available nationwide for grants. The funding for the grant program comes from funds from the incentive auctions carried out by the Federal Communications Commission (FCC) under 47 U.S.C. § 309(j)(8)(G) or the auction of spectrum pursuant to Section 6401. The amount available may be reduced because the program is subject to the Budget Control Act of 2011 and the Bipartisan Budget Act of 2013, which imposed certain budget limits and sequestration caps on the program. As a state entity overseeing the planning and implementation of a statewide NG9-1-1 plan, the Department may be in a positive position to apply for grant funds from the matching grant program and to leverage its own funds to create more opportunity in Illinois. Strategically, the Department may want to consider specific needs for the migration to an IP-enabled emergency network in the state. The notice of proposed rulemaking (NPRM) was published on September 21, 2017. In the past, grantees from the National 911 Program have used awarded funds to upgrade their 9-1-1 systems to comply with Phase II wireless E9-1-1 requirements, implement NG9-1-1 technologies, and make significant improvements in technology and emergency communications. The NPRM proposes to expand to also allow NG9-1-1 services, training, planning, and administration, and operation of NG9-1-1 during the transition. Grant applications are expected to be accepted during the fall 2017 timeframe with awards expected to be made in early 2018.29 While the final grant rules have not been published, the NPRM states each state is eligible for at least $500,000; the final amount will be based on a combination of population and road miles. The previous grant made Illinois initially eligible for up to $1.34 million in 50/50 grant funds, and additional funds were allowed for eligible states. Using that grant as a reference, Illinois may be eligible for $2 million to $3.5 million in 60/40 matching grant funds in this round. 4.5.1.2 Other Federal Grant Funding Several federal agencies offer a multitude of grant programs annually in different fields (e.g., disaster prevention, contingency planning, communications infrastructure, communications planning, training, education, etc.). Many of these grant programs are considered emergency communications-related and

29 https://www.911.gov/911grants.html

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support the ability to build and improve the capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from threats that pose the greatest risk to national security. A list of all federal financial assistance programs30 with funding available for emergency communications is made available by the National 911 Program. 4.5.2 Federal Grant Guidance 4.5.2.1 Emergency Communications Preparedness Center Reference Guide The Emergency Communications Preparedness Center (ECPC) Reference Guide provides common guidance for federal program managers to use when developing notices of funding opportunities, award agreements, performance, and financial reports, and other program materials, and includes common grant guidelines for applicants of emergency communications funds. Consequently, it is a useful starting point for information about guidelines applicable to federal grants that might be used for 9-1-1 and NG9-1-1. 4.5.2.2 SAFECOM Grant Guidance SAFECOM was formed to improve public safety interoperability, allowing emergency responders to communicate effectively before, during, and after emergencies and disasters. “SAFECOM’s mission is to improve designated emergency response providers’ inter-jurisdictional and inter-disciplinary emergency communications interoperability through collaboration with emergency responders across Federal, State, local, tribal, and territorial governments, and international borders.”31 To further these ideas, SAFECOM annually publishes SAFECOM Guidance on Emergency Communications Grants and compliance requirements for Department of Homeland Security (DHS) grants, to include conforming to NG9-1-1 standards, as published in the document entitled Next Generation 911 (NG911) Standards Identification and Review32 a compendium of all NG9-1-1 standards published annually by the National 911 Program. The Office of Emergency Communications: Fiscal Year 2017 SAFECOM Guidance on Emergency Communications Grants provides general guidance for entities applying for federal financial assistance for emergency communications projects, including: • Recommendations for planning, coordinating, and implementing projects • Emergency communications activities that can be funded through federal grants • Best practices, policies, and technical standards that help to improve interoperability

30 Federal Financial Assistance Programs for Emergency Communications. https://www.911.gov/pdf/FY_2016_Federal_Financial_Assistance_Programs_for_Emergency_Communications.pdf 31 https://www.dhs.gov/safecom/about-safecom 32 https://www.911.gov/pdf/NG911-Standards-Identification-and-Analysis-mar2017.pdf

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• Resources to help grantees comply with technical standards and grant requirements33 4.5.3 Public–Private Partnerships As discussed in the Blue Ribbon Panel on 911 Funding, Report to the National 911 Program34, “one of the most successful methods employed by other infrastructure-related industries to improve project delivery efficiency, minimize government project risk, increase cost effectiveness, and potentially generate revenues is a P3;”35 a Public-Private Partnership. “In addition to decreasing costs and raising new revenue, P3s can significantly reduce the time and costs required to complete a capital project while reallocating risks from the public to the private sector.”36 MCP cautions that a certain amount of risk is also inherent in P3s and any private company the Department considers partnering with should be thoroughly vetted prior to any agreements being signed. The success other countries and industries have had in utilizing P3s has led to the recognition that the P3 may be an effective financing method for federal, state, and municipal governments. “Government assets procured in such transactions have included water and wastewater management, highways, transit, healthcare, airports, seaports, and social services (e.g., education, health). “In addition to government incentive, private sector interest in infrastructure as an investment asset vehicle has increased dramatically over the past decade, with many pension, private wealth, and insurance funds looking for P3 opportunities as a transition from the risk/return profiles of equities and bonds. Sources estimate that more than $200 billion in private capital is currently available for investment in U.S. infrastructure.”37

Table 6: Advantages and Concerns of Public-Private Partnerships38

Advantages Concerns

Additional financial capacity Public scrutiny and stakeholder management

Lifecycle cost efficiencies met through management and integration of project phases

Loss of flexibility of public agency in managing asset

Innovation in design owing to private sector expertise

33 https://www.dhs.gov/sites/default/files/publications/FY%202017%20SAFECOM%20Guidance%20for%20Emergency%20Communications%20Grants_060717_FINAL508.pdf, page 3. 34 https://www.911.gov/pdf/BlueRibbonPanel-911Funding-report-dec2013.pdf 35 Ibid., page 31. 36 Ibid. 37 Ibid. 38 Ibid.

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Advantages Concerns

Redistribution of risk from the public to private sector

Delivery and construction efficiency driven by market pressures in the private sector

Ability to contract quality of service through negotiations

High interest of private sector investors (pension funds, private wealth), operators, and developers in investment and partnership with governments in infrastructure projects.

4.5.4 Fund Diversion NHTSA published an NPRM39 for the next round of 9-1-1 grant monies that will be made available through the National 911 Program as a result of the enactment of the Next Generation 9-1-1 Advancement Act of 2012. Section 6503 of the Act requires applicants seeking to receive grants under this program to certify that no portion of any designated 9-1-1 charges imposed by the state or other taxing jurisdiction within which the applicant is located are being obligated or expended “for any purpose other than the purposes for which such charges are designated or presented.” The NPRM proposes to keep the requirement that a state certify it has not diverted any portion of designated 9-1-1 funding for 180 days prior to the application and that it will not divert funds during the time period of the grant. Fund diversion has become a significant topic and a point of contention among state and local authorities. There is concern that the potential for the governor to designate a 5 percent “reserve” of funds appropriated to the Department, as called for in Public Act 100-0023, could jeopardize Illinois’ ability to receive federal funding in the future. Section 8.52 (a) Special Fund Transfers allows the State Treasurer and State Comptroller to make transfers from special funds into the General Revenue Fund, the Budget Stabilization Fund, the Healthcare Provider Relief Fund, or the Health Insurance Reserve Fund if authorized by the Governor's Office of Management and Budget. The transfer may occur at any time prior to June 30, 2018, and an amount not to be exceeded is specified for each special fund. The legislation allows an amount not to exceed $5,926,000 from the Statewide 9-1-1 Fund and an amount not to exceed $327,000 from the Wireless Carrier Reimbursement Fund diverted to another fund within the state.

39 NPRM 47 CFR Part 400 https://www.federalregister.gov/documents/2017/09/21/2017-19944/911-grant-program

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Public Act 100-0023 does include a clause that will help protect the funds and ability to get grants. If the Director of the Governor's Office of Management and Budget determines that any transfer jeopardizes federal funding based on a written communication from a federal official those funds may be returned. In the Eighth Annual Report to Congress on State Collection and Distribution of 911 and Enhanced 911 Fees and Charges, the FCC identified those states that have diverted funds collected for 9-1-1. Table 16 on page 65 of the reports lists the states diverting funds in 2016 compared to previous years. Illinois is identified in the very top line as having diverted funds each year from 2009 through 2016. Every effort should be made to ensure that funds collected for 9-1-1 purposes are not used for non-9-1-1-related activities or programs if the Department intends to apply for any federal grants noted previously. Current and future federal funding will clearly be contingent on following the intent and purpose of the fund collections and no funds will likely be awarded to those states or jurisdictions that do not follow this requirement.

5 Recommendations / Options

5.1 NG9-1-1 Guiding Principles 5.1.1 Themes During the town hall meetings, stakeholders expressed needs, visions, concerns, and priorities, which facilitators captured as a set of principle themes. Feedback received during the town hall meetings and through the PSAP survey was used to align the outcomes from the town hall meetings and the NG9-1-1 feasibility study. Detailed findings of the town hall meetings are included in Appendix A–Summary of Town Hall Meetings. Detailed survey results are included in Appendix B–Survey Details. Additional themes identified by MCP were presented to town hall meeting participants for consideration. The town hall themes along with the survey results were consolidated into a set of themes discussed below.

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Figure 10: NG9-1-1 Themes

Actions that will be taken to achieve the goals, objectives, and initiatives in the NG9-1-1 Comprehensive Plan for Illinois should align with these themes. 5.1.2 Guiding Principles Guiding principles set a benchmark for stakeholders as they engage in planning to consider what actions are necessary to achieve the mission. To realize the vision for the future of 9-1-1 in Illinois, all actions taken must align with these guiding principles.

•Standards development and implementation•Expectations established•Case studies and lessons learned from others

Standards-driven

•Dynamic routing and rerouting, overflow, and backup •Redundancy • Infrastructure management

Reliable/Survivable

•Sustainable•Costs understood and defined•No jurisdiction left behind

Sustainably Funded

•Shared resources and mapping•Enhanced data capabilities•Open architecture

Managed Data

•GIS boundary data overlap •FirstNet/NG9-1-1 integration• Internal systems

Integrated

•Protections•Standard practices•Policy-driven

Secure

•Interoperable•Leverage partnerships for surge and backup•Improved network capabilities and cross-jurisdictional transfer capabilities

Functional

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Figure 11: Guiding Principles

For stakeholder agencies in Illinois, continual improvement is a desired state. Agencies are profoundly interested in providing the highest quality service to their citizens and are fully intent on leveraging existing economies and initiatives while moving all Illinois systems to a higher level. 5.1.3 Desired Outcomes This Next Generation 9-1-1 Feasibility Study defines key strategic initiatives for moving the state forward to improve 9-1-1 services and functionality across Illinois. The study identifies the existing state of capabilities, the desired functionality, and a pathway to achieve the desired state. It describes a future for 9-1-1 and NG9-1-1, and will influence Illinois’ statewide decisions concerning the future of 9-1-1 service delivery to continue to meet the public’s high expectations for 9-1-1 emergency service. The path forward seeks to encourage and support a consistent level of emergency service across the state, and to contribute to excellent public safety capabilities that maintain safe and secure communities. 5.1.4 Vision The vision for NG9-1-1 in Illinois is to have a ubiquitous NG9-1-1 service and to provide each 9-1-1 caller with the same level of service for all residents and visitors of the state, regardless of location or device.

Strategic vision must address ALL of 9-1-1 needs, not just NG9-1-1

Broad stakeholder engagement is desired at all levels

Robust functionality is of paramount importance

Services must be improved, not degraded

Sustainable funding is essential to carry out the mission

Reliability, resiliency and sustainability is critical to success

Regional capabilities/initiatives must be leveraged

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The recommendations in this report are based on the current environment of the state of Illinois. A review of the technical, operational, regulatory, and fiscal situation of the State was conducted and the results documented in this report. These findings were used to develop the following recommendations of the vision of NG9-1-1 in Illinois. The following sections explain these in depth, but the general vision is as follows. • ESInet – Make use of the existing in-place ICN to allow for a rapid and cost-effective deployment within

the legislative timeframe. Limit the redundant connections to PSAPs to the larger PSAPs and about half of the smaller PSAPs to reduce costs.

• NGCS – Use hosted solutions provider given the limited staff and to limit the liability of the State. • GIS – Develop a statewide system; in the interim, place the receipt and management of GIS data of

the initial areas on the NGCS provider to speed the deployment. • Operational Issues – Allow each ETSB to develop the plans for which existing PSAPs will receive

various media types and will be backup sites for routing and redundant connections. The ETSBs are in the best position to identify the capabilities of the PSAPs and develop the COOPs.

• PSAP Systems – Ensure the RFP includes an option to provide hosted CPE and CAD systems for the ETSBs and PSAPs to procure from. While this is outside of the normal activities, the PSAPs in the survey and town hall meetings indicated that they would like to be able to log in anywhere to get their calls. This is a CPE function and not an NG9-1-1 function.

This future vision for Illinois will be implemented successfully through regular involvement from local 9-1-1 authorities and practitioners—those who diligently serve the public every day and know the issues at hand—coupled with guidance from the State to ensure that all citizens receive consistent, quality 9-1-1 service commensurate with their expectations. 5.2 Illinois NG9-1-1 Operational Vision As an industry, best practices are being developed and vetted by local and state jurisdictions across the nation that will make the day-to-day operations in an NG9-1-1 environment easier. It is important while developing the vision for Illinois that stakeholders provide their concerns and vision about what NG9-1-1 will look like in Illinois. It is important to remember that because there is no single best method to achieve NG9-1-1, the goals for Illinois may look different than another state’s. 5.2.1 Consolidation PSAP consolidation already has begun in Illinois, but the continuation of it needs to be complete before the technical buildout and implementation phases of NG9-1-1 are complete. 5.2.2 Staffing In an NG9-1-1 environment, the roles and responsibilities of the staff will change somewhat. The roles should be identified now and the changes to the job descriptions should be reviewed to ensure that they align with the NG9-1-1 environment. One role that will gain importance will be technical support. The days

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of setting up systems and forgetting about them until the next update are over. Technical staff will be needed to monitor the health of the systems and ensure they are protected. 5.2.3 Mutual Aid Agreements and Memoranda of Understanding Call routing policies need to be established for the NG9-1-1 environment. Mutual aid agreements and MOUs should be reviewed to ensure that they are NG9-1-1 ready. Existing ETSB and PSAP agreements will need to be expanded to include new technologies and scenarios for the NG9-1-1 environment. Appendix G–Cooperative Agreements provides guidance on drafting MOUs. 5.2.4 Multimedia In an NG9-1-1 environment, PSAPs eventually will be able to accept real-time video and pictures. There has been concern about the impact of seeing live events unfold, and whether that could be detrimental to telecommunicators who will be accepting different pieces of multimedia. It must be decided how these types of media files will be handled in the PSAP. ETSBs will need to decide how they individually will accept multimedia requests for service, while ensuring everyone across the state has access to the same level of service. 5.2.5 Training All training materials should be reviewed to ensure they are NG9-1-1-compliant. Additional training should be conducted for veteran telecommunicators, including training on what will change during the migration. 5.2.6 Consistent Level of Service A statewide minimum level of service should be decided upon, with the onus being on the individual ETSBs to ensure that they are meeting the minimum level of service established. 5.2.7 Policies and Procedures Policies and procedures will change with the shift from a legacy environment to an NG9-1-1 environment. Therefore, all policies and procedures will need to be reviewed, and use-case scenarios for the NG9-1-1 environment will need to be developed to ensure changes to the policies and procedures will be applicable. 5.3 Illinois NG9-1-1 Technical Vision The transition from legacy TDM-based 9-1-1 services to IP-based NG9-1-1 offers options to resolve challenges to bringing new and emerging technologies to citizens of Illinois. Of paramount importance is the delivery of ubiquitous, robust, and reliable 9-1-1 service to the citizens. NG9-1-1 offers great promise in accomplishing each of these goals; while providing a platform to grow and expand as the environmental factors change over time.

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To accomplish the vision of NG9-1-1 in Illinois, which will include both the ESInet and NGCS, standards-based system solutions are required. The use of a standards-based NENA i3 architecture will ensure that vendor-agnostic solutions are deployed to meet the needs of the system, thus allowing for flexibility in procurement options when considering both the ESInet and NGCS. Outlined in the technical vision is a high-level roadmap for delivering universal, reliable, and standards-based NG9-1-1 ESInets and NGCS in Illinois. Ensuring compliance with standards while allowing flexibility for growth and emergence of new technologies is key to keeping pace with the evolving patchwork of NG9-1-1 implementations occurring nationwide. 5.3.1 ESInet The foundation upon which the statewide NG9-1-1 solution is built must be highly available, diverse, and deliver consistent high-quality, public safety-grade service. Because NG9-1-1 will be a statewide solution, each PSAP must be able to obtain access to the statewide ESInet; therefore, the ESInet must be capable of scaling to meet the needs of the smallest PSAPs operating in the state, as well as those of the largest PSAPs operating in the nation. 5.3.1.1 Carrier-based Network Existing telecommunications service provider infrastructure operating within the state provides an option for facilitating an ESInet. In addition to ESInets already in operation in Illinois into regional locations, telecommunications service providers are abundant and already in operation; facilities range from copper to fiber backhaul at the physical layer. Any communications service provider solution selected for the ESInet must provide last-mile bandwidth capable of supporting a wide range of customers. PSAPs operating in Illinois range from small to very large and as such will have different needs to support operations. Adequate POP must be available for OSP egress to the network and be within reasonable proximity to avoid long-haul circuit costs. Operational support of the ESInet should also be considered as a factor. Implementing a network is only half of the equation; it must be maintained and supported beyond turn-up. Therefore, network operations centers (NOCs), security, and operations must be factored into decision-making. OSPs in many cases have these support solutions already in operation, with business processes vetted and improved over many years. Nationally, there are ESInets successfully in operation using the OSP model. The advantages and disadvantages to carrier-based networks are provided below.

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Table 7: Carrier-based Networks

Advantages Disadvantages

Multiple provider options Cost generally higher than public option

Operational support Coverage may require interoperability agreements

Existing networks in place

Proven model

5.3.1.2 Public-provided Network The State has gone to great lengths to build and maintain a significant fiber footprint in Illinois. In addition to over 2,000 miles of lit fiber, ICN maintains interconnect agreements with last-mile providers reaching most PSAPs, and supports LEADS connectivity for most State agencies. Currently last-mile service is a mix between copper and Metro-E based on LEC capabilities. ICN operates best-in-class Distributed Denial of Service (DDoS) protections, operates their own MPLS cloud and is currently working with providers to increase redundancy, provides network monitoring NOC services for the ICN, and provides Quality of Service (QoS) and SIP trunking services. DoIT, the agency that oversees the ICN, operates two data centers, one owned and one leased. The advantages and disadvantages to public-provided networks are provided below.

Table 8: Public-provided Network

Advantages Disadvantages

Considerable fiber backbone Lack of 9-1-1 industry experience

Cost generally lower than carrier networks Southern Illinois fiber access limited

Operations support NOC will need to increase staffing

Last-mile agreements in place for LEADs program

From a cost and timing perspective, the ICN solution for the ESInet provides a logical choice. By providing an existing large fiber footprint and existing last-mile interconnection agreements, the ICN will provide the NG9-1-1 network a foundation already in place from which to grow. Furthermore, the competitive cost for connectivity provides a major benefit to the State. Current initiatives to expand reach and convert all

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existing LEADS connections, which are in place at all law enforcement agencies, to Metro-E services ensures adequate bandwidth for current and future needs. Technical requirements of the RFP for the ESInet will be separated from NGCS requirements to allow for competitive pricing and solutions analysis with other ESInet bidder options to avoid directly impacting the ability to secure NGCS should the State of Illinois chose to procure services from ICN. 5.3.1.3 NG9-1-1 Core Services Hosted core services have become a popular option in recent deployments due to flexibility and scalability. Furthermore, hosted solutions support economies of scale, allowing vendors to reduce cost of hardware infrastructure and data center leasing/own fees through platform sharing. At the onset of NG9-1-1, core services vendors marketed these solutions to smaller regional system agencies to lower the cost of entry to the market. However, hosted solutions have proven to have a wider market interest, as evidenced by the recent shift by national providers to offering large-scale hosted solutions for NGCS. Hosted solutions can be located within the state borders in privately owned or leased facilities; however, the reach of IP networks combined with the ability to configure virtual routing and forwarding (VRF) allows providers to support more than one customer solution on the same network, yet retain security and segmentation of services from remote data centers. Hosted NGCS rely on managed services for provisioning and maintenance; licensing and associated fees are incorporated into the overall cost of the solution. The advantages and disadvantages to hosted NGCS are provided below.

Table 9: Hosted NGCS

Advantages Disadvantages

Flexible Black box approach

Scalable Potential higher cost for support

Managed service Minimal customization

Bundled services

Speed of deployment

Lower initial cost

In-network NGCS is another option that exists for the facilitation of NGCS deployments. In-network deployments, in general, consist of customer-owned or leased equipment residing in customer facilities,

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either managed by a vendor or customer IT staff. Managed services may still be used to support and provision in-network NGCS; however, the equipment costs and licensing/maintenance costs reside with the customer. There are current production solutions in place under this model; however, it is becoming rarer due to the significant level of support required to operate and maintain 9-1-1 systems. The advantages and disadvantages to in-network NGCS are provided below.

Table 10: In-network NGCS

Advantages Disadvantages

More control Resource intensive

Own the solution Requires owned or leased space

Extended deployment

Operations requirements

Hardware maintenance

Higher initial cost

Examples of both models are in operation today supporting regional and/or statewide solutions. Given the organizational make up and the potential staffing and support needs for in-network deployments, MCP recommends a hosted NGCS approach for the state of Illinois. The RFP to be developed will focus on requirements to direct this outcome from proposing vendors. It should also be noted that a hosted NGCS solution will also support the goal of NG9-1-1 availability by 2020. Standards-based solutions are predicated on the basis that all vendors develop solutions to the same minimum guidelines. Two options for the procurement of NGCS exist when operating under the premise that all standards-based solutions should be interoperable: single-source and multi-vendor. Single-source procurement in this instance would either imply that a single service provider is offering all required NGCS functional elements, or is teaming with a preferred/complementary partner to offer a single robust solution under one contract. There are benefits to single-source, which include full interoperability of functionality, a single agency or vendor to resolve disputes or work through for feature enhancement, and change control. However, the benefits of ease of use by the end user can also come at a higher price to the customer as opposed to competitively bidding each function separately, and less choice in the functionality or product options. The balance must be decided as to how much day-to-day management and involvement of the customer is desired. Turn-key solutions afford agencies that are not staffed with technical resources or adequate personnel, which is often the case, to offer high-quality solutions to their stakeholders; while maintaining a low overhead of human resources.

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The advantages and disadvantages to single-source NGCS are provided below.

Table 11: Single-Source NGCS

Advantages Disadvantages

Better interoperability for NGCS functions Less control over implementation and solution

Simplified project management and change control

Single vendor interface for ongoing operational support

Bundled pricing – potential for cost savings

A multi-vendor approach offers an alternative to single-source. In a multi-vendor solution, specific functional elements for the NGCS are chosen based on the specific criteria that best meets the customer’s needs; either cost, features, or a combination of both can dictate the selection of a vendor. This option allows for more flexibility in the immediate and future needs; however, requires more coordination and vendor management, and removes the single point of contact for all needs. In addition to more coordination and management, interoperability can prove to be challenging, even in a standards-based environment, when incident and problem resolution are needed. Strong cross-coordination is required to successfully manage multiple vendors. The advantages and disadvantages to multi-vendor NGCS are provided below.

Table 12: Multi-vendor NGCS

Advantages Disadvantages

Choose each NGCS functions provider Management of multiple vendors/contracts

More vendor options Incident and problem resolution challenges

Interoperability challenges

Both options offer reasonable positive benefits; however, the detractors of the multi-vendor option should give pause for selection. Managing multiple component vendors requires active involvement and resources to ensure that contracted providers are working together to deliver services in the manner expected to produce the desired outcomes. With more choice in solution types and the lure of more competitive pricing, piecemealing an NGCS solution can be appealing; however, the buyer must be prepared to face the

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challenges that come with interoperability and incident/change management. Therefore, MCP recommends that single-source NGCS be the focus for vendor selection. In summary, to achieve the legislative intent of NG9-1-1 by 2020, using existing infrastructure will help to speed the process and provide cost savings. The State’s technical solution should focus on procuring ESInet services from ICN, coupled with a single-source NGCS solution to support the statewide NG9-1-1 system. ESInet and NGCS implementation costs vary by region and size. A rough order of magnitude estimate based on empirical data would average $0.157 per population base for monthly recurring costs, and fixed start-up costs of $1.717 per population base, which includes cost provisions for core GIS services, but not CPE. Based on the population base of 12.8 million for Illinois, a total of 182 PSAPs, and using cost estimates derived from other regional and state-level NG9-1-1 implementations, the proposed model was used to develop a rough order of magnitude.

Table 13: Rough Order of Magnitude Cost Estimation

Non-recurring Setup Cost Annual Recurring Cost

PSAP Connectivity $9,979,000 $1,714,320

Network Core $8,000,000 $3,000,000

ESInet Monitoring $858,000

NGCS $17,223,360

GIS $4,000,000 $1,281,500

Total Cost $21,979,000 $24,077,180

5.3.1.4 Access The ESInet must interface with 9-1-1 service providers, OSPs, as well as other ESInets operating within and outside Illinois. The ESInet should have multiple POP, and the ability to access MPLS and cloud networks, providing flexibility options for the delivery of NGCS. The use of multiple POP and requiring the OSPs to connect to at least two provides redundancy, but may reduce OSP cost by reducing the number of connections they need from the current up to 39 selective routers. 5.3.1.5 Diversity and Redundancy A hallmark of NG9-1-1 is the ability to be cost effective, yet improve the overall diversity and redundancy of 9-1-1 service to PSAPs. Therefore, the solution chosen for Illinois must have network diversity to provide

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no single point of failure at the core. Furthermore, the ESInet must have redundant core infrastructure to ensure that hardware failures do not result in the inability to reach any point in the network. 5.3.1.6 Quality of Service The ESInet must be designed to meet the QoS requirements necessary to deliver public safety voice calls over the network, and to have the appropriate markings to ensure priority traffic, in addition to meeting latency, packet loss, and jitter requirements. 5.3.1.7 Security Security of IP-based systems utilized for public safety must be robust to avoid the increasing frequency of cyberattacks on networks, and to protect sensitive data. The ESInet security posture should leverage industry best practices and deliver best-in-class service, meeting or exceeding current standards for NG9-1-1 Security. 5.3.1.8 Interstate / Intrastate Operability As the nationwide infrastructure supporting NG9-1-1 expands at the state and regional level, the importance of interstate and intrastate operability rises to the forefront as highlighted in the Playbook. In today’s environment, there are regional ESInet operations operating within Illinois; ergo, the statewide ESInet must not only be capable of integration with these standalone networks, but also have the capacity and reach to incorporate the agencies associated with them should future changes dictate they no longer are operational. The statewide NG9-1-1 solution also must be capable of interfacing with neighboring jurisdictions’ networks to allow continuity of service where PSAPs serve border areas. The OSPs for the existing regional intrastate systems, such as CSI and NINGA, will be interconnected through the POP to the statewide system. The regional systems will then be interconnected to the statewide system through the BCF, which will serve as a Back-to-Back user agent (B2BUA), and utilize a non-proprietary native SIP interface to maintain a vendor-agnostic approach. This will allow the OSPs the benefit of reducing their connections, but the regional systems may continue to operate. This methodology will also be employed for interconnectivity for interstate solutions outside of the state. 5.3.2 Next Generation Core Services Leveraging the solid ESInet foundation, the State will implement i3 standards-based NGCS. These NG9-1-1 functional elements will provide significant benefits to the Illinois PSAP community, through the enhancement of call routing features and inclusion of new technologies offering more robust and accurate location information and supplemental data.

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5.3.2.1 Spatial Interface A core component of NG9-1-1 is geospatial data in a GIS. Accurate GIS data, meeting NENA Civic Location Data Exchange Format (CLDXF) standards, provisioned to the ECRF and LVF will enable geospatial routing in Illinois’ NG9-1-1 solution. The spatial interface should involve establishing a program to collect, evaluate, and improve existing GIS data for all agencies in the state. This data not only must meet the standard for CLDFX, but also be contiguous, matching all segments and boundaries. Once ready for use by the call routing functions, this data must be maintained on a regular basis to ensure accuracy and quality. 5.3.2.2 Location Validation Function and Location Information Server Following the establishment of the spatial interface, to ensure i3 compliance, the LVF will be the basis for replacing the legacy MSAG process, which serves to verify telephone subscribers to valid addresses prior to 9-1-1 calls. The Location Information Server (LIS) functional element will be used to provide location information to be delivered to the PSAP’s CPE during a 9-1-1 call. The NGCS provider may have one or many LISs within the core services offering that will interface with the NG9-1-1 system. 5.3.2.3 Border Control Function As with the ESInet, security is a critical component of the NGCS functional elements. Illinois’ NG9-1-1 NGCS should include a BCF to comply with i3 standards. The BCF serves as the entry point for all calls entering the NG9-1-1 environment, as well as a connection point for other ESInets. Additionally, the BCF polices packet traffic and serves as the anchor for media entering the network. 5.3.2.4 Legacy Network and PSAP Gateways Illinois’ NG9-1-1 solution will need to support legacy network ingress and egress from the NG9-1-1 solution for the immediate future. Therefore, both legacy network gateways (LNGs) and legacy PSAP gateways (LPGs) must be included in the solution. Both elements will allow the core call routing functions to operate using i3 standards-based solutions, while acknowledging that not all OSPs will be able to deliver call traffic to the network using SIP. In a similar fashion, PSAPs may require the ability to support an analog-to-SIP conversion until they are able to procure i3-capable CPE. Solutions providers responding to the State of Illinois RFP will be required to coordinate with all OSPs serving Illinois for ingress/egress regardless of their interface capabilities. 5.3.2.5 Call Routing Functions The ESRP and ECRF will be i3 standards-compliant functional elements of the NGCS. Using the GIS data provided by the spatial interface provider, Illinois’ NG9-1-1 NGCS solution will be able to perform geospatial routing with the ECRF for service providers that have ability to provide geospatial location. The PRF will be enabled for NGCS with policies defined by the local agency and implemented by the NGCS provider. The ability to transfer a call from a PSAP to any other PSAP in the state will be available via the NGCS.

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5.3.2.6 Additional Data Repositories The ability to provide supplemental call data to improve location accuracy and response is a key enhancement gained by the implementation of NG9-1-1. As such, NGCS for Illinois should ensure the ability to interface with the access network, originating network, or service providers (third-party) for the Additional Data Repository (ADR) and Identity Searchable ADR (IS-ADR) functions when they are available. 5.3.2.7 Hosted Call Handling The ubiquitous design of the ESInet and NGCS allows for a paradigm shift to occur in call handling. While the host-remote concept in call handling is not new, the implementation is largely confined to smaller local and regional applications. Cloud-based solutions with imbedded call handling controllers allow for much greater scale of use. Offering hosted call handling as a function of NGCS on a statewide basis will provide cost savings and operational efficiencies not available in today’s segmented environment. 5.3.2.8 Text-to-9-1-1 and Video In compliance with NENA standards, the ability to support Real-time Text (RTT), Message Session Relay Protocol (MSRP) text-to-9-1-1, and teletypewriter (TTY) service should be made available for delivery through core network and services functions in the NG9-1-1 solution. All components will support Real-time Transport Protocol (RTP) and Secure Real-time Transport Protocol (SRTP), allowing for the delivery of video and pictures to PSAPs with CPE capable of accepting media; this excludes PSAPs that interface with the network via an LPG. 5.4 Implementation Vision The objective of implementing NG9-1-1 in Illinois by June 2020 is an aggressive goal. This will require several simultaneous activities, and will rely on multiple stakeholders and activities that will need to be coordinated.

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2018 2019 2020 2021

Figure 12: General Timeline

At the completion of the procurement and once the contract has been signed, the vendor must present a detailed implementation schedule and GIS data requirements for its system. These requirements will be used to develop GIS guidelines for the ETSBs and PSAPs for updating their GIS information. 5.4.1 NGCS Buildout The vendor will gather information needed for the NGCS and build out the needed infrastructure in accordance with the plan approved by the State. 5.4.2 GIS Development While there is no formal State-, Region-, or Local-led GIS initiatives to prepare for NG9-1-1 outside of the current NG9-1-1 regional systems, as it relates to preparation of GIS data, local agencies should begin to develop the GIS data sets required for NG9-1-1. Agencies should reference NENA Standards for the Provisioning and Maintenance of GIS data to ECRFs and LVFs (NENA-STA-005.1.1-2017) and NENA’s CLDFX standard. This process may take a long time and will require a significant investment in human resources; as such, deployment will proceed during this process and leverage tabular data sets until geospatial data is ready for use with the NGCS solution. As local data sets become available they should be collected and consolidated to the statewide data set. 5.4.3 ESInet Buildout Concurrently the ESInet will begin to roll out to the PSAPs, using available infrastructure, while fiber connectivity is developed. The limited initial bandwidth requirements for voice traffic will allow this, but

NGCS Buildout

ESInet Buildout

Connect PSAPs and OSPs

PSAPs and Local ETSBs Develop GIS Data Sets

PSAPs Use Geospatial Routing

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larger bandwidth will be needed as the deployments progress. The initial connectivity may remain as a redundant path for some PSAPs. 5.4.4 PSAP Connections As the interconnected PSAP connections and systems are tested, they can be transitioned to the NGCS. At the same time, the OSPs will be connecting to the NGCS. This will result in a period when some PSAPs may have both legacy 9-1-1 and NG9-1-1 in service simultaneously. Retaining legacy connections beyond demonstrated success of the NG9-1-1 transition can result in increased cost for 9-1-1 service and local PSAP equipment. Therefore, retaining dual connectivity during the transition from legacy to NG9-1-1 should be short-term, but of sufficient time to ensure confidence in the solution at the State and PSAP level prior to removal of legacy network connections. A duration of 30-45 days in most cases is adequate for system soak and troubleshooting, while providing a rollback path if needed. 5.4.5 Geospatial Routing PSAPs initially will be brought on line with traditional MSAG-type routing using a Location Database (LDB) while they develop their GIS. Once the GIS is complete, loaded to the system and tested, the PSAP can transition to geospatial routing. Due to the extensive work of developing GIS, this may continue past the initial 2020 target date. 5.5 Statutory, Regulatory, and Political Environment 5.5.1 Statutory Environment The Statewide 9-1-1 Advisory Board and the Department suggested that several changes to legislation should be considered to effectively carry out the mission established by the legislature. A review of the current statutes and recommendations is included in Appendix C—Detailed Statutory and Regulatory Gaps and Considerations and Appendix D—Statutory Alignment. The Department should consider undertaking strategic planning activities that will help guide all aspects of 9-1-1 and NG9-1-1 implementation, management, administration, and funding. All parts of the Department’s responsibilities need to be cohesive and coordinated. Without a strategic plan, one or more of the activities such as rules updates or allowable expense parameters may not be in sync and resources and effort squandered. Without a cohesive view and plan that a strategic plan provides, Department resources may be fragmented, control and management of budgets might be compromised, and functions may be misdirected and ineffective. Only with a concrete master plan, based on adopted guiding principles and appropriate stakeholder engagement, can the Department ensure the effectiveness that it desires. MCP recommends development of an Illinois NG9-1-1 Master Plan to tie goals, desired outcomes, and financial structures into a comprehensive path forward for the state.

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Appendix C–Detailed Statutory and Regulatory Gaps and Considerations identifies areas for consideration. Appendix D–Statutory Alignment identifies any perceived issues with Public Act 100-0020 for NG9-1-1 feasibility. 5.5.2 Regulatory Environment 5.5.2.1 Department Administrative Rules Now that Public Act 99-0006 has been replaced by Public Act 100-0020, the Department’s administrative rules need to be reviewed and updated accordingly. The areas where gaps still exist can be a starting point for the Department. Areas that are hampered by legacy terminology or vendor-specific references can be defined more broadly in administrative rules. A greater emphasis on GIS and the associated data that will be necessary in NG9-1-1 can be encouraged, funded, and identified among the Department’s priorities. Program and funding priorities can be defined. Associated network design and cost estimates to carry out the intent of legislation will provide the necessary guidance for grants and integration of regional systems into a cohesive whole. MCP recommends the Department take the time before editing the Administrative Rules to evaluate the big picture of what is required to meet the very aggressive timeline set by the legislature for implementing NG9-1-1. The Department should establish program priorities and should link those program priorities with the grant guidance it should also establish. All 9-1-1 funds collected and expended should be advancing NG9-1-1 initiatives to meet the intent of the legislation. The Department has the authority and indeed the responsibility to clarify the direction and guide the local 9-1-1 authorities in this way. Both programmatic guidance and funding should work in parallel and support the direction as defined by the Department. The current Department Rules are available for review in Appendix F–Department Administrative Rules. 5.5.2.2 ICC Rules for Service Providers During this assessment process, MCP identified that a modification or deletion may not be appropriate until a full legacy-to-NG9-1-1 transition occurs. In such cases, the changes are not necessary immediately and the current ICC rule text may be adequate until all legacy technology is transitioned out of service and no longer is part of the Illinois 9-1-1 system. More importantly, in some cases the modification is more urgent and should be considered immediately as it impacts what the Department and the legislature want to achieve regarding NG9-1-1 implementation, because the current statutes and/or rules do not provide clear direction to the service providers in the state. Not addressing recommended changes may impact the State’s ability to move NG9-1-1 forward on the preferred deployment schedule. In other cases, the terminology or definitions in the statute may be prohibitive or limiting, which also would affect the State’s ability to implement the needed system changes on the desired schedule. The State should conduct a thorough and extensive review of existing statutes and supporting ICC rules along with the Department administrative rules to ensure consistency in language and references and that

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no language exists that could hinder the adoption of NG9-1-1 technology statewide. The ICC and the Department collectively should be actively engaged in this process. In addition, a review of the ICC’s rules for service providers should be conducted as well for consistency in terms and references, reduction in terms that refer to legacy and outmoded technology, direction to providers, clarity in system requirements and expectations of service applications. The ICC and the Department should work collaboratively on terms so that consistency is obtained. Appendix E–ICC Rules Review and Assessment identifies several specific areas to be included in this review. 5.6 Illinois NG9-1-1 Economic / Funding Vision NG9-1-1 provides 9-1-1 authorities with the opportunity to share equipment and services, and therefore take advantage of economies of scale that will result in cost savings. NG9-1-1 allows for local 9-1-1 authorities to retain local control over data and operations while sharing in the cost savings of a larger procurement. 5.6.1 State-level Procurement The ESInet not only must fit within the technical constraints listed in section 5.3, Illinois NG9-1-1 Technical Vision, but also must be financially feasible for the State to implement. To determine if the ESInet is financially feasible, a network design and cost estimate is needed. Just as the State currently pays for PSAP trunking charges directly, MCP recommends that the State provide the ESInet and NGCS. The State will have the ability to negotiate a better price for these two items at the state level than if regions were to procure these services individually. The ESInet provides the ability for PSAP CPE and CAD to reside on the core of the network and be shared with PSAPs throughout the state. This provides economies of scale for the initial procurement and allows for future functionality costs, such as integrated text-to-9-1-1, to be shared among many PSAPs instead of being paid for by each individual PSAP. MCP has seen examples of the CPE vendors pricing this text functionality at the equipment-host level, which means the cost is the same for an individual PSAP as it is for a hosted system with 50 PSAPs. MCP recommends that the State pursue a catalog-type CPE procurement. The State could provide a limited catalog of up to three vendors. This may include an option for the host equipment residing on the ESInet core and the PSAPs would have the ability to select their preferred vendor. This allows the PSAP to continue having a choice of vendors, while also providing a cost savings for state-level procurement. To truly explore cost-savings options, the State may want to include this procurement with the ESInet and NGCS procurement. MCP also recommends that the State investigate providing CAD and logging services via the ESInet to enable further cost savings.

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5.6.2 Funding NASNA published a paper in 2015 titled Four Potential Sustainable Funding Models for NG911.40 This document provides some national perspective on potential sustainable funding, acknowledging that this is a very complex and diverse issue. In 2016, NASNA produced a follow-up paper, which said, “State 911 Administrators agree that the current 911 funding model needs to be optimized and sustained for the time being, but understand that it will eventually become necessary to change to a different mechanism.”41 MCP recommends that any NG9-1-1 funding plan ensures that all devices capable of accessing 9-1-1 share equally in the funding of 9-1-1. Illinois has taken the first step by setting the 9-1-1 surcharge at the same rate for wireline, wireless, and VoIP devices. In addition, Illinois is collecting surcharge fees from prepaid cellular devices at the point of purchase. However, NASNA pointed out in its 2015 paper that the percentage being collected for prepaid devices is less than what would be collected on a postpaid device. MCP recommends that the State work with the Department of Revenue to determine a method for monitoring the funds remitted from prepaid devices to determine whether they are generating the revenue needed to implement NG9-1-1. An estimated number of prepaid devices remitting fees would allow the State to compare the amount per device remitting on prepaid to that being remitted on postpaid devices. In addition, MCP recommends that the State consider updating the statutory language to remove references to specific technology and broaden the definition so that any device capable of accessing the 9-1-1 network will remit the surcharge. 5.6.2.1 Current Revenue During the transition to NG9-1-1, it will be necessary to pay for the legacy network and services, while also paying for the new ESInet and NGCS. The amount of time needed to pay for both systems can be managed with careful planning and oversight, but there still will be a need for a large financial investment. The rough order of magnitude pricing provided in Section 5.3.1.3, Table 13, identifies a one-time fee for the ESInet and NGCS of $21,979,000 and annual fees of $24,077,180. These two figures alone amount to 35.1 percent of the revenue collected in 2017, and the annual recurring cost is 18.4 percent of the revenue collected in 2017. Public Act 100-0020 allows the Department to hold funds in reserve for grants as described in Section 15.4b of the Act and NG9-1-1 expenses up to $12.5 million in both 2016 and 2017, up to $20 million in 2018 and $20.9 million in 2019. The Act provides a cap on the amount held in reserve through 2023 when it stays at $17 million per year. In addition, the Act requires a minimum of $6.5 million to be held in reserve for FYs 2018 and 2019. All remaining funds are to be distributed as monthly proportional grants to the 9-1-1 authorities taking wireless calls. MCP interprets this to mean that there is no financial limit on the amount the Department can expend each month to implement NG9-1-1 by 2020; and, the Department may also hold in reserve the amounts detailed in Public Act 100-0020 Section 30 (b) (2) (D) each year. In 2016, all the revenue received was expended without any funds being set aside for future NG9-1-1 expenditures.

40 https://drive.google.com/file/d/0B6UENGshedL6MmI5dWFFMVlneU9PZ2hVakNoUVpCeDdOLVZj/view 41 https://drive.google.com/file/d/0B5HEHifGSF-eX3ZvUVZfVENYTmM/view

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MCP recommends that the Department begin to reserve the allowable funds in Section 30 (b) (2.) (D) in order to fund the transition to NG9-1-1 with as little impact to the ETSBs as possible. While MCP understands the reasoning behind distributing all funds to the PSAPs, it will be very hard for the ETSBs to operate with a sudden significant loss of funds in one or two years as opposed to spreading that impact out over several years. The ETSBs received an increase in funding in FY2016 with the disbursement from Section 30(b) (2.) (E) and will begin to base their expenditures on that revenue. It would be better to set their revenue expectations slightly lower each year than to take a 10 percent loss of revenue in one year. MCP recommends the Department finalize the design and strategic plan for the transition to NG9-1-1 in order to conduct an in-depth financial analysis of surcharge funds needed for the transition.

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Appendix A – Summary of Town Hall Meetings

State of Illinois – NG9-1-1 Town Hall Meeting Themes System Requirements

1. Standards-driven 2. Reliability

a. Calls are not dropped b. Calls route properly

i. Receive device location versus tower location ii. Back up routing

c. Every call is answered d. No caller ever gets a busy signal when dialing 9-1-1 e. System never fails f. No matter where the call is transferred, there must be consistent level of service g. Location accuracy

i. Incorporation of z axis h. Hardened system (survivability) i. Service level agreements with vendors ensuring high level of reliability and monitoring

3. Integration a. Between existing regional systems and state system

i. Counties that already have an NG9-1-1 system are not required to spend additional money

b. One platform c. Regional systems (i.e., CSI) to connect to the state system d. CAD and text-to-9-1-1 integrated on a single screen

4. Redundancy a. At local level and across regional networks b. Shared resources c. Data centers d. Back up capabilities go beyond one main switch e. Neighboring counties should be able to answer calls and dispatch agencies f. Overflow capabilities

5. Security a. DDoS attacks – concerns about impact to 9-1-1 when some calls ride the Internet b. Desire monitoring capability to detect problems and alert users c. Cybersecurity – concerns about paths in/out of the PSAP

6. Network a. Vendor-agnostic at local PSAP level b. Network that supports NENA i3 basic functionalities c. Open architecture

7. Automatic number identification (ANI)/ALI functionality

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8. Portability a. 9-1-1 operations can move anywhere b. Call takers/dispatchers can sit in any seat c. Ability to relocate 9-1-1 operations via roaming profiles

9. GIS a. Location accuracy

i. Better than 100 meters ii. Accurate up to 2-foot planimetrics iii. ANI/ALI inbound

b. Geofencing i. Ability to capture incident details from neighbors within determined distance of a

jurisdiction’s PSAP border ii. Ability to flag any 9-1-1 calls that occur near a special event, within the geofenced

area around the event c. Clean data that has been vetted between jurisdictions d. Shared, integrated mapping – same map and CPE e. x, y, z axis

10. Text messaging 11. Text-to-9-1-1

a. Fear of being overwhelmed with texts b. Unclear on how to prioritize texts

12. Video a. Concerns about graphic images and large-scale data management (big data) b. Must be able to turn it off c. Each PSAP must be able to set own policy about whether or when to accept video, how to

store it and manage its release, and how long it will be stored d. If accepting video, additional training required for call takers e. SOPs to define how to handle video f. Ability to access officers’ body-worn cameras

13. Borderless sharing and transferring of calls (between states and localities) 14. Data

a. Shared between counties and states b. Data management (retention and storage capabilities)

15. Calls a. Ability to transfer calls inter- and intra-state b. One-button click to transfer 9-1-1 calls c. Reduced call set-up times d. NG9-1-1 system handles call routing, not telephone company (poor record)

16. Ability to better identify and queue telemarketing calls and deal with abandoned calls

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Keys to Successful Implementation

1. Frequent communication and information sharing (progress, milestones, expectations, deadlines, actions, etc.)

a. Specific communications materials simplified for consumption by elected officials and the public

b. Must manage expectations around system’s capabilities with the public, public safety, elected officials

2. Capitalizing on regional systems already in place a. RFP must request that state system interface with the NINGA and CSI networks b. Not undoing any progress already made

Barriers to Success

1. Legacy rules, policies and procedures 2. Unreliable internet 3. Inaccurate GIS data

Transitional Needs

1. Project timeline 2. Cost estimates 3. Progress reports 4. Understanding responsibilities of localities versus the State 5. Increased education, communications, and outreach

a. Education/outreach to chiefs, sheriffs, ETSBs, and elected officials to help explain what is coming

b. Attend association meetings c. Simplify the message (non-technical) d. Provide talking points for PSAPs to share with leaders or develop an education package

that can be shared with ETSBs and government officials e. State messages that quash rumors and overcome misinformation

i. Belief among some CSI members that it will be overtaken and State-run 6. Minimum standards and requirements for GIS data 7. Details on whether regional systems’ equipment will be supported 8. A diagram demonstrating the relationship between new NG9-1-1 technology components and

existing technology in PSAPs 9. For the State to help manage expectations and quash rumors 10. Examples, case studies and lessons learned from other NG9-1-1 implementations

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DuPage County Meeting Date: 3/14/2017 Desired Features or Functions

1. Reliability a. The system does not fail b. Reliability cannot be compromised once multiple vendors are involved in NG9-1-1 (instead

of one vendor like it is now, with AT&T as only partner) c. Do not want to experience the problems similar to those during Phase II wireless d. The “pipe” has to be big enough to carry all the data; providers are not able to get all the

calls into PSAP – architectural issue 2. Integration

a. One platform is key b. Do not want to have to buy multiple pieces of equipment c. Want consistency

i. Text-to-9-1-1 – too many solutions, different levels of solutions, different costs d. Backup centers

i. Not the right size currently ii. Issue: NWC/DuComm – Too close to serve as backup centers; when weather hits

both are affected iii. Need a better backup plan – overflow of calls bouncing back and forth and want a

voice in coordinating the plan e. Ability to integrate ESInet and NG9-1-1 networks already in place f. All counties statewide must have GIS capabilities; cannot be left behind because they lack

GIS resources g. Must be standards-driven system h. CPE to CAD – sharing data to those who need it i. Analytics and Public Safety Communications Research (PSCR)

3. What does my CAD and CPE need to do Consistency

a. No matter where the call is transferred, there must be consistent level of service b. No one should ever get a busy signal when dialing 9-1-1

4. GIS a. Improved geofencing capabilities

5. Accuracy 6. Security

a. Ransomware b. Concerned about outside/inside attacks, security requirements, sign-on c. Concerned about outside attacks when increasing size of the system d. Monitoring capability to detect problems and alert users

7. Funding a. Understanding responsibilities of localities versus state

8. Maintenance

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9. Other a. How are policies and staffing being handled nationwide during transition

i. Increasing other staff; IT/database/standards b. Interest in case studies, learning from other’s lessons c. Ability for PSAPs to view or be aware of the calls that are pending.

Features and Functions that are Not Important/Should Not be Included

1. Text-to-9-1-1 a. “Stupidest thing to ever happen” b. Will overburden the system c. How do you prioritize calls when dealing with text d. How do we exclude texts that are not 9-1-1-related

2. Video Integration a. Need to exclude video that is not 9-1-1-related b. Need ability to turn video off (example: butt-dials) c. Would prefer option to accept video – video on-demand d. Must determine scope of video within NG9-1-1

i. Facetime, text with attachment, 100s of app e. Concern: video could be traumatizing for call takers

i. This will require different training f. Takes up a lot of bandwidth g. Storage requirements, body cameras h. Video creates additional SOPs around evidence chain and retention – State's attorneys i. Video is not important to the telecommunicator, but is important to the responding officers;

need plan for how to get it to the responders General Discussion

1. Public Education a. NG9-1-1 requires education/outreach to elected officials and general public b. Must manage public expectations c. Policy making (state level), rulemaking, state-level legislation

2. Must establish technology standards and boundaries a. What will/will not PSAPs accept b. OnStar – good example of telematics data to responder c. Too high expectations about providing technology to consumers

i. Selling apps – better 9-1-1 location, gets people away from dialing 9-1-1 d. Identify relationship between NG9-1-1/FirstNet e. Have data go directly to responders f. IoT – Call takers will receive calls from "things" g. Must be able to use analytics to get the data where it needs to go

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h. Authenticating the incoming data i. How do you know data was not modified; is not a virus ii. Standalone PSAP is not going to be able to handle that

3. Risk a. Biggest risk to implementation is GIS; no statewide repository

How NG9-1-1 Will Improve PSAP Operations and/or ETSBs/Regions

1. Ability to plug-and-play; pick up and move operations 2. Natural redundancy/virtual PSAP 3. Ability to hand off to anyone at anytime 4. Reduces number of transfers, getting the call to the right PSAP the first time 5. Ability to share information 6. Better asset allocation – particularly from fire perspective

a. Monitoring fire alarms – being able to see video b. If you could verify no fire, send less apparatus c. See availability of neighboring assets

7. Better data, cleaner, less rebids 8. Better GIS data – nearby municipalities 9. More information for first responders 10. Leverage ESInet for more uses, connections to neighboring agencies 11. Improved redundancy 12. NG9-1-1 transition will raise the level of service by raising concerns with how transferred calls are

handled NG9-1-1 Impacts on PSAP Operations and ETSBs/Regions

1. Potential cost savings a. Currently no cost recovery method; fighting for every penny

2. Establishes expectations on level of service; providing more for less 3. Will make it harder to keep up with technology changes; whatever we put in will already be

outdated 4. GIS activities

a. Need to be sharing GIS data b. Need governance c. Define a standard base, minimum layers d. GIS sharing needs to improve

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Transition Needs

1. Timeline with an explanation of what is happening when 2. How the system will be funded

a. Cost impact versus setting expectations i. Statewide 9-1-1 funds should not be used to bring up some communities that have

not been responsible over their needs 3. One entity guiding it all

a. Skepticism about State’s ability to complete the project, so reassurance and facts b. Understanding of delineation between the 9-1-1 Administrator and the State of Illinois

4. Education/outreach to state legislation a. Sweeping of funds, availability of funds b. Use of federal dollars c. Helpful if localities could receive short one-page overview documents to brief them

i. Possibly through NENA NG Committees 5. Understanding on how to integrate multiple ESInets (city versus northern/southern Illinois)

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DeKalb County Meeting Date: 3/15/2017 Desired Features or Functions

1. 9-1-1 backup and redundancy a. Shared resources b. Radio backup is to be determined; do you need to physically be able to dispatch an agency c. Would like neighboring counties to be able to answer calls and dispatch agencies

2. Share GIS data a. Intrastate and Interstate

3. Geofencing a. Ability to transfer calls more specifically to closer neighbors to provide backup b. Not sure all calls for transfers; some counties are very large c. Geofencing for incidents (i.e., State fair)

4. Integrating text-to-9-1-1 a. Too expensive today

5. NINGA: ability to receive calls coming from a different county 6. Integration with existing NG9-1-1 systems 7. Counties that already have an NG9-1-1 system are not required to spend additional money 8. Integration with FirstNet 9. Incorporation of z axis into location data 10. Basic ANI/ALI functionality

General

1. Does NG9-1-1 include CPE 2. Responders want more than dispatchers can currently provide; expect more/faster

Features and Functions that are Not Important/Should Not be Included

1. Not Applicable How NG9-1-1 Will Improve PSAP Operations and/or ETSBs/Regions

1. Improved GIS information sharing 2. Backup (redundancy) 3. Ability to better assist neighbors 4. Text-to-9-1-1

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NG9-1-1 Impacts on PSAP Operations and ETSBs/Regions

1. Perception that text-to-9-1-1 may increase dispatch times and require additional staffing 2. Video and data

a. Amount of video and photo data storage will increase b. Must be able to catalog and preserve it c. Who will be responsible for data that is transferred between PSAPs d. How will Freedom of Information Act (FOIA) requests be handled e. What is the impact on bandwidth and redundancy (fiber versus microwave)

3. Latency on IP system (3 milliseconds [ms]) a. May impact callers; loss of that comforting background noise b. May impact dispatchers who are not prepared for the delay

4. Staff of varying ages/generations may adapt differently to the required changes 5. Fear the state NG9-1-1 system will impact local/regional systems 6. GIS

a. Will have to fund the accumulation/management of GIS information 7. Licensing cost increases

Transition Needs

1. Need an “NG9-1-1 for Dummies” education package that can be shared with ETSB and government officials

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Peoria County Meeting Date: 3/16/2017 Desired Features or Functions

1. Network that supports NENA i3 basic functionalities and existing CPE equipment a. Could help eliminate SWATting

2. CAD and text-to-9-1-1 integration on a single screen 3. GIS

a. Best route information b. Metadata analysis; calls that are tagged with GPS coordinates

4. Accurate call routing and location data received; remove borders a. Receive device location versus cell tower location (remove legislative boundaries) b. Access to GPS coordinates is key

5. Security a. Worried about DDoS attacks impact to 9-1-1 b. Need a solution for when there is a DDoS attack impacting the entire Internet

6. Reliability a. Need a hardened system to reduce "blue sky" outages

7. Data management a. Investigative function allowing users to integrate data coming into public safety agencies;

text/GPS/voice/video/officer data b. Data retention and storage capabilities

8. Redundancy a. More than one main switch

9. User portability a. Dispatcher can sit at any seat

10. Network must be vendor-agnostic at the PSAP level 11. Must be able to overcome problems with transferring calls across state lines (Illinois to Iowa)

a. Metro area divided between Illinois and Iowa; resolved LATAs and Interstate boundaries to go away

General

1. Concerns about how consolidation will be impacted by NG9-1-1 Features and Functions that are Not Important/Should Not be Included

1. Not Applicable

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How NG9-1-1 Will Improve PSAP Operations and/or ETSBs/Regions

1. Freedom from geographic boundaries 2. Unified reporting and system-wide analysis

NG9-1-1 Impacts on PSAP Operations and ETSBs/Regions

1. Counties do not have funding to support necessary GIS personnel 2. Concerns about reliability; some may want to skip the local providers 3. Concerns about getting out-of-county calls

a. Transferring data back and bogging down smaller PSAP 4. Concerns about data retention and redaction burdens; evidentiary, chain of custody issues 5. Video

a. Should not necessarily be the burden of 9-1-1 telecommunicators to see things first hand b. Possible for sworn officer to be the filter c. Video must be able to go somewhere besides the PSAP d. Highest value in getting video to officer right away versus caching it e. Potential liability issues involved if a telecommunicator does not see a weapon

6. Elected officials have expressed concerns over costs Transition Needs

1. Need timelines, roles and responsibilities, progress reports, and decision trees 2. Consistent communications 3. Level of cooperation with FirstNet

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Sangamon County Meeting Date: 3/28/2017 Desired Features or Functions

1. i3 support 2. Text messaging 3. Native SIP connectivity, including private branch exchange (PBX)/telecommunications 4. Interstate and intrastate boundaries; cross LATA/cross incumbent local exchange carrier (ILEC) 5. Reliable network in backup center to support radio over IP (RoIP) 6. Improved location accuracy; something better than 100 meters 7. Routing accuracy to resolve constant transfers between counties 8. GIS

a. Improve the GIS data to match MSAG; good quality b. A reliable data scrubbing system c. Needs to be built in to the vendor's NG9-1-1 system

9. Data sharing capabilities a. With third-parties and responder agencies

i. ANI ii. Different ALI formats cross states

b. With responders without PSAP intervention i. Bring your own device one-way direction; FirstNet; iamresponding; active 9-1-1 ii. Smart911 – no way to import directly into CAD iii. Supplemental

10. Data sharing standards 11. x, y, z coordinates data 12. Ability to better queue telemarketing calls and deal with abandoned calls

General

1. Issues a. No network infrastructure and broadband in rural communities

i. Answering calls is not a backup ii. Reliable network in their backup center to support RoIP iii. Network is great to answer, but need to get responders there

b. Madison/St. Clair County are unable to transfer ALI data across state boundaries c. St. Clair County receives 50–75 transfers from Missouri per day d. West Central 9-1-1 deals with 3–6 relay callers per day

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Features and Functions that are Not Important/Should Not be Included

1. Features that are too cutting edge 2. Untested features 3. Video if cannot meet the expectations 4. Relay callers 5. Non-service initialized (NSI) phones 6. Anonymous calls from telemarketers

How NG9-1-1 Will Improve PSAP Operations and/or ETSBs/Regions

1. Will allow for dynamic routing of calls a. Send Spanish speakers to Spanish-speaking call takers b. Send people with medical issues to someone for EMD

NG9-1-1 Impacts on PSAP Operations and ETSBs/Regions

1. Anticipate increases in call handling times a. Callers will be sending images/videos; filtering and storing

2. Expectations associated with new types of data; FOIA-able, storage, chain of custody 3. Call takers exposed to more graphic, real-time images

a. Anticipate more Workers' Compensation claims 4. Financial impacts

a. Costs of storing data, redacting, additional infrastructure 5. GIS is unequal across jurisdictions and GIS employee may have several roles in smaller counties

a. Need each county’s GIS data to match 6. Security concerns

a. Fear that "bad code" could accidentally cause 9-1-1 calls; malicious attacks Transition Needs

1. Implementation of standards 2. State communications on expectations 3. Examples, case studies, and lessons learned from other NG9-1-1 implementations 4. Assistance in working with first responders; historically resistant to change/paying for it

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Effingham County Meeting Date: 3/29/2017 Desired Features or Functions

1. Text-to-9-1-1 2. Video

a. To receive images and video, especially live video from location during an alarm activation (bank, school, etc.)

b. Functionality and SOPs to know how to handle video 3. Open architecture; do not want to be held hostage to vendor 4. Redundancy

a. Do not want to miss a call b. Want calls to roll to 1 of 13 backups

5. Security 6. Plotting on a map; ANI/ALI 7. Reliable, speedy internet, and a plan for handling calls when internet fails 8. Ability to find every phone, even NSI phones 9. Easy operation; quick, easy, accurate 10. Shared data 11. One-button click to transfer 9-1-1 calls 12. Would want to see GIS data from other counties/states 13. Calls from another county need to plot correctly on the map

General

1. Concerns a. IP-based technology and security b. Cost: monthly charge; free; based on number of connections to network

i. State says there are 100 CADs and would not likely pay for CAD interface/connection, but would pay for the "connection" to the PSAP

c. State system’s compatibility with existing systems i. How will the state interconnect with CSI/NINGA systems ii. Will existing systems pay a cost due to upgrade requirements

d. Video i. Will responders instead become witnesses ii. State says it will not mandate that PSAPs accept video

e. GIS and NG9-1-1 are tied at the hip and if jurisdictions have not yet started cleaning up GIS, they should start now

i. CSI had boundary issues, two different solutions, some on NG some on WTH ii. Overlapping ESN boundaries iii. Involved Southern Illinois University (SIU) student

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f. Will there be a flag to indicate an overflow situation; uncertain what to do with the call if inundated; sending it back does no good

2. Lessons Learned (CSI) a. Would have hired an attorney to review vendor contracts

Features and Functions that are Not Important/Should Not be Included

1. Text-to-9-1-1 How NG9-1-1 Will Improve PSAP Operations and/or ETSBs/Regions

1. Helpful to all be together in a single system a. Could send information already gathered from a caller would be helpful; speed the process

2. Ability to plug-in at some other PSAP and take/dispatch all your calls NG9-1-1 Impacts on PSAP Operations and ETSBs/Regions

1. Costs for FOIA, data storage for images and videos 2. Depending on what is allowed on the network, will jurisdictions be able to access their

radio/CAD/CPE 3. Need additional staff, especially if accepting video 4. Mental health impacts on staff 5. Security concerns 6. Will require new policy and procedures

Transition Needs

1. Specifics on GIS data updates/changes that need to be made to prepare for NG9-1-1 2. Minimum standards and requirements for GIS 3. Education/outreach to chiefs, sheriffs, ETSBs, elected officials to help explain what is coming 4. Increased communications and outreach generally

a. Attend association meetings, etc. b. Simplify the message (non-technical) c. Provide talking points for leaders

5. Create a diagram demonstrating the relationship between new NG9-1-1 technology components and existing technology in PSAPs

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Williamson County Meeting Date: 3/30/2017 Desired Features or Functions

1. All work that has been done should not be undone and no jurisdiction should be left behind 2. CSI data recorded at both PSAP and data center level 3. Dramatic reduction in call set-up times 4. Text integration, through the network, show on the map, spill to CPE, etc. 5. Ability to reach across state lines and back

a. Kentucky and Missouri; restricted by current laws 6. Standards-based system 7. Shared integrated mapping; same map and CPE so that everyone is looking at the same thing 8. No calls ever die and every call is answered 9. Way to overcome receive auto dials and telemarketers calling 9-1-1 10. Longest idle/”no record found” still forwards to the correct PSAP 11. Ability to relocate 9-1-1 operations via roaming profiles 12. Overflow capabilities 13. NG9-1-1 system to handle call routing versus telephone company (poor track record) 14. Backup routing 15. Ticket system that provides global messages to all connected PSAPs; must print date/time 16. Ability to regionalize operations 17. Redundancy

a. Across regional networks 18. Service level agreements (SLAs) with vendors that provide a high level of reliability and monitoring 19. Governance; a seat at the table/voice on the Board that is geographically-based instead of

population-based 20. For local system to connect with the state system with no additional cost or need to redo any work

that has been done locally General

1. Illinois Institute of Technology (IIT) conducted testing of the CSI session border controller (SBC); 50,000 attack calls, four real calls got through, 1 million DDoS attacks

2. Legacy test calls, would hear three rings before rang at PSAP, now it is simultaneous 3. CSI lessons learned (model for the state)

a. "Connect to us and pay us to use our equipment" b. Use their two SBCs by ACME packets; sized for the whole state c. Their two data centers could handle two-thirds of the state’s traffic d. Leverage IIT; experience with the state/CSI e. GIS

i. State should have its own GIS staff 1. Network / hardware in place, but 30 percent of the data is bad

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ii. Cleansing the GIS data was a long, detailed process; start early iii. Some ESNs were duplicated across the region iv. No standards in place when CSI started, and still none; would have made it easier v. Just because your assessor's office has data, does not mean it is good enough vi. Issues with roads with no address ranges vii. Use of commercial GIS files as a base, such as Topologically Integrated

Geographic Encoding and Referencing (TIGER) files viii. Kentucky CMRS Board ix. Need to make data from county to county match at the border

4. 49 simultaneous callers would get a busy signal 5. Just because someone answers the call, does not mean dispatch can get them help – cannot

dispatch 6. RoIP would provide support "as long as it's not STARCOM" 7. Must have multiple definitions of a PSAP

a. In the north, PSAPs take the 9-1-1 calls b. In the south, police and fire departments take the calls

8. Want to call back NSI devices 9. Parking lot issues

a. Concerns about prank text calls b. Phase II location on texting mandatory

10. Southern Illinois 9-1-1 is like a “MASH unit” patching people up and moving them out 11. Out of 400 calls per month, 125 are non-emergency or prank 12. Experiencing problems with ticketing system tracking and the ability to communicate between CSI

members 13. Vendor is monitoring the health of the system 14. Like that Indiana has a statewide map allowing PSAPs to see statewide activity; increases

awareness a. If the south had to take over calls from the north, PSAPs would be inundated so quickly

15. Three regional ESInets and diverse carriers: North versus South versus City a. NG-911 Inc., Frontier, AT&T

16. "As long as it's not STARCOM" a. No redundancy and the tower is in a flood zone – Alexandria b. "A piece of copper on a 100-year-old pole” c. Southern Illinois does not have a reliable system; not enough sites d. Agencies are fearful of the fees

i. $8 per month and two radios/county e. Lack of sites f. Very negative reputation; if you use it, change the name g. Not all agencies have Law Enforcement Agencies Data System (LEADS) access; smaller

counties contact ISP via radio 17. Randolph County is operating on 10-year-old equipment; must act soon because no

parts/maintenance 18. CSI wants to interconnect with the State with little to no disruption/change

a. "Less we have to change the better"

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b. Should not be punished for being progressive c. Do not want to pay more for something they are already doing d. State should not reinvent the wheel e. All the counties in southern Illinois should be part of CSI; fill in the blanks f. Decisions made at the ETSB level; financial reason; no longer part of CSI

Features and Functions that are Not Important/Should Not be Included

1. Not Applicable How NG9-1-1 Will Improve PSAP Operations and/or ETSBs/Regions

1. Not Applicable NG9-1-1 Impacts on PSAP Operations and ETSBs/Regions

1. Not Applicable Transition Needs

1. Information needed in southern Illinois is different a. When can we connect versus how do you do it

2. CSI currently works with one vendor; will we have to transition to State paying the bill/managing vendor relationships; will not be able to negotiate

a. Contract conflicts with state law b. Joint ETSBs cannot form because of the State

3. Need help overcoming concerns and understanding costs, whether current equipment will be supported, and what is coming

4. Need State to quash rumors, help CSI users understand that they will not become a State project run by the State

5. Cost efficiencies with direct connection, consolidated circuits a. CAMA trunks versus SIP trunks b. Telecommunications providers need to lose; LECs are not required to direct connect,

connecting to an aggregation point c. ICC could require a direct connect d. Wireless carriers direct connect; wireline does not connect because of tariffs e. The State is paying $5,000 for 18 percent of call volume f. The State does not pay for the wireless for network connections; NG-911 Inc. pays network

costs (supposedly) 6. AT&T no longer supports, "necessary for implementation of NG9-1-1"

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7. Assure 9-1-1 does CSI network monitoring; new version, proven network monitoring

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Chicago Meeting Date: 4/5/2017 Desired Features or Functions

1. Redundancy 2. Reliability 3. Resiliency 4. Survivability 5. Added capabilities that help protect system 6. Security

a. Cybersecurity – concerns about opening up paths in and out of the PSAP 7. Interoperability 8. Text-to-9-1-1 9. GIS

a. Location accuracy i. Accurate up to 2-foot planimetric ii. ANI/ALI inbound

b. Have a handful a day of misroutes with no ALI data 10. Mutual Alarm Box Information System (MABIS) 11. Ability to leverage partnerships for surge capacity 12. Public safety is always ten years behind, so think ahead and use technology that allows state to

move quickly in adapting to the technology changes 13. Applications

a. That help leverage information to make better decisions i. Emergency Management could track resources ii. GPS could track vehicles

b. That takes disparate data into a single platform c. Advanced analysis d. Mobile component that identifies which information to share with responders on

PDT/mobile device 14. Ability to access officers’ body-worn cameras

General

1. Not Applicable Features and Functions that are Not Important/Should Not be Included

1. Not Applicable

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How NG9-1-1 Will Improve PSAP Operations and/or ETSBs/Regions

1. Allows PSAPs to live up to expectations public already has of them NG9-1-1 Impacts on PSAP Operations and ETSBs/Regions

1. Video a. Must put policies in place before implementation b. Will staff need new skillsets to handle video c. Emotional impact on staff; concern for their well-being d. Uncertain if it will take longer to dispatch calls

2. Must develop a process flow for handling calls; will decision making process include more steps 3. Additional operators may be necessary 4. Unsure how legacy call takers will adjust or if PSAPs will need specialized call takers to handle

specific types of calls 5. It is all about the call volume

Transition Needs

1. Need elected officials to know it is coming 2. Additional capability for residents, beginning with text-to-9-1-1 3. Expectation management 4. Cost estimates

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Appendix B – Survey Details

The Survey Data Results report, prepared by MCP in June 2017, is provided under separate cover.

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Appendix C – Detailed Statutory and Regulatory Gaps and Considerations

Definitions and Terms Terms exist in current statutes that may need review and revision going forward. Several examples are noted below, but are not exhaustive. A full review, in light of NG9-1-1 terminology that should be added, legacy terminology that should be removed, or changes in terminology to reflect current usage, might be warranted. Some of these terms are identified in the table below.

Section Ref. Current Term Assessment Federal Guidance

9-1-1 Not defined NENA Glossary: A three-digit telephone number to facilitate the reporting of an emergency requiring response by a public safety agency.42

50 ILCS 750/2 (fr Ch. 134, par.32) Sec 2 Definitions

“9-1-1 system” means “a geographic area granted an order of authority by the Commission or the Statewide Administrator…”

The reference is confusing; if the Commission grants authority it is for a service provider; if the Administrator grants authority it pertains to a 9-1-1 authority.

NENA Glossary: The set of network, software applications, databases, components and operations & management procedures required to provide 9-1-1 service. This may include commercial, governmental and human resources.43

42 https://www.nena.org/?page=Glossary 43 Ibid.

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Section Ref. Current Term Assessment Federal Guidance

50 ILCS 750/2 (fr Ch. 134, par.32) Sec 2 Definitions

“Hearing-impaired individual” means “a person with a permanent hearing loss …”

What if impaired but it is temporary?

ADA definition of “disability” Sec. 12102. Definition of disability (1) Disability: The term "disability" means, with respect to an individual (A) a physical or mental impairment that substantially limits one or more major life activities of such individual; (B) a record of such an impairment; or (C) being regarded as having such an impairment (as described in paragraph (3)). The definition goes on to state: “An impairment that is episodic or in remission is a disability if it would substantially limit a major life activity when active.”44

50 ILCS 750/2 (fr Ch. 134, par.32) Sec 2 Definitions

“System provider” means “the contracted entity providing 9-1-1 network and database services.”

Not “or” ??? NENA Glossary: An entity providing one or more of the following 9-1-1 elements: network, CPE, or database service.45

50 ILCS 750/2 (fr Ch. 134, par.32) Sec 2 Definitions

“Voice-impaired individual” means a person with a permanent speech disability …”

What if impaired, but it is temporary? May want to consider if “permanent” is the best word for the definition. How are temporary but significant disabilities treated/considered in the law.

NENA Glossary: Speech disabilities include communications disorders, such as stuttering, impaired articulation, language or voice impairment, which adversely affect a person’s ability to articulate speech clearly.46

44 https://www.ada.gov/pubs/adastatute08.htm#12102 45 Ibid. 46 https://www.nena.org/?page=Glossary

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Section Ref. Current Term Assessment Federal Guidance

50 ILCS 750/8

The Administrator, with the advice and recommendation of the Statewide 9-1-1 Advisory Board, shall coordinate the implementation of systems established under this Act …

National guidelines suggest need for statewide coordination and IL50 provides that coordination. However, the current statute offers only implicit interpretation that the State can procure in order to implement. May need to stipulate clearly that the Administrator, through the State Plan, has the authority to procure and/or operate statewide 9-1-1 components of NGCS.

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment; Guideline SR1: The statutory environment provides for comprehensive statewide 9-1-1 coordination. Guideline SR9: The statutory environment provides contractual authority to procure and/or operate statewide 9-1-1 components. Guideline GV2: An entity has authority and responsibility for statewide 9-1-1 coordination.

Recommendation MCP recommends a thorough examination of terms to update them to ensure: technology-neutral language; relevancy for NG9-1-1; consistency of definitions between various 9-1-1 related acts, rules and nationally-accepted terms; deletion of terms no longer in use; new terms that are appropriate for new elements of the NG9-1-1 ecosystem; and language/text clean up throughout all acts and rules pertaining to 9-1-1. GIS Conversion The definition of MSAG can be found in Section 2 of the current law. "Master Street Address Guide" is defined as the computerized geographical database that consists of all street and address data within a 9-1-1 system. With geographical databases being removed in the revised definition, and GIS or geospatial data and databases not included in allowable expenses, it may be difficult for the Department to fully support the needs of the local 9-1-1 authorities to transition fully to NG9-1-1 services. While the definition of NG9-1-1 does include “databases that replicate traditional E9-1-1 features,” GIS may or may not be considered one of the traditional E9-1-1 features. Conversion of the tabular data found in legacy MSAGs to geospatial data files that assist the system for routing and call processing is a critical component of NG9-1-1 and future services. The process of

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converting and validating the data—which will involve multiple other systems and stakeholders—is no small task, and the time and cost associated with such activity should not be overlooked. The MSAG error ratio established in the ETSA should be retained and an equivalent error ratio should be established in future legislation or, in the interim, administrative rules for geospatial data accuracy, which is equally important and necessary for an effective NG9-1-1 system. Additionally, the Statewide 9-1-1 Administrator may want to consider the cost of MSAG-to-geospatial conversion as an allowable cost reimbursement for the 9-1-1 authorities. Recommendation MCP recommends that the Department update terms in definitions in future legislation; establish error rates for geospatial databases similar to current MSAG ratios; establish statewide geospatial rules, including addressing border issues; and update administrative rules to include conversion of MSAG data to geospatial data as an allowable expense. Data Collection Current statute sections 50 ILCS 750/40 (b) (1), (2) and (3) allow the Department to request that the local 9-1-1 authorities provide financial information to include: • A detailed summary of revenue from all sources including, but not limited to, local, state, federal, and

private revenues, and any other funds received • Operating expenses, capital expenditures, and cash balances • Such other financial information that is relevant to the provisioning of 9-1-1 services as determined by

the Department It is and will continue to be important for the Department to have access to current financial data from the 9-1-1 authorities. It also is important that the State be able to request statistical and call data information as it determines is necessary to evaluate the functionality of the statewide system. This can be a huge advantage for the Department to be able to have a mechanism for engaging local 9-1-1 authorities regularly in information sharing, assessing the adequacy of current call routing arrangements, and uses of technology and technology-sharing opportunities, as well as determining the network adequacy and functionality. Recommendation The State should consider pursuing the ability to request that 9-1-1 call data and statistics be provided by the local 9-1-1 authorities for ongoing evaluation and assessment of State system functionality and effectiveness.

106

Integrated Governance Policy Suite Equally important, but often overlooked, is an effective governance policy suite including clear change management processes, technical requirements documents and standards, interface requirements for various elements, integrated continuity of operations planning, interconnection points within the system(s), and a strong system integration plan. The change management process outlines the responsibilities and requirements for communicating changes to the system that impact all aspects. The statewide NG9-1-1 plan should address the process and how any state-, regional- or local-level changes are communicated throughout the state. Change management processes should be included for software and hardware, changes in technology, changes to the staff, changes in operational/technical functions, changes in regulations, and changes within the vendor community, such as changes in technologies that should be communicated to 9-1-1 authorities. Advanced notice of changes also should be a consideration. With an interconnected system of systems, such as NG9-1-1 is envisioned to be, the need for clear change management understanding and cooperation is critical. As the state authority for 9-1-1 service, the Department is the essential entity that can ensure effectiveness throughout Illinois. The Department is authorized to establish technical and operational standards. As a part of this authorization, the Department should develop a policy that directs the integration of local 9-1-1 authority systems, often referred to as a Technical Requirements Document (TRD). The TRD outlines for the local 9-1-1 authorities their responsibilities, defines points of demarcation, and establishes effective processes to ensure efficient transitions and ongoing management of systems. The Interface Requirements (IRs) establish the necessary technical and operational procedures to connect and interconnect system elements. Requirements and processes to inform local and regional ESInets how to interconnect will ensure that the statewide NG9-1-1 system is maintaining the highest level of functionality with the least amount of potential trouble. In the NG9-1-1 world, interconnected systems will have to interoperate to be effective. Establishing rules and best practices not only is part of the role of the state administrator, but also will help to increase the efficiencies of the system and the benefits of NG9-1-1. COOPs are an essential function of government that effectively address service failure and backup scenarios, help to ensure the ongoing functions, and provide for the safety and well-being of citizens. This planning is fundamental to 9-1-1 service provisioning. The National 911 Program’s National 9-1-1 Guidelines Assessment Tool, Security and Continuity of Operations, Guideline SC1 addresses the need for strong COOPs. It recommends that the state should have a COOP for 9-1-1 to ensure continuous operations and that service delivery will continue uninterrupted when faced with a threatening situation that may hinder operations. As the state authority for managing 9-1-1 services within Illinois, it is well within the Department’s responsibilities to ensure that opportunities for system failures are minimized and operations have the appropriate level of system redundancy and resiliency. The ability to predetermine failure routing and to dynamically reroute 9-1-1 traffic to alternate facilities or 9-1-1 centers is part of the NG9-1-1 platform.

107

In addition to a statewide COOP, the need for integrated COOP planning by, among, and between ETSBs and local 9-1-1 authorities will become even more critical in an NG9-1-1 ecosystem. Current ICC rules consider the need for redundant systems and require “provisioning all 9-1-1 facilities over dedicated redundant facilities.” This should be considered the standard method of providing all incoming 9-1-1 facilities and, where possible, should employ diverse routing. Further, the ICC rules require that the service provider “adopt practices to minimize the possibility of service disruption on all facilities associated with 9-1-1 service to a PSAP prior to 9-1-1 going on line.” The rules do not, however, ensure that this original practice be maintained or that an annual diversity audit is conducted and reported to the ICC and the Department, as well as the local 9-1-1 authority. The service provider can and will at times manage its technology and rearrange facilities to maximize its network proficiency. Such rearrangements may inadvertently dilute the robustness of the 9-1-1 network. Recommendation MCP recommends that the State establishes rules and requirements for integrated policies of change management, technical requirements, interface requirements, and continuity of operations. Security Closely related to continuity of operations planning is considerations for system and network security. The National 911 Program’s National 9-1-1 Guidelines Assessment Tool, Security and Continuity of Operations, Guidelines SC3 and SC5 call for the State to have plans and procedures that address the logical security of the system and network, and which safeguard information from unauthorized use, disclosure, modification, damage or use. The services rendered through the 9-1-1 system play an increasingly important role in critical infrastructure, government continuity and everyday life. At the same time, the reliance on and significance of 9-1-1 also increases cybersecurity risks, and these systems become attractive to those who would desire to disrupt the very fiber of the emergency response system. Attacks should be expected and every effort should be made to protect against their impact. As part of the required elements of the local 9-1-1 authority plans to be filed with the State, the State should consider controls and procedural safeguards for: • System Security • Cybersecurity • Physical Security • Security Training • Security Audits Security consists of software, operational, and procedural safeguards for an organization’s systems, including user identification and password access, authentication, access rights and authority levels. Systems (network, data, hardware and users) preventive monitoring can help to safeguard the information and equipment from unauthorized use, disclosure, damage or loss.

108

The consequences of unintentional faults or malicious attacks could have severe impact on human lives. Proactive and coordinated efforts are needed to strengthen security and reliance. Recommendation MCP recommends that the State require the local 9-1-1 authorities’ 9-1-1 plans include procedural security safeguards for system security, cybersecurity, physical security, security training, and security audits, and that the State develop its own procedures and safeguards for these areas of concern.

109

Appendix D – Statutory Alignment

Public Act 100-0020 50 ILCS 750/Emergency Telephone Systems Act

Current Statute Text

Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

1 The General Assembly finds and declares that the most critical aspect of the design of any system is the procedure established for handling a telephone request for emergency services.

50 ILCS 750/6 (fr Ch. 134, par.36); Sec 6 Capabilities of the System

Does the statute or authority assigned in the legislation support this?

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR6: The statutory environment authorizes the operation of a 9-1-1 system. Guideline SR27: The statutory environment identifies 9-1-1 as an essential government service for states that are able to make the distinction.

No perceived issues

2 …the Administrator, with the advice and recommendation of the Statewide 9-1-1 Advisory Board, shall establish a general overview or plan to effectuate the purposes of this Act within the time frame provided in this Act.

50 ILCS 750/7 (fr Ch. 134, par.37); Sec 7

Statewide Plan National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR2: The state has a designated State 9-1-1 coordinator. National 9-1-1 Guidelines Assessment Report; Governance Environment: GV1: The State has a comprehensive statewide 9-1-1 plan.

A statewide 9-1-1 plan is called for in the statute. Authority to carry out the plan and the legislation is assigned to the Administrator. No change is necessary.

110

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

3 The Administrator, with the advice and recommendation of the Statewide 9-1-1 Advisory Board, shall coordinate the implementation of systems established under this Act.

50 ILCS 750/7 (fr Ch. 134, par. 40.1); Sec 8

Coordination National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR1: The statutory environment provides for comprehensive statewide 9-1-1 coordination. Guideline SR9: The statutory environment provides contractual authority to procure and/or operate statewide 9-1-1 components. National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV2: An entity has authority and responsibility for statewide 9-1-1 coordination.

While the authority to coordinate and plan is assigned to the Administrator, the statute may need to stipulate clearly that the Administrator, through the State Plan, has the authority to procure and/or operate statewide 9-1-1 components.

4 To assist with this coordination, all systems authorized to operate under this Act shall register with the Administrator information regarding its composition and organization, including, but not limited to, identification of all PSAPs, SAPs, VAPs, Backup PSAPs, and Unmanned Backup PSAPs. The Department may adopt rules for the administration of this Section.

50 ILCS 750/7 (fr Ch. 134, par. 40.1); Sec 8

New text National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR1: The statutory environment provides for comprehensive statewide 9-1-1 coordination.

Authority to adopt rules is furthered in this section. Ensures PSAPs participate in the coordination and keep Administrator informed. Assists with later requirement that Administrator keep a list of all agencies. No perceived issues

111

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

5 Sec. 10. The Administrator, with the advice and recommendation of the Statewide 9-1-1 Advisory Board, shall establish uniform technical and operational standards for all 9-1-1 systems in Illinois.

50 ILCS 750/10 (fr Ch. 134, par. 40); Sec 10

Technical and operational standards

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR12: The statutory environment fosters the adoption of technical and operational consensus standards for the statewide system. National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST1: Standards and best practices have been identified and implemented at the state level. Guideline ST6: The state program fosters the adoption of technical and/or operational consensus standards and requirements.

IL PUC Act: Section 1325.220 Compliance with Technical and Operational Standards The Department and Administrator shall have the authority to complete a site visit with 9-1-1 systems to verify compliance with technical and operational standards set forth in the Act and in this Part.

6 (c) Nothing in this Act shall deprive the Commission of any authority to regulate the provision by telecommunication carriers or 9-1-1 system service providers of telecommunication or other services under the Public Utilities Act.

50 ILCS 750/10 (fr Ch. 134, par. 40); Sec 10

Authority assigned to ICC to regulate carriers

National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV2: An entity has authority and responsibility for statewide 9-1-1 coordination.

112

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

7 (d) For rules that implicate both the regulation of 9-1-1 authorities under this Act and the regulation of telecommunication carriers and 9-1-1 system service providers under the Public Utilities Act, the Department and the Commission may adopt joint rules necessary for implementation.

50 ILCS 750/10 (fr Ch. 134, par. 40); Sec 10

Authority to plan and carry out the plan

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR12: The statutory environment fosters the adoption of technical and operational consensus standards for the statewide system. Guideline SR2: The state has a designated State 9-1-1 coordinator National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST6: The state program fosters the adoption of technical and/or operational consensus standards and requirements. National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV1: The State has a comprehensive statewide 9-1-1 plan.

No perceived issues

8 (e) Any findings, orders, or decisions of the Administrator under this Section shall be deemed a final administrative decision and shall be subject to judicial review under the Administrative Review Law. (Source: P.A. 99-0006, eff. 1-16.)

50 ILCS 750/10 (fr Ch. 134, par. 40); Sec 10

No perceived issues

113

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

9 (b) 9-1-1 information, including information described in subsection (a), may be used by a public safety agency for the purpose of placing out-going emergency calls.

50 ILCS 750/10.1 (fr Ch. 134, par. 40.1); Sec 10.1 Confidentiality (b)

Confidentiality National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR25: The statutory environment defines confidentiality and disclosure of 9-1-1 records.

No perceived issues

10 (d) Any public safety agency that uses 9-1-1 information for the purposes of subsection (b) must establish methods and procedures that ensure the confidentiality of information as required by subsection (a).

50 ILCS 750/10.1 (fr Ch. 134, par. 40,1); Sec 10.1 Confidentiality (d)

Confidentiality National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR25: The statutory environment defines confidentiality and disclosure of 9-1-1 records. National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC3: The state has a plan and procedures to safeguard information from unauthorized use, disclosure or modification, damage or loss. Guideline SC4: The state has a procedure that ensures confidentiality of information to the extent permitted and/or required by law.

Department should define confidentiality and disclosure of 9-1-1 records in Administrative rules.

114

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

11 Sec. 10.3. Notice of address change. The Emergency Telephone System Board or qualified governmental entity in any county implementing a 9-1-1 system that changes any person's address

50 ILCS 750/10.1 (fr Ch. 134, par. 40,1); Sec 10.3

Pertains to ETSB or for Joint ETSBs to notify Administrator. Supports Administrator’s requirement to keep current list of all agencies.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 7.2.2.)

No perceived issues Should be included in Administrative rules.

12 Sec. 11. All local public agencies operating a 9-1-1 system shall operate under a plan that has been filed with and approved by the Commission prior to January 1, 2016, or the Administrator.

50 ILCS 750/11 (from Ch. 134, par. 41) Sec 11

9-1-1 Plans; no change from previous legislation; while the national guideline refers to a state plan and the statute refers to local ETSB plans the effective practice is applied on a local level.

National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV1: The State has a comprehensive statewide 9-1-1 plan.

No perceived issues

115

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

13 Sec. 14. The General Assembly declares that a major purpose of in enacting this Act is to ensure that 9-1-1 systems have redundant methods of dispatch for: (1) each public safety agency within its jurisdiction, herein known as participating agencies; and (2) 9-1-1 systems whose jurisdictional boundaries are contiguous, herein known as adjacent 9-1-1 systems, when an emergency request for service is received for a public safety agency that needs to be dispatched by the adjacent 9-1-1 system. Another primary purpose of this Section is to eliminate instances in which a public safety agency responding emergency service refuses, once dispatched, to render aid to the requester because the requester is outside of the jurisdictional boundaries of the public safety agency emergency service.

50 ILCS 750/14) (from Ch. 134, par. 44, Sec 14

Backup systems National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC1: The state has business continuity of operations plans (COOP) for 9-1-1 to ensure continuous operations. Guideline SC2: Plans are in place statewide that define and meet needs and priorities to respond to and recover from a disaster. National 9-1-1 Guidelines Assessment Report; Functional and Operational Planning Environment: Guideline OP5: The state requires a data backup plan. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.13.3 Superior Criteria) Mission critical systems, subsystems are redundant to the extent that they provide full service.

No perceived issues

116

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

14 in implementing a 9-1-1 system systems under this Act, all 9-1-1 authorities public agencies in a single system shall enter into call handling and aid outside jurisdictional boundaries agreements with each participating agency and adjacent 9-1-1 system a joint powers agreement or any other form of written cooperative agreement which is applicable when need arises on a day-to-day basis. Certified notification of the continuation of such agreements shall be made among the involved parties on an annual basis. In addition, such agreements shall be entered into between public agencies and public safety agencies which are part of different systems but whose jurisdictional boundaries are contiguous.

50 ILCS 750/14) (from Ch. 134, par. 44, Sec 14

JPA or ILA National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR7: The statutory environment provides for interlocal cooperation. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.13) Redundancy of mission critical systems or subsystems [S13]. Related NRIC47 Best Practices: NRIC BP 7-7-0575 3.2.13.1: Standard Criteria for ALL mission critical systems or subsystems written Memorandums of Understanding (MoUs) or similar contractual agreements exist to sustain COOP in the event of a mission critical system or subsystem failure.

No perceived issues

47 Network Reliability and Interoperability Council

117

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

15 The agreements shall provide a primary and secondary means of dispatch. It 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.

50 ILCS 750/14) (from Ch. 134, par. 44) Sec 14

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.13) Redundancy of mission critical systems or subsystems [S13]. Related NRIC Best Practices: NRIC BP 7-7-0575 3.2.13.1: Standard Criteria for ALL mission critical systems or subsystems written Memorandums of Understanding (MoUs) or similar contractual agreements exist to sustain COOP in the event of a mission critical system or subsystem failure.

Should be included in Administrative rules

16 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.

50 ILCS 750/14) (from Ch. 134, par. 44) Sec 14

Local requirement No federal guidance Should be included in Administrative rules

17 Copies of the annual certified notification of continuing agreement required by Section 14 shall be filed with the Attorney General and the Administrator. All such agreements shall be so filed prior to the 31st day of January.

(50 ILCS 750/15) (from Ch. 134, par. 45) Sec. 15.

Local requirement No federal guidance Should be included in Administrative rules

118

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

18 Public body; exemption from civil liability for developing or operating emergency telephone system.

50 ILCS 750/15.1) (from Ch. 134, par. 45.1, Sec. 15.1.

Liability protection National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR11: The statutory environment provides liability protection.

No perceived issues

19 (a) In no event shall a public agency, the Commission, the Statewide 9-1-1 Advisory Board, the Administrator, the Department of State Police, public safety agency, public safety answering point, emergency telephone system board, or unit of local government assuming the duties of an emergency telephone system board, or carrier, or its officers, employees, assigns, or agents be liable for any civil damages or criminal liability that directly or indirectly results from, or is caused by, any act or omission in the development, design, installation, operation, maintenance, performance, or provision of 9-1-1 service required by this Act, unless the act or omission constitutes gross negligence, recklessness, or intentional misconduct.

50 ILCS 750/15.1) (from Ch. 134, par. 45.1, Sec. 15.1.

Liability protection National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR11: The statutory environment provides liability protection.

No perceived issues

119

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

20 Sec. 15.2a. The installation of or connection to a telephone company's network of any automatic alarm, automatic alerting device, or mechanical dialer that causes the number 9-1-1 to be dialed in order to directly access emergency services is prohibited in a 9-1-1 system. This Section does not apply to a person who connects to a 9-1-1 network using automatic crash notification technology subject to an established protocol. This Section does not apply to devices used to enable access to the 9-1-1 system for cognitively-impaired or special needs persons or for persons with disabilities in an emergency situation reported by a caregiver after initiating a missing person's report…

50 ILCS 750/15.2a (from Ch. 134, par. 45.2a, Sec 15.2a

Automatic alarms prohibited IL PUC Act, Section 1325.510 Electronic Communication Devices Except for the purpose specifically indicated and authorized by law, the installation of or connection to the 9-1-1 system network of an automatic alarm, automatic alerting device, or mechanical dialer that causes the number 9-1-1 to be dialed is prohibited in a 9-1-1 system (e.g., elevator one-button phones, security pole one-button phones, or burglar alarms).

No federal guidance

No perceived issues

120

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

21 Sec. 15.3. Local non-wireless surcharge …the corporate authorities of any municipality or any county may … impose a monthly surcharge on billed subscribers of network connection provided by telecommunication carriers engaged in the business of transmitting messages by means of electricity originating within the corporate limits of the municipality or county imposing the surcharge at a rate per network connection determined in accordance with subsection (c), however the monthly surcharge shall not apply to a network connection provided for use with pay telephone services.

50 ILCS 750/15.3) (from Ch. 134, par. 45.3)

Wireline surcharge Level required for sustainable funding is not known

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR4: The statutory environment provides for dedicated and sustainable 9-1-1 funding.

Once NG9-1-1 plan is developed and accepted, costs will be better understood and an analysis of funding can be conducted. Then and only then will a determination of whether the current funding level is “sustainable” be known.

121

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

22 Sec. 15.3. Local non-wireless surcharge h) Except as expressly provided in subsection (a) of this Section, on or after the effective date of this amendatory Act of the 98th General Assembly and until December 31, 2017 July 1, 2017, a municipality with a population of 500,000 or more shall not impose a monthly surcharge per network connection in excess of the highest monthly surcharge imposed as of January 1, 2014 by any county or municipality under subsection (c) of this Section. Beginning January 1, 2018 and until December 31, 2020, a municipality with a population over 500,000 may not impose a monthly surcharge in excess of $5.00 per network connection. On or after January 1, 2021, July 1, 2017, a municipality with a population over 500,000 may not impose a monthly surcharge in excess of $2.50 per network connection.

50 ILCS 750/15.3 (from Ch. 134, par. 45.3)

Wireline surcharge amounts Level required for sustainable funding is not known

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR4: The statutory environment provides for dedicated and sustainable 9-1-1 funding.

Once NG9-1-1 plan is developed and accepted, costs will be better understood and an analysis of funding can be conducted. Then and only then will a determination of whether the current funding level is “sustainable” be known.

122

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

23 Sec. 15.3. Local non-wireless surcharge (j) The corporate authorities of any municipality or county may issue, in accordance with Illinois law, bonds, notes or other obligations secured in whole or in part by the proceeds of the surcharge described in this Section.

50 ILCS 750/15.3 (from Ch. 134, par. 45.3)

May issue bonds No federal guidance Bonding for major purchases such as NG9-1-1 system components may be a way for Illinois to pay for these systems; full evaluation of this option, should it be necessary, will need to be conducted and discussed with state purchasing Authorities.

24 k) Any surcharge collected by or imposed on a telecommunications carrier pursuant to this Section shall be held to be a special fund in trust for the municipality, county or Joint Emergency Telephone Board imposing the surcharge.

50 ILCS 750/15.3 (from Ch. 134, par. 45.3; (k)

Surcharge special fund text from existing legislation

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute.

See Fund Diversion discussion in Section 4.5.4.

123

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

25 (l) On and after the effective date of this amendatory Act of the 99th General Assembly, no county or municipality, other than a municipality with a population over 500,000, may impose a monthly surcharge under this Section in excess of the amount imposed by it on the effective date of this Act. Any surcharge imposed pursuant to this Section by a county or municipality, other than a municipality with a population in excess of 500,000, shall cease to be imposed on January 1, 2016.

50 ILCS 750/15.3 (from Ch. 134, par. 45.3; (l)

Ability to impose a surcharge; local surcharge has ceased

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR4: The statutory environment provides for dedicated and sustainable 9-1-1 funding

It has not been determined if the current amount of surcharge is sustainable. Once NG9-1-1 plan is developed and accepted, costs will be better understood and an analysis of funding can be conducted. Then and only then will a determination of whether the current funding level is “sustainable” be known.

26 (a)…any surcharge imposed shall be imposed based upon the municipality or county that encompasses the customer's place of primary use as defined in the Mobile Telecommunications Sourcing Conformity Act.48

50 ILCS 750/15.3a Ability to impose a surcharge National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR4: The statutory environment provides for dedicated and sustainable 9-1-1 funding

Once NG9-1-1 plan is developed and accepted, costs will be better understood and an analysis of funding can be conducted. Then and only then will a determination of whether the current funding level is “sustainable” be known.

48 http://www.ilga.gov/legislation/ilcs/ilcs3.asp?ActID=623&ChapterID=8

124

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

27 (b) Until December 31, 2017 July 1, 2017, the corporate authorities of a municipality with a population in excess of 500,000 on the effective date of this amendatory Act of the 99th General Assembly may by ordinance continue to impose and collect a monthly surcharge per commercial mobile radio service (CMRS) connection or in-service telephone number billed on a monthly basis that does not exceed the highest monthly surcharge imposed as of January 1, 2014 by any county or municipality under subsection (c) of Section 15.3 of this Act. Beginning January 1, 2018, and until December 31, 2020, a municipality with a population in excess of 500,000 may by ordinance continue to impose and collect a monthly surcharge per commercial mobile radio service (CMRS) connection or in-service telephone number billed on a monthly basis that does not exceed $5.00. On or after January 1, 2021 July 1, 2017, the municipality may continue imposing and collecting its wireless carrier surcharge as provided in and subject to the limitations of subsection (a) of this Section.

50 ILCS 750/15.3a (b) Ability to impose a surcharge National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR4: The statutory environment provides for dedicated and sustainable 9-1-1 funding.

Once NG9-1-1 plan is developed and accepted, costs will be better understood and an analysis of funding can be conducted. Then and only then will a determination of whether the current funding level is “sustainable” be known.

125

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

28 Emergency Telephone System Board; powers. The corporate authorities shall provide for the manner of appointment and the number of members of the Board, provided that the board shall consist of not fewer than 5 members, one of whom must be a public member who is a resident of the local exchange service territory included in the 9-1-1 coverage area, one of whom (in counties with a population less than 100,000) may be a member of the county board, and at least 3 of whom shall be representative of the 9-1-1 public safety agencies, including but not limited to police departments, fire departments, emergency medical services providers, and emergency services and disaster agencies, and appointed on the basis of their ability or experience.

50 ILCS 750/15.4) (from Ch. 134, par. 45.4; Sec. 15.4.

ETSB powers National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR14: The statutory environment provides for stakeholder involvement.

No perceived issues

126

Current Statute Text Public Act 100-0020 Reference Section Comment/Assessment Federal Guideline Alignment NG9-1-1 Feasibility

29 Any 2 or more municipalities, counties, or combination thereof, may, instead of establishing individual boards, establish by intergovernmental agreement a Joint Emergency Telephone System Board pursuant to this Section. The manner of appointment of such a joint board shall be prescribed in the agreement. On or after the effective date of this amendatory Act of the 100th General Assembly, any new intergovernmental agreement entered into to establish or join a Joint Emergency Telephone System Board shall provide for the appointment of a PSAP representative to the board.

50 ILCS 750/15.4) (from Ch. 134, par. 45.4; Sec. 15.4.

JPA allowed; ensures as consolidation occurs representation of the consolidated jurisdiction also has a seat on the board

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR7: The statutory environment provides for interlocal cooperation.

No perceived issues

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30 b) The powers and duties of the board shall be defined by ordinance of the municipality or county, or by intergovernmental agreement in the case of a joint board. The powers and duties shall include, but need not be limited to the following: (1) Planning a 9-1-1 system. (2) Coordinating and supervising the implementation, upgrading, or maintenance of the system, including the establishment of equipment specifications and coding systems. (3) Receiving moneys from the surcharge imposed under Section 15.3, or disbursed to it under Section 30, and from any other source, for deposit into the Emergency Telephone System Fund. (4) Authorizing all disbursements from the fund. (5) Hiring any staff necessary for the implementation or upgrade of the system.

50 ILCS 750/15.4) (from Ch. 134, par. 45.4; Sec. 15.4.

Duties of the board National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV3: Stakeholder groups participate in 9-1-1 planning, implementation, and changes. Guideline GV4: A statewide board or advisory council provides input and oversight for statewide 9-1-1 system coordination.

No perceived issues

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31 (c) All moneys received by a board pursuant to a surcharge imposed under Section 15.3, or disbursed to it under Section 30, shall be deposited into a separate interest-bearing Emergency Telephone System Fund account. All interest accruing on the fund shall remain in the fund. No expenditures may be made from such fund except upon the direction of the board by resolution passed by a majority of all members of the board.

50 ILCS 750/15.4) (from Ch. 134, par. 45.4; Sec. 15.4.

Funds in separate interest-bearing account

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute. Guideline SR4: The statutory environment provides for dedicated and sustainable 9-1-1 funding.

See Fund Diversion discussion in Section 4.5.4.

32 (d) The board shall complete a Master Street Address Guide database before implementation of the 9-1-1 system. The error ratio of the database shall not at any time exceed 1% of the total database.

50 ILCS 750/15.4) (from Ch. 134, par. 45.4; Sec. 15.4.

MSAG error ratio established No federal guidance IL PUC ACT: Section 1325.520 9-1-1 Traditional Legacy Service Database (g) Error Resolution 1) It shall be the joint responsibility of the 9-1-1 Authority, the 9-1-1 system provider, and telecommunications carriers to ensure that the error ratio of each 9-1-1 system's database shall not, at any time, exceed 1%.

No perceived issues; should be included in Administrative rules

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33 (e) On and after January 1, 2016, no municipality or county may create an Emergency Telephone System Board unless the board is a Joint Emergency Telephone System Board. The corporate authorities of any county or municipality entering into an intergovernmental agreement to create or join a Joint Emergency Telephone System Board shall rescind an the ordinance or ordinances creating a single the original Emergency Telephone System Board and shall eliminate the single Emergency Telephone System Board, effective upon the creation of the Joint Emergency Telephone System Board, with regulatory approval by the Administrator, or joining of the Joint Emergency Telephone System Board. Nothing in this Section shall be construed to require the dissolution of an Emergency Telephone System Board that is not succeeded by a Joint Emergency Telephone System Board or is not required to consolidate under Section 15.4a of this Act.

50 ILCS 750/15.4) (from Ch. 134, par. 45.4; Sec. 15.4.

Requires consolidated governance after 1/1/16

No federal guidance No perceived issues

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34 (f) Within one year after the effective date of this amendatory Act of the 100th General Assembly, any corporate authorities of a county or municipality, other than a municipality with a population of more than 500,000, operating a 9-1-1 system without an Emergency Telephone System Board or Joint Emergency Telephone System Board shall create or join a Joint Emergency Telephone System Board.

50 ILCS 750/15.4) (from Ch. 134, par. 45.4; Sec. 15.4. (f)

Requires consolidated governance after 1/1/16

No federal guidance No perceived issues

35 (6) Any 9-1-1 Authority that does not have a PSAP within its jurisdiction shall be consolidated through an intergovernmental agreement with an existing 9-1-1 Authority that has a PSAP to create a Joint Emergency Telephone Board.

50 ILCS 750/15.4a ILA National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR7: The statutory environment provides for interlocal cooperation.

No perceived issues

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36 (7) each county that has no 9-1-1 service as of January 1, 2016 shall provide enhanced 9-1-1 wireline and wireless enhanced 9-1-1 service for that county by either (i) entering into an intergovernmental agreement with an existing Emergency Telephone System Board to create a new Joint Emergency Telephone System Board, or (ii) entering into an intergovernmental agreement with the corporate authorities that have created an existing Joint Emergency Telephone System Board.

50 ILCS 750/15.4a Allows joint authority National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR7: The statutory environment provides for interlocal cooperation.

No perceived issues

37 (7) (b) (1) No county or 9-1-1 Authority may avoid the requirements of this Section by converting primary PSAPs to secondary or virtual answering points. Any county or 9-1-1 Authority not in compliance with this Section shall be ineligible to receive consolidation grant funds issued under Section 15.4b of this Act or monthly disbursements otherwise due under Section 30 of this Act, until the county or 9-1-1 Authority is in compliance.

(50 ILCS 750/15.4a) Sec. 15.4a. Consolidation.

Prevents local authority from ignoring consolidation requirement

No federal guidance No perceived issues

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38 An entity that provides or operates private residential switch service and provides telecommunications facilities or services to residents shall provide to those residential end users the same level of 9-1-1 service as the public agency and the telecommunications carrier are providing to other residential end users of the local 9-1-1 system. This service shall include, but not be limited to, the capability to identify the telephone number, extension number, and the physical location that is the source of the call to the number designated as the emergency telephone number.

50 ILCS 750/15.5 Multi-line Telephone System (MLTS) regulation

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR26: A statute/regulation exists that addresses multi-line telephone systems (MLTS) statewide for 9-1-1. NENA Model Legislation E9-1-1 for Multi-Line Telephone Systems (NENA 06-750, Version 3) NENA MLTS E9-1-1 Caller Location Discovery and Reporting (NENA 06-502, Version 1, October 25, 2008)

No perceived issues

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39 (a) After June 30, 2000, or within 18 months after enhanced 9-1-1 service becomes available, any entity that installs or operates a private business switch service and provides telecommunications facilities or services to businesses shall assure that the system is connected to the public switched network in a manner that calls to 9-1-1 result in automatic number and location identification.

50 ILCS 750/15.6 B-PBX section from 2000

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR26: A statute/ regulation exists that addresses multi-line telephone systems (MLTS) statewide for 9-1-1. NENA Model Legislation E9-1-1 for Multi-Line Telephone Systems (NENA 06-750, Version 3) NENA MLTS E9-1-1 Caller Location Discovery and Reporting (NENA 06-502, Version 1, October 25, 2008)

No perceived issues

40 Sec. 15.6a. These standards shall not in any way prescribe the technology or manner a wireless carrier shall use to deliver wireless 9-1-1 or wireless E9-1-1 calls, and these standards shall not exceed the requirements set by the Federal Communications Commission

50 ILCS 750/15.6a Wireless technology neutral FCC Task Force on Optimal PSAP Architecture (TFOPA), December 2, 2016 Working Group 3 Report: Funding Sustainment Model (stated a bias toward approaches that are technologically neutral). Section 5.2 Guiding Policy Principles for 9-1-1 Funding.

No perceived issues

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41 (c) …one or more of its public safety answering points to serve as a primary wireless 9-1-1 public safety answering point for its jurisdiction by notifying the Administrator in writing within 6 months after receiving its authority to operate a 9-1-1 system under this Act

50 ILCS 750/15.6a Primary PSAP designation No federal guidance No perceived issues; should be included in Administrative rules

42 The Department of State Police shall be the primary wireless 9-1-1 public safety answering point for any jurisdiction that did not provide notice to the Illinois Commerce Commission and the Department prior to January 1, 2016

50 ILCS 750/15.6a State Police default wireless PSAP

No federal guidance No perceived issues

43 Next Generation 9-1-1 service (a)The Administrator, with the advice and recommendation of the Statewide 9-1-1 Advisory Board, shall develop and implement a plan for a statewide Next Generation 9-1-1 network.

50 ILCS 750/15.6b Statewide NG9-1-1 Plan “Statewide coordination should include all 9-1-1 stakeholders, all 9-1-1 accessible services (e.g., wireline, wireless, Voice over Internet Protocol [VoIP] and emerging technologies) and governmental and non-governmental entities. Comprehensive coordination includes statewide planning, funding support, stakeholder

National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV1: The State has a comprehensive statewide 9-1-1 plan. National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR1: The statutory environment provides for comprehensive statewide 9-1-1 coordination.

While the authority to coordinate and plan is assigned to the Administrator, the statute may need to stipulate clearly that the Administrator, through the State Plan, has the authority to procure and/or operate statewide 9-1-1 components

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involvement, uniform statewide adherence to established technical and operational standards, influencing policy creation to the benefit of the stakeholders, public education, training, enforcement, rulemaking, procurement authority, grant writing assistance, grant management, dispute resolution, and program evaluation.”49

44 The Next Generation 9-1-1 network must be an Internet protocol-based platform that at a minimum provides: (1) improved 9-1-1 call delivery; (2) enhanced interoperability; (3) increased ease of communication between 9-1-1 (4) a hosted solution with redundancy built in; and (5) compliance with NENA Standards i3 Solution 08-003

50 ILCS 750/15.6b NENA i3 NENA Detailed Functional and Interface Standards for the NENA i3 Solution (NENA-STA-010.2-2016)

No perceived issues

49 https://resourcecenter.911.gov/911Guidelines/RPT053012_National_911_Assessment_Guidelines_Report_FINAL.pdf

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45 (c) Within 12 months of the final report from the consultant under subsection (b) of this Section, the Department shall procure and finalize a contract with a vendor certified under Section 13-900 of the Public Utilities Act to establish a statewide Next Generation 9-1-1 network. By July 1, 2020, the vendor shall implement a Next Generation 9-1-1 network that allows 9-1-1 systems providing 9-1-1 service to Illinois residents to access the system utilizing their current infrastructure if it meets the standards adopted by the Department.

50 ILCS 750/15.6b 2020 deadline established No federal guidance although this timeline is in alignment with NG911 NOW Coalition and draft federal legislation

Review date requirements as further planning is done

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46 Compliance with certification of 9-1-1 system providers by the Illinois Commerce Commission. In addition to the requirements of this Act, all 9-1-1 system providers must comply with the requirements of Section 13-900 of the Public Utilities Act.50

50 ILCS 750/15.7 Does this mean that the ICC will be certifying NG9-1-1 service providers and do those requirements need to be updated for new technologies?

No federal guidance PUA 13-900: Public Utilities Act [220 ILCS 5/13-900] - 9-1-1 system provider − Any person, corporation, limited liability company, partnership, sole proprietorship, or entity of any description that acts as a 9-1-1 system provider within the meaning of Section 2.18 at the ETSA by contracting to provide 9-1-1 network and database services and who has been certified by the Commission pursuant to Section 13-900 of the Public Utilities Act [220 ILCS 5/13-900]. ICC may need to ensure this language allows them to approve NG9-1-1 system component providers as well as whole network/systems providers

47 Service provided to businesses shall ensure that all systems installed on or after July 1, 2015 (the effective date of Public Act 98-875) are connected to the public switched network in a manner such that when a user dials "9-1-1", the emergency call connects to the 9-1-1

50 ILCS 750/15.8 9+911 not allowed HR 582 January 24, 2017 (Received in the Senate and read twice and referred to the Committee on Commerce,

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR26: A statute/regulation exists that addresses multi-line telephone systems (MLTS) statewide for 9-1-1.

No perceived issues

50 http://www.ilga.gov/legislation/ilcs/ilcs4.asp?DocName=022000050HArt.+XIV&ActID=1277&ChapterID=23&SeqStart=32200000&SeqEnd=33300000&Print=True

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system without first dialing any number or set of numbers.

Science, and Transportation.) Passed. (Sec. 2) This bill amends the Communications Act of 1934 to prohibit businesses from manufacturing or importing for use in the United States, or selling or leasing in the United States, a multi-line telephone system unless it is pre-configured to allow users to directly initiate a call to 9-1-1 (without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit "9") from any station equipped with dialing facilities. Businesses are prohibited from installing, managing, or operating multi-line telephone systems without such a direct 9-1-1 call configuration. NENA Industry Common Mechanisms for MLTS E9-1-1

NENA Model Legislation E9-1-1 for Multi-Line Telephone Systems (NENA 06-750, Version 3) NENA MLTS E9-1-1 Caller Location Discovery and Reporting (NENA 06-502, Version 1, October 25, 2008)

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Caller Location Discovery and Reporting Technical Information Documents (TID) NENA 06-502, Version 1, October 25, 2008: “In the MLTS environment, the recommended policy is that a user should be able to dial 9-1-1 and their call should go directly to the responsible PSAP. Although, some organizations make policy decisions that put in place alternative procedures, such as, different dialing codes or additional digits that need to be dialed before the call originates to the PSAP, this is not considered a best practice.”

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48 (b) The Department shall prepare a directory of all authorized 9-1-1 systems in the State. The directory shall include an emergency 24/7 10-digit telephone number for all primary public safety answering points located in each 9-1-1 system to which 9-1-1 calls from another jurisdiction can be transferred. This directory shall be made available to each 9-1-1 authority for its use in establishing standard operating procedures regarding calls outside its 9-1-1 jurisdiction.

50 ILCS 750/17.5

49 (c) Each 9-1-1 system shall provide the Department with the following information: (1) The name of the PSAP, a list of every participating agency, and the county the PSAP is in, including college and university public safety entities.

50 ILCS 750/17.5 Ensures there is a comprehensive listing of all PSAPs in the state

No federal guidance No perceived issues

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50 (2) The 24/7 10-digit emergency telephone number and email address for the dispatch agency to which 9-1-1 calls originating in another 9-1-1 jurisdiction can be transferred or by which the PSAP can be contacted via email to exchange information. Each 9-1-1 system shall provide the Department with any changes to the participating agencies and this number and email address immediately upon the change occurring. Each 9-1-1 system shall provide the PSAP information, the 24/7 10-digit emergency telephone number and email address to the Manager of the Department's 9-1-1 Program within 30 days of the effective date of this amendatory Act of the 100th General Assembly.

50 ILCS 750/17.5 Ensures there is a comprehensive listing of all PSAPs in the state

No federal guidance No perceived issues

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51 (3) The standard operating procedure describing the manner in which the 9-1-1 system will transfer, forward, or relay 9-1-1 calls originating within its jurisdiction, but which should properly be answered and dispatched by another 9-1-1 system, to the appropriate 9-1-1 system. Each 9-1-1 system shall provide the standard operating procedures to the Manager of the Department's 9-1-1 Program within 180 days after the effective date of this amendatory Act of the 100th General Assembly.

50 ILCS 750/17.5 Ensures there is a comprehensive listing of all PSAPs in the state

No federal guidance No perceived issues

52 Sec. 19. Statewide 9-1-1 Advisory Board Creation …within the Department of State Police. The Board shall consist of the following 11 voting members: (1) The Director of the State Police, or his or her designee, who shall serve as chairman. (2) The Executive Director of the Commission, or his or her designee. (3) Nine members appointed by the Governor as follows: (A) one member representing the Illinois chapter of the National Emergency

50 ILCS 750/19 Statewide advisory board creation

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR14: The statutory environment provides for stakeholder involvement. Guideline SR15: Service providers that deliver and/or enable telecommunications services to the public are involved in the 9-1-1 system.

Review composition after comprehensive NG9-1-1 Plan is completed and system procured to ensure appropriate representation.

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Number Association, or his or her designee; (B) one member representing the Illinois chapter of the Association of Public-Safety Communications Officials, or his or her designee; (C) one member representing a county 9-1-1 system from a county with a population of less than 50,000; (D) one member representing a county 9-1-1 system from a county with a population between 50,000 and 250,000; (E) one member representing a county 9-1-1 system from a county with a population of more than 250,000; (F) one member representing a municipality with a population of less than 500,000 in a county with a population in excess of 2,000,000; (G) one member representing the Illinois Association of Chiefs of Police; (H) one member representing the Illinois Sheriffs' Association; and (I) one member representing the Illinois Fire Chiefs Association.

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53 The Governor shall appoint the following non-voting members: (i) one member representing an incumbent local exchange 9-1-1 system provider; (ii) one member representing a non-incumbent local exchange 9-1-1 system provider; (iii) one member representing a large wireless carrier; (iv) one member representing an incumbent local exchange small wireless carrier; and (v) one member representing the Illinois Telecommunications Association, (vi) one member representing the Cable Television and Communication Association of Illinois; and (vii) one member representing the Illinois State Ambulance Association. The Speaker of the House of Representatives, the Minority Leader of the House of Representatives, the President of the Senate, and the Minority Leader of the Senate may each appoint a member of the General Assembly to temporarily serve as a non-voting member of the Board during the 12 months prior to the repeal date of this Act to discuss legislative initiatives of the Board.

50 ILCS 750/19 Non-voting members Adds legislators to Board prior to repeal date

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR15: Service providers that deliver and/or enable telecommunications services to the public are involved in the 9-1-1 system.

Review composition after comprehensive NG9-1-1 Plan is completed and system is procured to ensure appropriate representation.

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54 (1) Each telecommunications carrier shall impose a monthly surcharge of $0.87 per network connection; provided, however, the monthly surcharge shall not apply to a network connection provided for use with pay telephone services. Where multiple voice grade communications channels are connected between the subscriber's premises and a public switched network through private branch exchange (PBX), or centrex type service, or other multiple voice grade communication channels facility, there shall be imposed 5 such surcharges per network connection for both regular service and advanced service provisioned trunk lines. Until December 31, 2017, the surcharge shall be $0.87 per network connection and on and after January 1, 2018, the surcharge shall be $1.50 per network connection.

50 ILCS 750/20 Statewide wireline surcharge No federal guidance Amount of collection may need review and modification once costs for procurement and ongoing operation are known.

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55 (2) Each wireless carrier shall impose and collect a monthly surcharge of $0.87 per CMRS connection that either has a telephone number within an area code assigned to Illinois by the North American Numbering Plan Administrator or has a billing address in this State. Until December 31, 2017, the surcharge shall be $0.87 per connection and on and after January 1, 2018, the surcharge shall be $1.50 per connection.

50 ILCS 750/20 Wireless surcharge No federal guidance Amount of collection may need review and modification once costs for procurement and ongoing operation are known.

56 (d)The telecommunications carrier collecting the surcharge may deduct and retain an amount not to exceed shall also be entitled to deduct 3% of the gross amount of surcharge collected to reimburse the telecommunications carrier for the expense of accounting and collecting the surcharge. On and after July 1, 2022, the wireless carrier collecting a surcharge under this Section may deduct and retain an amount not to exceed shall be entitled to deduct up to 3% of the gross amount of the surcharge collected to reimburse the wireless carrier for the expense of accounting and collecting the surcharge

50 ILCS 750/20 Wireline entitled to 3% now; wireless not until 2022.

No federal guidance No perceived issues.

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57 (e) Surcharges imposed under this Section shall be collected by the carriers and shall be remitted to the Department, within 30 days of collection, remitted, either by check or electronic funds transfer, by the end of the next calendar month after the calendar month in which it was collected to the Department for deposit into the Statewide 9-1-1 Fund. Carriers are not required to remit surcharge moneys that are billed to subscribers but not yet collected.

50 ILCS 750/20 Stipulates when collections are due to the Department

No federal guidance No perceived issues

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58 (j) nothing shall impair the right of wireless carriers to recover compliance costs for all emergency communications services that are not reimbursed out of the Wireless Carrier Reimbursement Fund directly from their wireless subscribers by line-item charges on the wireless subscriber's bill. Those compliance costs include all costs incurred by wireless carriers in complying with local, State, and federal regulatory or legislative mandates that require the transmission and receipt of emergency communications to and from the general public, including, but not limited to, E9-1-1

50 ILCS 750/20 Cost recovery Current wireless fund and cost recovery process will be retired by 2022

FCC determined that cost recovery was not to be a requirement or a deterrent to wireless 9-1-1 service.

No perceived issues

59 (a) A special fund in the State treasury known as the Wireless Service Emergency Fund shall be renamed the Statewide 9-1-1 Fund. Any appropriations made from the Wireless Service Emergency Fund shall be payable from the Statewide 9-1-1 Fund.

50 ILCS 750/30 Statewide 9-1-1 Fund renamed; surcharge disbursements are made from this fund. Wireless surcharge revenue; prepaid surcharge revenue; appropriations; grants interest; premiums or other earnings.

No federal guidance No perceived issues

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60 (b) Subject to appropriation and availability of funds, the Department shall distribute the 9-1-1 surcharges monthly as follows: …

50 ILCS 750/30 Directs Department disbursements only if funds are available after priorities are funded.

No federal guidance See Economic / Funding Environment, Section 3.4.3.

61 (1)(A) $0.013 shall be distributed monthly in equal amounts to each County Emergency Telephone System Board or qualified governmental entity in counties with a population under 100,000 according to the most recent census data which is authorized to serve as a primary wireless 9-1-1 public safety answering point for the county and to provide wireless 9-1-1 service as prescribed by subsection (b) of Section 15.6a of this Act, and which does provide such service. (1)(B)$0.033 shall be transferred by the Comptroller at the direction of the Department to Wireless Carrier Reimbursement Fund until June 30, 2017; from July 1, 2017 through June 30, 2018, $0.026 shall be transferred; from July 1, 2018 through June 30, 2019, $0.020 shall be transferred; from July 1,

50 ILCS 750/30 Directs Department disbursements only if funds are available after priorities are funded.

No federal guidance Review when comprehensive statewide plan and procurements are completed. See Economic / Funding Environment, Section 3.4.3.

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2019, through June 30, 2020, $0.013 shall be transferred; from July 1, 2020 through June 30, 2021, $0.007 will be transferred; and after June 30, 2021, no transfer shall be made to the Wireless Carrier Reimbursement Fund. (C) Until December 31, 2017, $0.007 and on and after January 1, 2018, $0.017 shall be used to cover the Department's administrative costs.

62 (D) Beginning January 1, 2018, until June 30, 2020, $0.12, and on and after July 1, 2020, $0.04 shall be used to make monthly proportional grants to the appropriate 9-1-1 Authority currently taking wireless 9-1-1 based upon the United States Postal Zip Code of the billing addresses of subscribers wireless carriers.

50 ILCS 750/30 Directs Department disbursements

No federal guidance Review when comprehensive statewide plan and procurements are completed. See Economic / Funding Environment, Section 3.4.3.

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63 (E) Until June 30, 2020, $0.05 shall be used by the Department for grants for NG9-1-1 expenses, with priority given to 9-1-1 Authorities that provide 9-1-1 service within the territory of a Large Electing Provider as defined in Section 13-406.1 of the Public Utilities Act.

50 ILCS 750/30 Directs Department disbursements and establishes priorities

No federal guidance Review when comprehensive statewide plan and procurements are completed See Economic / Funding Environment, Section 3.4.3.

64 (D) Funds may be held in reserve by the Statewide 9-1-1 Advisory Board and disbursed by the Department for grants under Section 15.4b of this Act Sections 15.4a, 15.4b, and for NG9-1-1 expenses up to $12.5 million per year in State fiscal years 2016 and 2017; up to $20 $13.5 million in State fiscal year 2018; up to $20.9 $14.4 million in State fiscal year 2019; up to $15.3 million in State fiscal year 2020; up to $16.2 million in State fiscal year 2021; up to $23.1 million in State fiscal year 2022; and up to $17.0 million per year for State fiscal year 2023 and each year thereafter. The amount held in reserve in State fiscal years 2018 and 2019 shall not be less than $6.5 million. Disbursements under this subparagraph (D) shall be prioritized as

50 ILCS 750/30 Funds may be held in reserve for NG9-1-1 up to $12.5 million for 2016/2017 $20 million for 2018 $20.9 million for 2019 $15.3 million for 2020 $16.2 million for 2021 $23.1 million for 2022 $17.0 million for 2023 and thereafter

No federal guidance Retain. Review when comprehensive statewide plan and system procurement are completed. Department required to hold no less than $6.5 million in reserve in 2018 and 2019 even though more is permitted; this is the lowest level they are obligated to reserve. Funding priorities established.

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follows: (i) consolidation grants prioritized under subsection (a) of Section 15.4b of this Act; (ii) NG9-1-1 expenses; and (iii) consolidation grants under Section 15.4b of this Act for consolidation expenses incurred between January 1,2010, and January 1, 2016.

65 9-1-1 surcharge; allowable expenditures. Except as otherwise provided in this Act, expenditures from surcharge revenues received under this Act may be made by municipalities, counties, and 9-1-1 Authorities only to pay for the costs associated with the following: (1) The design of the Emergency

Telephone System (2) The coding of an initial Master Street

Address Guide database, and update and maintenance thereof

(3) The repayment of any moneys advanced for the implementation of the system.

(4) The charges for Automatic Number Identification and Automatic Location Identification equipment, a computer

50 ILCS 750/35

Allowable expenditures NENA Next Generation Partner Program: A Policy Maker Blueprint for Transitioning to the Next Generation 9-1-1 System — “State and local governments should examine funding, operations, and legislation to ensure they promote the needed ESInets and cooperation, including interstate ESInets and NG9-1-1 in general.”51

Review when comprehensive statewide plan and system procurement are completed. Legacy elements should be transitioned out of allowable expense category; Department priorities emphasizing advancement to NG9-1-1 implementation should be considered and added to Administrative rules or County Plan requirements. 9-1-1 plans required by the local 9-1-1 jurisdiction should be required to start to transition away from legacy components and the ability or requirement to use

51 http://www.nena.org/resource/resmgr/ng9-1-1_project/ng9-1-1policymakerblueprintt.pdf

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aided dispatch system that records, maintains, and integrates information, mobile data transmitters equipped with automatic vehicle locators, and maintenance, replacement, and update thereof to increase operational efficiency and improve the provision of emergency services

(5) The non-recurring charges related to installation of the Emergency Telephone System.

(6) The initial acquisition and install for road or street signs Funds may not be used for ongoing expenses associated with road or street sign maintenance and replacement.

(7) Other products and services necessary for the implementation, upgrade, and maintenance of the system and any other purpose related to the operation of the system, including costs attributable directly to the construction, leasing, or maintenance of any buildings or facilities or costs of personnel attributable directly to the operation of the system. Costs attributable directly to the operation of an emergency telephone system do not include the costs of public safety

funds for legacy elements should be discouraged if not disallowed. Consider updating list of allowable expenditures in next legislation to eliminate legacy elements.

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agency personnel who are and equipment that is dispatched in response to an emergency call.

(8) The defraying of expenses incurred to implement Next Generation 9-1-1, subject to the conditions set forth in this Act.

(9) The implementation of a computer aided dispatch system or hosted supplemental 9-1-1 services.

(10) The design, implementation, operation, maintenance, or upgrade of wireless 9-1-1, E9-1-1, or NG9-1-1 emergency services and public safety answering points.

66 Moneys in the Statewide 9-1-1 Fund may also be transferred to a participating fire protection district to reimburse volunteer firefighters who man remote telephone switching facilities when dedicated 9-1-1 lines are down.

50 ILCS 750/35 Use of funds for fire district as back up

No federal guidance No perceived issues

67 The Department shall create uniform accounting procedures applicable only to municipalities with a population in excess of 500,000, that any emergency telephone system board, qualified governmental entity, or unit of local government receiving surcharge money

50 ILCS 750/40 Financial reports

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute.

No perceived issues

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pursuant to Section 15.3, 15.3a, or 30 of this Act must follow. (b) By January 31, 2018, and every January 31 thereafter October 1, 2016, and every October 1 thereafter, each emergency telephone system board, qualified governmental entity, or unit of local government receiving surcharge money pursuant to Section 15.3, 15.3a, or 30 shall report to the Department audited financial statements showing total revenue and expenditures for the period beginning with the end of the period covered by the last submitted report through the end of the previous calendar year previous fiscal year in a form and manner as prescribed by the Department. Such financial information shall include: (1) a detailed summary of revenue from all sources including, but not limited to, local, State, federal, and private revenues, and any other funds received; (2) all expenditures made during the reporting period from distributions under

Audited financial reports

(Superior criteria for this category is identified as “state audits and enforces the eligible use of funds.”) State of Florida requires financial audits (Model State 911 Plan, U.S. Department of Transportation, National Highway Traffic Safety Administration, February 2013) U.S. Government Accountability Office (GAO) 12-331G Government Auditing Standards, 2011 Revision

And interest

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this Act operating expenses, capital expenditures, and cash balances; and (3) call data and statistics, when available, from the reporting period, as specified by the Department and collected in accordance with any reporting method established or required such other financial information that is relevant to the provision of 9-1-1 services as determined by the Department. (4) all costs associated with dispatching appropriate public safety agencies to respond to 9-1-1 calls received by the PSAP; and (5) all funding sources and amounts of funding used for costs described in paragraph (4) of this subsection (b).

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR23: The statutory environment provides for the collection of 9-1-1 system data. National 9-1-1 Guidelines Assessment Report; Functional and Operational Planning Environment: Guideline OP4: The state provides guidelines for the retention of 9-1-1 call records and 9-1-1 related data.

Department is required to report call data; is there a mechanism for collecting reliable and consistently collected data? If not, the Department may want to consider automated data collections systems such as eCATS or similar or to stipulate call data that is to be collected and reported by PSAPs in Administrative rules.

68 The emergency telephone system board, qualified governmental entity, or unit of local government is responsible for any costs associated with auditing such financial statements.

50 ILCS 750/40 Audits required

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute.

No perceived issues

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The Department shall post the audited financial statements on the Department's website (c) Along with its audited financial statement, each emergency telephone system board, qualified governmental entity, or unit of local government receiving a grant under Section 15.4b of this Act shall include a report of the amount of grant moneys received and how the grant moneys were used.

Public disclosure Report of grants received and how used

(Superior criteria for this category is identified as “state audits and enforces the eligible use of funds.”) Support for audits can be found in the NASNA report on 911 Funding: Optimizing Revenue from the Current Surcharge Model52 as well as the TFOPA Adopted Final Report53

52 https://drive.google.com/file/d/0B5HEHifGSF-eX3ZvUVZfVENYTmM/view 53 https://transition.fcc.gov/pshs/911/TFOPA/TFOPA_FINALReport_012916.pdf

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69 Any emergency telephone system board or qualified governmental entity not in compliance with this Section shall be ineligible to receive any consolidation grant or infrastructure grant issued under this Act.

50 ILCS 750/40 Penalties for non-compliance Congress established a 9-1-1 grant program under the ENHANCE 911 Act and has prohibited Federal 9-1-1 grant monies to any State or political subdivision that “obligates or expends designated E–911 charges for any purpose other than the purposes for which such charges are designated or presented …”54 The U.S. GAO is required to monitor and report on states’ collection and usage of 9-1-1 funds, including information regarding the diversion of 9-1-1 funds from intended purposes.55

No perceived issues

70 (e) The Department may adopt emergency rules necessary to implement the provisions of this Section.

50 ILCS 750/40 Authority to adopt rules to carry out responsibilities

National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV2: An entity has authority and responsibility for statewide 9-1-1 coordination.

No perceived issues

54 P.L. 108-494, Sec. 104, codified as 47 U.S.C. §942(c)(3). 55 P.L. 108-494, Sec. 105(b). The report is available at http://www.gao.gov/new.items/d06338.pdf

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71 (f) Any findings or decisions of the Department under this Section shall be deemed a final administrative decision and shall be subject to judicial review under the Administrative Review Law.

50 ILCS 750/40 Department is final authority National 9-1-1 Guidelines Assessment Report; Governance Environment: Guideline GV2: An entity has authority and responsibility for statewide 9-1-1 coordination.

No perceived issues

72 (g) Beginning October 1, 2017, the Department shall provide a quarterly report to the Board of its expenditures from the Statewide 9-1-1 Fund for the prior fiscal quarter.

50 ILCS 750/40 Quarterly reporting required starting in October 2017

No federal guidance No perceived issues

73 Sec. 45. Wireless Carrier Reimbursement Fund A special fund in the State treasury known as the Wireless Carrier Reimbursement Fund, which was created previously under Section 30 of the Wireless Emergency Telephone Safety Act, shall continue in existence without interruption notwithstanding the repeal of that Act. Moneys in the Wireless Carrier Reimbursement Fund may be used,

50 ILCS 750/45 Wireless Carrier Reimbursement Fund

FCC ruling 94-102 on cost recovery56 stipulates that wireless carrier cost recovery, while allowed, is not required. National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment:

Is wireless fund slated to dissolve? See Fund Diversion discussion in Section 4.5.4.

56 https://apps.fcc.gov/edocs_public/attachmatch/FCC-02-146A1.pdf

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subject to appropriation, only (i) to reimburse wireless carriers for all of their costs incurred in complying with the applicable provisions of Federal Communications Commission wireless enhanced 9-1-1 service mandates, and (ii) to pay the reasonable and necessary costs of the Illinois Commerce Commission in exercising its rights, duties, powers, and functions under this Act. This reimbursement to wireless carriers may include, but need not be limited to, the cost of designing, upgrading, purchasing, leasing, programming, installing, testing, and maintaining necessary data, hardware, and software and associated operating and administrative costs and overhead.

No diversion of funds from the Wireless Carrier Reimbursement Fund Allowable cost recovery

Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute.

74 (b) To recover costs from the Wireless Carrier Reimbursement Fund, the wireless carrier shall submit sworn invoices to the Illinois Commerce Commission.

50 ILCS 750/45 Invoices submitted National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute.

No perceived issues; the priority for wireless cost recovery should be established.

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75 (d) A wireless carrier may not receive payment from the Wireless Carrier Reimbursement Fund for its costs of providing wireless enhanced 9-1-1 services in an area when a unit of local government or emergency telephone system board provides wireless 9-1-1 services in that area and was imposing and collecting a wireless carrier surcharge prior to July 1, 1998.

50 ILCS 750/45 No reimbursement from fund if wireless service not established prior to 1998

No federal guidance No perceived issues

76 (e) The Illinois Commerce Commission shall maintain detailed records of all receipts and disbursements and shall provide an annual accounting of all receipts and disbursements to the Auditor General.

50 ILCS 750/45 ICC responsible for reviewing receipts

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute.

No perceived issues

77 (f) The Illinois Commerce Commission must annually review the balance in the Wireless Carrier Reimbursement Fund as of June 30 of each year and shall direct the Comptroller to transfer into the Statewide 9-1-1 Fund for distribution in accordance with subsection (b) of Section 30 of this Act any amount in excess of

50 ILCS 750/45 ICC responsible for reviewing fund balance

No federal guidance No perceived issues

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outstanding invoices as of June 30 of each year.

78 Sec. 50. Fund audits. The Auditor General shall conduct as a part of its bi-annual audit, an audit of the Statewide 9-1-1 Fund and the Wireless Carrier Reimbursement Fund for compliance with the requirements of this Act. The audit shall include, but not be limited to, the following determinations: (1) Whether detailed records of all receipts and disbursements from the Statewide 9-1-1 Fund and the Wireless Carrier Reimbursement Fund are being maintained. (2) Whether administrative costs charged to the funds are adequately documented and are reasonable. (3) Whether the procedures for making disbursements and grants and providing reimbursements in accordance with the Act are adequate. (4) The status of the implementation of statewide 9-1-1 service and Next Generation 9-1-1 service in Illinois.

50 ILCS 750/50 Fund audit required; compliance assessment; adequacy of administrative funds and status of 9-1-1 and NG9-1-1

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR5: The statutory environment prohibits the use of 9-1-1 funds for purposes other than those defined in the state’s 9-1-1 statute.

No perceived issues

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79 Sec. 55. Public disclosure … the Illinois Commerce Commission, the Department of State Police, governmental agencies, and individuals with access to that information shall take appropriate steps to prevent public disclosure of this information. Information and data supporting the amount and distribution of surcharge moneys collected and remitted by an individual wireless carrier shall be deemed exempt information for purposes of the Freedom of Information Act and shall not be publicly disclosed. The gross amount paid by all carriers shall not be deemed exempt and may be publicly disclosed.

50 ILCS 750/55 Competitive nature of industry National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR25: The statutory environment defines confidentiality and disclosure of 9-1-1 records. National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC4: The state has a procedure that ensures confidentiality of information to the extent permitted and/or required by law.

No perceived issues

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80 Sec. 60. Interconnected VoIP providers. Interconnected VoIP providers in Illinois shall be subject in a competitively neutral manner to the same provisions of this Act as are provided for telecommunications carriers. Interconnected VoIP services shall not be considered an intrastate telecommunications service for the purposes of this Act in a manner inconsistent with federal law or Federal Communications Commission regulation.

50 ILCS 750/60 VoIP same as telecommunications carriers Interconnected VoIP not considered intrastate

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR25: The statutory environment defines confidentiality and disclosure of 9-1-1 records. National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC4: The state has a procedure that ensures confidentiality of information to the extent permitted and/or required by law.

No perceived issues

81 Transfer of rights, functions, powers, duties, and property to Department of State Police; rules and standards; savings provisions

50 ILCS 750/75 Transfer of authority to State Police

No federal guidance No perceived issues

82 (d) The Department is authorized to enter into an intergovernmental agreement with the Commission for the purpose of having the Commission assist the Department and the Statewide 9-1-1 Administrator in carrying out their duties and functions under this Act.

50 ILCS 750/75 IGAs allowed National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR7: The statutory environment provides for interlocal cooperation.

No perceived issues

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83 Sec. 80. Continuation of Act; validation. (a) The General Assembly finds and declares that this amendatory Act of the 100th General Assembly manifests the intention of the General Assembly to extend the repeal of this Act and have this Act continue in effect until December 31, 2020. (b) This Section shall be deemed to have been in continuous effect since July 1, 2017 and it shall continue to be in effect henceforward until it is otherwise lawfully repealed. All previously enacted amendments to this Act taking effect on or after July 1, 2017, are hereby validated. All actions taken in reliance on or under this Act by the Department of State Police or any other person or entity are hereby validated. (c) In order to ensure the continuing effectiveness of this Act, it is set forth in full and reenacted by this amendatory Act of the 100th General Assembly. Striking and underscoring are used only to show changes being made to the base text.

50 ILCS 750/80 Legislative housekeeping No federal guidance No perceived issues

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This reenactment is intended as a continuation of this Act. It is not intended to supersede any amendment to this Act that is enacted by the 100th General Assembly.

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Appendix E – ICC Rules Review and Assessment

A review of ICC rules was conducted. Although some work has been done to update rules for new and emerging technologies, additional revisions are needed to accommodate NG9-1-1 terms, components, and elements, as well as an alignment with definitions and service descriptions in new legislation. Many definitions for NG9-1-1 elements are not included in current rules. Three examples from the NENA Glossary are: • Service Boundary: A polygon in a GIS system, SIF, ECRF or other ESInet element that indicates the

area a particular agency or element serves. • Service Composition: Used to bring together multiple services to satisfy more complex or higher-level

needs. • Service Mapping: The element of a Lost, calculated by an ECRF to indicate the PSAP or destination a

call should be routed or transferred to.

A complete review of the NENA Glossary definitions related to NG9-1-1 should be conducted and the rules updated accordingly. The ICC and the Department should conduct a thorough “sync up” of these elements as soon as is practical. The tables that follow will help to provide direction and recommendations the ICC should consider.

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TITLE 83: PUBLIC UTILITIES CHAPTER I: ILLINOIS COMMERCE COMMISSION

SUBCHAPTER f: TELEPHONE UTILITIES PART 725 STANDARDS OF SERVICE APPLICABLE TO 9-1-1 EMERGENCY SYSTEMS57

Current ICC Rules Text Recommendation(s)

SUBPART A: GENERAL PROVISIONS

Section 725.100 Application of Part

1 This Part shall apply to all 9-1-1 system providers and telecommunications carriers in the State of Illinois except to the extent of any exemptions conferred by law. This Part does not apply to a cellular or other mobile communication carrier as defined in Section 10 of the Wireless Emergency Telephone Safety Act [50 ILCS 751/10].

Consider explicit language that it applies to any provider of a service that can access 9-1-1.

(Source: Amended at 40 Ill. Reg. 8170, effective May 25, 2016)

Section 725.101 Definitions

2 In the interpretation of this Part, the following definitions shall be used.

3 "9-1-1 authority" − The ETSB, Joint ETSB or qualified governmental entity that provides for the management and operation of a 9-1-1 system within the scope of those duties and powers as are prescribed by the Emergency Telephone System Act (ETSA) [50 ILCS 750].

Add State 9-1-1 Administrator.

57 http://www.ilga.gov/commission/jcar/admincode/083/08300725sections.html

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Current ICC Rules Text Recommendation(s)

4 "9-1-1 network" – The network used for the delivery of 9-1-1 emergency calls over dedicated and redundant facilities, as required by this Part, to a PSAP or backup PSAP that meets the applicable grade of service.

Consider modification for NG9-1-1 to add “The network and associated services used for….”

5 "9-1-1 system" − The geographic area that has been granted an order of authority by the Administrator to use "9-1-1" as the primary emergency telephone number.

Retain

6 "9-1-1 system provider" − Any person, corporation, limited liability company, partnership, sole proprietorship, or entity of any description that acts as a 9-1-1 system provider within the meaning of Section 2 of the ETSA by contracting to provide 9-1-1 network and database services and who has been certified by the Commission pursuant to Section 13-900 of the Public Utilities Act [220 ILCS 5/13-900].

Will ICC be certifying all NG9-1-1 providers?

7 "9-1-1 telecommunications network" or "9-1-1 traditional legacy service" − An arrangement of channels, such as loops, trunks, and associated switching facilities to exchange voice and data.

Retain until full transition has been completed.

8 "Access line" − The connecting facility between a customer's premises network interface device and the local exchange carrier's facility that provides access to the switching network for local exchange and interexchange telecommunications service.

May need to consider adding a definition for ACCESS LINE, ACCESS POINT or ACCESS PROVIDER. From NENA: Access Line: The connection between a customer premises network interface and the Local Exchange Carrier that provides access to the

170

Current ICC Rules Text Recommendation(s)

Public Switched Telephone Network (PSTN). Access Provider: An access provider is any organization that arranges for an individual or an organization to have access to the Internet.

9 "Act" or "ETSA" – The Emergency Telephone System Act [50 ILCS 750]. Retain

10 "Administrator" – The Statewide 9-1-1 Administrator. Retain

11 "Aggregation point" – A point at which network monitoring data for a 9-1-1 system is collected and routed to a network operation center (NOC) or other location for monitoring and analyzing network status and performance.

Retain

12 "Automatic alarm" or "automatic alerting device" − Any device that will access the 9-1-1 system for emergency services upon activation. [50 ILCS 750/2.14]

Retain

13 "Automatic Location Identification" or "ALI" − In an E9-1-1 system, the automatic display at the PSAP of the caller's telephone number, the address/location of the telephone and supplementary emergency services information.

Retain Consider adding italicized text …the address/location of the telephone and supplementary location or emergency services information.

171

Current ICC Rules Text Recommendation(s)

14 "Automatic Number Identification" or "ANI" − The automatic display of the 9-1-1 calling party's number on the PSAP monitor.

Retain

15 "Backup PSAP" − A public safety answering point that serves as an alternate to the PSAP for enhanced systems and 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.

Retain

16 "Busy day" – A consecutive 24 hour period during which the greatest volume of traffic is handled in the central office.

Retain

17 "Busy hour" − The two consecutive half-hours each day during which the greatest volume of traffic is handled in the central office.

Retain

18 "Busy tone" − An audible signal indicating a call cannot be completed because the called access line is busy. The tone is applied 60 times per minute.

Retain

19 "Central office" − The site where switching equipment is located. A local central office, also called an end office, is the switching office where individual subscriber's access lines appear. It houses the equipment that receives calls transmitted on the local loop and routes the call over the switched network either directly to the person called, if the call is placed to a location served by the same local central office, or to another central office, if the call is placed to a customer served by a different central office.

Retain

20 "Circuit" – The physical connection (or path) of channels, conductors, and equipment between two given points through which an electronic or optical signal may be established.

Retain

21 "Commission" − The Illinois Commerce Commission. Retain

22 "Customer premises equipment" or "CPE" − Communications or terminal equipment located in the customer's facilities/terminal equipment at a PSAP.

Retain

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Current ICC Rules Text Recommendation(s)

23 "Default routing" − A feature that allows emergency calls to be routed to a designated default PSAP if the incoming emergency call cannot be selectively routed due to ANI failure, garbled digits, or other causes that prevent selective routing.

Retain, but update with NG9-1-1 terminology such as gateway or routing terms.

24 "Department" – The Department of State Police. Retain

25 "Diverse routing" – The practice of routing circuits along different physical or electrical paths in order to prevent total loss of 9-1-1 service in the event of a facility or hardware failure.

Retain

26 "E9-1-1 selective router" − A telecommunications carrier switching office or stand alone selective routing switch equipped with enhanced 9-1-1 service capabilities. This switch serves as an E9-1-1 selective router for emergency calls from other local offices in the 9-1-1 service area.

Retain until selective routers are no longer part of the network; selective router will transition to NGCS or IP selective router (transitional) until geospatial call routing.

27 "Emergency call" − Any type of request for emergency assistance through a 9-1-1 network, not limited to voice. This may include a session established by signaling with two-way real-time media, and involves a human making a request for help.

Retain

28 "Emergency service number" or "ESN" − Sometimes known as emergency service zone (ESZ). An ESN is a three to five digit number representing a unique combination of public safety agencies (police, fire and emergency medical service) designated to serve a specific range of addresses within a particular geographical area or ESZ. The term ESZ refers to the geographic area itself and is generally used only during the ESN definition process to label specific areas. The ESN facilitates the selective routing of calls to appropriate PSAPs in a traditional legacy 9-1-1 system.

Retain In NG9-1-1, once geospatial routing and definitions are implemented this will need to morph.

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Current ICC Rules Text Recommendation(s)

29 "Emergency Telephone System Board" or "ETSB" − A board appointed by the corporate authorities of any county or municipality that provides for the management and operation of a 9-1-1 system within the scope of those duties and powers prescribed by ETSA. The corporate authorities shall provide for the manner of appointment, provided that members of the board meet the requirements of the statute.

Retain

30 "English Language Translation" or "ELT" − A database table that provides the names of the public safety agencies (or services) associated with an ESN/ESZ number that is displayed on the ALI screen at the PSAP.

Consider making term consistent with the definition in Administrative Rules. From NENA: ELT (English Language Translation): An ELT alphanumeric description of the primary Law Enforcement, Fire and Emergency Medical Service agencies associated with a given Emergency Services Zone/Number. The ELT includes the name of the first-responder agency, and may include its station number (for dispatch purposes) and telephone number.

31 "Enhanced 9-1-1" or "E9-1-1" − An emergency telephone system that includes dedicated network, selective routing, database, ALI, ANI, selective transfer, fixed transfer, and a call back number.

Retain

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Current ICC Rules Text Recommendation(s)

32 "Error ratio" − The percentage of database records that are not Master Street Address Guide valid for a specific 9-1-1 traditional legacy service system.

Retain until full transition to NG9-1-1 is complete. Consider change to define an error ratio appropriate for geospatial data used in NG9-1-1 call processing is same as MSAG error ratio (98%) or add specific geospatial data error rate that is appropriate.

33 "Exchange" − A unit established by a telecommunications carrier and approved by the Commission for the administration of telecommunications service in a specified geographical area. It may consist of one or more central offices together with associated plant used in furnishing telecommunications services in that area. Exchanges are identified on exchange boundary maps on file with the Commission.

Retain

34 "Forced disconnect" − A feature that allows the PSAP to release a telephone connection, even though the calling party has not yet disconnected, to avoid caller jamming of the incoming trunks.

Retain

35 "Geographical Information System" or "GIS" − A system for capturing, storing, displaying, analyzing and managing data and associated attributes that are spatially referenced.

Retain

36 "Geospatial Data" − Information that accurately refers to a precise location on the earth's surface using latitude, longitude, elevation and other data that identify the coordinate system used.

Retain

37 "Grade of Service" – P.01 for Basic 9-1-1 or Enhanced 9-1-1 services or NENA i3 Solution standard for NG9-1-1 services.

Retain

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Current ICC Rules Text Recommendation(s)

38 "Interconnected VoIP provider" – Has the meaning given to that term under Section 13-235 of the Public Utilities Act.

Retain

39 "IP" – Internet Protocol. Retain

40 "Joint Emergency Telephone System Board" or "Joint ETSB" – A board established by intergovernmental agreement of two or more municipalities or counties or a combination thereof to provide for the management and operation of a 9-1-1 system.

Retain

41 "Legacy network gateway" – A signaling and media interconnection point between callers in legacy wireline/wireless originating networks and the i3 architecture, so that i3 PSAPs are able to receive emergency calls from legacy networks.

Retain

42 "Local loop" − A channel between a customer's network interface and its serving central office. The most common form of loop, a pair of wires, is also called a line.

Retain

43 "Master Street Address Guide" or "MSAG" − The computerized geographical file that either consists of all street and address data or its functional equivalent (i.e. geospatial data) within the 9-1-1 system area. This database is the key to the selective routing capability of E9-1-1 systems. It matches an originating caller to a specific answering point based on the address data. The MSAG will require updating after the initial file is created.

Retain

44 "National Emergency Number Association" or "NENA" − The international not-for-profit organization whose purpose is to lead, assist and provide for the development, availability, implementation and enhancement of a universal emergency telephone number or system common to all jurisdictions through research, planning, publications, training and education.

Retain

45 "Network connection" − A voice grade communication channel directly between a subscriber and a telecommunications carrier's public switched network, without the intervention of any other telecommunications carrier's switched network, that would be required to carry the subscriber's inter-premises traffic. The

Retain

176

Current ICC Rules Text Recommendation(s)

connection either is capable of providing access through the public switched network to a 9-1-1 system, if one exists; or if no system exists at the time a surcharge is imposed under Section 15.3 of ETSA, would be capable of providing access through the public switched network to the local 9-1-1 system if one existed. [50 ILCS 750/2]

46 "Network diagram" − A schematic flow chart that shows the actual network pieces and flow of activities in a picture.

Consider change to the network diagram that shows the P.01 and trunking, system components and interconnection points, routing and backup configuration for the 9-1-1 system; both physical and logical.

47 "Next generation 9-1-1 service" or "NG9-1-1" − A system comprised of managed IP-based networks, gateways, functional elements and databases that augment or replicate present day E9-1-1 features and functions and provide new capabilities. NG9-1-1 is designed to provide access to emergency services from all sources, and to provide multimedia data capabilities for PSAPs and other emergency service organizations.

Retain. Closely aligned with NENA definition as follows (differences are in italics): NG9-1-1 is an Internet Protocol (IP)-based system comprised of managed Emergency Services IP networks (ESInets), functional elements (applications), and databases that replicate

177

Current ICC Rules Text Recommendation(s)

traditional E9-1-1 features and functions and provides additional capabilities. NG9-1-1 is designed to provide access to emergency services from all connected communications sources, and provide multimedia data capabilities for Public Safety Answering Points (PSAPs) and other emergency service organizations.

48 "On-site database" − A copy of the database that resides with the local 9-1-1 authority. Retain

49 "Operator services" − Any of a variety of telephone services that need the assistance of an operator or an automated "operator" (i.e., using interactive voice response technology and speech recognition). These services include collect calls, third party billed calls, and person-to-person calls.

Retain

50 "Originating Service Provider" or "OSP" − A communications provider that allows its users or subscribers to originate 9-1-1 voice or non-voice messages from the public to the 9-1-1 authority.

Retain

51 "Overflow" − A call or position used when a call is blocked or rerouted due to excessive traffic. Consider change to “a condition under which a call is rerouted or redirected to a predetermined position or facility due to blockage or excessive traffic.”

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Current ICC Rules Text Recommendation(s)

52 "P.01" – The probability (P), expressed as a decimal fraction, of an emergency call being blocked. P.01 is the grade of service reflecting the probability that one call out of 100 during the average busy hour of the average busy day will be blocked, or the number of 9-1-1 circuits or facilities from the 9-1-1 system provider's routing equipment to the primary PSAP or PSAPs that are sufficient to complete 99% of all requests for emergency service during the average busy hour of the average busy day.

Retain

53 "Primary point of contact" or "9-1-1 contact person" − The individual designated by the 9-1-1 authority as the contact point for the participating telecommunications carriers and 9-1-1 system providers.

Retain

54 "Private Branch Exchange" or "PBX" − A private telephone system and associated equipment located on the user's property that provides communications between internal stations and external networks.

Consider change to MLTS as found in the NENA Glossary or adding MLTS to definitions. From NENA: MLTS: A system comprised of common control unit(s), telephone sets, control hardware and software and adjunct systems used to support the capabilities outlined herein. This includes network and premises based systems. E.g., Centrex, VoIP, as well as PBX, Hybrid, and Key Telephone Systems (as classified by the FCC under Part 68 Requirements) and

179

Current ICC Rules Text Recommendation(s)

includes systems owned or leased by governmental agencies and non-profit entities, as well as for profit businesses.

55 "Public safety agency" − A functional division of a public agency that provides police, firefighting, medical or other emergency services.

Retain

56 "Public Safety Answering Point" or "PSAP" − The initial answering location of an emergency call. Retain

57 "Public Utilities Act" – 220 ILCS 5. Retain

58 "Rate center" − A geographically specified area used for determining mileage and/or usage dependent rates in the public switched network.

Retain

"Selective routing" − A system that automatically routes calls to predetermined PSAPs, based on the location of the calling telephone number.

Retain until full NG9-1-1 transition is complete and if selective routers are no longer part of the 9-1-1 network. Term may morph several times.

180

Current ICC Rules Text Recommendation(s)

59 "Service address" − The location of the primary use of the network connection or connections. Retain or change to align with NENA definition. From NENA: Service Address: The physical location of a subscriber access line. Service Address is the recommended address for 9-1-1 use. (May be different from the listed address or billing address)

60 "Split exchange" − An exchange shared with more than one 9-1-1 system. Retain

61 "Surcharge" − A monthly surcharge amount imposed, pursuant to Section 20 of the Act, on all customers of telecommunication carriers, wireless carriers and interconnected VoIP providers for the purpose of installing and maintaining an Enhanced 9-1-1 or NG9-1-1 system, with the exception of a municipality with a population of 500,000 or greater.

Retain

181

Current ICC Rules Text Recommendation(s)

62 "System" − The communications equipment required to produce a response by the appropriate emergency public safety agency as a result of an emergency call being placed to 9-1-1. [50 ILCS 750/2]

Consider change to “the communications equipment, databases, and related software applications required to transport a 9-1-1 call through network(s) and equipment for the purpose of producing sufficient data for a response by the appropriate emergency public safety agency or other provider of emergency services.”

63 "Telecommunications carrier" − Shall have the same meaning as specified in Section 13-202 of the Public Utilities Act, including those carriers acting as resellers of telecommunications services. For the purpose of 9-1-1 service, this definition shall include telephone systems operating as mutual concerns. A telecommunications carrier under the Public Utilities Act may provide competitive or noncompetitive local exchange telecommunications services or any combination of the two as defined in Section 13-204 of the Public Utilities Act.

Retain

64 "Telecommunications service" − Shall have the same meaning as specified in Section 13-203 of the Public Utilities Act.

Retain

65 "Terminal equipment" − Telephone station apparatus. Retain; however, “Telephone station apparatus” is not defined.

182

Current ICC Rules Text Recommendation(s)

66 "Transfer" − A feature that allows the PSAP telecommunicator to transfer emergency calls to a specific location or secondary PSAP.

Consider change to not use the word being defined in the definition, such as: "A feature that allows the PSAP telecommunicator to redirect emergency calls to a specific location or secondary PSAP.”

67 "Trunk" − A transmission path between switching units, switching centers, and/or toll centers. Retain; definition may require updating for NG9-1-1.

68 "Virtual Answering Point" or "VAP" – A temporary or non-permanent location that: is capable of receiving an emergency call; contains a fully functional worksite that is not bound to a specific location but rather is portable and scalable connecting emergency call takers or dispatchers to the work process; and is capable of completing the call dispatching process.

Retain

69 "Virtual PSAP" – A fully functional worksite that is not bound to a specific location but is portable and scalable, connecting employees to the work process in the most advantageous setting, rather than employees having to come to a centralized work location to connect to the work process.

Retain

(Source: Amended at 40 Ill. Reg. 8170, effective May 25, 2016)

SUBPART B: AUTHORIZATION TO OPERATE AS A 9-1-1 SYSTEM (REPEALED)

Section 725.200 General Requirements (Repealed)

Section 725.205 Tentative, Final or Modified Plans (Repealed)

183

Current ICC Rules Text Recommendation(s)

Section 725.210 Order of Authority (Repealed)

Section 725.215 Records and Reports (Repealed)

Section 725.220 Testing for Compliance with Technical and Operational Standards (Repealed)

SUBPART C: MANAGEMENT

Section 725.300 Management Systems (Repealed)

Section 725.305 Commission Liaison (Repealed)

Section 725.310 ETSB, Joint ETSB and Qualified Governmental Entities (Repealed)

SUBPART D: STANDARDS OF SERVICE

Section 725.400 9-1-1 Authority (Repealed)

(Source: Repealed at 40 Ill. Reg. 8170, effective May 25, 2016)

Section 725.402 Technical Review of 9-1-1 Plans

70 a) Upon receipt of notice from the Department that a consolidation plan has been filed pursuant to 83 Ill. Adm. Code 1324 or an initial or modified plan has been filed pursuant to 83 Ill. Adm. Code 1325, Commission Staff will begin an informal review of each plan to ensure its technical compliance with Sections 725.405, 725.410 and 725.412. Notice will also be provided to the 9-1-1 system providers and carriers by the Department pursuant to 83 Ill. Adm. Code 1324.200(f) and 1325.210(c).

Retain

184

Current ICC Rules Text Recommendation(s)

71 b) Formal Review For each consolidation plan, initial plan and modified plan that involves the use of a 9-1-1 system provider that already provides service to a 9-1-1 Authority under a plan previously approved by the Commission or the Department, the following process shall apply:

Retain

72 1) Within 16 days after the notice date that a consolidation plan, initial plan or modified plan is filed pursuant to subsection (a), any interested party may file a request for a formal review of the plan by the Commission.

Retain

73 2) If, after its informal review of any consolidation plan, initial plan or modified plan, and no later than 20 days from the date of receipt from the Department, Commission Staff has either identified a matter of technical concern or received a request for a formal review pursuant to this subsection (b), Commission Staff will notify the Department that the Commission will initiate a docketed proceeding to formally review the plan and request that the Department seek an extension with the filing entity or deny the plan pending the outcome of the Commission's formal technical review.

Retain

74 3) Once an order resolving the matter of technical concern or unresolved dispute has been rendered by the Commission, a copy will be provided to the Department.

Retain

75 4) If the Commission Staff does not provide the Department with notification as described in subsection (b)(2) within 20 days after receipt of the plan, the Commission will not undertake any separate proceedings regarding the plan without first conferring with the Department.

Retain

76 c) Informal Review For each consolidation plan, initial plan or modified plan that involves the use of a 9-1-1 System Provider that does not already provide service to a 9-1-1 Authority under a plan approved by the Commission or the Department (new 9-1-1 System Provider), the following process shall apply:

Retain

185

Current ICC Rules Text Recommendation(s)

77 1) Within 16 days after receipt of the plan, Commission Staff will notify the Department that the plan involves the use of a new 9-1-1 system provider and that Commission Staff will follow the review process prescribed by this subsection (c) and request that the Department seek an extension with the filing entity or deny the plan pending the outcome of the informal technical review by Commission Staff.

Retain

78 2) Within 16 days after the receipt of the plan, Commission Staff will establish an informal process, to last no more than 90 days from the date of the receipt of the plan, for review of the plan with input from interested parties, including review of the plan's provisions for transitioning from any existing 9-1-1 system provider to a new 9-1-1 system provider and proposed interconnection arrangements with impacted carriers.

Retain

79 3) If, at any time within 90 days after receipt of the plan, Commission Staff has completed its informal review and determined that there are no disputed issues regarding the plan, Commission Staff will immediately notify the Department of the completion of the informal technical review process under this subsection (c).

Retain

80 4) If, as a result of the informal technical review process, but no later than 90 days from the date of receipt of the plan, Commission Staff has either determined that there are issues regarding the plan that remain in dispute or received a request for a formal review, Commission Staff will notify the Department that the Commission will initiate a docketed proceeding to formally review the plan and request that the Department seek an extension with the filing entity or deny the plan pending the outcome of the Commission's formal technical review.

Retain

81 5) Once an order resolving any disputed issues has been rendered by the Commission, a copy will be provided to the Department.

Retain

82 6) If the Commission Staff has not provided the Department with the notification described in either subsection (c)(3) or (c)(4) within 90 days after receipt of the plan, the Commission will not undertake any separate proceedings regarding the plan without first conferring with the Department.

Retain

(Source: Added at 40 Ill. Reg. 8170, effective May 25, 2016)

186

Current ICC Rules Text Recommendation(s)

Section 725.405 9-1-1 System Provider

83 A 9-1-1 System Provider: a) Shall be certified under Section 13-900 of the Public Utilities Act as a 9-1-1 system provider prior to entering into any contract with a 9-1-1 authority to provide 9-1-1 services;

Add “… with a 9-1-1 authority and the state for to provide ...”

84 b) Shall file tariffs under Sections 13-900.1 and 9-102 of the Public Utilities Act for 9-1-1 services prior to offering such services;

Retain

85 c) Shall enter into a service contract with each 9-1-1 authority for which it plans to provide 9-1-1 database, call routing and other 9-1-1 duties and services associated with the 9-1-1 system that clearly delineates the responsibilities of the 9-1-1 system provider and 9-1-1 authority;

Add “… with each 9-1-1 authority and the state for which it …”

86 d) Shall assume the lead role in coordinating the implementation of the 9-1-1 project. The 9-1-1 system provider is responsible for the initial implementation and mutually agreed upon changes/modifications, project timeline, milestone progress report/conference calls with Commission 9-1-1 Program Staff and all involved parties. If there are multiple 9-1-1 system providers, the 9-1-1 authority shall specify the role of each provider pursuant to Section 1325.400(f);

Retain

87 e) Shall comply with any provisions of all applicable federal or State laws regarding the provisioning of 9-1-1 services regarding wireline, wireless and VoIP or any other medium;

Retain

88 f) Shall comply with back-up power requirements for 9-1-1 equipment and facilities as specified in 83 Ill. Adm. Code 730.325 or 737.410;

Retain

89 g) Shall comply with physical security requirements for its facilities as specified in 83 Ill. Adm. Code 785.35; Retain

187

Current ICC Rules Text Recommendation(s)

90 h) Shall provision "9-1-1 Service" in one of the following types: 1) Basic 9-1-1 service is an emergency telephone system that automatically connects 9-1-1 callers to a designated answering point through either dedicated direct trunking and/or tandem trunking from the central office to the PSAP. Basic 9-1-1 does not typically support ANI and ALI. The features associated with basic service shall be according to the following format types:

Modify for NG9-1-1 when comprehensive implementation plan is completed.

91 A) Type #1 – This is the most basic configuration available, and provides: i) no per-call charge; ii) loop-type ringdown signaling toward PSAP; iii) ringback tone to caller; and iv) transmission path for communication between the caller and the PSAP;

Modify for NG9-1-1 when comprehensive implementation plan is completed.

92 B) Type #2 – This configuration provides all the features of the Type #1 circuit with the following options: i) called party hold; ii) forced disconnect; iii) idle circuit tone application; and iv) originating switchhook status indication contingent on the installation of appropriate terminal equipment at the PSAP;

Modify for NG9-1-1 when comprehensive implementation plan is completed.

93 C) Type #3 – This configuration provides all the features of the Type #1 and Type #2 circuits with the addition of ringback of the calling party on a held line;

Modify for NG9-1-1 when comprehensive implementation plan is completed.

94 D) Type #4 – This configuration provides for optional features beyond those described in the configuration of Type #2 or Type #3. This type of Basic 9-1-1 also requires trunks capable of carrying ANI.

Modify for NG9-1-1 when comprehensive implementation plan is completed.

188

Current ICC Rules Text Recommendation(s)

95 2) E9-1-1 service is a system that includes a dedicated network, selective routing, and a database that interfaces with a PSAP CPE capable of receiving and providing ANI and ALI. It can be provisioned through either a 9-1-1 telecommunications network that is commonly referred to as "9-1-1 traditional legacy service" or a 9-1-1 IP network which is commonly referred to as "NG9-1-1 service":

Retain

96 A) 9-1-1 traditional legacy service: Provides the capability to serve several PSAPs existing within the 9-1-1 service area with tandem trunking through the E9-1-1 selective router. The main features of E9-1-1 service is the capability of the E9-1-1 selective router to selectively route an emergency call originating from any station in the 9-1-1 service area to the correct PSAP. The features associated with tandem trunking in an E9-1-1 system may include the following: i) Selective routing; ii) Default routing; iii) Alternate routing; iv) Transfer capabilities; v) Forced disconnect; vi) No per call charge; vii) ANI; and viii) ALI.

Retain until full transition is complete.

189

Current ICC Rules Text Recommendation(s)

97 B) NG9-1-1 service provides the capability to serve PSAPs through an IP network. The main feature of NG9-1-1 service is the capability to route an emergency call originating from multiple types of technology capable of calling 9-1-1. The capabilities and features associated with NG9-1-1 may include but are not limited to the following: i) Legacy network gateway; ii) Geospatial routing; iii) Default routing; iv) Alternate routing; v) Transfer capabilities; vi) ANI; vii) ALI; viii) Transmit data and/or text and/or video with the emergency call when feasible and/or available; and ix) Emergency Services IP networks (ESInets).

Retain

98 C) Any combination of subsections (h)(2)(A) and (B). Retain

99 i) The 9-1-1 system provider shall meet the following technical requirements for the provisioning of 9-1-1 service: 1) Utilizing mutually acceptable and agreed upon standards for database record exchange as prescribed, at a minimum, by the National Emergency Number Association in "NENA, Standard Data Formats For ALI Data Exchange, MSAG & GIS Mapping" (NENA 02-010, v9, 3/28/2011; this incorporation includes no later amendments or editions).

Need to keep current with NENA standards when specifically identified; there may also be subsequent applicable standards.

100 2) Obtaining, maintaining and updating end user subscriber information provided by all participating OSPs in order to maintain the 9-1-1 database to meet the requirements set forth in ETSA Section 15.4(d).

Retain

101 3) Creating, maintaining and updating the MSAG and database, GIS database, or functional equivalent in conjunction with the 9-1-1 authority and all OSPs.

Retain

102 4) Updating the ALI database on a daily basis during normal business days. Retain

190

Current ICC Rules Text Recommendation(s)

103 5) Providing notification of errors to the appropriate entities within 24 hours for corrective action. Retain

104 6) Providing the error ratio to the 9-1-1 authority no later than December 31 of each year. 9-1-1 authorities may request the percentage on a more frequent basis, but not more than once a month.

Retain

105 7) Providing a network diagram to the 9-1-1 authority, annually within the 4th quarter of each year, no later than December 31. Additionally, updated diagrams must be provided to the 9-1-1 authority when a modification is required to be filed with the Commission.

Retain

106 8) Coordinating the development and the maintenance of the 9-1-1 database with all participating OSPs and the 9-1-1 authority and ensure that all required information for routing tables, i.e., NPA/NXX, ESN, default ESN, PANIs and any other items that may become necessary for the functionality of maintaining an accurate database and/or routing tables, is obtained.

Retain

107 9) Coordinating the installation of all network components with all participating OSPs and/or third party provider who may connect its network and transport 9-1-1 traffic to the appropriate 9-1-1 system provider on behalf of an OSP. In these cases, the OSP, the 9-1-1 system provider, and the third party telecommunications carrier shall work cooperatively with the 9-1-1 authority to ensure that appropriate default routes are chosen and proper network congestion control measures are maintained. The network design must adhere to the default routing and acceptable engineering practices as specified in subsections (h)(11) and (22).

Retain

108 10) Routing all emergency calls from any OSP without discrimination where technically feasible. Retain

191

Current ICC Rules Text Recommendation(s)

109 11) Provisioning all 9-1-1 facilities over dedicated redundant facilities. This should be considered to be the standard method of providing all incoming 9-1-1 facilities and, where possible, employ diverse routing. 9-1-1 circuits and facilities shall be sufficient to complete 99% of all emergency calls during the average busy hour of the average busy day. In all cases, the 9-1-1 network shall be provisioned to handle a minimum of two circuits and/or simultaneous calls, and shall use dedicated, diverse and/or redundant equipment, where available, in order to increase the survivability of the 9-1-1 network. Additionally the Commission 9-1-1 Program Staff and or 9-1-1 authority may on an annual basis or in the event of a problem request traffic studies be performed or other documentation be provided to verify that the standard is being met.

Retain

110 12) Provisioning 9-1-1 facilities for one way incoming only service to the PSAP. Origination of outbound dialing on 9-1-1 circuits without a caller or active 9-1-1 call on the circuit is prohibited.

Retain

111 13) Provisioning the transmission grade of service for 9-1-1 facilities using inter-exchange facilities equivalent to those specified in 83 Ill. Adm. Code 730.520 or 737.440.

Retain

112 14) Provisioning the transmission grade of service for the intra-exchange loop portion of any 9-1-1 facilities equivalent to those specified in 83 Ill. Adm. Code 730.525 or 737.630.

Retain

113 15) Notifying the 9-1-1 authority a minimum of 48 hours prior to performing any planned activities that could adversely affect 9-1-1 service.

Retain

114 16) Adopting practices to minimize the possibility of service disruption on all facilities associated with 9-1-1 service to a PSAP prior to 9-1-1 going on line.

Retain

115 17) Maintaining a contact number for notifying the appropriate 9-1-1 authority in the event of an outage or failure of a 9-1-1 system.

Retain

192

Current ICC Rules Text Recommendation(s)

116 18) Notifying a primary point of contact within a 9-1-1 system within 15 minutes after detecting a confirmed outage within the system and advising the primary point of contact as to the magnitude of the outage once fully known. In addition, the 9-1-1 system provider must notify the Commission's 24 hour emergency number (217-558-6166) pursuant to 83 Ill. Adm. Code 730.550 or 737.430.

Modify by adding “… within a 9-1-1 system and the state 9-1-1 administrator within 15 minutes”

117 19) Notifying a primary point of contact of a 9-1-1 system and the Commission's 24 hour emergency number (217-558-6166) pursuant to 83 Ill. Adm. Code 730.550 or 737.734 within 30 minutes after the confirmed restoration of 9-1-1 services.

Modify by adding “… contact of a 9-1-1 system, and the state 9-1-1 administrator, and the Commission …”

118 20) Delivering 9-1-1 service elements for the provisioning and ongoing maintenance of the 9-1-1 systems as follows: A) Provide database coordination with all participating OSPs when applicable.

Retain

119 B) Provide network coordination with all participating OSPs when applicable. Retain

120 C) Provide maintenance and repair procedures, service and repair center contact information, a restoration plan and call trace procedures to the 9-1-1 authority.

Retain

121 21) Adopting practices and implementing procedures to reduce or minimize the conditions that cause default routed calls.

Retain

122 22) Default routing, at a minimum, by county. Where an exchange boundary/rate center crosses county boundaries, the 9-1-1 system provider may establish a single default with the approval of the 9-1-1 authority for those affected 9-1-1 systems.

Modify when all new configurations are complete and ETSB regions are known.

193

Current ICC Rules Text Recommendation(s)

123 23) Adopting practices to provide the appropriate services to Private Business Switch and Private Residential Switch subscribers for the purposes of complying with ETSA Sections 15.5 and 15.6 and 83 Ill. Adm. Code 1326.

Retain

124 24) Providing the 9-1-1 authority with the information, reports or other documents required, to enable the 9-1-1 authority to complete its annual filings to the Commission.

Retain

125 25) Cooperating with other 9-1-1 system providers to hand off split exchange subscribers to another 9-1-1 system provider in a mutually acceptable manner and in accordance with good engineering design and standards.

Retain

126 26) Cooperating with other 9-1-1 system providers in the installation of a new 9-1-1 system or migration of a system from another 9-1-1 system provider.

Retain

(Source: Amended at 40 Ill. Reg. 8170, effective May 25, 2016)

Section 725.410 Telecommunications Carriers

127 a) Each telecommunications carrier shall file tariffs under Section 13-900.1 of the Public Utilities Act for 9-1-1 telecommunications service to be applied to all services specific to 9-1-1 installations on the carrier's network side of the customer demarcation point.

Retain

128 b) Dedicated redundant facilities should be considered to be the standard method of providing all incoming 9-1-1 facilities and, when possible, employ diverse routing. 9-1-1 circuits and facilities shall be sufficient to complete 99% of all requests for emergency services during the average busy hour of the average busy day. In all cases, the 9-1-1 network shall be provisioned to handle a minimum of two circuits and/or simultaneous calls, and shall use dedicated, diverse and/or redundant equipment, when available, in order to increase the survivability of the 9-1-1 network. Additionally, the Commission 9-1-1 Program Staff and/or 9-1-1 authority may, on an annual basis or in the event of a problem, request traffic studies or other documentation to verify that the standard is being met.

Retain

194

Current ICC Rules Text Recommendation(s)

129 c) Coin-free dialing of the digits 9-1-1 shall be provided from all coin telephones within an exchange with 9-1-1 service.

Retain

130 d) The transmission grade of service on 9-1-1 facilities using inter-exchange facilities shall be at least equivalent to the transmission grade of service specified in 83 Ill. Adm. Code 730.520 or 737.440 dealing with interoffice transmission objectives.

Retain

131 e) The transmission grade of service for the intra-exchange loop portion of any 9-1-1 facilities shall be at least equivalent to the transmission grade of service specified in 83 Ill. Adm. Code 730.525 or 737.630 dealing with local loop transmission objectives.

Retain

132 f) When all 9-1-1 facilities are busy in the originating central office, the switching facility, when equipped to provide the function, shall route the caller to an announcement or busy tone. When an all trunks busy situation occurs in an intermediate switching facility, that switch shall, when equipped, route the caller to an appropriate backup or alternate answering location, announcement, or busy tone.

Retain

133 g) All telecommunications carriers shall arrange for each of their switching offices to accept the 9-1-1 code. Retain

134 h) Telecommunications carrier's personnel shall notify the 9-1-1 authority a minimum of 48 hours prior to performing any planned action that could adversely affect 9-1-1 service.

Consider adding “… shall notify the 9-1-1 authority and the state 9-1-1 Administrator a minimum of 48 hours prior to …”

135 i) Each telecommunications carrier shall adopt practices to minimize the possibility of service disruption on all facilities associated with 9-1-1 service to a 9-1-1 system. These practices will provide for facility guarding at all terminations with protective devices that will minimize accidental worker caused service interruption. These practices shall also contain procedures for physical identification of all 9-1-1 facilities with special warning tags and/or labels and identification of circuits in company records.

Retain

195

Current ICC Rules Text Recommendation(s)

136 j) Each telecommunications carrier shall deliver 9-1-1 service elements for the provisioning and ongoing maintenance of the 9-1-1 systems as follows: 1) Provide database downloads and updates to the appropriate 9-1-1 system provider for each 9-1-1 system in which it has subscribers.

Retain

137 2) Adhere to acceptable and agreed upon standards for database record exchange as prescribed, at a minimum, by NENA Standard Data Formats For ALI Data Exchange, MSAG & GIS.

Retain

138 3) Process error corrections within 2 business days after receipt of an error report from the 9-1-1 system provider and/or 9-1-1 authority.

Retain

139 4) Provision and connect its network to the appropriate 9-1-1 system provider. Nothing in this Section prohibits a telecommunications carrier from contracting with a third party provider who may connect its network to the appropriate 9-1-1 system provider for the transport of 9-1-1 traffic. The network design must adhere to the engineering practices and default routing requirements specified in Section 725.405(i)(11) and (22).

Retain

140 5) Not deliver emergency calls to operator services. Retain

141 6) Provide maintenance and repair procedures, service and repair center contact information, maintain a restoration plan and perform call trace procedures to the 9-1-1 authority.

Retain

142 7) Comply and arrange for default routing requirements with the 9-1-1 system provider and the 9-1-1 authority. Retain

143 8) Maintain a list of contact numbers for notifying the appropriate 9-1-1 system in the event of an outage or failure of a 9-1-1 system.

Consider modification to add “… the appropriate 9-1-1 system and the state 9-1-1 administrator in the event of an outage …”

196

Current ICC Rules Text Recommendation(s)

144 9) Notify a primary point of contact for the 9-1-1 authority within 15 minutes after a confirmed outage within the system and also advise the primary point of contact as to the magnitude of the outage. In addition, the telecommunications carrier must notify the Commission's 24 hour emergency outage number (217-558-6166) pursuant to 83 Ill. Adm. Code 730.550 or 737.430.

Consider modification to add “… for the 9-1-1 authority and the state 9-1-1 administrator within 15 minutes …”

145 10) Shall notify a primary point of contact with the 9-1-1 authority and the Commission's 24 hour emergency outage number (217-558-6166) pursuant to 83 Ill. Adm. Code 730.550 or 737.734 within 30 minutes after the confirmed restoration of 9-1-1 services.

Consider modification to add “… contact with the 9-1-1 authority, the state 9-1-1 administrator and the Commission's 24 hour emergency outage …”

146 11) Cooperate with 9-1-1 system providers to assist in terminating split exchange traffic between 9-1-1 systems.

Retain

147 12) Cooperate with 9-1-1 system providers in the installation of a new 9-1-1 system or migration of an existing 9-1-1 system to another 9-1-1 system provider.

Retain

148 k) Each telecommunications carrier and interconnected VoIP provider shall adopt practices and procedures to deliver emergency calls to the appropriate 9-1-1 system provider.

Retain

(Source: Amended at 40 Ill. Reg. 8170, effective May 25, 2016)

Section 725.412 Next Generation 9-1-1 System Provider

149 Each next generation 9-1-1 system provider shall: a) Provide redundant legacy network gateways so that the originating wireline, wireless and VoIP networks can deliver emergency calls in a manner that IP capable PSAPs can receive until such time that conversions of legacy networks for IP is no longer necessary.

Retain

197

Current ICC Rules Text Recommendation(s)

150 b) Provide redundant geographic locations for the legacy network gateways within the State of Illinois that are both technologically feasible and cost effective.

Retain

151 c) Provide network monitoring. Retain

152 d) A next generation 9-1-1 system provider that has deployed a 9-1-1 network prior to December 31, 2015 with a service offering that does not meet the requirements of this Section shall not be required to comply with this Section until the 9-1-1 system provider or a 9-1-1 authority requests to make a change to the network. The next generation 9-1-1 system provider shall not expand the current service until its service offering in both its existing and expanded service areas is provisioned to meet the requirements of this Section.

Although NG9-1-1 system provider is not specifically defined, NG9-1-1 system is. The italicized text is not clear and should be revisited. It may be that the State or the PSAP request a change in the network and then both the legacy and NG 9-1-1 system providers should be required to comply.

(Source: Added at 40 Ill. Reg. 8170, effective May 25, 2016)

Section 725.415 Public Safety Answering Point (Repealed)

SUBPART E: OPERATIONS

Section 725.500 Testing Procedures (Repealed)

Section 725.505 Call Handling Procedures (Repealed)

Section 725.510 Electronic Communication Devices (Repealed)

198

Current ICC Rules Text Recommendation(s)

Section 725.515 Physical Security (Repealed)

Section 725.520 9-1-1 Traditional Legacy Service Database These definitions should be retained only until such time as all legacy services are no longer in use.

153 a) 9-1-1 database queries will only be allowed by PSAPs for purposes of dispatching or responding to an emergency call or for database integrity verification as set forth in subsection (c).

Retain

154 b) Prior to an initial database integrity verification, the 9-1-1 authority shall obtain a court order detailing the information that is to be disclosed and the reason for disclosure.

Retain

155 c) The 9-1-1 database shall have the capability of allowing database verification queries, provided that the following procedures are adhered to: 1) The 9-1-1 authority shall be responsible for providing a level of security and confidentiality to the database that will prohibit random inquiries;

Retain

156 2) Direct access to 9-1-1 database information will be under strict control and, when technically feasible, a password will be assigned for access by authorized persons only;

Retain

157 3) Database verification queries shall be by subscriber number only and as necessary for purposes of database integrity. Queries in excess of 10 per 24-hour period will only be done with 2 or more days advance notice to the respective 9-1-1 system provider for scheduling purposes. Queries may be for the specific purpose of cross-checking information in the 9-1-1 database with other sources of information, including telephone and other directories, maps, municipal database listings, etc., and for verifying that database update information provided to the 9-1-1 system provider has indeed been posted and is correct. On-site 9-1-1 databases are exempt from 9-1-1 system provider advance notification requirements of this Section;

Retain

199

Current ICC Rules Text Recommendation(s)

158 4) Information retrieved will be used exclusively for the maintenance, update and verification of the 9-1-1 database except as otherwise specified in subsection (a). Any other use is expressly prohibited. The information is subject to strict non-disclosure agreements between the various OSPs, 9-1-1 system providers and 9-1-1 authority. All personnel associated in any way with the 9-1-1 authority and the 9-1-1 systems are bound by these agreements.

Retain

159 5) Trunks/facilities that are not used to transport 9-1-1 emergency calls into the PSAP are prohibited from being connected to the 9-1-1 CPE in any way to allow for queries of the 9-1-1 database.

Retain

160 6) Database queries for the purpose of database verification shall be limited to off-peak times. Retain

161 7) Database queries shall not be made if there is any known outage or impairment in the database system, including a database data link outage. In the event of an outage, the 9-1-1 system provider shall treat outage notification of the 9-1-1 authority regarding database query suspension as a priority. When practicable, this notification shall be made not later than 15 minutes after a confirmed incident that will cause database queries to be suspended.

Retain

162 d) Each telecommunication carrier shall provide updates to the appropriate 9-1-1 system provider for the 9-1-1 database on a daily basis or more frequently when technology supports it, Monday through Friday during business hours.

Retain

163 e) A 9-1-1 authority using an on-site database is restricted from making any changes to the 9-1-1 data that has been downloaded for its use. Only the 9-1-1 system provider has the authority to correct errors or provide updates to the database. The 9-1-1 authority must adhere to the proper error resolution procedures as specified in subsection (g)(l).

Retain

200

Current ICC Rules Text Recommendation(s)

164 f) 9-1-1 authorities, 9-1-1 system providers and telecommunications carriers shall utilize mutually acceptable and agreed upon standards as prescribed, at a minimum, by the NENA Standards for 9-1-1 databases. 1) Data Formats for ALI, MSAG and GIS (02-010, v9); 2) 9-1-1 Data Management (02-011, v7); and 3) Provisioning and Maintenance of MSAG Files to VDBs and EKDBS (02-013, v3).

Retain

165 g) It shall be the joint responsibility of the 9-1-1 authority, the 9-1-1 system provider and telecommunications carriers to ensure that the error ratio of each 9-1-1 system's database shall not, at any time, exceed 1%.

Retain

166 h) The 9-1-1 authority or 9-1-1 system provider shall forward all error reports within two business days after finding the error to the 9-1-1 authority, 9-1-1 system provider, or carrier to take appropriate action to resolve the error.

Retain

167 i) If the error is a record of the 9-1-1 system provider, it must be corrected and updated within two business days after receipt of the error. If the error is for a participating telecommunications carrier, the 9-1-1 system provider shall forward the error to the appropriate telecommunications carrier or 9-1-1 authority for resolution.

Retain

168 j) Any telecommunications carrier receiving an error record from the 9-1-1 system provider has two business days upon receipt of the error to work with the 9-1-1 Authority and process the corrections and forward the appropriate updates to the 9-1-1 system provider. If the error is for an OSP, the 9-1-1 authority will forward those on to the appropriate company for review.

Retain

169 k) The 9-1-1 authority shall retest and/or validate that all errors have been corrected (e.g., no record found, misroutes).

Retain

170 l) The 9-1-1 authority shall, on a continuing basis, maintain the MSAG (or GIS database or functional equivalent), the ELT for each ESN and the associated telephone numbers for the ELTs.

Retain

201

Current ICC Rules Text Recommendation(s)

171 m) Upon a written request of the 9-1-1 authority, the 9-1-1 system provider shall submit, within 14 working days, a report to assist in the validation of the accuracy of the 9-1-1 database. Before this report is delivered to the 9-1-1 authority, the 9-1-1 authority shall enter into nondisclosure agreements with telecommunication carriers and interconnected VoIP providers to protect proprietary network and customer-related information from public disclosure consistent with the Illinois Freedom of Information Act (FOIA) [5 ILCS 140/7(1)] and other applicable federal or state law.

Retain

172 1) This report shall include the following information when available in the 9-1-1 database: A) telephone number − area code, prefix, and number in separate fields;

Retain

173 B) pilot number − single telephone number used to tie multiple numbers within a system together; Retain

174 C) service (civic) address − including street name, house number or equivalent, suffix, directional, community name, state, zip code and location and/or descriptive information, including intersection if MSAG indicates an intersection, in separate fields;

Retain

175 D) billing address − if different than the service address, in separate fields, to be provided on a telephone number only basis pursuant to procedures defined by the telecommunications carrier and the 9-1-1 authority. Billing address information shall be subject to non-disclosure agreements;

Retain

176 E) name − first, last, and middle names or initials in separate fields; Retain

177 F) date service was initiated − the month, day and year that service was initiated, in separate fields. If this information is not available, the date reflecting the most current service order activity may be provided instead;

Retain

178 G) type of service − residential, business, coin, etc.; Retain

179 H) PBX/Centrex Extensions/Station Numbers − identify those numbers that are part of a PBX/Centrex system when this information is available;

Retain

202

Current ICC Rules Text Recommendation(s)

180 I) surcharge status − when this information is available, the report shall identify those lines on which a surcharge is being collected and the date on which the collection was initiated. Identify those lines on which no surcharge is being collected and the reason for each exemption, including telecommunications carrier lines, in separate fields;

Retain

181 J) Emergency Service Number (ESN) − appropriate ESN, if assigned, is to be made available only from the primary telecommunications carrier providing database development and routing services.

Retain

182 2) This report may be requested by the 9-1-1 authority in writing, at a maximum, on a monthly basis. The information in this report is considered proprietary and shall be used exclusively for validating the accuracy of the 9-1-1 database. This report will be delivered in an electronic format. It will not be delivered in paper format. There will be a charge for this report that will be a tariffed item by each 9-1-1 system provider.

Retain

182 n) A 9-1-1 authority that has or is in the process of transitioning to an NG9-1-1 system when the 9-1-1 traditional legacy service database will be used in conjunction with, or eventually be replaced with, dynamic data must provide a detailed explanation of the initial development and ongoing maintenance of necessary databases in the NG9-1-1 final plan or modification, pursuant to Section 1325.205.

Retain

(Source: Amended at 40 Ill. Reg. 8170, effective May 25, 2016)

Section 725.525 Call Boxes (Repealed)

SUBPART F: SURCHARGE

Section 725.600 Surcharge Administration and Monthly Report to the Emergency Telephone System Board (Repealed)

Section 725.APPENDIX A Monthly Surcharge Report to the 9-1-1 Authority (Repealed)

203

Current ICC Rules Text Recommendation(s)

AUTHORITY: Implementing and authorized by Section 10 of the Emergency Telephone System Act [50 ILCS 750/10].

SOURCE: Adopted at 4 Ill. Reg. 2, p. 163, effective December 31, 1979; amended at 5 Ill. Reg. 888, effective January 9, 1981; codified at 8 Ill. Reg. 12188; Part repealed, new Part adopted at 20 Ill. Reg. 5335, effective April 1, 1996; amended at 28 Ill. Reg. 15742, effective December 1, 2004; old Part repealed at 37 Ill. Reg. 10098, and new Part adopted at 37 Ill. Reg. 10100, effective July 1, 2013; emergency amendment at 40 Ill. Reg. 961, effective January 1, 2016, for a maximum of 150 days; amended at 40 Ill. Reg. 8170, effective May 25, 2016.

204

TITLE 83: PUBLIC UTILITIES CHAPTER I: ILLINOIS COMMERCE COMMISSION

SUBCHAPTER f: TELEPHONE UTILITIES PART 730 STANDARDS OF SERVICE FOR LOCAL EXCHANGE TELECOMMUNICATIONS CARRIERS58

Current Rules Text Recommendation(s)

SUBPART A: GENERAL

Section 730.100 Application of Part

1 a) This Part shall apply to all local exchange carriers offering or providing noncompetitive telecommunications services as defined in Section 13-210 of the Universal Telephone Service Protection Law of 1985 (Law) [220 ILCS 5], except this Part does not apply to Electing Providers as defined in Section 13-506.2(a)(1) of the Public Utilities Act [220 ILCS 5/13-506.2(a)(1)], and except that Sections 730.115(b), 730.535(c), 730.540(d) and (e), and 730.545(h) and (i) are not applicable to telephone cooperatives as defined in Section 13-212 of the Law pursuant to Section 13-701 of the Law. This Part shall only apply to the relationship between a serving local exchange carrier and its end user. This Part shall not apply to the relationship between a serving local exchange carrier that provides wholesale facilities or services to another serving local exchange carrier for provisioning of services to its retail end user customers.

Ensure definitions and terms are consistent with NG9-1-1 service offerings and the types of companies that will be providing parts of the system. Terms refer to legacy systems/providers. Term also references non-competitive telecommunications services; unsure of its application to NG9-1-1. Ensure references to laws and acts have not changed

58 http://www.ilga.gov/commission/jcar/admincode/083/08300730sections.html

205

Current Rules Text Recommendation(s)

2 b) This Part does not supersede the authority of, nor prohibit, the Commission from imposing different, additional, or more stringent service quality standards, reporting requirements or penalties upon a carrier pursuant to Section 13-506.1 of the Public Utilities Act (Alternative forms of regulation for noncompetitive services).

Ensure references have not changed

(Source: Amended at 39 Ill. Reg. 355, effective December 22, 2014)

Section 730.105 Definitions

As used in this Part, the following terms shall have these definitions:

3 "Access line" means the connecting facility between a customer's premises network interface device and the local exchange carrier's facility that provides access to the switching network for local exchange and interexchange telecommunications service. This includes the network interface or equivalent, the outside plant facilities, the office frame and frame wiring and the office line termination.

Update facility, local exchange carrier, switching network terms for NG9-1-1. Add definitions for NG9-1-1, such as ESInet.

4 "Act" means the Public Utilities Act [220 ILCS 5]. Retain

5 "Analog" means a continuous electrical signal that carries information by means of variations in its amplitude or frequency. The electrical signal being transmitted varies in direct relation to the signal generated by the source.

Retain

6 "Answer time" means a measurement in seconds from the point the carrier's telephone system receives the call until the call is answered by the carrier's representative or voice response unit and ready to accept information. In the case when the carrier uses a menu-driven system, the measurement begins once the menu-based system has transferred the customer into the carrier's telephone system until the call is answered by the carrier's representative.

Retain; update if references to carrier are expanded for NG9-1-1 providers.

206

Current Rules Text Recommendation(s)

7 "Application" means a verbal or written request for a telecommunications service. Retain

8 "Appointment" means an arrangement made by a telecommunications carrier to meet a customer within an agreed 4 hour window to address an installation or repair situation, or, until June 30, 2004, between 8 A.M. and 4 P.M. on a particular day if the carrier uses the resold services, network or network elements of another carrier to provide service to the customer, at the customer's premises, to perform work on the network.

Retain

9 "Assistance calls" means calls in which the operator provides assistance or instructions to the customer. Examples: rate quotes, credit requests, trouble reports, dial assistance and dialing instructions.

Retain

10 "Basic local exchange service" means residential and business lines used for local exchange telecommunications service as defined in Section 13-204 of the Public Utilities Act, excluding: services that employ advanced telecommunications capability as defined in section 706(c)(1) of the federal Telecommunications Act of 1996 (P.L. 104-104); vertical services; company official lines; and records work only. [220 ILCS 5/13-712(b)(2)].

Retain Ensure references are correct.

11 "Basic local exchange service installation" means the installation of basic local exchange service whereby the physical connecting and diagnostic testing of a local loop results in the provisioning of dial tone to the requesting customer's network interface device. It includes move orders and orders for additional lines.

Retain

12 "Business office" means those offices of the company where calls are answered and made. A business office typically employs company representatives to assist customers for order entry and lookup on customers' orders and account records through the use of a computerized system.

Retain

13 "Busy hour" means the two consecutive half-hours each day during which the greatest volume of traffic is handled.

Retain

207

Current Rules Text Recommendation(s)

14 "Busy tone" means an audible signal indicating a call cannot be completed because the called access line is busy. The tone is applied 60 times per minute.

15 "Call data" means the recorded information necessary to measure and bill each call. Retain

16 "Calls" means customers' messages attempted. Retain

17 "Central office" means the site where switching equipment is located. A local central office, also called an end office, is the switching office where individual subscriber's access lines appear. It houses the equipment that receives calls transmitted on the local loop and routes the call over the switched network either directly to the person called, if the call is placed to a location served by the same local central office, or to another central office, if the call is placed to a customer served by a different central office. Each central office serves local loops in an exclusive geographic area.

Retain

18 "Certificate of service authority" means the authorization by the Commission granting a local exchange carrier the right to provide telecommunications services within a specified geographical area.

May need to expand who, under the authority of the ICC, will receive a certificate of authority; it may not be a LEC going forward.

19 "Channel" means a single path between two or more points provided for transport of user information and/or signaling for a communications service.

Retain

20 "Commission" means the Illinois Commerce Commission. Retain

208

Current Rules Text Recommendation(s)

21 "Connecting company" means a corporation, association, partnership or individual (other than a company affiliated interest) that owns or operates central offices or similar switching facilities and interchanges traffic directly or indirectly with the local exchange carriers.

May need to expand the definition and remove the legacy specific references to central offices or switching facilities and the reference to LECs.

22 "Customer" means any person, building owner, firm, partnership, corporation, municipality, cooperative, organization, governmental agency, etc., provided with local exchange carrier telecommunications services as defined in Section 13-204 of the Act. Customer may also be referred to as "end user".

Consider updating definition and aligning with statute; removing references to LECs; ensure statute references are correct.

23 "Customer premises equipment" or "CPE" means equipment employed on the premises of a person (other than a carrier) to originate, route or terminate telecommunications. Customer premises equipment includes customer premises wire.

Retain

24 "Customer premises wire" means any wire, including interface equipment, on the customer side of the network interface or equivalent.

Retain

25 "Customer trouble report" means any verbal or written report relating to difficulty or dissatisfaction with the operation of regulated telecommunications services. One report shall be counted for a verbal or written report received. When several items are reported by one customer at the same time, and the group of troubles so reported is clearly related to a common cause, they are counted as one report.

Retain

26 "dBrnc" means a measure of the interfering effect of noise. Retain

27 "Decibel" or "dB" means a standard unit used for expressing a transmission signal gain or loss. Retain

209

Current Rules Text Recommendation(s)

28 "Dial tone" means an audible tone sent from an automatic switching system to a customer to indicate the equipment is ready to receive dial signals.

Retain

29 "Dial tone first" means coin telephone service that allows a customer to obtain a dial tone before money is deposited into the coin telephone.

Retain

30 "Digital" means a signal that carries information by discrete changes in its parameters. For digital transmission of analog information, the incoming voice, data or video signals are sampled periodically and digitally coded for transport through the network.

Retain

31 "Direct distance dialing" or "DDD" means the automatic establishment of toll calls in response to signals from the dialing device of the originating customer.

Retain

32 "Distributing system" means that part of the outside cable plant connecting the central office to the customer network interface at the customer's premises.

Retain

33 "Emergency situation" means a single event that causes an interruption of service or installations affecting end users of a local exchange carrier. The emergency situation shall begin with the first end user whose service is interrupted by the single event, and shall end with the restoration or installation of the service of all affected end users.

Consider removing references specific to legacy systems such as LEC.

210

Current Rules Text Recommendation(s)

34 The term single event shall include: a declaration made by the applicable State or federal governmental agency that the area served by the local exchange carrier is either a State or federal disaster area; or an act of third parties, including acts of terrorism, vandalism, riot, civil unrest or war, or acts of parties that are not agents, employees or contractors of the local exchange carrier; or a severe storm, tornado, earthquake, flood or fire, including any severe storm, tornado, earthquake, flood or fire that prevents the local exchange carrier from restoring service due to impassable roads, downed power lines, or the closing off of affected areas by public safety officials.

Retain

35 The term emergency situation shall not include: a single event caused by high temperature conditions alone; or a single event caused, or exacerbated in scope and duration, by acts or omissions of the local exchange carrier, its agents, employees or contractors or by the condition of facilities, equipment or premises owned or operated by the local exchange carrier; or any service interruption that occur during a single event listed in this definition, but are not caused by those single events; or a single event that the local exchange carrier could have reasonably foreseen and taken precaution to prevent; provided, however, that in no event shall a local exchange carrier be required to undertake precautions that are technically infeasible or economically prohibitive.

Consider removing references specific to legacy systems such as LEC.

211

Current Rules Text Recommendation(s)

36 This Part shall be construed as being content neutral as to whether a strike or other work stoppage is an emergency situation. In the event of a strike or other work stoppage, the local exchange carrier's obligations to provide remedies for failure to comply with this Part shall, in the absence of a decision by a court of competent jurisdiction, be determined by the Commission on a case-by-case basis based upon the individual factual circumstances of each strike or other work stoppage. In making such a determination, and notwithstanding the definition of emergency situation above, the Commission shall not presume that a strike or other work stoppage is an act of an employee or of the local exchange carrier.

Consider removing references specific to legacy systems such as LEC.

37 "End user" means any person, building owner, firm, partnership, corporation, municipality, cooperative, organization, governmental agency, etc., provided with local exchange carrier telecommunications services for consumption, not for resale, as defined in Section 13-204 of the Act. End user may also be referred to as "customer".

Consider removing references specific to legacy systems such as LEC.

38 "Exchange area" means a unit established by a local exchange carrier and approved by the Commission for the administration of telecommunications service in a specified geographical area. It may consist of one or more central offices together with associated plant used in furnishing telecommunications services in that area. Exchange areas are identified on exchange boundary maps on file with the Commission.

Consider removing references specific to legacy systems such as LEC.

39 "Foreign exchange service" means a classification of exchange services whereby customers may be provided a telecommunications service from a local exchange other than the one from which they would normally be served.

Consider removing references specific to legacy systems such as LEC.

40 "Information call" means a call in which a customer will be connected to directory assistance by dialing the proper service code or number and will be given the directory number of the customer whom he or she desires to call, provided that the customer's number to be called is or will be published or listed in the information records. An information call is also referred to as directory assistance.

Retain

41 "Inside wire" means the same as "customer premises wire" defined above. Retain

212

Current Rules Text Recommendation(s)

42 "Installation trouble report" means any network trouble report filed within seven days after the completion of a basic local exchange service installation on the same line.

Consider removing references specific to legacy systems such as LEC.

43 "Intercept service" means a service arrangement provided by the local exchange carrier whereby calls placed to a disconnected or discontinued telephone number are intercepted and the calling party given such information as the called telephone number has been disconnected, discontinued or changed to another number, or that calls are being received by another telecommunications line.

Retain

44 "InterMSA" means those calls originating in one Market Service Area (MSA) but terminating in another MSA. InterMSA calls are also referred to as "InterLATA calls". See Section 13-208 of the Act.

Retain

45 "Interoffice trunk" means a communication path between two central offices. Retain

46 "Line" means the conductor or conductors, supporting circuit equipment, and structures extending between customer network interfaces and central offices, or between central offices, whether they be in the same or different communities.

Retain

47 "Local exchange carrier" or "LEC" means a telecommunications carrier certificated by the Commission to provide intra-exchange and/or inter-exchange service within the same MSA.

Retain

48 "Local exchange service" means the same as "local exchange telecommunications service" as defined in Section 13-204 of the Act.

Retain

49 "Local exchange service area" means the area where telecommunications service is furnished to customers under a specific schedule of rates and without toll charges. A local exchange service area may include one or more exchange areas or portions of exchange areas.

Retain

50 "Local message" means a completed call between customers served by the same central office or between customers served by two different central offices as defined by and in accordance with tariffs.

Retain

213

Current Rules Text Recommendation(s)

51 "Local loop" means a channel between a customer's network interface and its serving central office. Retain

52 "Local usage charge" means the charge that applies to a call defined as a "local message". Retain

53 "Map" means a drawing showing a geographical area in which a local exchange carrier furnishes telecommunications services.

Retain

54 "Message" means a completed customer call. Retain

55 "Network" means the aggregate of transmission systems and switching systems. It is an arrangement of channels, such as loops, trunks and associated switching facilities.

Retain

56 "Network interface" means the point of termination on the customer premises at which the local exchange carrier's responsibility for the provision and maintenance of network channel or line service ends. The network interface is part of the network and the order of appearance of central office lines on it is determined solely by the local exchange carrier

Consider removing references specific to legacy systems such as LEC.

57 "Network service" means a telecommunications service that links two or more discrete channels for the purpose of creating a point-to-point connection.

Retain

58 "Noise to Ground" or "Ng" means the noise measured between ground and the tip and ring conductors. The customer does not hear the noise to ground, but the amount of noise to ground affects the amount of noise metallic that a customer hears.

Consider changing acronym to N2G so as not to confuse with NG9-1-1.

59 "Noise Metallic" or "Nm" means the noise measured across the tip and ring of a circuit and is the noise that the customer hears.

Retain

214

Current Rules Text Recommendation(s)

60 "Out of Service > 30 Hours" means that 30 hours after reporting an out of service condition to the local exchange carrier the customer still: has no dial tone; or cannot be called; or cannot call out.

Retain

61 This defined term excludes call blocking or any other intentional alteration to an end user's calling or call receiving ability.

Retain

62 "Outside plant" means the telecommunications equipment and facilities installed on, along, over, or under streets, alleys, highways or on private rights-of-way between the central office and customer locations or between central offices.

Retain

63 "Party line service" is a service offering where two or more unaffiliated customers share the same line and telephone number.

Retain

64 "Premises" means the space occupied in a single local exchange area by a customer in a building or in adjoining buildings not separated by a public thoroughfare or in a public office building where the customer's office space is all contiguous.

Consider removing references specific to legacy systems such as local exchange area.

65 "Public telephone service" means one-party access line service equipped with a coin collecting and/or calling-card only telephone instrument installed for the use of the general public in locations where the general public has access to these telephones.

Retain

215

Current Rules Text Recommendation(s)

66 "Repair office" means an office to handle customers' reported telephone facility problems. Customers may call to request trouble verification tests, initiate trouble reports and obtain information on the status of open trouble reports.

Retain

67 "Repeat trouble report" means any network trouble report filed within 30 days after the closing of a previous network trouble report filed by the same customer for the same working line.

Retain

68 "Reporting entity" means a unit established by the local exchange carrier for the purpose of administering the customer service operations established by this Part.

Retain

69 "Staff" means the Staff of the Illinois Commerce Commission. Retain

70 "Telecommunications service" means any regulated communication service provided by local exchange carriers.

Consider removing references specific to legacy systems such as LEC.

71 "Toll call" means a completed message between customers in different exchanges for which message toll rates are applicable.

Retain

72 "Traffic" means call volume based on number and duration of messages. Retain

73 "Transmission" means the process of sending information from one point to another. Retain

74 "Trouble report" means any customer complaint to the local exchange carrier regarding the operation of the network affecting their basic local exchange service, including both service-affecting conditions or out of service conditions.

Consider removing references specific to legacy systems such as LEC.

75 "Trunk" means a transmission path between switching units, switching centers and/or toll centers. Retain

216

Current Rules Text Recommendation(s)

76 "Vertical services" means optional telecommunication services, including, without limitation, Caller ID or Call Waiting, that a customer may choose to have added to its basic access line.

Retain

77 "Working line" means an active access line or channel. Retain

(Source: Amended at 36 Ill. Reg. 14990, effective October 1, 2012)

Section 730.110 Waiver

78 The Commission, on application of a company, customer, applicant, or end user or on its own motion, may grant a temporary or permanent waiver from this Part, or any subsections contained in this Part, in individual cases where the Commission finds that:

Consider adding the term “provider”.

79 a) The provision from which the waiver is granted is not statutorily mandated; Retain

80 b) No party will be injured by the granting of the waiver; and Retain

81 c) The rule from which the waiver is granted would, as applied to the particular case, be unreasonable or unnecessarily burdensome.

Retain

(Source: Amended at 27 Ill. Reg. 17997, effective December 1, 2003)

Section 730.115 Reporting

82 a) All reports required to be submitted to either the Staff or to the Illinois Commerce Commission under this Part 730 shall be certified by an authorized agent of the reporting carrier. All such reports will be public records available for inspection, copying and posting to the Commission's website.

Consider changing “carrier” to “provider” to expand term.

83 b) Disaggregation Retain

217

Current Rules Text Recommendation(s)

84 1) Each telecommunications carrier shall provide to the Commission, on a quarterly basis and in a form suitable for posting on the Commission's website, a public report that includes monthly performance data for basic local exchange service quality of service as required to be collected and reported pursuant to this Part. The performance data shall be disaggregated for each geographic area and each customer class of the State for which the telecommunications carrier internally monitored performance data as of March 2, 2001. The report shall include, at a minimum, operator answer time – toll and assistance, Section 730.510(a)(1)(A); operator answer time – information, Section 730.510(a)(1)(B); repair office answer time, Section 730.510(b)(1); business or customer service answer time, Section 730.510(b)(1); percent of service installations, Section 730.540(a); percent of lines out of service for more than 30 hours, including monthly itemization of the "w" variable via attachment, Section 730.535(a); trouble reports per 100 access lines, Section 730.545(a); percent of repeat trouble reports, Section 730.545(c); percent of installation trouble reports, Section 730.545(f); missed repair appointments, Section 730.545(h); and missed installation appointments, Section 730.540(d).

Ensure references are accurate.

85 2) Carriers shall disaggregate their performance data at least to the extent required pursuant to this Section and Section 13-712(f) of the Act and, by January 1, 2004, shall provide to the Commission a certification by an authorized officer of the carrier specifying the disaggregation that is required as well as supporting documentation sufficient to demonstrate the required disaggregation (specifically identifying the geographic and customer class disaggregation). The carriers shall bear the burden of proof with respect to the required disaggregation. The certification and supporting documentation shall be delivered in a form that can be made publicly available and posted upon the Commission's website.

Consider if “telecommunications carrier” is still appropriate term.

(Source: Amended at 36 Ill. Reg. 14990, effective October 1, 2012)

SUBPART B: RECORDS AND REPORTS

Section 730.200 Preservation of Records

218

Current Rules Text Recommendation(s)

86 All records required by this Part shall be preserved in accordance with provisions of 83 Ill. Adm. Code 705.

Repealed at 38 Ill. Reg. 18159, effective August 15, 2014.

SUBPART C: ENGINEERING

Section 730.305 Maintenance of Plant and Equipment

87 Each local exchange carrier shall: a) adopt a maintenance program for its equipment based on the minimum standards set forth in this Part, which program shall be updated regularly but not less than every two years unless an earlier update is requested by the Commission.

Consider if still applicable to LEC and if similar requirements are appropriate for other types of carriers, service providers, access providers.

88 b) inspect every two years, in accordance with the National Electric Safety Code (NESC) standards identified in 83 Ill. Adm. Code 305, its electrical grounding equipment owned by such carrier for each central office, including, without limitation, the component of such system commonly known as the master ground bar, to ascertain the integrity of the central office ground field, and maintain a copy of the test results in the office and available for inspection. The inspection shall be performed annually if one of the following events occurs: an office conversion (replacement of the current switching equipment), a building addition to a central office, or renovations to the building facilities and grounds, such as water, sewer, gas, electric facilities or parking lot.

Consider if still applicable to LEC and if similar requirements are appropriate for other types of carriers, service providers, access providers.

219

Current Rules Text Recommendation(s)

89 c) copy, on a monthly basis, its database for switching equipment applicable to each central office and store such copy off-site or in a fireproof on-site storage for use in emergency restoration purposes (such copying and storage to be performed in accordance with current software backup procedures).

Consider if still applicable to LEC and if similar requirements are appropriate for other types of carriers, service providers, access providers.

90 d) copy, on a monthly basis, its digital access and cross-connect system (DACS) database for each central office, if technically feasible, and store such copy off-site or in a fireproof on-site storage for use in emergency restoration purposes (such copying and storage to be performed in accordance with current software backup procedures).

Consider if still applicable to LEC and if similar requirements are appropriate for other types of carriers, service providers, access providers.

91 e) copy, on a monthly basis, its fiber optic terminal database for each central office, if technically feasible, and store such copy off-site or in a fireproof on-site storage for emergency restoration purposes (such copying and storage to be performed in accordance with current software backup procedures).

Consider if still applicable to LEC and if similar requirements are appropriate for other types of carriers, service providers, access providers.

(Source: Amended at 27 Ill. Reg. 17997, effective December 1, 2003)

Section 730.320 Network Service

92 Local exchange carriers shall retain control of the network and not provide service to lines that introduce energy into the network at levels or frequencies that will interfere with other users.

This definition will need to change and reflect the NG9-1-1 ecosystem.

Section 730.325 Emergency Operation

220

Current Rules Text Recommendation(s)

93 a) Each local exchange carrier shall make provisions to meet emergencies resulting from failures of commercial or power service, sudden and prolonged increases in traffic, illness of personnel, fire, storm, or other natural disasters. Each local exchange carrier shall inform employees as to procedures to be followed in the event of emergency in order to prevent or minimize interruption or impairment of telecommunications service.

Expand definition to include all providers of NG9-1-1 service.

94 b) Each existing central office will contain a reserve battery supply of 5 hours where emergency power generators are not installed and 3 hours where they are in place. Central office batteries shall be maintained in accordance with Institute of Electrical and Electronic Engineers (IEEE) standards as adopted in Section 730.340, and records verifying such maintenance shall be kept on site. New central offices or central offices being replaced shall contain a reserve battery supply of 8 hours where emergency power generators are not installed and 5 hours where they are in place. In central offices without installed emergency power generators, a mobile power unit shall be available that can be delivered and connected within 5 hours.

Retain Consider if updates to terms used or additional terms should be added for NG9-1-1.

95 c) In new central offices exceeding 3,000 working lines, a permanent power generator shall be installed. For existing central offices having over 3,000 lines, permanent power generators shall be installed at the time of office replacement or battery replacement.

Retain Consider if updates to terms used or additional terms should be added for NG9-1-1.

96 d) Emergency generator units shall have available at least a 12 hour fuel supply. Retain

97 e) Emergency generator units shall be tested under load once a month. A record of the test results shall be maintained.

Retain

(Source: Amended at 27 Ill. Reg. 17997, effective December 1, 2003)

Section 730.335 Network Interface

221

Current Rules Text Recommendation(s)

98 a) Telecommunications carriers shall have in place, no later than December 31, 2003, external combination protector/demarcation interfaces for all one- and two-line customers in single tenant residences and commercial buildings.

Consider if any changes are required once NG9-1-1 technology has been determined.

99 b) The network interface for a residential customer shall be located on a structure owned, rented, or leased by the customer, in which the customer resides.

Retain

100 c) The network interface for business customers shall be located outside structures owned, rented, or leased by the customer, in which the customer is conducting business. The demarcation point shall be located at the minimum point of penetration of the network cable to the building, normally within 25 feet. Deviation from this location must be mutually agreeable to the building owner and the telecommunications provider.

Retain

101 d) Network interfaces shall not be located on fence posts, utility poles, or cable pedestals. Retain

102 e) Network interfaces for temporary services or serving trailers, boats, or customer-owned pay telephones shall be located on structures provided by the customer or on a utility pole.

Retain

(Source: Amended at 27 Ill. Reg. 17997, effective December 1, 2003)

Section 730.340 Incorporation of National Codes and Standards

222

Current Rules Text Recommendation(s)

103 a) The Commission adopts as its rules the following portions of the NESC (1997 edition, approved June 6, 1996, published by the Institute of Electric and Electronic Engineers, Inc., 345 East 47th Street, New York, New York 10017): 1) Section 2 (Definitions of Special Terms). 2) Section 9 (Grounding Methods of Electric Supply and Communications Facilities). b) The Commission adopts as its rules the following publications of the IEEE: 1) IEEE Std 1188-1996 Recommended Practice for Maintenance, Testing, and Replacement of Valve-Regulated Lead-Acid (VRLA) Batteries for Stationary Applications. 2) IEEE Std 450-1995 Recommended Practice for Maintenance, Testing and Replacement of Lead Acid Batteries for Stationary Applications. c) These incorporations do not include any later amendments or editions.

Are any additional standards for NG9-1-1 needed such as the NENA i3 standard?

(Source: Added at 27 Ill. Reg. 17997, effective December 1, 2003)

SUBPART D: CALL DATA, INSPECTIONS, AND TESTS

SUBPART E: STANDARDS OF QUALITY OF SERVICE

Section 730.500 Adequacy of Service

104 a) Traffic studies shall be made and records maintained to the extent and frequency necessary to determine that sufficient equipment and an adequate operating force are provided to meet the minimum standards of service set forth in Sections 730.520 and 730.525.

Consider applicability to NG9-1-1 and expand or amend requirement as appropriate.

105 b) Each local exchange carrier shall employ adequate procedures for assignment of facilities. The assignment record shall be kept up to date and checked every six months to determine if adjustments are necessary to maintain proper balance in all trunk and equipment groups.

Consider applicability to NG9-1-1 and expand or amend requirement as appropriate.

223

Current Rules Text Recommendation(s)

106 c) Local service furnished by pair gain devices at a given exchange shall provide service equivalent to that furnished other subscribers at that exchange served by means of normal physical loops.

Consider applicability to NG9-1-1 and expand or amend requirement as appropriate.

107 d) Local exchange carrier employees shall be instructed to comply with the provisions of all applicable Federal and state laws in maintaining secrecy of communications (see 47 U.S.C. Sec. 605 and Ill. Rev. Stat. 1989, ch. 38, pars. 14-1 to 14-9).

Consider applicability to NG9-1-1 and expand or amend requirement as appropriate. Are any additional standards for NG9-1-1 needed such as the NENA i3 standard?

Section 730.515 Central Office Administrative Requirements

108 a) Central office capacity and equipment shall be sufficient to provide a dial tone within three seconds on 95% of all calls placed during the busy hour of any given day. Whenever the dial tone rate falls below 95%, the local exchange carrier shall take corrective action and report such action to the Commission within 15% business days after the end of the month in which the violation occurred.

Retain until full transition is completed.

109 b) For purposes of subsection (a), the percent of calls that obtained dial tone within three seconds shall be derived by dividing the total number of customer dialing attempts during the busy hour that obtained dial tone within three seconds by the total number of customer attempts to obtain dial tone during the busy hour.

Retain

110 c) Each central office shall be equipped with alarms to indicate failures or improper functions. Consider if NG9-1-1 technology/equipment should be alarmed.

224

Current Rules Text Recommendation(s)

111 d) Either operator or mechanized intercept service shall be provided for nonworking or changed terminating numbers until the numbers are assigned or reassigned.

Retain Consider applicability to NG9-1-1.

112 e) All remote switching units are to be equipped to continue to perform basic internal switching functions if a base unit connection is interrupted.

Retain Consider applicability to NG9-1-1.

113 f) Whenever a local exchange carrier fails to meet the monthly objectives contained in this section, it shall report that fact to the Commission's Telecommunications Division, with a statement of the reasons for such failure, within 15 days after the end of the respective month.

Consider expanding this requirement to those providing NG9-1-1 components.

(Source: Amended at 27 Ill. Reg. 17997, effective December 1, 2003)

Section 730.520 Interoffice Trunks

114 a) Local interoffice trunks and intraoffice trunks, interoffice toll trunks, and the intertoll trunk and any related switching components shall be engineered so that at least 98% of calls shall not encounter an All Trunks Busy (ATB) condition and at least 98% of properly dialed incoming interMSA calls, during the busy hour, shall receive ringing signal, station busy tone, or intercept (other than ATB) on the first attempt. When the completion rate falls below 98% for three consecutive months, corrective action shall be initiated and such action reported to the Commission.

Consider expanding this requirement to those providing NG9-1-1 components.

225

Current Rules Text Recommendation(s)

115 b) For purposes of subsection (a), the information required to be reported shall be calculated by capturing total call attempts (local, toll, DDD, or inter/intraoffice) and calls that do not encounter an ATB condition that are going through trunk groups controlled by the reporting entity during the busy hour. Calls that do not encounter an ATB condition should be divided by Total Trunk Attempts to derive the percent of calls completed without encountering an ATB. The calculation should be performed for each base unit and all remotes that home on each base. Measurements for all of the base and remote units should be added to provide a statewide basis.

Retain Consider appropriateness to NG9-1-1.

(Source: Amended at 27 Ill. Reg. 17997, effective December 1, 2003)

Section 730.525 Transmission Requirements

109 Local exchange carriers shall furnish and maintain plant, equipment and facilities to meet the following minimum transmission standards. The transmission standards set forth in this Section are based upon measurements from the network interface at the customer premises through the local loop to a nominal 48-volt central office and measured at a frequency of 1004 hertz.

Retain until full transition is completed. Consider applicability to NG9-1-1 components and if similar requirements should be written.

110 a) Local line analog loops shall have a loop resistance not exceeding the operating design of the associated central office equipment. Longer loops may be used by deployment of loop range extenders. b) All analog loops are to be maintained to a minimum of 40,000 ohms insulation resistance. c) Transmission loss of analog local loop shall be engineered not to exceed 10.0 dB when measured in accordance with subsection (a). The local loop transmission loss shall be adjusted to 10.0 dB or less if it exceeds 10.0 dB.

Retain until full transition is completed. Consider applicability to NG9-1-1 components and if similar requirements should be written

226

Current Rules Text Recommendation(s)

d) Transmission loss in analog interoffice trunks shall be engineered not to exceed 7 dB. If the loss exceeds expected design loss by + or - 3.5 dB, it shall be corrected to within 1 dB of the design loss. e) Transmission loss on analog toll terminating trunks shall be engineered not to exceed 4 dB. If the loss exceeds expected design loss by + or - 3.5 dB, it shall be corrected to within 1 dB of the design loss. f) Transmission loss on all digital interoffice trunks shall be engineered and maintained not to exceed 6 dB. g) Loop current shall be maintained at 20 milliamperes or greater. h) Power influence (Noise to Ground) shall not exceed 90 dBrnc. i) Circuit noise (Noise Metallic) shall not exceed 30 dBrnc.

(Source: Amended at 35 Ill. Reg. 8808, effective June 1, 2011)

Section 730.545 Trouble Reports

111 a) Each local exchange carrier shall maintain basic local exchange service so that the average rate of all customer network trouble reports is no greater than 6 reports per 100 access lines per month.

Retain until full transition is complete. Consider revising to include NG9-1-1 components on which reports are wanted and what appropriate thresholds and data gathering mechanisms might be.

227

Current Rules Text Recommendation(s)

112 b) For purposes of maintaining records or reporting information relating to the requirement set forth in subsection (a), the information required to be so maintained or reported shall be calculated by dividing the number of customer initiated network trouble reports in any given month that are cleared to network dispositions, less customer premises equipment (CPE), inside wire, or emergency situations, by the total number of access lines in service. The rate shall be reported on a per 100 access line basis.

Retain until legacy components no longer apply. Consider if similar requirements should be written for NG9-1-1 component recordkeeping.

113 c) The local exchange carrier shall maintain service so that the percentage of repeat trouble reports for a month does not exceed 20% of the total customer trouble reports.

Retain for legacy. Consider applicability to NG9-1-1 and if similar requirements should be applied to NG9-1-1 providers.

114 d) For purposes of maintaining records or reporting information relating to the objective in subsection (c), the information required to be so maintained or reported shall be calculated by dividing the total number of repeat trouble reports by the total number of customer trouble reports, in said month, and shall exclude troubles related to CPE, inside wire, or emergency situations.

Retain

115 e) Each local exchange carrier shall maintain a record of repeat trouble reports as reported by its customers. This record shall include appropriate identification of the customer or service affected, the time, date and nature of the repeat trouble report, the action taken, and the date and time of trouble clearance or other disposition.

Retain for legacy. Consider applicability to NG9-1-1 and if similar requirements should be applied to NG9-1-1 providers.

228

Current Rules Text Recommendation(s)

116 f) The local exchange carrier shall maintain service so that the percentage of installation trouble reports for a month does not exceed 20% of the total installations.

Retain for legacy. Consider applicability to NG9-1-1 and if similar requirements should be applied to NG9-1-1 providers.

117 g) Each local exchange carrier shall maintain a record of installation trouble reports as reported by its customers. This record shall include appropriate identification of the customer or service affected, the time, date and nature of the report, the action taken, and the date and time of installation trouble clearance or other disposition.

Retain for legacy. Consider applicability to NG9-1-1 and if similar requirements should be applied to NG9-1-1 providers. May consider making requirement non-specific and apply to all providers.

229

Current Rules Text Recommendation(s)

118 h) Each local exchange carrier shall keep scheduled repair appointments when a customer premises visit requires a customer to be present. If the local exchange carrier is unable to keep a scheduled repair appointment, it shall notify the customer of the delay and the reason for the delay no later than 8 P.M. of the day prior to the scheduled date of the appointment of its inability to keep the repair appointment.

Retain for legacy. Consider applicability to NG9-1-1 and if similar requirements should be applied to NG9-1-1 providers. May consider making requirement non-specific and apply to all providers.

119 i) Each local exchange carrier shall maintain a record of repair appointments as reported by its customers. This record shall include appropriate identification of the customer or service affected, the time, date and nature of the repair appointment, the action taken, the date and time of repair appointments, and whether the appointments were kept, cancelled no later than 8 P.M. of the day prior to the scheduled date of the appointment, or missed without notice to the customer no later than 8 P.M. of the day prior to the scheduled date of the appointment.

Retain for legacy. Consider applicability to NG9-1-1 and if similar requirements should be applied to NG9-1-1 providers. May consider making requirement non-specific and apply to all providers.

(Source: Amended at 36 Ill. Reg. 14990, effective October 1, 2012)

Section 730.550 Network Outages and Notification

230

Current Rules Text Recommendation(s)

120 a) Notification 1) Each local exchange carrier shall inform the Commission by telephone or by e-mail of any service interruption exceeding 30 minutes' duration caused by a complete or partial central office failure or complete or partial isolation of an exchange due to toll circuit failure, including cut cables. A reportable outage is any one of the following occurrences with a duration, unless otherwise specified, of at least 30 minutes affecting more than 50% of the customers and affecting more than 100 access lines in the affected exchange: A) Toll isolation; B) Loss of dial tone; C) Isolation of one or more end offices or host/remote clusters from 9-1-1 service; D) Loss of ANI/ALI processing; E) Simplex conditions exceeding 5 days. 2) The notification shall be made via telephone call to (217)558-6166 or by e-mail to the outage notification e-mail address posted on the Commission's website and shall consist of the following information: A) Affected Area Code/Prefix B) Exchange Name C) Company Name D) Cause of Interruption E) Outage Date and Time F) Restoral Date and Time G) Effect on 9-1-1 Service H) Name and Number of Person Reporting the Service Interruption.

Retain until full transition is complete. Consider how NG9-1-1 outages should be reported.

121 3) Written Report A follow-up written report shall be filed within 30 days, either via U.S. Postal Service, facsimile or e-mail.

Retain until full transition is complete. Consider how NG9-1-1 outages should be reported.

231

Current Rules Text Recommendation(s)

122 4) All outages affecting 9-1-1 services shall be reported in accordance with 83 Ill. Adm. Code 725, Standards Applicable to 9-1-1 Emergency Systems. In particular, any cut cables or loss of host-remote links that result in the physical staffing of 9-1-1 call boxes are to be reported as soon as possible.

Retain until full transition is complete. Consider how NG9-1-1 outages should be reported. Verify references.

123 b) Whenever it is necessary to interrupt customer service for the purpose of working on the distribution system or central office equipment, the work should be completed with minimal customer impact. The local exchange carrier shall use reasonable efforts to notify in advance public service customers (e.g., 9-1-1 entities, police, fire, hospitals) it reasonably believes may be most seriously affected by the interruption. Any customer credits for interrupted service shall be made pursuant to 83 Ill. Adm. Code 732.

Make provider-neutral.

(Source: Amended at 41 Ill. Reg. 4724, effective April 19, 2017)

SUBPART F: SAFETY

SUBPART G: BOUNDARIES

Section 730.700 Map Requirements

124 Each local exchange carrier shall have on file with the Commission an exchange area boundary map for each of its exchanges within the State of Illinois.

Retain Consider making provider-neutral.

Section 730.705 Map Specifications

232

Current Rules Text Recommendation(s)

125 a) A local exchange carrier boundary map filed after the effective date of this Part shall be in accordance with an already existing certificate of service authority, a petition for a new certificate of service authority, or a notice submitted pursuant to 83 Ill. Adm. Code 730.711.

Retain Consider making provider-neutral.

126 b) Each map shall show the boundary lines of the area the local exchange carrier holds itself out to serve in connection with the exchange. Exchange boundary lines shall be located by appropriate measurement to an identifiable location if that portion of the boundary line is not otherwise located on section lines, waterways, railroads or roads.

Retain Consider making provider-neutral.

127 c) The name of the local exchange carrier filing the map shall be placed at the left side of the top of the map, and the name of the exchange followed by the words "(Name of carrier) Exchange Area Boundary Map" shall be placed at the right side of the top of the map. The first filing of a map shall be designated by the word "Original" placed just below the words "(Name of carrier) Exchange Area Boundary Map". If the map is subsequently refiled, the words "First Revisions" shall be substituted for the word "Original", and on each subsequent refiling the next higher number shall be substituted for the number preceding the word "Revision" on the last map filed. The date of the issuance of the new boundary map shall be placed under the word "Original" or "Revision".

Retain Consider making provider-neutral.

(Source: Amended at 35 Ill. Reg. 8808, effective June 1, 2011)

Section 730.711 Changes to Existing Boundaries

128 No telecommunications carrier shall make a change to any of its exchange area boundaries, except upon 45 days notice to any affected customers and 90 days notice to the Commission. These notices shall meet the following requirements:

Retain

233

Current Rules Text Recommendation(s)

129 a) Notice to the Commission shall be filed with the Office of the Chief Clerk with a copy to the Chief Telephone Engineer. The Chief Telephone Engineer will have the notice posted to the Commission's web site within seven calendar days after receipt. This notice shall be accompanied by a new exchange area boundary map for any exchange area affected by the revision, with the new maps conforming to the provisions of Section 730.705. If there are any customers whose local exchange service will be affected by the proposal, then the Commission notice shall also be accompanied by a copy of the customer notice as well as the names, addresses and telephone numbers of each customer being sent a copy of the notice. If the proposed revision affects the boundary line of more than one carrier, the notice shall also be accompanied by a verified statement that the revised boundary lines have been agreed to by the other local exchange carriers adjoining the boundary lines to be changed.

Retain

130 b) Notice to Customers. The carrier shall provide notice to those customers located within the area being changed, and the notice shall be dated and sent by mail to the affected customers. The notice shall provide specific details as to the carrier's proposal, including what impact it will have on the customer's telephone number, calling areas and rates. The notice shall also specifically inform the customer that he or she has 45 days after the mailing of the dated notice to express opposition to, or support for, the proposed boundary change by calling the Commission's Chief Telephone Engineer at (217)524-5072.

Retain

131 c) Proposed boundary changes shall go into effect after the stated 90 days notice, unless the Commission, upon its own motion or upon complaint, initiates an investigation of the proposed exchange area boundary. In such cases, the Commission may, after notice and hearing, prohibit the proposed exchange area boundary change if the Commission finds that the change would be contrary to the public interest.

Retain

132 d) For any boundary change that will result in the elimination of an exchange in its entirety, the carrier shall file a petition with the Commission seeking the issuance of a new certificate of service authority.

Retain

(Source: Added at 35 Ill. Reg. 8808, effective June 1, 2011)

Section 730.715 Service Outside Exchange Boundaries

234

Current Rules Text Recommendation(s)

133 a) No telecommunications service will be established outside the exchange boundary of the exchange that normally would provide service except on an emergency temporary basis or after the serving local exchange carrier has filed a notice of proposed boundary change with the Commission.

Consider making provider-neutral.

134 b) In cases where local exchange telecommunications service is provided outside the exchange boundary of the normal serving exchange without authorization of the Commission (other than foreign exchange service) and the location of the service is in the exchange of another local exchange carrier certificated by the Commission, the service shall be discontinued as soon as facilities are made available from the exchange in which the service is located. The customer whose service is affected by this Section shall be given at least 90 days notice prior to the time service can be provided from the proper telephone exchange.

Retain Consider applicability to NG9-1-1 provider or making provider-neutral.

(Source: Amended at 35 Ill. Reg. 8808, effective June 1, 2011)

Section 730.720 Map Maintenance

135 Each local exchange carrier shall maintain and make available for public inspection a map of each exchange served.

Consider making provider-neutral.

AUTHORITY: Implementing Sections 8-301, 8-505 and 13-712 and authorized by Section 10-101 of the Public Utilities Act [220 ILCS 5/8-301, 8-505, 13-712 and 10-101].

SOURCE: Filed November 6, 1970; amended at 7 Ill. Reg. 2147, effective February 4, 1983; codified at 8 Ill. Reg. 12191; Part repealed and new Part adopted at 15 Ill. Reg. 16060, effective November 1, 1991; amended at 24 Ill. Reg. 13861, effective September 1, 2000; amended at 27 Ill. Reg. 17997, effective December 1, 2003; amended at 35 Ill. Reg. 8808, effective June 1, 2011; amended at 36 Ill. Reg. 14990, effective October 1, 2012; amended at 39 Ill. Reg. 355, effective December 22, 2014; amended at 41 Ill. Reg. 4724, effective April 19, 2017.

235

TITLE 83: PUBLIC UTILITIES CHAPTER I: ILLINOIS COMMERCE COMMISSION

SUBCHAPTER f: TELEPHONE UTILITIES PART 735 PROCEDURES GOVERNING THE ESTABLISHMENT OF CREDIT, BILLING, DEPOSITS, TERMINATION OF SERVICE AND

ISSUANCE OF TELEPHONE DIRECTORIES FOR LOCAL EXCHANGE TELECOMMUNICATIONS CARRIERS IN THE STATE OF ILLINOIS59

Current Rules Text Recommendation(s)

Section 735.10 Definitions

1 "Act" – the Public Utilities Act [220 ILCS 5]. Retain

2 "Applicant" – a person who applies for telecommunications service. Includes persons seeking reconnection of their service after Company-initiated termination.

Retain

3 "Business Service" – is telephone service where the use of the service is primarily or substantially of a business, professional, institutional, or otherwise occupational nature and as further defined in the Company's tariffs.

Retain

4 "Commission" – the Illinois Commerce Commission. Retain

5 "Company" – telephone company or telecommunications carrier under the jurisdiction of the Illinois Commerce Commission.

Has it been determined if IP providers are under the jurisdiction of the ICC?

6 "Customer" – any person who agrees to pay for telecommunication services provided by a telephone company.

Where is this definition? Not in 725, 730 or 735; refer to Illinois Public Act 100-0020

59 http://www.ilga.gov/commission/jcar/admincode/083/08300735sections.html

236

Current Rules Text Recommendation(s)

7 "Discontinuance" – temporary (10 days or less) disconnection of telecommunications service. Retain

8 "Electing Provider" – has the same meaning as ascribed in Section 13-506.2(a)(1) of the Act. Retain; confirm reference is correct

9 "Network Access Line" – the connecting facility between a customer's premises network interface device and the local exchange carrier's facility that provides access to the switching network for local exchange and interexchange telecommunications service. This includes the network interface or equivalent, the outside plant facilities, the office frame and frame wiring, and the office line termination.

Retain

10 "NSF Check" – any negotiable instrument returned by a bank, savings institution, or other eligible institution that is returned by that institution with one of the following instructions: • not sufficient funds; • uncollectible funds; • account closed; • account frozen; • no account.

Retain

11 "Person" – a natural person, firm, partnership, corporation, association, municipality, cooperative, organization, governmental agency, real estate trust, or other legal entity.

Retain

12 "Residential Service" – telephone service where the major use of the service is of a social or domestic nature and business use, if any, is merely incidental; and where the service is located in a residence or, in the case of combined business and residential premises, where the service is located in bona fide residential quarters of the premises and business service is located in the business quarters of the same premises, and as further defined in the Company's tariffs.

Retain

13 "Termination" – permanent disconnection of telecommunications service. Retain

237

Current Rules Text Recommendation(s)

14 "User" – any person who uses telecommunications service provided by a company under the jurisdiction of the Illinois Commerce Commission.

May need updating to be technology neutral (e.g. telecommunications)

(Source: Amended at 37 Ill. Reg. 8373, effective July 1, 2013)

Section 735.30 Scope and Application

15 a) This Part shall apply to all telephone companies under the jurisdiction of the Commission in the offering or providing of noncompetitive telecommunications services as defined in Section 13-210 of the Act and shall regulate the:

May need updating for provider-neutral terms (e.g., telephone companies).

16 1) establishment of procedures governing eligibility for service, billing, deposits, and payment practices; and

Retain

17 2) establishment of conditions under which service may be discontinued or terminated. Retain

18 b) A telephone company that is an electing provider shall comply with this Part when offering or providing the optional packages required by Section 13-506.2(d) of the Act or stand-alone residential network access lines.

May need updating for provider-neutral terms (e.g., telephone company).

19 c) Except as otherwise provided in this Section, this Part sets forth the minimum general requirements and shall apply to any telecommunications carrier as defined as such by the Act that engaged in providing noncompetitive telecommunications telephone service and that comes under the jurisdiction of the Commission, provided that this Part also applies to electing providers only with respect to the offering or provision of the optional packages required by Section 13-506.2(d) of the Act and stand-alone residential network access lines.

Does the reference to the Act refer to the Public Utilities Act or Public Act 100-0020?

238

Current Rules Text Recommendation(s)

20 d) This Part shall supersede any rate, rule, regulation or condition of service that any telephone utility presently has on file with the Commission. If any rate, rule, regulation or condition of service, or portion thereof, fails to meet the minimum general requirements in this Part, the utility shall refile that rate, rule, regulation or condition of service to conform with the provisions of this Part within 90 days after February 4, 1983. Any rate, rule, regulation or condition of service, or portion thereof, that fails to meet the minimum general requirements in this Part shall be considered null and void 91 days after February 4, 1983.

Retain

(Source: Amended at 37 Ill. Reg. 8373, effective July 1, 2013)

Section 735.130 Discontinuance or Refusal of Service

21 a) The company may discontinue or refuse service for any of the following reasons: Retain

22 1) For failure to make or increase a deposit pursuant to Sections 735.100, 735.110, and 735.120; Retain

23 2) For failure to pay a past due bill owed to the company, including one for the same class of service furnished to the applicant or customer at the same or another location, or where the applicant or customer voluntarily assumed, in writing, responsibility for the bills of another applicant or customer. For purposes of this subsection (a)(2), a company may discontinue service if the current customer is liable for a past due bill for telephone service pursuant to Section 15 of the Rights of Married Persons Act [750 ILCS 65/15], unless the customer, at the option of the company, pays any past due bill and/or provides a deposit pursuant to Section 735.120 and/or enters into a deferred payment agreement pursuant to Section 735.80;

Retain Verify references are correct.

24 3) For failure to provide company representatives with necessary access to company-owned service equipment, after the company has made a written request to do so;

Retain

25 4) For failure to make payment in accordance with the terms of a deferred payment arrangement; Retain

239

Current Rules Text Recommendation(s)

26 5) When a company has reason to believe that a customer has used a device or scheme to obtain service without payment and where the company has so notified the customer prior to disconnection;

Retain

27 6) For violation of or noncompliance with a Commission order; Retain

28 7) For violation of or noncompliance with any rules of the company on file with the Commission for which the company is authorized by tariff to discontinue service for violation or noncompliance on the part of the customer or user;

Retain

29 8) For violation of or noncompliance with municipal ordinances and/or other laws pertaining to service; or Retain

30 9) The customer's use of equipment adversely affects the company's service to others. This disconnection may be done without notice to the customer or user.

Retain

31 b) The following shall not constitute sufficient cause for discontinuance or refusal of service: Retain

32 1) Except as specified in subsection (a)(2), failure to pay the past due bill of a previous customer of the premises to be served, unless the applicant for service voluntarily signed a form agreeing to assume responsibility for the bills of the previous customer, or the previous customer is currently a member of the same household as the applicant;

Retain

33 2) Failure to pay charges for directory advertising; Retain

34 3) Failure to pay the past due bill for a different class of service (residential or business); or Retain

35 4) Failure to pay charges for terminal equipment or other telephone equipment purchased from the company, an affiliate, or a subsidiary.

Retain

240

Current Rules Text Recommendation(s)

36 c) Discontinuance procedures. The company may discontinue service to a customer only after it has mailed or delivered by other means a written notice of discontinuance, substantially in the form of Appendix A. Service shall not be discontinued until at least five days after the notice is delivered in person or eight days after the notice is mailed to the customer. If the notice is mailed, the company shall maintain and retain, for a two-year period, any documentation of the date of mailing that the US Postal Service requires for the mailing method used by the company. If the notice is mailed by the company and the envelope is postmarked by the US Postal Service, then the date of the postmark shall satisfy this documentation requirement.

Retain

37 1) The notice of discontinuance shall be delivered separately from any other written matter or bill. Retain

38 2) Notice of discontinuance shall not be delivered or mailed before the third business day following the due date shown on the bill.

Retain

39 d) The notice required by subsection (c) shall remain in effect for 20 days beyond the date of discontinuance shown on the notice. The company shall not discontinue service beyond the 20 day period until at least five days after delivery of a new written notice of discontinuance or eight days after the postmark on a mailed notice.

Retain

40 e) In addition to the written notice, the company shall attempt to advise the customer when service is scheduled for discontinuance. The company shall not deliver more than two consecutive notices of discontinuance for past due bill without engaging in collection activity with the customer.

Retain

41 f) Timing of the discontinuance 1) Service shall not be discontinued for a past due bill after 12 noon on a day before or on any Saturday, Sunday, legal holiday recognized by the State of Illinois, or any day when the utility's business offices are not open for business. Services may be discontinued only between the hours of 8 a.m. and 2 p.m., unless the company is prepared to restore service within three hours after receipt of payment, at the standard restoral charge, if any.

Retain

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Current Rules Text Recommendation(s)

42 2) Each company shall have personnel available until at least 5 p.m. on business days authorized to reconnect service if the conditions cited as grounds for discontinuance are corrected and any restoral charge specified by the company's tariff is paid.

Retain

43 g) Service shall not be discontinued, and shall be restored if discontinued, when a present customer who is indebted to the company enters into a payment arrangement pursuant to Section 735.80 and complies with the terms of the arrangement.

Retain Verify references are correct.

44 h) Service shall not be discontinued, and shall be restored if discontinued, for any reason that is the subject of a dispute or complaint pursuant to Section 735.190 and/or 735.200 while the dispute or complaint is pending and the complainant has complied with the provisions of those Sections.

Retain Verify references are correct.

45 i) Service shall not be discontinued for an amount due the company that has not been included in a discontinuance notice.

Retain

46 j) Nothing in this Section shall be construed to prevent immediate discontinuance of service without notice or the refusal of service for reasons of public safety or health.

Retain

(Source: Amended at 34 Ill. Reg. 3263, effective March 1, 2010)

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Current Rules Text Recommendation(s)

AUTHORITY: Implementing Sections 8-101 and 9-252 and authorized by Section 10-101 of the Public Utilities Act [220 ILCS 5/8-101, 9-252 and 10-101].

SOURCE: Adopted at 7 Ill. Reg. 2108, effective February 4, 1983; codified at 7 Ill. Reg. 15969; emergency amendment at 7 Ill. Reg. 16055, effective November 17, 1983, for a maximum of 150 days; amended at 8 Ill. Reg. 5161, effective April 13, 1984; amended at 18 Ill. Reg. 4146, effective March 15, 1994; amended at 18 Ill. Reg. 6164, effective May 1, 1994; amended at 18 Ill. Reg. 17981, effective December 15, 1994; emergency amendment at 25 Ill. Reg. 16552, effective December 13, 2001 for a maximum of 150 days; amended at 26 Ill. Reg. 7078, effective May 1, 2002; amended at 34 Ill. Reg. 3263, effective March 1, 2010; amended at 37 Ill. Reg. 8373, effective July 1, 2013.

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Appendix F – Department Administrative Rules

Administrative Rule Reference Recommendations

Section 1325.101 Definitions

1 "9-1-1 Authority" means the ETSB or qualified governmental entity that provides for the management and operation of a 9-1-1 system within the scope of those duties and powers as prescribed by the Emergency Telephone System Act (ETSA) [50 ILCS 750].

Local definition Aligns with NENA: A State, County, Regional or other governmental entity responsible for 9-1-1 service operations. For example, this could be a county/parish or city government, a special 9-1-1 or Emergency Communications District, a Council of Governments or other similar body.

In some cases, and for some concerns, the State 9-1-1 Administrator is the 9-1-1 authority? Verify references are accurate with recent statute change.

2 "9-1-1 Network" means the network used for the delivery of 9-1-1 emergency calls over dedicated and redundant facilities, as required by 83 Ill. Adm. Code 725 to a PSAP or backup PSAP that meets the applicable grade of service.

No NENA definition Definition is OK for analog technology; talking about transport only, not services. Consider further change to ”… the network and associated services used for …” Change in ICC rules 725 also.

3 "9-1-1 System" means the geographic area that has been granted an order of Authority by the Administrator to use "9-1-1" as the primary emergency telephone number.

Same as in ICC rules 725 Retain

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Administrative Rule Reference Recommendations

4 "9-1-1 System Provider" means any person, corporation, limited liability company, partnership, sole proprietorship, or entity of any description that acts as a 9-1-1 system provider within the meaning of ETSA Section 2 by contracting to provide 9-1-1 network and database services and that has been certified by the Commission pursuant to the Public Utilities Act [220 ILCS 5/13-900].

Same as in ICC rules 725 Retain

5 "9-1-1 Traditional Legacy Service" means that an arrangement of channels, such as loops, trunks and associated switching facilities to exchange voice and data.

Local definition NENA definition of Legacy 9-1-1 System Service Provider: Traditional ILEC acting as a 9-1-1 System Service Provider.

Retain Consider adding Department definition to statute also.

6 "Access Line" means the connecting facility between a customer's premises network interface device and the local exchange carrier's facility that provides access to the switching network for local exchange and interexchange telecommunications service.

NENA definition: The connection between a customer premises network interface and the Local Exchange Carrier that provides access to the Public Switched Telephone Network (PSTN).

Retain Aligns closely with NENA; consider applicability to NG9-1-1 or making the definition provider neutral.

7 "Act" or "ETSA" means the Emergency Telephone System Act [50 ILCS 750].

Local reference Retain Verify reference is correct.

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8 "Adjacent Agencies" means any public or private safety agencies (police, firefighting, emergency medical and ambulance services or other emergency services) whose jurisdiction is outside the 9-1-1 system jurisdiction, but that is adjacent to or touches that 9-1-1 system's boundary.

Local definition Retain

9 "Administrator" means the Statewide 9-1-1 Administrator.

Local definition Retain

10 "Aid Outside Normal Jurisdiction Boundaries Agreement" means a written cooperative agreement entered into by all participating and adjacent agencies and public safety agencies providing that, once an emergency unit is dispatched to a request through a system, that unit shall render its services to the requesting party without regard to whether the unit is operating outside its normal jurisdictional boundaries.

Local definition Retain

11 "Audible Signal" means a buzzer, bell or tone device used to alert an individual that appropriate action is required.

Not in NENA Glossary Retain

12 "Automatic Alarm" or "Automatic Alerting Device" means any device that will access the 9-1-1 system for emergency services upon activation. [50 ILCS 750/2]

Aligns with NENA definition Retain

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Administrative Rule Reference Recommendations

13 "Automatic Location Identification" or "ALI" means the automatic display at the PSAP of the caller's telephone number, the address/location of the telephone, and supplementary emergency services information.

Aligns with NENA definition Retain

14 "Automatic Number Identification" or "ANI" means the automatic display of the telephone number associated with the access line from which a call originates on the PSAP monitor.

Aligns with NENA definition with exception of the underlined text

Retain or consider changing to delete specific method of display, which may change in the future.

15 "Backup PSAP" means a public safety answering point that serves as an alternate to the PSAP for enhanced systems and 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.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.14) Level of service provided from an alternate facility [S14] (aka: back-up PSAP) during a significant event that precludes use of the primary facility. Related NRIC BP 7-7-0568

Retain

16 "Busy Day" means a consecutive 24-hour period during which the greatest volume of traffic is handled in the central office.

No NENA definition Retain

17 "Busy Hour" means the two consecutive half-hours each day during which the greatest volume of traffic is handled in the central office.

Local definition NENA definition broader: The hour each day with the greatest call volume.

Retain

18 "Busy Tone" means an audible signal indicating a call cannot be completed because the called access line is busy. The tone is applied 60 times per minute.

Aligns with NENA definition Retain

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Administrative Rule Reference Recommendations

19 "Call Referral" means a 9-1-1 service in which the PSAP telecommunicator provides the calling party with the telephone number of the appropriate public safety agency or other provider of emergency services.

Local definition Retain

20 "Call Relay" means a 9-1-1 service in which the PSAP telecommunicator takes the pertinent information from a caller and relays that information to the appropriate public safety agency or other provider of emergency services.

Local definition Aligns with NENA definition

Retain

21 "Call Transfer" means a 9-1-1 service in which the PSAP telecommunicator receiving a call transfers the incoming call to the appropriate public safety agency or other provider of emergency services.

Local definition NENA definition: The capability to redirect a call to another party.

Retain

22 "Carrier" means a telecommunications carrier and a wireless carrier.

Local definition NENA definition: In the context of 9-1-1 database vernacular, the term carrier means a business entity that provides a function to a customer base, typically for a fee. Examples of carriers and associated services are; a Local Exchange Carrier providing PSTN service, a VoIP Service Provider providing VoIP service, an Internet Service Provider providing email service.

Definition could be enhanced in next iteration of legislative changes to make sure VoIP and other IP service providers are part of telecommunications definition.

248

Administrative Rule Reference Recommendations

23 "Central Office" means the site where switching equipment is located. A local central office, also called an end office, is the switching office where individual subscriber's access lines appear. It houses the equipment that receives calls transmitted on the local loop and routes the call over the switched network either directly to the person called, if the call is placed to a location served by the same local central office, or to another central office, if the call is placed to a customer served by a different central office.

More expansive than NENA definition: The Local Exchange Carrier facility where access lines are connected to switching equipment for connection to the Public Switched Telephone Network.

Retain Consider revision.

24 "Circuit" means the physical connection (or path) of channels, conductors and equipment between two given points through which an electronic or optical signal may be established.

No NENA definition Retain

25 "Commission" means the Illinois Commerce Commission.

Local definition Retain

26 "Customer Premises Equipment" or "CPE" means communications or terminal equipment located in the customer's facilities/terminal equipment at a PSAP.

Aligns with NENA definition Retain

27 "Default Routing" means a feature that allows emergency calls to be routed to a designated default PSAP if the incoming emergency call cannot be selectively routed due to ANI failure, garbled digits, or other causes that prevent selective routing.

Aligns with NENA definition: The capability to route a 9-1-1 call to a designated (default) PSAP when the incoming 9-1-1 call cannot be selectively routed due to an ANI failure or other cause.

Retain

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Administrative Rule Reference Recommendations

28 "Department" means the Department of State Police.

Local definition Retain

29 "Direct Dispatch" means a 9-1-1 service that provides for the direct dispatch, by a PSAP telecommunicator, of the appropriate unit upon receipt of an emergency call and the decision as to the proper action to be taken.

Differs slightly from NENA definition: The performance of 9-1-1 call answering and dispatching by personnel at the primary PSAP.

Retain Consider simplifying definition in next iteration of legislative changes.

30 "Diverse Routing" means the practice of routing circuits along different physical or electrical paths in order to prevent total loss of 9-1-1 service in the event of a facility or hardware failure.

Aligns with NENA definition Retain

31 "E9-1-1 Selective Router" means a telecommunications carrier switching office, or stand-alone selective routing switch, equipped with enhanced 9-1-1 service capabilities. This switch serves as an E9-1-1 selective router for emergency calls from other local offices in the 9-1-1 service area.

Local definition Not in complete alignment with NENA definition: The Central Office that provides the tandem switching of 9-1-1 calls. It controls delivery of the voice call with ANI to the PSAP and provides Selective Routing, Speed Calling, Selective Transfer, Fixed Transfer, and certain maintenance functions for each PSAP.

Retain until selective routers are no longer part of the network. Selective router will transition to NGCS or IP selective router (transitional) until geospatial call routing.

32 "Emergency Call" means any type of request for emergency assistance through the 9-1-1 network, not limited to voice. This may include a session established by signaling with two-way, real-time media and involves a human making a request for help.

Local definition No NENA definition

Retain

250

Administrative Rule Reference Recommendations

33 "Emergency Service Number" or "ESN" is sometimes known as emergency service zone (ESZ). An ESN is a three- to five-digit number representing a unique combination of public safety agencies (police, fire and emergency medical service) designated to serve a specific range of addresses within a particular geographic area or ESZ. The term ESZ refers to the geographic area itself and is generally used only during the ESN definition process to label specific areas. The ESN facilitates the selective routing of calls to appropriate PSAPs in a traditional legacy 9-1-1 system.

Local definition is much more expansive than the NENA definition: The 3-5 position Emergency Service Number (ESN) used by a selective router to selectively route a 9-1-1 call and for switch-based selective transfer features. In cases where Routing ESNs are not used, the routing ESN equals the Administrative ESN. (Refer to Administrative ESN).

Retain In NG9-1-1, once geospatial routing and definitions are implemented this will need to be changed; consider changes to next iteration of legislative changes.

34 "Emergency Telephone System Board" or "ETSB" means a board appointed by the corporate authorities of any county or municipality that provides for the management and operation of a 9-1-1 system within the scope of the duties and powers prescribed by ETSA. The corporate authorities shall provide for the manner of appointment, provided that members of the board meet the requirements of the statute.

Local definition Retain

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Administrative Rule Reference Recommendations

35 "English Language Translation" or "ELT" means an alphanumeric description of the primary law enforcement, fire and emergency medical service agencies associated with a given emergency services zone number. The ELT (also known as an "agency file" or "tell tale" in some systems) includes the name of the first-responder agency and may include its station number (for dispatch purposes) and telephone number.

Aligns with NENA definition Retain

36 "Enhanced 9-1-1" or "E9-1-1" means an emergency telephone system that includes dedicated network, selective routing, database, ALI, ANI, selective transfer, fixed transfer, and a call back number.

Aligns with NENA definition Retain

37 "Error ratio" means the percentage of database records that are not Master Street Address Guide or geospatial data valid for a specific 9-1-1 traditional legacy service system.

No NENA definition Retain until full transition to NG9-1-1 is complete; consider change to define an error ratio appropriate for geospatial data used in NG9-1-1 call processing (98%). Add geospatial data error rate.

38 "Exchange" means a defined area, served by one or more telephone central offices, and approved by the Commission, within which a local exchange carrier furnishes service. Exchanges are identified on exchange boundary maps on file with the Commission.

More extensive than NENA definition

Retain Consider changes for next legislative changes that simplifies the definition more in alignment with NENA’s definition.

252

Administrative Rule Reference Recommendations

39 "Geospatial Mapping Data" means accurate references to a precise location on the earth's surface using latitude, longitude, elevation and datum that identifies the coordinate system used.

Local definition Retain

40 "Geographic Information System" or "GIS" means a system for capturing, storing, displaying, analyzing and managing data and associated attributes that are spatially referenced.

NENA Standards for the Provisioning and Maintenance of GIS data to ECRFs and LVF (NENA-STA-005.1-2017, August 10, 2017)

Retain

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

NENA definition: Grade of Service is the probability of a call in a circuit group being blocked or delayed for more than a specified interval, expressed as a vulgar fraction or decimal fraction. This is always with reference to the busy hour when the traffic intensity is the greatest.

Retain

42 "Interconnected Voice Over Internet Protocol Provider" or "Interconnected VoIP Provider" means every corporation, company, association, joint stock company or association, firm, partnership, or individual, their lessees, trustees or receivers appointed by any court whatsoever that owns, controls, operates, manages, or provides within this State, directly or indirectly, Interconnected VoIP, service, or the meaning prescribed in 47 CFR 9.3 [220 ILCS 5/13-234 and 13-235]. VoIP service is a service that enables real-time, two-way voice communications; requires a

NENA definition: A company that provides Internet access to other companies and individuals

Verify references are correct. Consider simplification of definition in next iteration of legislative changes.

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Administrative Rule Reference Recommendations

broadband connection from the user's location; requires Internet protocol-compatible customer premises equipment; and permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched network.

43 "IP" means Internet Protocol. NENA definition: The method by which data is sent from one computer to another on the Internet or other networks.

Consider revision to definition to align with NENA definition.

44 "IP Gateway" means the point at which a circuit-switched call is encoded and repackaged into IP packets. Equipment that provides interconnection between two networks with different communications protocols.

Retain

45 "Joint ETSB" means a Joint Emergency Telephone System Board established by intergovernmental agreement of two or more municipalities or counties, or a combination thereof, to provide for the management and operation of a 9-1-1 system.

Local definition Retain

46 "Local Loop" means a channel between a customer's network interface and its serving central office. The most common form of loop, a pair of wires, is also called a line.

NENA definition: A physical facility between a customer’s network interface and the local serving central office. The most common form of local loop is a pair of wires.

Retain

47 Logging Recorder" means a device that records, stores and is capable of playing back all communication media with the

Aligns with NENA definition Retain

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Administrative Rule Reference Recommendations

domain to which it is assigned. Media can include, but is not limited to, voice, radio, text and network elements involved with routing a 9-1-1 call. Logging recorders should have the capability to simultaneously record from several sources.”

48 "Master Street Address Guide" or "MSAG" means the computerized geographic file that either consists of all street and address data or its functional equivalent (i.e., Geospatial Mapping Data) within the 9-1-1 system area. This database is the key to the selective routing capability of E9-1-1 systems. It matches an originating caller to a specific answering point based on the address data. The MSAG will require updating after the initial file is created.

More expansive than NENA definition

Retain

49 "Mechanical Dialer" means a device that either manually or remotely triggers a dialing device to access the 9-1-1 system. [50 ILCS 750/2]

Local definition Retain

50 "National Emergency Number Association" or "NENA" means the international not-for-profit organization whose purpose is to lead, assist and provide for the development, availability, implementation and enhancement of a universal emergency telephone number or system common to all jurisdictions through research, planning, publications, training and education.

Local definition Retain

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Administrative Rule Reference Recommendations

51 "NENA i3 Solution standard" means the NENA 08-003 Detailed Functional and Interface Standard for NG9-1-1 (i3), published by the National Emergency Number Association, 1700 Diagonal Rd., Suite 500, Alexandria VA 22314 (www.NENA.org) (June 14, 2011). These standards are hereby incorporated by reference and do not include any later amendments or additions.

Local definition Retain Update if NENA reference numbers, standards identifiers, or publication dates are changed. NENA 08-003 will be issued as NENA_STA-010.2-201X.

52 "Network Connection" means a voice grade communication channel directly between a subscriber and a telecommunications carrier's public switched network, without the intervention of any other telecommunications carrier's switched network, that would be required to carry the subscriber's interpremises traffic. The connection either is capable of providing access through the public switched network to a 9-1-1 system, if one exists; or, if no system exists at the time a surcharge is imposed under ETSA Section 15.3, would be capable of providing access through the public switched network to the local 9-1-1 system if one existed. [50 ILCS 750/2]

No NENA definition Retain Verify reference is accurate.

53 "Network costs" means those recurring costs that directly relate to the operation of the 9-1-1 network, including costs for interoffice trunks, selective routing charges, transfer lines and toll charges for 9-1-1 services,

No NENA definition Retain

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Administrative Rule Reference Recommendations

Automatic Location Information (ALI) database charges, call box trunk circuit (including central office only and not including extensions to fire stations), independent local exchange carrier charges and nonsystem provider charges, carrier charges for third-party database for on-site customer premises equipment, backup PSAP trunks for nonsystem providers, periodic database updates as provided by carrier (also known as "ALI data dump"), regional ALI storage charges, circuits for call delivery (fiber or circuit connection), NG9-1-1 costs, and all associated fees, taxes and surcharges on each invoice. "Network Costs" shall not include radio circuits or toll charges that are for other than 9-1-1 services.

54 "Network Diagram" means a schematic flow chart that shows the actual network pieces and flow of activities in a picture.

Local definition Consider change to enhance definition to add: “both physical and logical.”

55 "NG9-1-1" or "Next Generation 9-1-1 Service" means a system comprised of managed IP-based networks, gateways, functional elements and databases that augment or replicate present day E9-1-1 features and functions and provide new capabilities. NG9-1-1 is designed to provide access to emergency services from all sources, and to provide multimedia data capabilities for PSAPs and other emergency service organizations.

NENA definition: NG9-1-1 is an Internet Protocol (IP)-based system comprised of managed Emergency Services IP networks (ESInets), functional elements (applications), and databases that replicate traditional E9-1-1 features and functions and provides additional capabilities. NG9-1-1 is designed to provide access to emergency services from all connected communications sources, and provide multimedia data capabilities for Public Safety Answering Points

Consider aligning more closely with NENA. Consider also adding a definition of Next Generation Core Services found in the NENA Glossary. Reference: NENA-INF-015 NG9-1-1 Security Information Document.

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Administrative Rule Reference Recommendations

(PSAPs) and other emergency service organizations.

56 "On-site Database" means a copy of the database that resides with the local 9-1-1 Authority.

Local definition No NENA definition

Retain

57 "Order of Authority" means an order from the Administrator that authorizes public agencies or public safety agencies to provide 9-1-1 service in a geographical area.

Aligns with NENA definition Retain

58 "Originating Service Provider" or "OSP" means a communications provider that allows its users or subscribers to originate 9-1-1 voice or nonvoice messages from the public to the 9-1-1 Authority.

Local definition Retain

59 "Outbound Notification Systems" means a community outreach tool that automatically disperses information to the public and is not considered a function or part of a 9-1-1 system (see "System").

Local definition Retain

60 "Overflow" means a call or position used when a call is blocked or rerouted due to excessive traffic.

Local definition Not in NENA Glossary

Consider change to “means a condition under which a call is rerouted or redirected to a predetermined position or facility due to blockage or excessive traffic.”

258

Administrative Rule Reference Recommendations

61 "P.01" means the probability (P), expressed as a decimal fraction of an emergency call being blocked. P.01 is the grade of service reflecting the probability that one call out of 100 during the average busy hour of the average busy day will be blocked, or the number of 9-1-1 circuits or facilities from the 9-1-1 system provider's routing equipment to the primary PSAP or PSAPs that is sufficient to complete 99% of all requests for emergency service during the average busy hour of the average busy day.

NENA defines Grade of Service as the probability of a call in a circuit group being blocked or delayed for more than a specified interval, expressed as a vulgar fraction or decimal fraction. This is always with reference to the busy hour when the traffic intensity is the greatest.

Retain

62 "Participating Agencies" means any public or private safety agency (police, firefighting, emergency medical and ambulance services or other emergency services, pursuant to ETSA Section 4) whose jurisdiction is located within the 9-1-1 system boundaries.

Local definition Retain

63 "Primary Point of Contact" or "9-1-1 Contact Person" means the individual designated by the 9-1-1 Authority as the contact point for the participating telecommunications carriers.

Local definition Retain

64 "Private Branch Exchange" or "PBX" means a private telephone system and associated equipment located on the user's property that provides communications between internal stations and external networks.

NENA definition: A private telephone switch that is connected to the Public Switched Telephone Network.

Consider changing to Multi-Line Telephone System (MLTS) as defined by NENA.

259

Administrative Rule Reference Recommendations

65 "Public Agency" means the State or any unit of local government or special purpose district located in whole or in part within this State that provides police, firefighting, medical or other emergency services or has authority to do so. [50 ILCS 750/2].

Local definition Retain Verify references for accuracy.

66 "Public Safety Agency" means a functional division of a public agency that provides police, firefighting, medical or other emergency services.

Local definition Retain

67 "Public Safety Answering Point" or "PSAP" means the initial answering location of an emergency call.

NENA definition also takes into account the act of “processing the call” according to specific operational policy.

Retain

68 "Secondary Answering Point" or "SAP" means a location, other than a PSAP, that is able to receive the voice, data and call back number of E9-1-1 or NG9-1-1 emergency call transferred from a PSAP and completes the call taking process by dispatching police, medical, fire or other emergency responders.

Local definition NENA definition of a secondary PSAP: A PSAP to which 9-1-1 calls are transferred from a Primary PSAP.

Retain

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Administrative Rule Reference Recommendations

69 "Selective Routing" means a switching system that automatically routes calls to predetermined PSAPs based on the location of the calling telephone number.

NENA definition: The process by which 9-1-1 calls/messages are routed to the appropriate PSAP or other designated destination, based on the caller’s location information, and may also be impacted by other factors, such as time of day, call type, etc. Location may be provided in the form of an MSAG-valid civic address or in the form of geo coordinates (longitude and latitude). Location may be conveyed to the system that performs the selective routing function in the form of ANI or pseudo-ANI associated with a pre-loaded ALI database record (in Legacy 9-1-1 systems), or in real time in the form of a Presence Information Data Format – Location Object (PIDF-LO) (in NG9-1-1 systems) or whatever forms are developed as 9-1-1 continues to evolve.

Retain until full NG9-1-1 transition is complete and selective routers are no longer part of the 9-1-1 network. Consider updating term/ definition in legislation and rules.

70 "Service Address" means the location of the primary use of the network connection or connections.

NENA definition: The physical location of a subscriber access line. Service Address is the recommended address for 9-1-1 use. (May be different from the listed address or billing address)

Consider updating definition in legislation to align with NENA.

71 "Split Exchange" means an exchange shared with more than one 9-1-1 system.

Local definition No NENA definition

Retain

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Administrative Rule Reference Recommendations

72 "Surcharge" means a monthly amount imposed, pursuant to ETSA Section 20, on all customers of telecommunications carriers, wireless carriers and interconnected VoIP providers for the purpose of installing and maintaining an E 9-1-1 or NG9-1-1 system, with the exception of a municipality with a population of 500,000 or greater.

Local definition Retain

73 "System" means the communications equipment and related software applications required to produce a response by the appropriate emergency public safety agency or other provider of emergency services as a result of an emergency call.

Local definition Consider change to “…means the communications equipment, databases, and related software applications required to transport a 911 call through network(s) and equipment for the purpose of producing sufficient data for a response by the appropriate emergency public safety agency or other provider of emergency services.”

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Administrative Rule Reference Recommendations

74 "TDD" means a telecommunications device for the deaf. See "TTY".

The phrase TTY (or Teletype device) is how the deaf community used to refer to the extremely large machines they used to type messages back and forth over the phone lines. A TDD operates in a similar way, but is a much smaller desktop machine. The deaf community has used the phrase "TTY" and sometimes uses it interchangeably with "TDD." http://www.gallaudet.edu/dpn-home/tty-relays-and-closed-captions.html

Retain

75 "Telecommunications Carrier" or "Carrier" shall have the same meaning ascribed in Section 13-202 of the Public Utilities Act [220 ILCS 5/13-202], including those carriers acting as resellers of telecommunications services. It includes telephone systems operating as mutual concerns, but does not include a wireless carrier.

Local reference Retain Verify references for accuracy.

76 "Telecommunications Service" shall have the meaning ascribed in the Public Utilities Act [220 ILCS 5/13-203].

Retain

77 "Telecommunicator" means a person who is trained and employed in public safety telecommunications and is qualified to answer incoming emergency calls and/or provides for the appropriate emergency response, either directly or through communication with the appropriate PSAP, SAP or VAP.

NENA definition: Person employed by a PSAP and/or an EMD Service Provider qualified to answer incoming emergency telephone calls and/or provides for the appropriate emergency response either directly or through communication with the appropriate PSAP.

Retain

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Administrative Rule Reference Recommendations

78 "Terminal Equipment" means telephone station apparatus.

Local definition Telephone station is not defined by NENA nor by Illinois legislation.

Retain

79 "Transfer" means a feature that allows the PSAP telecommunicator to transfer emergency calls to a specific location or secondary PSAP.

NENA definition: A feature which allows the PSAP Telecommunicator to redirect a 9-1-1 call to another location.

Consider change to not use the word being defined in the definition; such as "Transfer" means a feature that allows the PSAP telecommunicator to redirect emergency calls to a specific location or secondary PSAP.

80 "Trunk" means a transmission path between switching units, switching centers and/or toll centers.

NENA definition: Typically, a communication path between central office switches, or between the 9-1-1 Control Office and the PSAP.

Consider greater alignment with NENA definition.

81 "TTY" or "Teletypewriter" means a telegraph device capable of transmitting and receiving alphanumeric information over communications channels and capable of servicing the needs of those persons with a hearing or speech disability.

http://www.gallaudet.edu/dpn-home/tty-relays-and-closed-captions.html

Retain

82 "Uninterruptible Power Supply" means an emergency power source that can detect any change in power line frequency or voltage and automatically compensates for these changes by supplying additional power or converting to an auxiliary power source, without any loss of voltage or frequency.

No NENA definition Retain

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Administrative Rule Reference Recommendations

83 "Vendor" means an entity that provides some or all elements of E9-1-1, 9-1-1, and/or other services for which it incurs network costs for one or more 9-1-1 Authorities.

Local definition Retain

84 "Virtual Answering Point" or "VAP" means a temporary or nonpermanent location that: • is capable of receiving an

emergency call; • contains a fully functional

worksite that is not bound to a specific location, but rather is portable and scalable, connecting emergency call takers or dispatchers to the work process; and

• is capable of completing the call dispatching process.

NENA definition: An operational model directly enabled through NG9-1-1 features and/or network hosted PSAP equipment in which telecommunicators are geographically dispersed, rather than working from the same physical location. Remote access to the PSAP applications by the dispersed telecommunicators requires the appropriate network connections, security, and work station equipment at the remote location. Unified communications applications supporting voice, data, instant messaging, and video communications between telecommunicators may be used to enable the telecommunicators to work cooperatively from diverse locations. The virtual work place may be a logical combination of physical PSAPs, or an alternate work environment such as a satellite facility, or any combination of the above. Workers are connected and interoperate via IP connectivity.

Retain

SUBPART B: AUTHORIZATION TO OPERATE AS A 9-1-1 SYSTEM Section 1325.200 General Requirements

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85 a) The digits "9-1-1" shall be the primary emergency telephone number within the system, but a public agency or public safety agency shall maintain a separate secondary 10-digit emergency backup number for at least six months after the 9-1-1 system is in operation and shall at all times maintain a separate number for nonemergency telephone calls.

Local requirement Retain

86 b) 9-1-1 service is a terminating-only service that connects a person who has dialed the universal emergency service code 9-1-1 to the appropriate PSAP.

Local agreement Retain

87 c) Outbound notification systems used to notify the general public of a particular incident are not considered part of a 9-1-1 "system" as defined in this Part.

Local requirement Retain

88 d) 9-1-1 plans for 9-1-1 systems shall be filed in compliance with this Part and the Act.

Local requirement Retain

89 e) 9-1-1 plans shall be filed electronically at the link posted on the Department's website as detailed in Section 1325.205.

Local requirement Retain Verify reference for accuracy.

90 f) A 9-1-1 system shall not become operational without an order from the Commission, prior to January 1, 2016, or the Administrator. Pursuant to ETSA Section 10, all orders of authority issued by the Commission shall continue in force unless rescinded by the Administrator.

Local requirement Retain

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91 g) The following modifications to a 9-1-1 Authority's existing 9-1-1 plan shall be filed for approval electronically at the link posted on the Department's website. The submission shall include a modified plan, consisting of the revised application prescribed in Section 1325.205. Modifications requiring Administrator approval shall include: 1) Changing boundaries that require an intergovernmental agreement between local governmental entities to exclude or include residents within the 9-1-1 jurisdiction; 2) Changing or adding a 9-1-1 system provider; 3) Changes in network configuration, except as provided for in subsection (h); and 4) Change of backup arrangement.

Local requirement Retain Verify reference for accuracy.

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92 h) The following modifications to a 9-1-1 Authority's existing 9-1-1 plan need not be formally submitted to the Administrator for approval. While Administrator approval is not necessary for these modifications, the 9-1-1 Authority must provide written notification 10 business days prior to making the following changes: 1) Permanent relocation of a PSAP or backup PSAP facility; 2) Any reduction in 9-1-1 trunks from the selective router to the PSAP; or 3) Further reduction within a 9-1-1 Authority of PSAPs beyond consolidation as required by the Act.

Local requirement Retain unless any of these items are impacting the NG9-1-1 network(s) under the management of the State, such as location of the PSAP facility. Require a change to County/PSAP 9-1-1 Plans and all the normal requirements that go along with that approval.

Section 1325.205 Initial or Modified Plan Filings (not Including Consolidation Plan)

93 a) Initial or modified plans, excluding consolidation plan filings, shall be filed in accordance with ETSA Section 11 and must conform to minimum standards as established pursuant to ETSA Section 10.

Local requirement Retain Verify reference for accuracy.

94 b) Initial or modified plans must include a completed application to the Administrator for the initial provision of, or modification to, 9-1-1 service. The application, which can be found on the Department's website, shall include the following documents: 1) Contact and 9-1-1 system information; 2) Notarized statement of truth regarding information provided in the plan;

Local requirement Retain

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3) A letter that is sent to the 9-1-1 system provider, with a copy of the plan; 4) A detailed summary of the proposed system's operation, including but not limited to, a five-year strategic plan for implementation with financial projections; 5) A summary of the anticipated implementation costs and annual operating costs of the proposed system that are directly associated with 9-1-1, as well as anticipated revenues; 6) A list of all communities that are served by the 9-1-1 system; 7) A list of public safety agencies (police, fire, EMS, etc.) that are dispatched by the 9-1-1 system, including their addresses, telephone numbers and form of dispatch; 8) A list of the public safety agencies (police, fire, EMS, etc.) that are adjacent to the 9-1-1 system's jurisdictional boundaries; 9) A list of the carriers and Interconnected VoIP providers that are known by the applicant to provide service within the jurisdiction of the 9-1-1 system;

95 10) Attachments (as applicable): A) Any local ordinances that create an ETSB;

Local requirement Retain

96 B) Any intergovernmental agreements or memorandums of understanding or any other agreements pertinent to the 9-1-1 system;

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR3: The statutory environment defines jurisdictional roles and responsibilities.

Include agreements across state borders.

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97 C) Any contracts with a new 9-1-1 system provider;

Local requirement Retain

98 D) The backup PSAP Agreement that establishes backup and overflow services between 9-1-1 Authorities or PSAPs within those Authorities;

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR3: The statutory environment defines jurisdictional roles and responsibilities. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.14) Level of service provided from an alternate facility [S14] (aka: back-up PSAP) during a significant event that precludes use of the primary facility. Related NRIC BP 7-7-0568

Retain

99 E) The network diagram that is provided by the 9-1-1 system provider showing the P.01 and trunking, routing and backup configuration for the 9-1-1 system;

Local requirement Consider change to: E) The network diagram that is provided by the 9-1-1 system provider showing the P.01 and trunking, system components and interconnection points, routing and backup configuration for the 9-1-1 system, both physical and logical;

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Administrative Rule Reference Recommendations

100 F) The Call Handling and Aid Outside Jurisdictional Boundaries Agreements i) Call Handling Agreements shall be made between the 9-1-1 Authority and public agencies and/or public safety agencies in a single system and also between the 9-1-1 Authority and/or public agencies or public safety agencies whose jurisdictional boundaries are contiguous. Call Handling Agreements shall describe the primary and secondary dispatch methods to be used by the requesting parties within their respective jurisdictions.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.7) Emergency Communications Plans are in place for risks associated with local vulnerabilities. [S7] SAFECOM Writing Guide for a Memorandum of Understanding (MOU) https://transition.fcc.gov/pshs/docs/clearinghouse/DHS-MemorandumOfUnderstanding.pdf

Retain

101 ii) Aid Outside Jurisdictional Boundaries Agreements shall be made between the 9-1-1 Authority and the public agencies and/or public safety agencies in a single system and between the 9-1-1 Authority and the public agencies and public safety agencies in adjacent systems, whose jurisdictional boundaries are contiguous. Aid Outside Jurisdictional Boundaries Agreements shall provide that, once an emergency unit is dispatched in response to a request through the system, that unit shall render its services to the requesting party without regard to whether the unit is operating outside its normal jurisdictional boundaries.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.7) Emergency Communications Plans are in place for risks associated with local vulnerabilities. [S7]

Retain

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102 iii) When possible, Call Handling and Aid Outside Jurisdictional Boundaries Agreements may be consolidated into a single agreement;

Local requirement Retain

103 11) The Test Plan, which is the 9-1-1 system's overall plan detailing how and to what extent the network and database will be tested;

NRIC BP 7-7-0579 Network Operators, Service Providers, and 911 administrators, and public safety agencies should routinely team to develop, implement, periodically test, evaluate and update as needed plans for 911 disruption contingencies (e.g., share information about network and system security and reliability where appropriate).

Retain

104 12) If incorporating an NG9-1-1 solution, the application must, in the narrative portion of the modification plan: A) Indicate the name of the certified 9-1-1 system provider being utilized;

Local requirement Retain

105 B) Explain what national standards, protocols and/or operating measures will be followed;

Local requirement Retain

106 C) Explain what measures have been taken to create a robust, reliable and diverse/redundant network and whether other 9-1-1 Authorities will be sharing the equipment;

National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST3: The state has defined PSAP performance standards. Guideline ST6: The state program fosters the adoption of technical and/or operational consensus standards and requirements.

Retain Consider modification to require listing what other 9-1-1 Authorities are sharing equipment.

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107 D) Explain how the existing 9-1-1 traditional legacy wireline, wireless and VoIP network, along with the databases, will interface and/or be transitioned into the NG9-1-1 system;

Local requirement Retain Consider modification to include an anticipated transition timeline.

108 E) Explain how split exchanges will be handled;

Local requirement Retain Consider modification to request map detail if appropriate.

109 F) Explain: i) how the databases will be maintained and how address errors will be corrected and updated on a continuing basis; and

Local requirement Retain

110 ii) who will be responsible for updating and maintaining the data, at a minimum, on a daily basis Monday through Friday; and

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para. 7.3.2.) Jurisdictions are responsible for the maintenance and content of their MSAG.

Retain

111 G) Explain what security measures will be placed on the IP 9-1-1 network and equipment to safeguard it from malicious attacks or threats to the system operation and what level of confidentiality will be placed on the system in order to keep unauthorized individuals from accessing it.

National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC6: The state has a plan for physical security and access control.

Retain Consider modification to request detail on both physical security, access security and cybersecurity.

Section 1325.210 Order of Authority

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112 a) Any order of authority issued by the Commission to a 9-1-1 Authority prior to January 1, 2016 shall remain in effect as if issued by the Administrator until the 9-1-1 Authority files a plan for consolidation under 83 Ill. Adm. Code 1324.200 or for modification under Section 1325.205 of this Part and a new order of authority is issued by the Administrator. The 9-1-1 Authority of a proposed or modified 9-1-1 system shall file a plan with the Administrator for an order of authority to operate a 9-1-1 system as detailed and described in the Authority's 9-1-1 plan. The Administrator will issue an order of authority authorizing the 9-1-1 Authority to operate under the terms of its initial or modified plan.

Local requirement Retain

113 b) Pursuant to ETSA Section 10, the Department is authorized to set technical standards for the provision of 9-1-1 Authorities throughout the State of Illinois. Pursuant to the Public Utilities Act [220 ILCS 5/13-900], the Commission is authorized to set technical standards for the provision of 9-1-1 service to be provided by telecommunication carriers and 9-1-1 system providers.

National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST1: Standards and best practices have been identified and implemented at the state level.

Retain

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Administrative Rule Reference Recommendations

114 c) All 9-1-1 plans must be filed electronically with the Department. Upon receipt of the plan, it will be posted on the Department's website. The Department will notify all vendors registered with it pursuant to Section 1325.305, perform a technical review to ensure compliance with this Part, and simultaneously submit the plan for a technical review by the Commission to ensure compliance with 83 Ill. Adm. Code 725.

Local requirement Retain

115 d) The public and industry will have 20 days to file written comments with the Administrator. After 20 days, or until notified otherwise by the Commission, the Department will proceed as though no separate Commission proceeding will be undertaken.

Local requirement Retain

116 e) If there are no contested issues in the filing, no public hearing will be warranted.

Local requirement Retain

117 f) If there are contested issues, the Administrator will schedule a public hearing to allow the parties who have issued written comments to appear in front of the Administrator and the applicant.

Local requirement Retain

118 g) Once the hearing is concluded the Administrator will decide whether to issue an order of authority or to deny the plan.

Local requirement Retain

Section 1325.215 Records and Reports

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119 a) The 9-1-1 Authority shall maintain those records it considers necessary to document its operations. As a minimum, those records shall include: 1) a log of major system operations;

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR24: The statutory environment has rules for retention of 9-1-1 call records and 9-1-1 related data.

Retain

120 2) critical CPE or network outages; and

Local requirement Retain

121 3) records of telecommunications carrier database queries by the 9-1-1 Authority.

Local requirement Retain

122 b) The records specified in subsection (a) shall be preserved for a minimum of one year and then disposed of in compliance with the Local Records Act [50 ILCS 205].

Local requirement Retain This does not apply specifically to the 9-1-1 call records; Consider a modification to include 9-1-1 call records and retain for at least a 6-month period. Verify reference for accuracy.

123 c) Pursuant to ETSA Section 15, and by January 31 of every year, each 9-1-1 Authority shall be required to file with the Administrator and the Illinois Attorney General the following items: 1) the current 9-1-1 contact person for the 9-1-1 system and that person's contact information; 2) the current error ratio for the E9-1-1 traditional legacy service database, as provided by the 9-1-1 system providers pursuant to Section 1325.405(i)(6);

Local requirement Retain Consider modification to also require certification that a Diversity Assurance Audit has been conducted and certified that the highest level of diversity that is available exists in the network.

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3) the current makeup of the ETSB and each board member's capacity (i.e., current public safety representative, public member, county board member, or elected official), as provided in ETSA Section 15.4; 4) a current network diagram for the 9-1-1 system, as provided by the 9-1-1 system providers pursuant to Section 1325.405(i)(7); 5) copies of the annual certified notification of continuing agreement for all participating agencies and adjacent agencies; 6) current list of all participating agencies and adjacent agencies; and 7) names and locations of all PSAPs, SAPs, VAPs and backup PSAPs.

Section 1325.220 Compliance with Technical and Operational Standards

124 The Department and Administrator shall have the authority to complete a site visit with 9-1-1 systems to verify compliance with technical and operational standards set forth in the Act and in this Part.

National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST2: The State requires specific operational standards for PSAPs to ensure a minimum level of service delivery.

Retain

SUBPART C: MANAGEMENT Section 1325.300 Department Liaison

125 Each 9-1-1 Authority, and each vendor eligible to receive network cost reimbursements pursuant to 83 Ill. Adm. Code 1329.210 or providing 9-1-1 service shall designate an individual as the Department liaison for the system. The 9-1-1 Authority and vendors

Local requirement Retain Verify reference for accuracy.

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shall provide the Department with their liaison's name, phone number, mailing address and e-mail address. The Department shall be notified of any change in this information within 10 days after this change. These liaisons shall be responsible for receiving and responding to all legal notices provided pursuant to 83 Ill. Adm. Code 1324, 1327 and 1329 and this Part.

SUBPART D: STANDARDS OF SERVICE Section 1325.400 9-1-1 Authority

126 The 9-1-1 Authority: a) Shall obtain Administrator authorization pursuant to Section 1325.210 prior to operating or making a modification to a 9-1-1 system;

Local requirement Retain Verify reference for accuracy.

127 b) Shall provide continual review using recognized administrative, engineering, database and security procedures to assure adequate service to the general public in accordance with ETSA and this Part;

Local requirement Retain

128 c) Shall comply with the provisions of all applicable federal or State laws regarding the provisioning of 9-1-1 services regarding wireline, wireless and VoIP or any other medium;

Local requirement Retain

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129 d) Shall provide the overall management for the 9-1-1 system and all of its PSAPs and work in conjunction with the 9-1-1 system providers on initial installation, continued maintenance, and any future modifications to the system;

Local requirement Retain

130 e) Shall enter into a service contract with one or more 9-1-1 system providers that have been authorized to operate in the State of Illinois pursuant to the Public Utilities Act [220 ILCS 5/13-900] to provide 9-1-1 database, call routing, and other 9-1-1 duties and services associated with the 9-1-1 system that clearly delineates the responsibilities of the 9-1-1 system provider and 9-1-1 Authority. A copy of this contract shall be filed with the initial or modified plan to be approved by the Administrator pursuant to Section 1325.205. Parties to the contract may deem all or a portion of the contract as proprietary and confidential;

Local requirement Retain Verify reference for accuracy.

131 f) Shall ensure that contracts with multiple 9-1-1 system providers clearly define the role of each 9-1-1 system provider as it relates to its responsibility for providing database, routing of emergency calls, and the building of the 9-1-1 network. The 9-1-1 Authority shall coordinate the tasks between 9-1-1 system providers;

Local requirement Retain

132 g) Must maintain data in the MSAG or its functional equivalent for those 9-1-1 systems employing new and emerging technology;

Local requirement Retain

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Administrative Rule Reference Recommendations

133 h) Shall develop and utilize written 9-1-1 Standard Operating Procedures (SOPs) for use by its telecommunicators and supervisory personnel (i.e., call trace for basic systems, service restoration/equipment failure, and disaster procedures in the event that critical functions of the PSAP are partially or totally disabled). Each PSAP shall be given a copy of the 9-1-1 SOPs that shall be kept on file at each PSAP;

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.12.2) SOPs support staff by providing procedural guidance. [S12b]

Retain

134 i) Shall ensure that civic 9-1-1 locatable addresses, with U.S. Postal Service approval, are assigned to all subscribers with a static address and provided to the 9-1-1 system provider;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

135 j) Shall coordinate with the appropriate authorities to ensure that the initial installation of road or street signs that are essential to the implementation of an E9-1-1 system will be installed prior to activating the system;

Local requirement Retain

136 k) Shall accept all OSP end user emergency calls from its 9-1-1 system provider as long as it is technically feasible, regardless of the technology employed in generating the emergency call. The 9-1-1 Authorities may only accept emergency calls routed into their system from a certified 9-1-1 system provider; and

Local requirement Retain

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Administrative Rule Reference Recommendations

137 l) Shall ensure that emergency calls are not routed or transferred to an automated attendant or automated voice response system.

Local emergency Retain

Section 1325.415 Answering Points – PSAP, Backup PSAP, SAP and VAP

138 a) All 9-1-1 CPE used by a PSAP, SAP or VAP must be compatible with the 9-1-1 system provider's equipment and transport arrangements.

National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST3: The state has defined PSAP performance standards.

Retain

139 b) Each PSAP, after consultation with the 9-1-1 system provider, shall designate an area of adequate size to be used by the 9-1-1 system provider for termination of the company's lines and equipment.

Local requirement Retain

140 c) The CPE shall indicate incoming calls by both audible and visible signals for each 9-1-1 circuit. Each outgoing circuit shall have a visual display of its status.

Local requirement Retain

141 d) Each 9-1-1 answering position shall have access to all incoming 9-1-1 circuits and outgoing circuits.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.1) Receipt of E9-1-1 calls using static ALI functionality. [S1]

Retain Consider modification that would exclude training positions.

142 e) The CPE shall be designed to achieve transfers with at least 99.9% completion. This may require the use of dedicated facilities between the PSAPs. When the telecommunicator verifies that the transfer has been completed and the telecommunicator's services are

Local requirement Retain

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Administrative Rule Reference Recommendations

no longer required, the telecommunicator may manually release himself/herself from the emergency call, provided that the CPE is so designed. A 9-1-1 system should be designed so that an emergency call will never be transferred more than once; however, there could be circumstances beyond the PSAP's control that might warrant more than one transfer.

143 f) Each answering position shall have direct access to an operational teletypewriter or its equivalent, and all PSAP, SAP and VAP telecommunicators shall be trained in its use at least every six months. The 9-1-1 Authority will ensure that TTY equipment or its equivalent is available to continue service in the event of emergency, malfunction or power failure.

National 9-1-1 Guidelines Assessment Report; Human Resources Environment: Guideline HR7: The state has continuing education guidelines for operational staff. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.6) Americans with Disabilities Act (ADA) compliance [S6] References: [01], [29] (3.3.17.1) TDD/TTY Equipment - DoJ Compliance [D17a] References: [01], [26], [29] (3.3.17.2) TDD/TTY Equipment Testing [D17b] References: [01], [26], [29]

Retain

282

Administrative Rule Reference Recommendations

144 g) At a minimum, each PSAP shall have at least two fully equipped answering positions. The staffing levels and the number of positions beyond this requirement shall be determined by the 9-1-1 Authority based on call volume and average length of calls (i.e., if PSAP is responsible for EMD, call processing could take longer and require additional telecommunicators). Overflow emergency calls shall be routed to a backup PSAP as provided for in subsection (i).

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR20: Statute exists for the provision of emergency medical dispatch (EMD).

Retain

145 h) The 9-1-1 Authority is responsible for ensuring that its PSAPs, backup PSAPs and SAPs provide continuous and uninterrupted operation 24 hours per day, 7 days a week.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.10.3) Status Monitoring of PSAP CPE [S10c] Related NRIC Best Practices: 7-7-0568 PSAP CPE is alarmed 24x7 for automatic trouble reporting/alerting. This includes the elements that are part of the transport path for voice or data, i.e., ANI/ALI controller, Private Branch Exchange (PBX) used for voice calls, modems used to support such equipment, and other mission critical equipment and associated software. It is acceptable for the PSAP to contract this monitoring out. The intent of S11c is for these alarms to be presented at the PSAP, even if they are remotely monitored too. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.14) Level of service provided from an alternate facility [S14] (aka: back-

Retain Consider also adding a requirement for CPE that should be alarmed for trouble 24x7.

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Administrative Rule Reference Recommendations

up PSAP) during a significant event that precludes use of the primary facility. Related NRIC BP 7-7-0568

146 i) Backup PSAP 1) Each 9-1-1 system shall have a backup PSAP that must operate independently from the primary PSAP. The backup PSAP must have the capability to dispatch (by either direct, transfer or call relay methods) the appropriate public safety agencies for that 9-1-1 system. A backup PSAP shall meet the same standards as the primary PSAP, except as provided for in subsection (i)(2).

National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST2: The State requires specific operational standards for PSAPs to ensure a minimum level of service delivery. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.14) Level of service provided from an alternate facility [S14] (aka: back-up PSAP) during a significant event that precludes use of the primary facility. Related NRIC BP 7-7-0568

Retain

147 2) In a 9-1-1 system with a population of fewer than 10,000, when the system has demonstrated that the requirements of subsections (g), (h) and (i) would place an undue financial burden on the system, the 9-1-1 Authority can ask the Administrator for an exemption from having a full feature, manned backup PSAP. A 9-1-1 system operating under this exemption should, as funds become available, upgrade its backup PSAP capability to meet those standards specified in subsections (g), (h) and (i)(1). If the system ever exceeds 5,000 billable access lines for a period of one year, it shall upgrade to meet the

National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST2: The State requires specific operational standards for PSAPs to ensure a minimum level of service delivery. Population thresholds: local requirement

Retain

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standards specified in subsections (g), (h) and (i)(1). For those systems operating under this exemption, some alternative form of backup shall be required. The backup PSAP requirement may be met by one of the following:

148 A) An unattended PSAP shall have: i) the capability to provide 9-1-1 service; ii) the communication equipment necessary to dispatch emergency services; iii) a backup power supply; iv) the ability to communicate via TTY; and v) the capability to be immediately activated with authorized and trained personnel; or

Local requirement Retain

149 B) Some other method that the 9-1-1 Authority must be able to demonstrate, in its request for an exemption, would meet the public safety needs of its community by being able to take 9-1-1 calls and dispatch them successfully on a temporary basis in an emergency situation.

Local requirement Retain

150 j) The use of VAPs may be acceptable; however, this must be included as a part of the 9-1-1 system final or modified plan authorized by the Administrator.

Local requirement Retain

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Administrative Rule Reference Recommendations

151 k) All telecommunicators shall be trained in emergency dispatch procedures and 9-1-1 SOPs as specified by the 9-1-1 Authority to fulfill the responsibilities of their position, with the following requirements: 1) Newly hired telecommunicators must receive, at a minimum, an 80-hour training curriculum approved by the 9-1-1 Authority prior to handling emergency calls.

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR18: The statutory environment provides for training. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.3.5) Training [D5a through D5b] There is a documented training process for new employees that meets local or State minimum requirements, and it is reviewed annually to retain consistency with operational changes that may be driven by new technologies, applications etc.

Does 9-1-1 Administrator have authority to require minimum training and that recommended minimum training guidelines are included in any 911 authority training program or that the 911 authority certify that their training program meets the recommended minimum training guidelines? http://wc911.squarespace.com/minimum-training-guidelines-do

152 2) If emergency medical dispatch is being provided that involves the dispatch of any fire department or emergency medical service agency, additional training must be completed in accordance to the Emergency Medical Services (EMS) Systems Act [210 ILCS 50] and 77 Ill. Adm. Code 515 in addition to the 80-hour minimum.

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR20: Statute exists for the provision of emergency medical dispatch (EMD).

Retain

153 3) Continuing education for existing telecommunicators is required in all aspects of emergency call handling and will be specified by the 9-1-1 Authority.

National 9-1-1 Guidelines Assessment Report; Human Resources Environment: Guideline HR7: The state has continuing education guidelines for operational staff.

Retain

286

Administrative Rule Reference Recommendations

154 l) The 9-1-1 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. These recordings shall have the time of each event noted. The 9-1-1 Authority may elect to record, on a circuit-by-circuit basis, or by way of the telecommunicator's position.

National 9-1-1 Guidelines Assessment Report; Statutory and Regulatory Environment: Guideline SR24: The statutory environment has rules for retention of 9-1-1 call records and 9-1-1 related data. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.3.6) Logging Recording [D6] 3.3.6.1 Standard Criteria: Records all incoming emergency calls, with instant recall capability. 3.3.6.2 Advanced Criteria: Records all incoming emergency calls and all radio traffic associated with emergency calls. 3.3.6.3 Superior Criteria: Records all new incoming emergency and non-emergency calls, associated ALI/CAD and multimedia data.

Retain

155 m) The 9-1-1 Authority shall ensure that each answering point maintains an archive of the storage media for a minimum of 90 days without recirculation of any media.

Local requirement 9-1-1 records should be kept for a longer period than 90 days; in most cases it is generally six months.

156 n) When CPE is implemented and is not tolerant of power fluctuations or interruptions, and is vital to the PSAP's, backup PSAP's, SAP's and VAP's operation, an uninterruptible power supply shall be installed at all locations for continuous operation.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.21) Alternate Power Source with Sustainable Fuel Options/Sources [S21]

Retain Consider modification: “The backup power source shall be tested under load for reliability on a monthly basis.” A test of backup power under load is performed according to NFPA 1221 [08] Chapter 11-Testing.

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Administrative Rule Reference Recommendations

157 o) All answering point locations must be equipped with an emergency backup power source capable of supplying electrical power to serve the basic power requirements of the answering point, without interruption, for longer outage time frames. It shall provide a minimum of four hours of power. The backup power source shall be tested for reliability on a monthly basis.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.21) Alternate Power Source with Sustainable Fuel Options/Sources [S21]

Retain Consider modification: “The backup power source shall be tested under load for reliability on a monthly basis.” A test of backup power under load is performed according to NFPA 1221 [08] Chapter 11-Testing.

158 p) Each answering point shall have at least one 24-hour staffed telephone number to be provided to telecommunications carrier operators, adjacent PSAPs, and public safety agencies in order to communicate with that answering point.

NFPA has recently amended their standards to require a minim of two people per dispatch center at all times.

Consider modification in alignment with NFPA 1221 standard.

159 q) 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 of communications.

Recommended Minimum Training Guidelines http://wc911.squarespace.com/minimum-training-guidelines-do

Consider adopting the Recommended Minimum Training Guidelines.

160 r) Each answering point shall ensure that all emergency calls are answered and handled without preference to the location of the caller.

Confirm with NFPA standard Retain

161 s) Each answering point should answer 90% of all emergency calls within 10 seconds.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.15) Staffing as Applied to Critical Incident Situations [S15] 5

Retain Check NFPA revised standard for compliance.

288

Administrative Rule Reference Recommendations

162 t) All calls of an administrative or nonemergency nature shall be referred to the appropriate agency's published telephone number.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.15) Staffing as Applied to Critical Incident Situations [S15] 5

Retain

163 u) A current copy of the 9-1-1 Authority's SOPs shall be on file in every answering point.

APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.2.10.4) [S10d] Related NRIC Best Practices: 7-7-0568

Retain

SUBPART E: OPERATIONS Section 1325.500 Testing Procedures

164 a) The 9-1-1 Authority shall prepare a written test plan to be submitted as an exhibit to the final plan filled with the Administrator, pursuant to Section 1325.205. The test plan will explain how the 9-1-1 Authority plans to perform its testing in conjunction with the 9-1-1 system providers and carriers.

Local requirement Retain Verify reference for accuracy.

165 b) The 9-1-1 Authority shall ensure that proper field testing and data verification has been performed on access lines in the 9-1-1 service area as prescribed in this subsection (b). The testing shall include each NXX for every telecommunications carrier and for every ESN within each service area prior to the 9-1-1 system being able to announce its availability to the public.

Local requirement Retain

166 1) New 9-1-1 system, or a new 9-1-1 system consolidating with an existing 9-1-1 system: 10% of the new portion only shall be tested;

Local requirement Retain

289

Administrative Rule Reference Recommendations

167 2) Change of 9-1-1 system provider, conversion to NG9-1-1, consolidation of an ETSB with a rerouting of calls to a different PSAP, and consolidation with a reduction of PSAPs with the same ETSB: a sample of each exchange, 2 test calls per type of service; i.e., each land-line carrier (2 calls each), each wireless carrier (2 calls each), each Interconnected VoIP provider (2 calls each, if known); and

Local requirement Retain

168 3) Other changes to a 9-1-1 system, not outlined in subsection (b)(1) or (2): testing as directed by the Department's Office of the Statewide 9-1-1 Administrator.

Local requirement Retain

169 c) The 9-1-1 system provider may not cut the 9-1-1 system live until the 9-1-1 traditional legacy service database is at a 1% or less error ratio, pursuant to ETSA Section 750/15.4(d). Errors found during testing shall be corrected prior to cutting the system live.

Local requirement Retain

290

Administrative Rule Reference Recommendations

170 d) The 9-1-1 Authority is responsible for ongoing testing once the 9-1-1 system is on-line and shall, at a minimum, include the following: 1) The 9-1-1 Authority shall conduct testing, including, but not limited to, the 9-1-1 database, networking, system overflow, system backup, default routing, and call transfer on a continuing basis to ensure system integrity. The testing shall be coordinated in advance and in conjunction with the 9-1-1 system provider and carriers.

Local requirement/agreement Retain

171 2) The 9-1-1 Authority and 9-1-1 system providers shall participate in coordinated testing with the carriers when any of the following occurs: A) New central office switching installations; B) E9-1-1 selective router or functional equivalent installations, upgrades or rehomes (i.e., resetting of the network system); C) NPA (Numbering Plan Area) additions; D) Migration from one 9-1-1 system provider to another; and E) Any other event that affects 9-1-1.

Local agreement Retain

172 3) Upon request, after notification of implementation, the 9-1-1 Authority shall perform coordinated testing with the private residential or business switch operators.

Local agreement Retain

Section 1325.505 Call Handling Procedures

291

Administrative Rule Reference Recommendations

173 a) The 9-1-1 Authority shall ensure that the disposition of each emergency call is handled according to the agreements it has negotiated with its participating public agencies and public safety agencies and adjacent 9-1-1 Authorities and/or public agencies or public safety agencies listed in the plan (see Section 1325.205).

Local requirement SAFECOM Writing Guide for a Memorandum of Understanding (MOU) https://transition.fcc.gov/pshs/docs/clearinghouse/DHS-MemorandumOfUnderstanding.pdf

Retain Verify reference for accuracy.

174 b) Certified notification of the continuing agreements shall be made among the involved parties on an annual basis pursuant to ETSA Section 14.

SAFECOM Writing Guide for a Memorandum of Understanding (MOU) https://transition.fcc.gov/pshs/docs/clearinghouse/DHS-MemorandumOfUnderstanding.pdf

Retain

175 c) In instances in which a selected agency refuses a 9-1-1 request on the basis that a request is outside its jurisdictional boundaries, the telecommunicator shall make every effort to determine the appropriate responding agency and complete the disposition of the call.

Local requirement Retain

176 d) The agreements shall provide that, once an emergency unit is dispatched in response to a request through the system, that unit shall render its services to the requesting party without regard to whether the unit is operating outside its normal jurisdictional boundaries. [50 ILCS 750/14]

Local requirement Retain

Section 1325.510 Electronic Communication Devices

292

Administrative Rule Reference Recommendations

177 Except for the purpose specifically indicated and authorized by law, the installation of or connection to the 9-1-1 system network of an automatic alarm, automatic alerting device, or mechanical dialer that causes the number 9-1-1 to be dialed is prohibited in a 9-1-1 system (e.g., elevator one-button phones, security pole one-button phones, or burglar alarms).

Local requirement Retain

Section 1325.515 Physical Security

178 a) The 9-1-1 Authority must ensure that critical areas of an answering point shall have adequate physical security to prevent malicious disruption of service and shall be protected against damage due to vandalism, terrorism and civil disturbances. These critical areas shall, at a minimum, include all communications equipment, personnel, electronic equipment rooms, and mechanical equipment rooms that are vital to the operation of the answering point.

National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC6: The state has a plan for physical security and access control. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale (3.3.4) Physical Access Controls for Primary and Off Site Locations Where the Buildings or Applicable Space Used for PSAP Purposes are Under the Control of the AHJ. [D4] This item refers to physical access to rooms, equipment and software applications, etc. Off site locations may include radio towers and other equipment locations essential for PSAP operations. References: [22], [27]

Retain Consider adding a section on Access Security separating Physical security (things like hardened facilities, dual equipment entrances, etc.) and Access security (who has access to equipment, password protections, etc.)

293

Administrative Rule Reference Recommendations

179 b) The answering point and its personnel shall be isolated from direct public contact.

National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC6: The state has a plan for physical security and access control.

Retain

180 c) Entry to the answering point shall be restricted to authorized persons only. Additionally, doors that lead directly from the exterior into the answering point, or from within a building into the answering point, shall be secured at all times.

National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC6: The state has a plan for physical security and access control.

Retain May decide to put this under Access Security section suggested above.

181 d) Access to the communications and electronic equipment rooms shall be restricted within the building by means of secured doors.

National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC6: The state has a plan for physical security and access control.

Retain May decide to put this under Access Security section suggested above.

182 e) Wherever practical, service entrances for electric and telephone service shall be underground, at least to the respective utilities' nearest serving distribution point. Protective measures shall be taken against vandalism and natural or manmade hazards at each answering point.

National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC6: The state has a plan for physical security and access control. APCO/NENA ANS 1.102.2-2010 Service Capability Criteria Rating Scale

Retain May decide to put this under Physical Security section suggested above.

294

Administrative Rule Reference Recommendations

183 f) The answering point shall be equipped with a fire extinguisher. Personnel shall be instructed in proper use of these extinguishers.

National 9-1-1 Guidelines Assessment Report; Security and Continuity of Operations Environment: Guideline SC7: PSAP facilities and system facilities are planned, designed and constructed according to accepted site selection standards and best practices.

Retain May decide to put this under physical Security section suggested above. Consider change “to appropriate fire suppression devices …”

Section 1325.520 9-1-1 Traditional Legacy Service Database

184 a) 9-1-1 database queries will only be allowed by PSAPs, backup PSAPS, SAPs and VAPs for purposes of dispatching or responding to an emergency call or for database integrity verification as set forth in subsection (c).

Local agreement with data provider Retain

185 b) Prior to an initial database integrity verification, the 9-1-1 Authority shall obtain a court order detailing the information that is to be disclosed and the reason for disclosure.

Local requirement Retain

186 c) The 9-1-1 database shall have the capability of allowing database verification queries, provided that the following procedures are adhered to: 1) The 9-1-1 Authority shall be responsible for providing a level of security and confidentiality to the database that will prohibit random inquiries.

Local agreement with data provider Retain

295

Administrative Rule Reference Recommendations

187 2) Direct access to 9-1-1 database information will be under strict control and, when technically feasible, a password will be assigned for access by authorized persons only.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

188 3) Database verification queries shall be by subscriber number only and as necessary for purposes of database integrity. Queries in excess of 10 per 24-hour period will only be done with 2 or more days advance notice to the respective 9-1-1 system provider for scheduling purposes. Queries may be for the specific purpose of cross-checking information in the 9-1-1 database with other sources of information, including telephone and other directories, maps, municipal database listings, etc., and for verifying that database update information provided to the 9-1-1 system provider has indeed been posted and is correct. On-site 9-1-1 databases are exempt from 9-1-1 system provider advance notification requirements of this Section.

Local agreement with data provider Retain

296

Administrative Rule Reference Recommendations

189 4) Information retrieved will be used exclusively for the maintenance, update and verification of the 9-1-1 database, except as otherwise specified in subsection (a). Any other use is expressly prohibited. The information is subject to strict nondisclosure agreements between the various OSPs and 9-1-1 system providers and the 9-1-1 Authority. All personnel associated in any way with the 9-1-1 Authority and the 9-1-1 systems are bound by these agreements.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 3.25) The ALI SP shall restrict the usage of LEC data to emergency purposes as mandated by legislation. SP data shall not be provided to other entities without the written permission of that SP, unless legislation permits.

Retain

190 5) Trunks/facilities that are not used to transport 9-1-1 emergency calls into the PSAP are prohibited from being connected to the 9-1-1 CPE in any way to allow for queries of the 9-1-1 database.

Local requirement Retain

191 6) Database queries for the purpose of database verification shall be limited to off-peak times.

Local agreement with data provider Retain

192 7) Database queries shall not be made if there is any known outage or impairment in the database system, including a database data link outage. In the event of an outage, the 9-1-1 system provider shall treat outage notification of the 9-1-1 Authority regarding database query suspension as a priority. When practicable, this notification shall be made no later than 15 minutes after a confirmed incident that will cause database queries to be suspended.

Local agreement with data provider Retain

297

Administrative Rule Reference Recommendations

193 d) Each telecommunications carrier shall provide updates to the appropriate 9-1-1 system provider for the 9-1-1 database on a daily basis, or more frequently when technology supports it, Monday through Friday during business hours.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 3.22) Periodic reconciliation of the 9-1-1 database with the originator’s database is required as specified in the Data Quality Measurements. (para: 5.2) 9-1-1 DBMSPs must process each SP’s update file(s) and provide positive electronic confirmation of the processing of 9-1-1 DBMS updates to all SPs within one (1) business day of receipt of the file from the SP. The confirmation shall include the entire TN record processed, date and time processed, number of records processed, number of records that erred, and the actual error records. (para: 5.9) In order to maintain database accuracy and update timeliness, 9-1-1 DBMSPs must forward copies of all MSAG Update Requests, ANI/ALI Trouble Reports, Daily Error Files, No Record Found (NRF) reports within one (1) business day of receipt to all SPs. Additionally, all documents must be logged with date/time stamp.

Retain Consider requiring annual reconciliation of the 9-1-1 database.

298

Administrative Rule Reference Recommendations

194 e) A 9-1-1 Authority using an on-site database is restricted from making any changes to the 9-1-1 data that has been downloaded for its use. Only the 9-1-1 system provider has the authority to correct errors or provide updates to the database. The 9-1-1 Authority must adhere to the proper error resolution procedures specified in subsection (g).

Local requirement Retain

195 f) 9-1-1 Authorities, 9-1-1 system providers, and carriers shall utilize mutually acceptable and agreed upon standards as prescribed, at a minimum, by the NENA Standards for 9-1-1 databases. 1) Data Formats for ALI, MSAG and GIS (02-010, v9); 2) 9-1-1 Data Management (02-011, v7); and 3) Provisioning and Maintenance of MSAG Files to VDBs and EKDB (02-013, v3).

Local requirement Retain

299

Administrative Rule Reference Recommendations

196 g) Error Resolution 1) It shall be the joint responsibility of the 9-1-1 Authority, the 9-1-1 system provider, and telecommunications carriers to ensure that the error ratio of each 9-1-1 system's database shall not, at any time, exceed 1%.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 6.7) It is desirable that Jurisdictions, DBMSPs, and SPs have a 98% database accuracy (MSAG valid ALI records) prior to taking ‘LIVE’ Enhanced 9-1-1 calls. National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST4: The state requires specific interface standards for the exchange of 9-1-1 related data between functional entities.

Retain

197 2) The 9-1-1 Authority or 9-1-1 system provider shall forward all error reports within two business days after finding the error to the 9-1-1 Authority, 9-1-1 system provider, or carrier to take appropriate action to resolve the error.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 5.9) In order to maintain database accuracy and update timeliness, 9-1-1 DBMSPs must forward copies of all MSAG Update Requests, ANI/ALI Trouble Reports, Daily Error Files, No Record Found (NRF) reports within one (1) business day of receipt to all SPs. Additionally, all documents must be logged with date/time stamp. National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST4: The state requires specific interface standards for the exchange of 9-1-1 related data between functional entities.

Retain

300

Administrative Rule Reference Recommendations

198 3) If the error is a record of the 9-1-1 system provider, it must be corrected and updated within 2 business days after receipt of the error. If the error is for a participating carrier, the 9-1-1 system provider shall forward the error to the appropriate carrier or 9-1-1 Authority for resolution.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 5.3) 9-1-1 DBMSPs must not correct a SP’s error records without that SPs written authorization. National Assessment Guideline ST4: The state requires specific interface standards for the exchange of 9-1-1 related data between functional entities. (para: 5.9) In order to maintain database accuracy and update timeliness, 9-1-1 DBMSPs must forward copies of all MSAG Update Requests, ANI/ALI Trouble Reports, Daily Error Files, No Record Found (NRF) reports within one (1) business day of receipt to all SPs. Additionally, all documents must be logged with date/time stamp. (para: 17.3.2) Individual Entity and total posting time for MSAG updates from receipt to completion, telco initiated and jurisdiction initiated. Jurisdictions have 5 business days to complete request as they usually have to work with another department within the county or city who is responsible for addressing, unless state regulations or local contracts are in force. Reporting and Resolving ANI/ALI Discrepancies and No Records (NENA 02-015, Version 1, June 6, 2009)

There is a conflict between what is required in the statute and what is recommended by the NENA standard. This conflict should be resolved and, if appropriate, the administrative rule should be updated.

301

Administrative Rule Reference Recommendations

199 4) Any telecommunications carrier receiving an error record from the 9-1-1 system provider has two business days upon receipt of the error to work with the 9-1-1 Authority and process the corrections and forward the appropriate updates to the 9-1-1 system provider. If the error is for an OSP, the 9-1-1 Authority will forward those on to the appropriate company for review.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 8.2) Each SP is responsible for resolving their own errors by working directly with the Jurisdiction. National 9-1-1 Guidelines Assessment Report; Standards Environment: Guideline ST4: The state requires specific interface standards for the exchange of 9-1-1 related data between functional entities.

Retain

200 5) The 9-1-1 Authority shall retest and/or validate that all errors have been corrected (e.g., no record found, misroutes).

Local requirement

Retain

201 h) The 9-1-1 Authority shall, on a continuing basis, maintain the MSAG (or GIS database or functional equivalent), the ELT for each ESN, and the associated telephone numbers for the ELTs.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 7.3.2) Jurisdictions are responsible for the maintenance and content of their MSAG.

Retain

302

Administrative Rule Reference Recommendations

202 i) Upon a written request of the 9-1-1 Authority, the 9-1-1 system provider shall submit, within 14 working days, a report to assist in the validation of the accuracy of the 9-1-1 database. Before this report is delivered to the 9-1-1 Authority, the 9-1-1 Authority shall enter into nondisclosure agreements with telecommunications carriers and Interconnected VoIP providers to protect proprietary network and customer-related information from public disclosure, consistent with the Illinois Freedom of Information Act (FOIA) [5 ILCS 140/7(1)] and other applicable federal or State law.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012): discusses data audits / reconciliation and comparisons. However, it does not require a written request nor does it speak to the NDA requirement noted in this local rule. NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012, para: 7.6) It is preferred that the Jurisdiction MSAG be compared with the DBMSP MSAG at least twice a year.

Retain

203 1) This report shall include the following information when available in the 9-1-1 database: A) telephone number − area code, prefix and number in separate fields;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

204 B) pilot number − single telephone number used to tie together multiple numbers within a system;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

205 C) service (civic) address − including street name, house number or equivalent, suffix, directional, community name, state, zip code and location and/or descriptive information, including intersection if MSAG indicates an intersection, in separate fields;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

303

Administrative Rule Reference Recommendations

206 D) billing address − if different than the service address, in separate fields, to be provided on a telephone number only basis, pursuant to procedures defined by the telecommunications carrier and the 9- 1-1 Authority. Billing address information shall be subject to nondisclosure agreements;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

207 E) name − first, last and middle names or initials in separate fields;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

208 F) date service was initiated − the month, day and year that service was initiated, in separate fields. If this information is not available, the date reflecting the most current service order activity may be provided instead;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

209 G) type of service − residential, business, coin, etc.;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

210 H) PBX/Centrex Extensions/Station Numbers − identify those numbers that are part of a PBX/Centrex system, when this information is available;

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain

304

Administrative Rule Reference Recommendations

211 I) surcharge status − when this information is available, the report shall identify those lines on which a surcharge is being collected and the date on which the collection was initiated. Identify those lines on which no surcharge is being collected and the reason for each exemption, including telecommunications carrier lines, in separate fields;

Local requirement Retain

212 J) Emergency Service Number − appropriate ESN, if assigned, is to be made available only from the primary 9-1-1 system service provider providing database development and routing services.

NENA Data Standards for Local Exchange Carriers, ALI Service Providers & 9-1-1 Jurisdictions (NENA 02-011, Version 7.1, May 12, 2012)

Retain Is this to be validated by the 9-1-1 Authority? The requirement should be clear and, if necessary, rewritten.

213 2) This report may be requested by the 9-1-1 Authority, in writing, at a maximum, on a monthly basis. The information in this report is considered proprietary and shall be used exclusively for validating the accuracy of the 9-1-1 database. This report will be delivered in an electronic format. It will not be delivered in paper format. There will be a charge for this report that will be a tariffed item by each 9-1-1 system provider.

Local requirement Retain Consider modification to: “There will may be a charge for this report that will be a tariffed item by each 9-1-1 system provider.” Is a “tariff” applicable to all service types and providers? If this is not going to be the case in NG9-1-1, this requirement may need to be updated to reflect the new environment.

305

Administrative Rule Reference Recommendations

214 j) A 9-1-1 Authority that has or is in the process of transitioning to an NG9-1-1 system when the 9-1-1 traditional legacy service database will be used in conjunction with, or eventually be replaced with, dynamic data must provide a detailed explanation of the initial development and ongoing maintenance of necessary databases in the NG9-1-1 final plan or modification, pursuant to Section 1325.205(f).

Local requirement Retain

Section 1325.525 Outage Notification

215 Once the 9-1-1 Authority has been notified of an outage occurring in the 9-1-1 system, it must make notification to any other PSAPs in the 9-1-1 system that are affected by the outage.

Network Reliability and Interoperability Council Best Practices

Retain Consider modification to: “…it must make notification to any other PSAPs in the 9-1-1 system that are affected by the outage and the state 9-1-1 Administrator.”

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Appendix G – Cooperative Agreements

Illinois statute, 50 ILCS 750/14) (from Ch. 134, par. 44, Sec 14) stipulates that “all 9-1-1 authorities public agencies in a single system shall enter into call handling and aid outside jurisdictional boundaries agreements with each participating agency and adjacent 9-1-1 system.” While PSAP jurisdictions are familiar with simple call handling agreements, the guidance in this section should assist 9-1-1 authorities with more complex agreements between multiple agencies and multiple legal jurisdictions and regions. It will also assist the State in formulating interstate cooperative agreements (ICAs) with its bordering states. Cooperative Agreements or Memorandum of Understanding An ICA, known also as an MOU, is the mechanism used by governing bodies and entities of authority that outlines the roles, authority, contributions, and parameters on which the parties to the agreement have concurred as they relate to a particular project or situation. Such an agreement identifies the responsibilities of the parties, any financial obligations or understandings, and demarcation of tasks or duties, and often is used to clarify policies, procedures, and practices that will be followed, and voting rights of the participants to the agreement. Informal agreements are fine for modest projects, but a complex undertaking such as combining previously separate 9-1-1 authorities in a consolidation project or linking/interconnecting two or more regional ESInets demands a more formal approach to how the jurisdictions will integrate and manage their services. The Need for an ICA/MOU Agencies use an ICA/MOU as the formal documentation of how the parties will work together on an agreed-upon project or meet an agreed-upon objective. The main purpose of such a document is to establish a written understanding of the responsibilities and expectations of each party. The ICA/MOU should be a legal document that is binding and holds the parties responsible to their commitments. Jurisdictions and agencies are familiar with these types of agreements and often will have agreements in place for call handling processes between counties or PSAP jurisdictions. There is less evidence that this is a common occurrence between states or regions, at least not within the 9-1-1 community. However, because NG9-1-1 systems will be intricately linked to enjoy the full benefits of NG9-1-1 features and functionality, it is becoming more and more a standard practice to initiate an MOU. When beginning to establish statewide best practices for ICAs, it is recommended that the State: • Engage local agency or regional legal departments early in the process • Try to find existing agreements between 9-1-1 authorities from which previously agreed-upon language

can be drawn to replicate in an NG9-1-1 ICA/MOU Do not underestimate the time it will take legal departments to craft appropriate language for the ICA/MOU to which both participating jurisdictions can agree; this is a lengthy process.

307

Writing an ICA/MOU There are numerous lessons learned that can be useful when undertaking an endeavor of this kind. Moreover, there are tools available to help the jurisdictions through the process. Consult the references provided, start the process early, get legal teams involved in the process, have a clear definition of what is wanted in an agreement, and formalize it in writing. The NENA Inter-Agency Agreements Model Recommendations Information Document60, NENA-INF-012.2-2015, provides model recommendation for the development of mutual aid agreements and MOUs between PSAPs and affiliated or support organizations. The documents should be modified to meet the unique requirements of individual municipalities, regions, or 9-1-1 authorities. The SAFECOM Writing Guide for a Memorandum for Understanding (MOU)61 addresses one of SAFECOM’s goals to provide the public safety community with tools to progress along all elements of the Interoperability Continuum. This tool focuses on the Governance element of the Continuum and is specifically aimed to help communities interested in establishing formal agreements, such as MOUs, to address multi-organization coordination and communications. The Governance continuum is provided below.

This document is laid out in a recommended MOU structure with suggested headings for each section. Each section poses questions to consider for guidance to the jurisdiction when writing content for it. Sample paragraphs are included as reference; however, please note that the sample paragraphs are geared for illustration purposes toward a specific MOU example. The document does not address every issue that jurisdictions may face when establishing an MOU. An MOU should be customized to the capability or resource for which it is established and should consider any unique characteristics of the specific community and participating jurisdictions. There are two primary reasons why writing a formal agreement is important. First, it will document everyone’s understanding of their respective responsibilities and the process that all parties will have to

60 www.nena.org/resource/resmgr/Standards/NENA-INF-012.2-2015_InterAge.pdf 61 https://www.dhs.gov/sites/default/files/publications/Writing%20Guide%20for%20a%20Memorandum%20of%20Understanding_0.pdf

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follow. Second, a formal agreement provides historical information that will be useful as time goes by to codify what has been done, even if the principals currently involved no longer are in their present positions. What an ICA/MOU Should Include Each section of the SAFECOM MOU guidance poses questions or concepts to consider, guiding the State or region when writing content for an agreement. Sample paragraphs also are included to provide suggestions on what might be included. It is important to note, however, that the sample paragraphs are intended for illustration purposes to help the jurisdiction build the specific ICA/MOU that is appropriate for their purposes. It is likely that each participating agency to an agreement will have existing agreements for other services or purposes from which they will want to draw. It might be helpful for the jurisdictions to consider all the factors that the jurisdiction established and consider any unique characteristics of the specific community and participating jurisdictions as appropriate. Some typical sections that should be considered for inclusion in an ICA/MOU are listed below.

Section Considerations

Clarify terminology Identify authorized representatives

State audit requirements State data practices considerations

State sovereign immunity conflicts Commitment of vendor(s) for testing

Entrance criteria for adding new partners to the ICA/MOU

Provisioning, testing and verification process responsibilities

Effective date of the agreement and any reference to renewal, review, or expiration dates, if desired

Contact information, including but not limited to escalation point of contact for reporting issues 24 x 7 x 365

Change notification process, i.e., if this is an agreement between two regions or between two states, how each of the parties will keep others informed of any changes they will be making to their systems that may have impact on other parts of the systems or networks

Mutual agreement of database reconciliation to ensure database compatibility within participating systems, e.g., pseudo ANI (P-ANI)

Change management processes that the parties will agree to follow when any changes to systems or networks are implemented

Commitments to provide prompt notification to the other parties regarding service interruptions or problems, regular system maintenance, system security, aligning operational procedures or any other processes that are employed by the jurisdictions

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Section Considerations

Dispute resolution process, i.e., how issues will be identified, tracked, addressed and escalated if not resolved:

• Who will manage or maintain the records, administer the system, or act as system integrator?

• What will be the venue for any litigation? Whose laws will govern?

• What are the responsibilities/actions of the disputed party?

Cost allocation, i.e., if there are any shared elements, how will costs be shared:

• How will the responsibilities of each jurisdiction be identified and clarified?

• How will upgrades and ongoing maintenance be funded?

• What are the financial obligations of the parties?

Termination/withdrawal of partners, i.e., the conditions, notification criteria, and technical issues under which a jurisdiction may withdraw from the Agreement:

• What are the circumstances or conditions for withdrawal?

• What notification to the other parties to the Agreement is necessary?

• What is the process for exiting the Agreement?

Is there any financial implication, either to the exiting jurisdiction or to the remaining parties?

Annual review of agreement(s) • What circumstances will require a change to

the Agreement? • What is an appropriate timeline for review? • What will be the process for amending the

Agreement?

Assignment: • Can the Agreement be “assigned” or

transferred to another entity or a succeeding legal authority?

• Is there any approval needed or required?

Mutually agreed-upon policies and procedures; it will be much easier to manage situations when things go awry

Other possible agreements that may be necessary or important to the successful implementation and ongoing operation of the networks include tribal agreements (if applicable) and SLAs.