Background and facts of interest:

The ETSA Emergency Telephone System Act (50 ILCS 750) governs how the Illinois 911 system
works. It defines the amounts levied in phone taxes, provides the administrative framework, spells out
how collected money can be spent and sets the technical standards by which 911 system is ran.
Vermilion and other counties have an administrative board, an ETSB (emergency telephone service
board). It is our 911 Authority for our jurisdiction.
Our county ETSB had two PSAPs, (primary service answering points) that took 911 calls, Hoopeston
and Vermilion Co. (at the PSB). Hoopeston was Vermilion's backup and vice versa. Earlier this year,
Vermilion changed their backup to Metcad in Champaign.
Illinois amended the ETSA last year in attempt to streamline and cut costs, while at the same time
expanding 911 to some counties that still didn't have a 911 system. A hodgepodge of different local
taxing rates were eliminated in favor of a uniform 87 cents per line (both wireless and landline) for
everyone in the state. Some of the money is used to establish 911 coverage for the counties without a
system. It also forced a consolidation of services, reducing PSAPs and ETSB's, especially in more
populated counties. Some counties had upwards of 18 PSAPs. The goal is to reduce PSAPs by 50%.
Hoopeston did not have the capability to receive wireless 911 calls. These were routed to Vermilion. As
people dropped landlines and cell phone use increased, nearly 75 percent of the 911 calls were taken by
Vermilion. The landline 911 calls were still being answered by Hoopeston. The overwhelming majority
of calls came in over the 283-5196 number.
At some point, Hoopeston was told that the state was mandating a consolidation of PSAPs. At that
point, the money that would need to be spent in upgrades seemed unnecessary since such a small
amount of actual 911 calls were being answered in Hoopeston anyway.
As it turns out, consolidation was not mandated. According to the statute, a county population less than
250,000 had to reduce PSAPs by 50 percent or a total of 2, whichever was greater.
Hoopeston had voluntarily given up its status as a PSAP, agreeing to have Vermilion become its
calltaker. A plan was submitted by Vermilion Co. ETSB to the state outlining their proposed system to
cover all of Vermilion County, complete with call handling agreements signed by all agencies formerly
served by HPD. These call handling agreements define the manner in which services would be
dispatched. It is what gives the PSAP the legal authority to dispatch the call after it is taken.
HPD and the agencies they dispatched believed, and were initially told, the only change would be in
the 911 call taking duties. Everything else would remain the same as it was. It would be almost exactly
as it had operated for years except now both wireless AND landline 911 calls would be answered by
Vermilion.
** Previously a wireless call was routed to Vermilion. The 911 call taker took the information and
made a CAD (computer aided dispatch) ticket that was visible to the HPD dispatchers, whereby
HPD would dispatch police, fire, ambulance. If a person walked into the police station, dialed 911
from a landline or dialed 283-5196, HPD would make a CAD ticket and dispatch appropriate agencies.

Shortly thereafter, interpretations on the dispatching process began to change. First, Vermilion decided
they must dispatch the calls they took. The previously used method of CAD was not acceptable. Then,
it was decided that all calls to 5196 had to be transferred to Danville. Then even people walking in to
the station had to wait until an officer was "dispatched" out of the office. It was not allowable for HPD
dispatch to type a call ticket into the CAD but instead had to call Vermilion and wait for them to do it.
None of these interpretations above appear to have any state mandated authority behind them, only
preference by Vermilion Co. and whatever negotiated agreements as to policy and protocol entered into
by Hoopeston. In the simplified version, Vermilion Co. is our 911 PSAP, our call taker. Everything
beyond that is negotiated agreement.
From the administrative code used to define the operational guidelines for 911 systems:
Section 1325.505 Call Handling Procedures
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).
b) Certified notification of the continuing agreements shall be made among the involved parties
on an annual basis pursuant to ETSA Section 14.
Many PSAP's residing in dispatch centers facing forced consolidation wish to retain their dispatch
centers. Waivers can be filed (and have been with the ISP, the department overseeing the Office of the
Statewide 911 Administrator . From the waiver filed by Madison Co.:
The Narrative indicates that most of the Madison County public safety agencies have
initially opted to continue to do their own dispatching, regardless of whether they become
consolidated. It says the agencies cited a threat to public safety, technical degradation of
service, and current dispatch center workload as primary reasons. According to the
Narrative, each agency has examined the workload and duties of their respective
telecommunications personnel. It notes that the agencies found that in addition to 9-1-1
call taking, their personnel are also responsible for additional duties, including, but not
limited to: non-emergency calls; administrative calls; serving as the after-hours point-ofcontact and notification centers for local public works agencies; feeding of housed
prisoners; monitoring (physical and video) of housed prisoners; radio traffic for all police
units, fire units, local public works agencies; etc. The Narrative states that the agencies
concluded that, after removing the minimal 9-1-1 call taking responsibilities, there remains
sufficient justification and local funding to retain the services of their dispatch center
operations. It asserts that this decision, made on a local level, is in compliance with
Section 1324.200 (b)(3) of Part 1324.
Mr. Decker asserts that removing the PSAP status from a dispatch center would not
alleviate the duties of the center. He explains that, without intergovernmental agreements
in place, the nominated PSAP would take the 9-1-1 calls, but could not dispatch them. He
emphasizes the importance of the intergovernmental agreements
Issues of Liability:
Liability issues were raised at one point as a reason for justifying direct dispatch of 911 calls by
VCD versus call relay via CAD. It was stated that given the recent ruling by the Illinois Supreme
Court tossing out the Public Duty Rule providing emergency services an immunity from lawsuits, a
more robust litigious situation exists now. In reality, what the court ruled was immunity was better

served by statute if the General Assembly so chose. In the case of 911 systems, part of the ETSA
specifically affords civil liability immunity via the statute:
50 ILCS 750/15.1) (from Ch. 134, par. 45.1)
(Section scheduled to be repealed on July 1, 2017)
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 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.

If a case was made that keeping HPD dispatch and dispatching via CAD ticket relay from VCD would
violate the provisions of Administrative Code 1324.200 (b)(3):
May not convert PSAPs to SAPs, VAPs, or Dispatch Centers to avoid the requirements for
consolidation in ETSA Section 15.4(a). The authorized PSAPs remaining after consolidation shall
directly dispatch all emergency calls and shall not transfer or relay those calls to an unauthorized
entity. Nothing in this subsection (b)(3) shall be construed to mean a PSAP, SAP or VAP cannot
serve as a Dispatch Center.
However this is directed at counties and 911 authorities required to consolidate PSAPs per ETSA Section
15.4a; Hoopeston was not required to consolidate and as such should not pertain to them. This is the only
mention in the ETSA or the administrative codes that references in any way what dispatching method is to
be employed.
Why the state is forcing consolidation
Prior to the amended ETSA requiring consolidation, each ETSB could levy whatever taxes they
wanted or needed to maintain as many PSAPs as they wished. They were also responsible for
paying the phone costs. At the same time there were counties which didn't have enough people to
afford the costs of operating a 911 system. What the new ETSA did was to establish a uniform 87
cent per line on wireline and wireless phones, took away the ability of municipalities and counties
to surcharge. In return, the state pays the telephone costs of the system now. Part of the state's
motivation in consolidation is to eliminate unnecessary telco costs for operating multiple PSAPs.
They also have money available to help unserved areas establish 911 coverage.

Links to sources:
Administrative code 1324 Consolidation of 911 Emergency Systems
https://www.isp.state.il.us/docs/83IAC1324.pdf
Administrative code 1325 Standards of Service Applicable to 911 Emergency Systems
ftp://www.ilga.gov/JCAR/AdminCode/083/08301325sections.html
Emergency Telephone Service Act (50 ILCS 750)
http://www.ilga.gov/legislation/ilcs/ilcs3.asp?ActID=741&ChapterID=11