Untitled - Illinois State Police
Transcription
Untitled - Illinois State Police
Please see narrative text after narrative section. VILLAGE OF ROSEMONT CONSOLIDATION WAIVER REQUEST NARRATIVE I. INTRODUCTION The amendments to the Emergency Telephone Systems Act made by Public Act 99-0006 provide for the consolidation of suburban Cook County 9-1-1 Authorities that have service populations of less than 25,000. 50 ILCS 750/15.4a(a)(2). As shown in more detail below, the Rosemont 9-1-1 Authority routinely serves a population of between 50,000 to 75,000 and, in excess of 100,000 during peak periods. The population served is predominately a transient one consisting of conventioneers, hotel guests, tourists, shoppers and attendees at events taking place at one or more of the Village’s numerous public and private sports, meeting, shopping, restaurant and entertainment venues. In addition, Rosemont 9-1-1 handles a large volume of cellular calls from nearby interstates and O’Hare Airport. There is no question that Rosemont 9-1-1 has a service population above the 25,000 threshold. This waiver application is necessary as a result of a technicality caused by the fact that Administrative Rules have defined Service Population by relying only upon the latest population estimates available from the U.S. Census Bureau. 83 Ill.Admin.Code §1324.110. Although Rosemont’s census Population is under 5,000, this single number is in no manner representative of the population actually served by Rosemont’s 9-1-1 authority. Rosemont is located at the front door of Chicago’s O’Hare airport within a web of interstate highways (I-90; I-294; I-190) and includes two Metra Commuter Rail Stations, a combined Chicago Transit Authority Rapid Transit rail and bus facility, a Regional Transportation Authority Pace Suburban Bus facility and an associated parking facility. Rosemont’s 9-1-1 operations are driven by the numerous privately and publically owned commercial and entertainment facilities whose visitors don’t get counted under the current definition of Service Population in the Administrative Rules. These facilities and venues include: (1) office complexes containing over 5.4 million square feet of office space employing approximately 19,000 – 20,000 people; (2) a nearly 900,000 square foot convention center and other hotel owned meeting and banquet spaces that received over 1,200,000 visitors in 2015; (3) 17 hotels containing 5,920 rooms with additional meeting/event/restaurant space; (4) a 530,000 square foot indoor outlet mall that was visited by more than 4,000,000 shoppers in 2015 and experienced a 11% increase in traffic in 2016; (5) a sports arena/concert venue (Allstate Arena) with a maximum capacity of 19,500 seats and yearly attendance of more than 1,000,000; (6) a 4,300 seat live performance Rosemont Theatre; (7) the thriving MB Financial Park Entertainment District expected to receive almost 2 million visitors in 2016 that contains an 18 screen movie theater, 8 different restaurants, a comedy club, an indoor sky diving center and common area used for ice skating, concerts, and other events; (8) numerous other restaurants and businesses; (9) a softball stadium and an air inflated sports dome facility; (10) future development which includes a new shopping mall, 2 new hotels (approximately 330 additional rooms), new restaurants/entertainment venues and a minor league baseball stadium; as well as (11) numerous public transportation facilities (O’Hare Airport, I-90, I-294, I-190, 2 Metra rail 1 stations, one at Balmoral and one at Zemke Avenue, a Chicago Transit Authority train and bus station, a Regional Transportation Authority Pace Suburban Bus facility and an associated parking facility). The Rosemont 9-1-1 Authority is seeking a waiver from the consolidation requirement based upon Public Safety and Economic Unreasonableness. This waiver application is being submitted without prejudice to the Village of Rosemont or its 9-1-1 Authority’s right to challenge the applicability of the consolidation component to it and the regulations that require that Service Population be determined based only upon U.S. Census estimates. The Rosemont 91-1 Authority believes that the regulatory definition of Service Population is: (1) contrary to the plain language and intent of Public Act 99-0006; (2) contrary to basic rules of statutory construction; (3) without any rational basis and invalid both on its face and as applied to the Rosemont 9-1-1 Authority in violation of the Federal and Illinois Constitutions. Nothing contained in this application is intended to waive any claim or argument that the Rosemont 9-11 Authority may have to challenge the applicability of the consolidation requirement to it or to the validity of any decision made on this waiver application. A copy of Rosemont’s letter commenting upon the regulatory definition of “Service Population” is attached hereto as Exhibit 1 and incorporated herein. II. SUBSTANTIAL THREAT TO PUBLIC SAFETY There is no other Village that is comparable to the Village of Rosemont. Although Rosemont has a census population of less than 5,000 and covers approximately 2.5 square miles, the variety and type of commercial and entertainment facilities located in Rosemont are more comparable to the State’s largest cities. The number of people actually served by the Rosemont 9-1-1 system on a daily basis by far exceeds the experience of many communities that do not need to even consider consolidation because their census populations are well above the 25,000 threshold. Requiring Rosemont to consolidate would be directly contrary to intent of Public Act 990006. Rosemont is not a sleepy bedroom community where economies of scale can be achieved by consolidating its 9-1-1 service with other similar bedroom communities that have like demands on their 9-1-1 systems. Instead, Rosemont is uniquely situated at the front door of O’Hare Airport, enveloped in a web of busy interstate highways and host to numerous public and private facilities that draw people from the entire region and the world. An attempt to mesh Rosemont with an entirely dissimilar 9-1-1 system will create a substantial threat to public safety caused by unheard calls, missed calls, mistakenly dispatched calls and the competing operational and economic needs of vastly different 9-1-1 systems. The substantial differences between Rosemont’s 9-1-1 system and most other suburban systems are highlighted below in subsections A through F: A. MASS CASUALTY RISKS: 2 Unlike any other community with a census population under 25,000, Rosemont has a dense concentration of high value soft targets that imposes unique risks, responsibilities and costs on Rosemont that are dissimilar in scope to anything experienced by any other community with a census population under 25,000. In October 2016, the Cook County Department of Homeland Security and Emergency Management’s Active Threat Program along with the Rosemont Public Safety Department will be hosting a large scale extensive training exercise involving an immediate and sustained response to a multi-assault active threat event at multiple soft target locations simultaneously. The unique clustering of large-scale soft targets located in a small geographical area offers a unique opportunity for Federal, State, County, and local law enforcement, fire suppression, and Emergency Medical Services providers, as well as other agencies including Statewide Search and Rescue agencies, County Medical Examiner's Office, service agencies including the American Red Cross to jointly test their agency's response to a realistic, plausible, and large-scale terrorist attack. The fact that Rosemont was chosen for this drill only highlights the unique demands imposed upon Rosemont and its 9-1-1 center that are unlike any other community with which it might consolidate. B. TYPE OF POPULATION SERVED: Rosemont’s 9-1-1 demands are fundamentally different than most communities because the population served is almost entirely a transient one which does not know their address or the level they are located on in a parking garage or building complex. Instead, their calls often need to be assessed using vanity information and landmarks. This places a premium upon the dispatcher having an intimate knowledge of the community that cannot be duplicated by a faraway dispatcher whose experience is largely based upon what comes up on a computer screen. Rosemont 9-1-1 guarantees that its dispatchers have and continually maintain an intimate knowledge of their community by requiring that its employees live within the Village. Rosemont’s full time Public Safety Officers also are required to live in the Village and expect they will be able to interact with 9-1-1 using the common knowledge they share by virtue of their common residency. An intermixing of Rosemont resident dispatchers with non-resident dispatchers poses a substantial threat to public safety. A Rosemont Public Safety officer will expect they can effectively communicate with 9-1-1 using the shared localized knowledge they inherently have by virtue of their shared common residency. The more stressful and serious the event, the more public safety requires the quick communications and the common understanding that can only be achieved when the responding officers and 9-1-1 share the same residency. The intimate knowledge that Rosemont dispatchers have with their community routinely benefits public safety when answering the numerous calls Rosemont 9-1-1 receives from O’Hare Airport, its rental cars areas and other areas at or near O’Hare including interstates 90, 294 and 190. As these callers usually are tourists or unfamiliar with the area, they often can be best assessed with answers to questions such as “what do you see?” – The answers to which can be best evaluated by dispatchers intimately familiar with the area because of their residency. A consolidation requirement that ignores the safety of calls from or near one of the world’s busiest 3 airports and the large traffic volumes on its surrounding interstates creates a substantial threat to public safety. Although the regulatory definition of Service Population is limited to census data, the simple truth is that public safety requires that the transient population served by Rosemont must be equally well served. Rosemont’s 9-1-1 demands are not driven by its census population but by the numerous private and public commercial facilities that it serves which include: Conventions/Trade Shows/Meetings: The Donald E. Stephens Convention Center has approximately 900,000 square feet of convention, exhibit and banquet space (11th largest in the U.S.) and hosts numerous trade shows, public shows, conventions and corporate meetings. It is capable of accommodating tens of thousands of attendees per day. This convention center is served by two different parking garages – the Williams street garage which has 8,000 parking spots and the East garage which has 350 parking spots. In 2015, 1,331,691 vehicles parked in the William street garage and 66,000 vehicles parked in the east garage. Through May 2016, 586,161 vehicles parked in the William street garage and 14,713 vehicles parked in the East garage (Exhibit 2). The Donald E. Stephens Convention Center is not the only driver of convention and meeting events as there are numerous hotel facilities that also have exhibition and meeting spaces. (See “Hotel” section below). Documentation from the Rosemont Convention Bureau shows that the total accumulated attendance for conventions, trade shows and corporate meetings was 1,079,371 in 2014 and 1,241,400 in 2015. (Exhibit 3). Allstate Arena. The Allstate Arena is an indoor sports/entertainment complex that has 15,500 permanent seats and a capacity of up to 19,500 seats depending upon the event and the configuration. Attached as Exhibit 4 is an itemization of the events and attendance at the Allstate Arena from January 1, 2014 through June 10, 2016 which shows that the Arena had 1,061,946 attendees in 2014, 1,034,531 attendees in 2015 and 489,058 attendees from January 1, 2016 through June 10, 2016. MB Financial Park. MB Financial Park is a 9 acre entertainment district that contains: an 18 screen Muvico movie theater with a restaurant and bar; a large Hofbrauhaus restaurant that features live entertainment; the Five Roses Irish themed restaurant and pub that offers live entertainment; a 27,000 square foot Kings Bowling entertainment facility featuring 20 upscale bowling lanes, two premium bars, a full-service restaurant and additional rooms with a total of 5 full size Billiard tables; an Adobe Gila’s Mexican themed restaurant with live entertainment; the Sugar Factory restaurant that also includes a retail shop for the sale of specialty candies, ice cream and gifts; a large restaurant and live music venue known as Bub City; a Zanies Comedy club; the Park Tavern restaurant and bar; Fogo de Chao, a Brazilian steakhouse; an iFly sky diving 4 center and an outdoor common area that hosts seasonal events including a full ice skating rink, winter festival, concerts, fireworks, Zumba and other exercise and yoga classes. Attached as Exhibit 5 is data measuring the people that enter the MB Park through only selected lobby areas which shows the MB Park had nearly 700,000 visitors from January through May 2016. This data, however, under represents attendance as there are no counters covering the Muvico, iFly and Hofbrauhaus Parking lots which are full during lunch hours and then used for valet parking of approximately 1,000 vehicles a week from 4 p.m. to 4 a.m. In total, it is anticipated that attendance at the MB Financial Park will approach 2 million in 2016. (Exhibit 5) Fashion Outlets of Chicago. The Fashion Outlets mall is a 530,000 square foot indoor outlet mall with over 130 stores including many luxury brands. It has an attached large 7 level parking garage. Jim Hansen, the senior property manager for the owner of the mall (Macerich) advises that in 2015 the mall had over 4,000,000 customers and that it was experiencing an 11% increase in 2016. Approximately 40+ percentage of the customers come on the weekend which equates to 32,000 to 40,000 people with much higher traffic levels during the holidays. Exhibit 6. Hotels. There are 17 hotels located in Rosemont that are served by the Rosemont 9-1-1 authority. These hotels have a total of 5,920 rooms with additional lounges and restaurant spaces. Many of these hotels also offer banquet/meeting spaces of various sizes ranging from a low of a several hundred square feet to a high of 110,000 square feet. A summary of information for these hotels and their other facilities and meeting spaces is attached as Exhibit 7. Two future hotels are planned for the near future which will add an additional 330 hotel rooms. Office Complexes/Employees. The Village has over 30 office buildings and complexes where people come to work every day. A summary attached as Exhibit 8 counts 5,446,930 square feet of space that is almost all fully leased. It is estimated that 19,000 to 20,000 people a day come to work in the Village of Rosemont. Attached as Exhibit 9 is a schedule from the Village’s 2015 comprehensive annual financial support identifying the 15 largest employers in the Village using research data compiled from the Illinois Department of Employment Security, the 2016 Illinois services, manufacturers and industrial directories and the Chamber of Commerce. These 15 largest employers employ 7,570 people which is estimated to be 40.1% of the total number of employees. This equates to a total employment estimate of 18,900 which is believed to be low because it would not account for two recently opened hotels or a new development at the northwest corner of Higgins and River Road. 5 Rosemont Theatre. The Rosemont Theatre is a 4,300 seat live performance Theater that hosts concerts, theatrical productions, family events and corporate events. Attendance at the Rosemont Theatre was 189,521 in 2014 and 192,137 in 2015. From January 2016 through mid-June 2016, 146,556 persons attended the Theatre. (Exhibit 10). Other venues. Other facilities that draw visitors to the Village include: (1) a softball stadium that serves as the home of the Chicago Bandits professional softball team; (2) a heated indoor air supported dome structure that houses 2 additional softball fields and other recreational facilities; (3) a health club; and (4) many numerous popular restaurants (Gibson’s, Morton’s, Gene & Georgetti, McCormick & Schmick’s, Carlucci’s et.al.) Future Planned Development. The population served will continue to be substantially increased by future planned development which includes a new/expanded Outlet Mall; a minor league baseball stadium, additional restaurants and entertainment venues and 2 new hotels. O’Hare Airport/Interstates/Traffic/Public Transportation. Given the location and direction of the cellular tower receiving antennas, numerous calls are received from O’Hare Airport, its rental cars areas and other areas at or near O’Hare including interstates 90, 294 and 190. As these callers usually are tourists or unfamiliar with the area, they need to be properly assessed as to whether they should properly be switched off to Chicago’s dispatch center in O’Hare, the State Police or responded to by Rosemont. Rosemont provides response to fire calls on adjacent interstates and includes a police dispatch to support the fire responders. As Rosemont has a combined Public Safety Department with cross trained police/fire/EMT responders, the police vehicle on patrol can be the first to arrive to make the initial contact and begin assessing the situation and informing other responders. The large volume of traffic in and out of O’Hare, on the surrounding interstates and within the Village’s streets results in traffic related calls well in excess of what other communities will ever receive. Attached as Exhibit 11 are records from an IDOT website showing the following average daily traffic volumes on the Interstate Highways and the Village’s arterial streets: Interstate/street Annual Average Daily Traffic Counts through Rosemont 120,900; 156,500 depends upon location 127,200; 176,700; 200,300 depends upon location 75,500; 87,200 depends upon location Jane Adams I-90 Tri-State I-294 I-190 (to/from O’Hare) 6 Touhy Ave. 24,800; 28,300; 32,600 depends upon location 19,400; 21,900 depends upon location 10,450; 12,700 depends upon location 31,000; 31,500 depends upon location 41,400; 41,900 depends upon location 14,200 Higgins Ave. Devon Ave. River Road Mannheim Road Balmoral In addition to these large daily traffic volumes, the Village also is a public transportation hub and is served by a Chicago Transportation Authority “el” station on the blue line that connects downtown Chicago to O’Hare. This facility also includes a CTA and Pace bus terminal and a large parking area for commuters traveling to O’Hare Airport, Downtown Chicago, or West to the Schaumburg Terminals of Pace. In addition, two METRA commuter rail stations are located in the Village which serves a line that runs from Downtown Chicago to the Northern suburbs. The nature of the population served by Rosemont 9-1-1 also directly impacts the nature of the services provided in other ways that are different than that of other communities. Services to a predominately transient population means that Rosemont 9-1-1 receives a substantial number of walk-ups and administrative calls that far exceeds anything that could be expected in a 9-1-1 authority that predominately serves a bedroom community. A 5 year history of Rosemont’s 9-1-1 calls is attached as Exhibit 12. In 2015, Rosemont 9-1-1 received 41,552 administrative calls and had much larger administrative call volumes in prior years. This requires a high level of integration and interaction between Rosemont 9-1-1 and other Village departments that would be unusual for other communities. Given the 4:00 a.m. closing times at MB Financial Park, the large population of hotel guests, the Village’s location next to an airport and interstates, Rosemont 9-1-1 is active at all times. These differences between the Rosemont 91-1 and other 9-1-1 systems places significant additional demands on Rosemont and resulting economic costs that simply are not experienced elsewhere. There can be no question the number of people served by Rosemont 9-1-1 by far exceeds the threshold 25,000 number. By requiring that consolidation only be considered for the smallest of communities, the legislature has inherently recognized that public safety requires that those 91-1 authorities that serve greater populations be allowed to remain on their own to locally determine how to serve these larger populations. Rosemont should not be required to consolidate and is entitled to a waiver. C. DEPARTMENT SIZE: The size and operation of Rosemont’s Public Safety Department and its 9-1-1 staffing levels that are needed to serve the above noted public and private facilities and venues also cannot be compared to any other suburban municipality. The Village has a combined Public Safety Department with 80 full time cross-trained police/fire/EMT officers. In addition to 7 working with full time public safety officers, dispatchers must monitor and engage an auxiliary force of between 250-300 officers. It is believed that the Village’s auxiliary force is the largest paid auxiliary force in the nation. Rosemont meets the needs of its Public Safety Department with 9 full-time and 6 part-time dispatchers. Every shift has a minimum of 2 dispatchers on duty with a 3rd dispatcher added when needed. The size and nature of Rosemont’s public safety needs would overwhelm any other authority with which they might consolidate. The more the calls and needs of the larger authority dominate, the greater the likelihood that the needs of the smaller low volume 9-1-1 authority go unheard or delayed to the determent of both public and officer safety. A review of call data leaves no doubt that Rosemont’s 9-1-1 needs would overwhelm any smaller low volume system. An itemization of the call data for Rosemont 9-1-1 for the last 5 years is attached as Exhibit 12. In 2015 Rosemont’s 9-1-1 calls totaled 11,172 and its administrative calls totaled 41,552 resulting in 23,992 incident cards. Rosemont’s 9-1-1 demands would overwhelm any comparatively low volume system. A substantial threat to public safety will arise to both the public and officer safety when the demands of Rosemont’s call volume causes other calls to be unheard, delayed, incorrectly switched or mistakenly handled. This substantial risk will only be increased where the operations of the other 9-1-1 authority and the demands of its system are so completely different than Rosemont’s 9-1-1 system. Rosemont’s 9-1-1 center further monitors 36 camera images on 4 different monitors, 4 additional prisoner cell cameras as well as additional security cameras for the office building in which the Village Hall and its Public Safety Department are located. Why would a department that does not provide services of the nature and scope of those provided by Rosemont 9-1-1 take responsibility for the costs necessary to provide a level of service that is not relevant to its own community? D. COMBINED PUBLIC SAFETY DEPARTMENT: Rosemont’s Public Safety Department is fundamentally different than any other department with which they might consolidate because Rosemont has a combined cross-trained police/fire/EMT department. Rosemont Public Safety Officers assigned to the fire side are required to carry a weapon and assist, support and backfill for the police side when needed. Likewise, officers assigned to the police side are required to have their fire gear in their trunks so they can assist, support and backfill for the fire side when needed. The switching from one capacity to the other and then back again places unique demands on a 9-1-1 dispatcher as each switch is then accompanied by a change in radio frequencies, a change in equipment to which the officer is assigned and a change in the service availability that needs to be accounted for when responding to calls. Unlike many jurisdictions which separate police and fire dispatch, the demands of a combined public safety force require dispatchers to simultaneously handle both police and fire keeping track and monitoring the switching of officers and their status at any given time. Consolidating a combined Public Safety Department with another authority that 8 serves separate police and fire departments presents a confusing mixture of duties for the dispatchers that can only lead to errors harming public safety. E. FREQUENCIES MONITORED: At maximum capacity, Rosemont’s dispatch center must monitor and dispatch 15 separate radio frequencies. Given the type of events and the number of simultaneous activities throughout the Village, it is common for 9-1-1 dispatchers to monitor 10-11 different radio frequencies at a given time. It is also common for the 9-1-1 staff to monitor and maintain radio communications with over 150 officers at a given time at various locations in the Village covering different types of events. (A calendar showing the simultaneous and overlapping events that are served by the Village’s 9-1-1 staff and Public Safety Department for the one-year period from May, 2015 through April 2016 is attached as Exhibit 13) The number of frequencies monitored is unlike anything that is experienced in other dissimilar bedroom communities. Adding more frequencies for another community adds to the complexity, increases errors and substantially jeopardizes public safety and officer safety. F. COMPETING OPERATIONAL AND ECONOMIC NEEDS: There is never enough funding to meet every governmental need. One of the fundamental tasks of every governmental division is the ordering of priorities to meet the available funding. A combination of Rosemont’s 9-1-1 service with a dissimilar system that operates differently inherently results in conflict. A low volume system has no reason to undertake the costs of extensive multiple mass casualty training nor the desire to fund the extensive on-site presence Rosemont requires to serve its population and the 41,000+ annual administrative calls when neither of these items are required for the community they serve. A large busy 9-1-1 authority that serves a combined public safety department and commonly monitors 10-11 frequencies and regularly has as many as 150 radios on the street will have much different priorities than a low volume system with a much smaller department that serves a drastically different population. A substantial threat to public safety is guaranteed when a larger department needs to compromise on items it feels are crucial to serve its needs in order to placate a partner whose primary goal is a balanced budget. Public Safety can only be harmed by forcing the consolidation of widely different communities with 9-1-1 systems that have widely different operations. This can only result in one community’s needs being overwhelmed by the other and an unacceptable risk of increased errors jeopardizing both the public and officer safety. III. ECONOMIC UNREASONABLENESS Rosemont receives 9-1-1 funding as if it were a small town when it has the needs and expenses of a very large municipality. In calendar year 2015, Rosemont’s 9-1-1 authority received total revenues of $492,722 and had expenses of $1,203,426 leaving an operational 9 deficit of $710,704. The Village of Rosemont substantially covered the vast majority of this deficit by transferring $515,465 to the Rosemont 9-1-1. (See Exhibit 14; Rosemont’s audited combined financial statement for Rosemont 9-1-1 for the fiscal year ended December 31, 2015) From January 1, 2016 to June 27, 2016, Rosemont 9-1-1 has received revenues in the amount of $119,633.43 and has had expenses of $669,605.96, resulting in a deficit of $549,972.53. (See Exhibit 15: Rosemont 9-1-1 Income Statement for the period from January 1, 2016 through June 27, 2016) There is no question that the State wide funding of 9-1-1 is woefully inadequate to even begin to fund the cost of providing the 9-1-1 service required to maintain public safety in the Village of Rosemont. In fact, the actual deficit in 9-1-1 funding for the above years is actually much greater than the above deficits shown because in addition to the monetary contributions, Rosemont 9-1-1 does not pay rent and does not receive an accounting charge for the benefit of using the class A office space in a Village owned office building where the Village has numerous other rent paying tenants. In addition, the Village of Rosemont pays utility expenses and bills for Rosemont 9-1-1 and provides IT and HR support. The creation of a consolidated 9-1-1 Board changes the financial reporting and would require that the full costs of Rosemont’s 9-1-1 system be charged to the combined entity. If Rosemont’s dispatch center was utilized for the combined center, additional expenses required for the expansion necessary to accommodate additional staff would need to be paid by the combined entity. If the consolidated system operated out of a non-Rosemont location, additional costs would be needed to fund an on-site presence to handle the public safety demands of the annual 41,000+ administrative calls and walk-up inquiries handled by Rosemont 9-1-1 as well as the camera network currently monitored by Rosemont 9-1-1. At present, public safety is not jeopardized by the need to take Rosemont officers off the street to handle these administrative calls and other duties handled by Rosemont 9-1-1. Any future change in these practices caused by consolidation would harm public safety by removing officers from the street. Any consolidation of Rosemont 9-1-1 is economically impractical. There is no rational reason as to why any other 9-1-1 system would want to join with Rosemont to undertake a share of Rosemont’s unfunded 9-1-1 costs when the demands placed on their 9-1-1 system are materially different than that necessary to maintain public safety in Rosemont. Given the predominately transient nature of the population served by Rosemont 9-1-1, the number of calls it serves vastly over represents the number of lines the Village gets paid for. There is no reason why a bedroom community would ever want to share these extra costs when there is no reason for them to do so. There is no rational reason why another 9-1-1 system would want to cover a share of the costs of specialized training uniquely tailored to the Village’s large public venues when they simply don’t have the similar facilities to which this training would be applicable. There is no reason why another system would want to help fund Rosemont’s service to the numerous uncompensated calls it receives from O’Hare Airport and the highly traveled interstates which border O’Hare and the Village of Rosemont. 10 IV. CONCLUSION For each and every one of the forgoing reasons Rosemont’s 9-1-1 authority should be given a waiver. Consolidation of Rosemont’s 9-1-1 system inherently involves the combination of: (1) a system designed to serve the needs of a predominately transient 24/7 population with a system serving a bedroom community; (2) dispatch for a combined public safety department with dispatch for separate police and fire departments; (3) the needs of a high volume dispatch center with a low volume dispatch center; (4) the operational needs and expenses of Rosemont 91-1 with a system that has no need for such expenses. In every way imaginable, a consolidation with Rosemont 9-1-1 would require a meshing of systems serving widely different populations having widely different priorities. The resulting combination will create a poor system that fails everyone and creates a substantial threat to public safety and officer safety. It would also be economically unreasonable to consolidate Rosemont 9-1-1 with any other system. Rosemont receives 9-1-1 funding as if it were a small town when it has the needs and expenses of a very large municipality. It would be entirely impracticable to expect any other community to want to share Rosemont’s unfunded 9-1-1 costs. Moreover, any consolidation involving Rosemont would not be a true consolidation. Given the dissimilarity of the communities served and differing operations, the best that could happen would be for each party to handle their own dispatch with minimal involvement in the activities of the other. There could be no true combination of dissimilar operations and no economies of scale to be achieved. Since there is no benefit to having separate communities perform their own separate functions independently of each other in the same location, the cost of achieving any such phony consolidation would also be unreasonable and economically unjustified. In further support of this waiver application, Rosemont 9-1-1 also submits the affidavits of James O‘Toole and Deputy Chief Kieran Mackey. Based upon their training, experience, knowledge and expertise in 9-1-1 dispatch and public safety, James O’Toole and Deputy Chief Mackey are of the opinion that a consolidation of Rosemont’s 9-1-1 system would: (1) create a substantial threat to public safety and (2) be economically unreasonable and impracticable. These Affidavits are attached as Exhibits 16 and 17. V. RESPONSE TO APPLICATION QUESTIONS 1) Question: A detailed explanation of the efforts taken, if any, to comply with the statutory requirement for consolidation prior to requesting a waiver? Answer: The Village of Rosemont is adjacent to Chicago on the east, Chicago’s O’Hare Airport on the west, and Des Plaines and Park Ridge on the North. Chicago is exempt from Public Act 99-0006 and both Des Plaines and Park Ridge are not required to consider consolidation. On the south, Rosemont is bordered by a strip of Chicago that connects O’Hare to Chicago proper and then by Schiller Park. The Village has been informed that Schiller Park intends to pursue consolidation with Norridge and Harwood 11 Heights. Schiller Park, Norridge and Harwood Heights are predominately bedroom communities that have similar 9-1-1 demands that are very different that the demands imposed upon Rosemont’s 9-1-1 system. Consolidation of vastly different communities that have vastly different demands creates a substantial threat to public safety and is economically impracticable. 2) Question: The duration of time for which a waiver is sought. Answer: A permanent waiver is being requested. 3) Question: A five year strategic plan, including but not limited to, financial projections, for implementation of a consolidation plan. Answer: Not Applicable as consolidation is not being requested. Consolidation of Rosemont’s 9-1-1 system would create a substantial threat to public safety and be economically impracticable. 4) Any additional information regarding planned equipment purchases or replacements, as well as efforts to establish interoperability or shared resources. Answer: Rosemont 9-1-1 plans to replace all of its 9-1-1 consoles in 2018 as a result of manufacturer’s recommendations regarding the end of its useful life and support. This is estimated to cost $600,000. As it always has in the past, Rosemont 9-1-1 is committed to maintaining and meeting future requirements for the provision of next generation service as well as any requirements necessary to address the interoperability of Rosemont’s system with other jurisdictions. LIST OF ATTACHED EXHIBITS Exhibit 1: April 4, 2016 letter commenting upon the Administrative Definition of Service Population. Exhibit 2: Certification of Grant Bailey; Assistant General Manager Donald E. Stephens Convention Center Exhibit 3: Rosemont Convention Bureau Visitor Fact Sheet Data; Certification of Grant Bailey. Exhibit 4: Allstate Arena Attendance Data; Certification of George Theo. Exhibit 5: MB Financial Park attendance data; Certification of Brad Stephens II. Exhibit 6: E-mail from Jim Hansen, Senior Property Manager of Macerich. 12 Exhibit 7: Information on Hotels in Rosemont, including number of rooms, number of restaurants and square footage of exhibit/banquet space. Exhibit 8: Office square footage data; Certification of Donald Calmeyn. Exhibit 9: Principal Employer’s section from the Village of Rosemont’s Comprehensive Annual Financial Report for the fiscal year ending December 31, 2015; Certification of Finance Director, Donald Calmeyn. Exhibit 10: Certification of George Theo; Rosemont Theatre attendance. Exhibit 11: IDOT website traffic maps showing Annual Average Daily Traffic Counts. Exhibit 12: Rosemont 9-1-1 call data for the last 5 years showing the number of 911 calls, administrative calls, and resulting incidents; Certification of James O’Toole. Exhibit 13: Calendar of events, May 2015 through April 2016. Exhibit 14: Rosemont’s audited combined financial statement for Rosemont 9-1-1 for the fiscal year ended December 31, 2015; Certification of Donald Calmeyn. Exhibit 15: Rosemont 9-1-1 Income Statement for the period from January 1, 2016 through June 27, 2016; Certification of Donald Calmeyn. Exhibit 16: Affidavit of James O’Toole. Exhibit 17: Affidavit of Deputy Chief Kieran Mackey. 13