This comment is provided by the Virginia Chapter of APCO International, the Association of Public Safety Communications Officials. Virginia APCO represents public safety professionals who support operate, manage, and support the emergency communications ecosystem, beginning with every 9-1-1 call, and working through the response with public safety radio systems, computer aided dispatch, and myriad technologies and protocols to manage the response.

Every community in the Commonwealth deserves individuals who are trained to meet expectations and competencies to assure the quality and consistency of public service each and every time an emergency occurs. Classroom training is one of the key elements for providing the baseline level of knowledge for every public safety communications professional. On-the-job training (OJT) is the other key element that is paramount in applying the knowledge obtained through classroom training.

Pursuant to Executive Order Number Seventeen (2014) “Development and Review of State Agency Regulations, “General Principles” it states, “…agencies shall consider:  (3) [t]he use of performance standards in place of mandating specific techniques or behavior and (4) [t]he consideration of reasonably available alternatives in lieu of regulation.” 

Where necessary, the Executive Order also strives to have regulations which are “clearly written and easily understandable” and “designed to achieve their intended objective in the most efficient, cost effective manner.”

The current DCJS Rules Relating to Compulsory Minimum Training Standards for Dispatchers [6 VAC 20-60] can be improved upon to provide comprehensive and needed training opportunities in a more efficient and cost-effective manner than currently exists in the Commonwealth.

For your consideration (see below for further explanation or information):

1. The DCJS requirements identified for training dispatchers are substantially inadequate and lacking in content.
2. With the fast-pace of changes to protocols due to community changes, technology changes, and future technologies anticipated, many of which will change the face of the profession. The curriculum is not designed to keep up with the fast-paced changes to operational protocols (reflecting community changes and needs,) or technology changes and advancements, many of which will considerably alter the profession.
3. There are many dispatchers throughout the Commonwealth who, if they do not work directly for a law enforcement agency, are not required to be “certified” yet they answer 9-1-1 calls and manage emergency responses.
4. Many localities provide internal training that meets and exceeds the DCJS requirements, yet additional expenses to the locality are incurred because they must attend an academy to be certified. In addition, dispatch resources for many localities are an invaluable commodity that cannot be spared. 
   1. Since many localities meet and exceed the DCJS requirements, if proof can be shown, why make them attend an academy? In addition, many are answering, responding to and managing resources as a fully functional dispatcher before they are “certified,” performing a functional role without the “required” training for up to two years. 

Some suggestions in expanding on the above are identified below:

1. Allow dispatch personnel (Telecommunicators) in our state to use the ANSI-approved APCO training standards as a basic class for introductory dispatch personnel (either in place of the current DCJS standards/certification or along with the DCJS standards/certification).
   1. Justification:
      1. This is a potential cost savings for some agencies. If they can use the APCO Basic Telecommunicator class, then several options open up to agencies for getting this certification for its staff.
      2. Regional academy staff (still compensated by the locality unless a “certified academy site”) could be utilized to monitor and insure compliance.

1. Support some degree of in-service/ongoing training expectations/requirements after initial introductory training.
   1. Justification:
      1. The knowledge of this industry is ever-changing to keep up with technology and community requirements. The applications used and protocols applied as a result are constantly challenging the professional to keep up  to support the public safety response.
      2. New and current technologies are changing the face of public safety communications and will challenge telecommunicators to think and operate in new and complex ways to synthesize and manage multiple streams of incoming and outgoing information.
      3. Whether a new dispatcher or a seasoned professional, complacency can be create the worst outcomes. Refreshing the basics is as critical in this profession as any other within public safety.  Complacency has proven to have devastating consequences, many of which make the front page of the national news.
      4. In-service/ongoing training can be completed in-house, thereby minimizing the cost to the agency. Reduced travel keeps telecommunicators in their home agencies and ready to work.
      5. The APCO ANSI standard requires continuing education, most of which is not cost prohibitive (e.g. read professional publications, utilize developed review articles with associated quizzes, reviewing in-house policies, procedures and protocols, etc.)

1. Support every public safety communications professional throughout the Commonwealth to receive the same level of training.
   1. Justification:
      1. The public safety communications professional is at the core of every public safety response.  In addition to taking 9-1-1 calls, they orchestrate the response while monitoring and supporting the responders and the community until emergency has been addressed.
      2. Whether taking a 9-1-1 call or monitoring/supporting the response, each and every component is critical to the response.  It does not end with the receipt of a 9-1-1 call, but continues through a tremendous amount of policies, protocols and coordination.  Whether supporting law enforcement or fire/rescue responses, these individuals fulfill a critical role in the public safety response.  The emergency response is not contained within a single discipline, but originating with 9-1-1 while carried through to the appropriate field responders.
      3. Why are communities treated differently?  The locality whose fire department answers and process 9-1-1 calls are not certified. Should a locality whose fire department answers 9-1-1 calls not be certified?  The consolidated locality that serves 100% of the public safety response continuum can have different levels of training depending upon the job assignment. Should this be so?  Why are communities treated differently?

1. Support a statewide curriculum, consistent across the Commonwealth that is reviewed regularly (not every 4 years) to ensure it is current. 
   1. Justification:
      1. The current DCJS requirements do not include significant call-delivery methods, as they are out-of-date.
      2. Adopting or utilizing an existing training standard that is updated on a regular basis could be reviewed within a similar cycle to ensure all training components remain current.
      3. Verification should be included to ensure classes are taught and attended.
      4. There could be dynamic ways in which training could be delivered. We should, as a Commonwealth, explore those and improve the delivery and caliber of training, consistent to ensure training is not the weakest link of public safety communications in Virginia.
      5. There are courses available, at a cost, that follow the established standard for the training of staff while supporting cost saving measures in keeping the dispatchers in the locality. 
      6. Protocols for all facets of public safety communications are available.  The dynamics of emergencies within our communities have changed tremendously since the DCJS became the home of training requirements dispatchers.  Times have changed and the training no longer is adequate or keeps up.