2019-125-Minutes for Meeting March 04,2019 Recorded 4/11/2019G�vT E 5 co
G
?� BOARD OF
COMMISSIONERS
1300 NW Wall Street, Bend, Oregon
(541) 3 88-65 70
Recorded in Deschutes County CJ2019-125
Nancy Blankenship, County Clerk
Commissioners' Journal 04/11/2019 3:56:58 PM
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2019-125
FOR RECORDING STAMP ONLY
ALLEN CONFERENCE ROOM
Present were Commissioners Phil Henderson, Patti Adair, and Anthony DeBone. Also present were Erik
Kropp, Deputy County Administrator; David Doyle, County Counsel; and Sharon Keith, Board Executive
Assistant. Several staff and representatives of the media were in attendance.
CALL TO ORDER: Chair Henderson called the meeting to order at 1:30 p.m.
ACTION ITEMS
1. Central Oregon Health Council Update
Donna Mills, Executive Director was present to report on the history,
structure, and responsibility of the COHC. Legislation creates the authority
of the COHC. A slide presentation is attached for the record. Commissioner
DeBone requested information on the basics of the legislation.
Commissioner Henderson requested a list of committees within the COHC
and their meeting schedule. Commissioner Adair expressed interest in
reviewing detailed budgets.
BOCC WORK SESSION MARCH 4, 2019 PAGE 1 OF 6
911 Radio System After Action Discussion
Commissioner Henderson reported the Trott Communication After Action
Report regarding the Radio System Implementation was received and he
inquired if the members of the media had received a copy of the report.
Commissioner DeBone thanked the staff involved in the work done and
concluded in the future the organization as a whole needs to be aware of any
system fails as well as successes. Commissioner Adair feels we can learn
from this report especially where contracts are involved. Commissioner
Henderson commented on his level of surprise when finally learning of the
radio system failure and his concern of 911 Director Reinke's performance
and decision making. Commissioner Henderson suggested modifying
processes of the 911 User Board to insure oversight that was missing here.
Commissioner DeBone spoke on the relationship with the public safety
agencies. Commissioner Adair noted County Administrator Anderson is on
vacation this week and recommends this item could be brought back for any
comments he has when he is in the office. Interim Director Sara Crosswhite
spoke on the positives since April 2018. In response to Commissioner
Henderson, County Counsel noted the limited involvement of County Legal
especially with regard to the Statement of Work.
2. Public Hearing Preparation - Appeal of Marijuana Retail Approval (19855
8t" Street, Bend (Tumalo)
This item was audio recorded for the record. Matt Martin, Community
Development Department planner presented this item for preparation of a
public hearing scheduled for March 13 to consider an appeal of a marijuana
retail approval. The hearing's officer found the project complied and a timely
appeal was filed by the neighboring property owner. The original hearing
was scheduled for February 25 but due to a winter storm closing the County
offices the hearing was rescheduled for March 13. The location of the
subject property was discussed. County Counsel will research the scope of
the easement and legal issues on marijuana legislation. Peter Russell Senior
Transportation Planner commented on the land use application and the new
category for trip generation rate developed for marijuana retail.
BOCC WORK SESSION MARCH 4, 2019 PAGE 2 OF 6
RECESS: The Board took a recess 2:57 p.m. and reconvened at 3:04 p.m.
EXECUTIVE SESSION:
At the time of 3:05 p.m. the Board went into Executive Session under ORS
192.660 (2) (h) Labor Negotiations. The Board came out of Executive Session
at 3:54 p.m. to direst staff to proceed as discussed.
OTHER ITEMS:
• Fair & Expo Director Interviews: Human Resources Director Kathleen
Hinman recapped the interview process for next week to include three
panels with a County Commissioner on each panel. She will draft the
interview questions and give a copy to the Board to review. Commissioner
Henderson was surprised that the panel that reviewed the applicants didn't
share discussion with the Board. Prothman conducted first level interviews
since there were 16 candidates and then the finalists were to be brought
back for the next interviews on March 12. Commissioner Adair inquired why
Prothman took so long to get to the point of interviews especially with the
Deschutes County Fairgrounds celebrating 100 years in 2019. Commissioner
Henderson would like to review the first round interview notes.
The Finance Director position was posted today. Wayne Lowry has offered to
stay longer to assist in transition. The position will be on the ballot for 2020.
COMMISSIONER UPDATES
The Board attended the House Bill 2020 hearing on Saturday.
BOCC WORK SESSION MARCH 4, 2019 PAGE 3 OF 6
3. Administrative Policies: Reissue and Housekeeping
Deputy County Administrator Erik Kropp reviewed the revisions to HR -10
Non -harassment and Non-discrimination policy, the GA -19 Title VI of the Civil
Rights Act, and the GA -13 ADA policy. Mr. Kropp reported the HIPAA policy is
also under review for review. Mr. Kropp asked the Board for consideration
of County Administrator signature.
ADAIR: Move Cou nty Ad m i n istrator's signature on policies HR10, GA19
and GA13
DEBONE: Second
VOTE: ADAIR: Yes
DEBONE: Yes
HENDERSON: Chair votes yes. Motion Carried
4. Discussions on Pending Committee Appointments
The following committees have vacancies with pending appointments:
• Audit Committee: Commissioner Henderson commented he knows of
someone that was trying to apply for the Audit Committee but was having
difficulties accessing the on-line process.
Local Public Safety Coordinating Council is going through the public posting
process.
• Investment Advisory Committee has a vacancy and has two applicants. The
Board is interested in reviewing the applications.
• COIC vacancy for tourism and recreation -Commissioner DeBone spoke on
transit dollars coming through the county. Commissioner Henderson
recommended asking someone from the resort community possibly
BOCC WORK SESSION MARCH 4, 2019 PAGE 4 OF 6
Tetherow. The Board suggested opening the public process requesting
applications.
• Central Oregon Cohesive Strategy Initiative - Commissioner Henderson will
meet with Alison Green, Cohesive Strategy Coordinator tomorrow and
requested postponing this discussion until after that meeting.
• Central Oregon Health Council - This committee still requires a Board of
Commissioners representation. Commissioner Henderson is not interested
in being on COHC and wants a commissioner that will keep us posted in what
is happening. Commissioner Adair commented on the financial statements
of COHC. Commissioner DeBone is interested in filling this vacancy.
Commissioner Adair inquired if COHC could be involved in the stabilization
center.
Commissioner DeBone asked for a motion supporting his appointment to
COHC. Commissioner Henderson would like to think about this for some
time. Commissioner Adair commented on their financial statement and feels
the BOCC needs to get involved. The next COHC meeting is scheduled for
April 11 and the full Board plans to attend.
COMMISSIONER UPDATES
• Commissioner DeBone reported on the status of the MOU for Fish and
Wildlife. The request of Deschutes County for resources involves an
estimated 200 hours of staff time. Commissioner DeBone reported he met
with Ron Nelson of the Deschutes River Conservancy last week.
Commissioner DeBone advocates for moving forward with the MOU and
Commissioner Henderson recommended placing it on the Board agenda for
Wednesday.
• Commissioner Henderson submitted a letter of support requested by the
Eastern Oregon Counties regarding the proposed cap and trade bill HB 2020.
ADAIR: Move approval of letter of support
DEBONE: Second
BOCC WORK SESSION MARCH 4, 2019 PAGE 5 OF 6
VOTE: ADAI R: Yes
DEBONE: Yes
HENDERSON: Chair votes yes. Motion Carried
Being no further items to come before the Board, the meeting was adjourned at 4:46 p.m.
ATTEST:
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BOCC WORK SESSION MARCH 4, 2019 PAGE 6 OF 6
L�\)I E S COG
o Deschutes County Board of Commissioners
1300 NW Wall St, Bend, OR 97703
(541) 388-6570 — www.deschutes.org
WORK SESSION AGENDA
DESCHUTES COUNTY BOARD OF COMMISSIONERS
1:30 PM, MONDAY, MARCH 4, 2019
Allen Conference Room - Deschutes Services Building, 2ND Floor - 1300 NW Wall Street - Bend
Work Session, which are open to the public, allow the Board to gather information and give direction to staff.
Public comment is not normally accepted. Written minutes are taken for the record
Pursuant to ORS 192.640, this agenda includes a list of the main topics that are anticipated to be considered or
discussed. This notice does not limit the Board's ability to address other topics.
Meetings are subject to cancellation without notice. Item start times are estimated and subject to change without
notice.
CALL TO ORDER
ACTION ITEMS
1:30 PM
2. 1:50 PM
3. 2:30 PM
4. 3:15 PM
5. 3:30 PM
Central Oregon Health Council Update - Donna Mills, Executive
Director
911 Radio System After Action Discussion
Public Hearing Preparation - Appeal of Marijuana Retail Approval
(19855 8th Street, Bend (Tumalo)) - Matthew Martin, Associate Planner
Administrative Policies: Reissue and Housekeeping - Erik Kropp, Deputy
County Administrator
Discussions on Pending Committee Apointments
COMMISSIONER'S UPDATES
Board of Commissioners Work Session Agenda Monday, March 4, 2019 Page 1 of 2
EXECUTIVE SESSION
Executive Session under ORS 192.660 (2) (h) Labor Negotiations
At any time during the meeting an executive session could be called to address issues relating to ORS
192.5660(2)(e); real property negotiations; ORS 192.660(2)(h) litigation; ORS 192.660(2)(d), labor
negotiations; ORS 192.660(2)(b); personnel issues; or other executive session categories. Executive sessions
are closed to the public; however ,with few exceptions and under specific guidelines, are open to the public.
OTHER ITEMS
These can be any items not included on the agenda that the Commissioners wish to discuss as part of the
meeting pursuant to ORS 192.640.
ADJOURN
Deschutes County encourages persons with disabilities to participate in all programs and
activities. To request this information in an alternate format please call (541) 617-4747.
FUTURE MEETINGS:
Additional meeting dates available at www.deschutes.org/meetingcalendar
Meeting dates and times are subject to change. If you have question, please call (541) 388-6572.
Board of Commissioners Work Session Agenda Monday, March 4, 2019 Page 2 of 2
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Deschutes County,, Oregon
After Action Review
P25 Radio System Implementation
February 25, 2019
ITROTT
COMMUNICATIONS GROUP
Trott Communications Group, Inc.
1303 W. Walnut Hill Lane
Suite 300
Irving, Texas 75038
(972) 518-1811
www.trottgroup.com
Deschutes County, Oregon
After Action Review
P25 Radio System Implementation
Table of Contents
1.0 Executive Summary................................................................................................. 1
2.0 Introduction............................................................................................................ 6
3.0 Project Background................................................................................................. 7
3.1 Sparling Report..................................................................................................... 7
3.2 911 Director Steve Reinke.................................................................................... 8
3.3 Boards & Advisory Teams..................................................................................... 9
3.3.1 Board of County Commissioners.................................................................. 9
3.3.2 DC911 User Board......................................................................................... 9
3.3.3 Public Safety Radio Team.............................................................................. 9
3.4 ODOT State Radio Project.................................................................................. 10
3.5 ADCOMM........................................................................................................... 10
3.6 Harris Proposal & Contract................................................................................. 11
4.0 Project Review...................................................................................................... 12
4.1 investigations & Discovery ................................................................................. 12
4.2 Expected Project Outcome................................................................................. 13
4.3 Actual Outcome..................................................................................................13
5.0 Misconceptions.....................................................................................................14
5.1 General...............................................................................................................14
5.2 DAQ 3.0 vs. DAQ 3.4........................................................................................... 14
5.2.1 General........................................................................................................14
5.2.2 DAQ Subjective Ratings............................................................................... 15
5.2.3 DAQ Equivalencies...................................................................................... 15
5.2.4 Contract & Testing...................................................................................... 16
5.2.5 Deschutes County DAQ Facts...................................................................... 17
5.3 Mobile, Portable, & In -Building Design.............................................................. 17
6.0 What Caused The Outcome?................................................................................ 19
6.1 General...............................................................................................................19
6.2 Undocumented System Requirements.............................................................. 20
6.3 Weak Purchase Contract.................................................................................... 20
6.4 Poor Contract Administration............................................................................ 21
6.5 DC911Overconfidence.......................................................................................23
6.6 Incomplete System Buildout.............................................................................. 24
6.7 Absence of Meaningful Acceptance Testing ...................................................... 25
6.8 Urgency to Cutover............................................................................................ 25
6.9 Cutover Errors.................................................................................................... 26
I
6.9.1 Cutover Plan................................................................................................ 26
6.9.2 System Testing & Validation....................................................................... 27
6.9.3 User Training...............................................................................................28
6.9.4 User Equipment Programming................................................................... 29
6.9.5 Vendor Support........................................................................................... 30
6.10 Installation/Configuration Errors....................................................................... 31
6.11 Inadequate Vendor Support............................................................................... 31
6.12 Insufficient Oversight & Accountability............................................................. 32
6.13 In Spite of Everything......................................................................................... 34
7.0 2018 Corrective Actions........................................................................................ 35
7.1 Harris Audit & Corrective Actions...................................................................... 35
7.2 ADCOMM Support.............................................................................................. 35
7.3 Motorola Programming, Firmware, and Microphones Accessories .................. 36
7.4 St. Charles Antenna Replacement...................................................................... 37
7.5 Overturf Butte Site............................................................................................. 37
8.0 Current Status.......................................................................................................38
8.1 P25 Radio System............................................................................................... 38
8.2 Coverage Testing................................................................................................ 38
8.3 Deputy Director of Technical Systems............................................................... 39
8.4 Seventh Site........................................................................................................ 39
9.0 Lessons Learned.................................................................................................... 40
10.0 Fire Services Cutover............................................................................................ 42
10.1 General...............................................................................................................42
10.2 User Buy-In......................................................................................................... 42
10.3 Training...............................................................................................................42
10.4 Recommended Verifications.............................................................................. 43
10.4.1 System Performance................................................................................... 43
10.4.2 User Equipment Readiness......................................................................... 43
10.4.3 Training Certification.................................................................................. 44
10.5 Cutover Plan....................................................................................................... 44
10.6 Post -Cutover Reviews........................................................................................ 44
11.0 Recommended Oversight Improvements............................................................. 44
Appendix A — Interviewee List
11
After Action Review
02/25/2019
Deschutes County, Oregon
After Action Review
P25 Radio System Implementation
1.0 EXECUTIVE SUMMARY
A new P25 digital radio system supporting law enforcement agencies in Deschutes County
went live on July 27, 2017. The system was designed and implemented by Harris
Corporation as an addition to a statewide effort by the Oregon Department of
Transportation (ODOT). Deschutes County partnered with ODOT in 2015 and contracted
directly with Harris to provide radio coverage and services designed for Deschutes County
and its public safety agencies. The intent of the partnership was to reduce system costs,
expedite construction, provide interoperable communications with ODOT and State
Police, and provide statewide coverage to County agencies. The Deschutes County
portion of the system is owned and managed by the Deschutes County 9-1-1 Service
District (DC911).
Immediately upon activation, users experienced a multitude of communications issues.
System and user radio problems lingered for months, with slow progress towards
resolution. A "Concern Letter", signed by seven Deschutes County law enforcement
associations, was signed and submitted to DC911 and command staff on 12/07/2017. A
complaint was subsequently filed with the Oregon Occupational Safety and Health
Division on 12/27/2017, outlining officer safety concerns in various priority situations and
documenting a complete system outage occurring on 12/27/2017. The Deschutes County
Board of Commissioners and the public at large were generally unaware of ongoing public
safety radio issues until these complaints were documented in December 2017.
Harris dedicated additional resources to the project in January 2018 and DC911 re-
engaged the services of ADCOMM, an independent engineering consulting firm. DC911,
Harris, and ADCOMM worked through June 2018, six months after the OSHA complaint
and eleven months after cutover, to resolve issues and stabilize system performance.
Based upon the magnitude of communications issues reported and the extended timeline
required to resolve those issues and stabilize operations, the initial system cutover has
been largely categorized as a failed effort. However, it is important to note that system
users generally report acceptable system operations and performance as of the summer
of 2018.
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After Action Review
02/25/2019
Trott Communications Group, Inc. was contracted by the Board of Commissioners to
conduct an After Action Review (AAR) of the P25 radio system project. The review seeks
to document answers to:
1. What was the expected project outcome?
2. What was the actual outcome?
3. What caused the outcome?
4. What lessons were learned?
The P25 radio project began in earnest with the "Sparling Report" in June 2014. The report
was prepared by Sparling, Inc. and documented the needs and requirements of public
safety stakeholders in Deschutes County. The report included recommendations for radio
system technology, performance, procurement terms, and acceptance criteria. The
overall project goal per the report was:
The end result is acquisition of a reliable, high performance radio system
that clearly and openly reflects to the citizens of Deschutes County the
efforts of responsible stewardship of taxpayers' dollars.
More specifically, the expected project outcome was to select a qualified P25 supplier to
deliver a system that meets the user requirements outlined in the Sparling Report.
Therefore, the system purchase contract should have provided:
Table 1
In review of the actual project outcome achieved, only three of the seven critical items
listed in Table 1 were addressed by the Harris contract. System cutover (i.e. activation)
Trott Communications Group, Inc. 2
Included In
Contract
P25 Digital Trunking Technology
V
Capacity to support all Deschutes
County public safety agencies
Guaranteed coverage to portable
X
radios throughout the County
Detailed acceptance testing
X
confirming guaranteed coverage
Acceptance testing for system
V/
equipment & features
User training
X
System cutover planning and
1C
execution
Table 1
In review of the actual project outcome achieved, only three of the seven critical items
listed in Table 1 were addressed by the Harris contract. System cutover (i.e. activation)
Trott Communications Group, Inc. 2
After Action Review
02/25/2019
was rushed by DC911 and included only limited technical assistance from Harris. System
cutover shortcomings included:
• Only five of the seven contracted sites were complete
• No meaningful coverage or system performance testing was performed
• User radios were not verified to have proper programming
• System users were not adequately trained
After the system cutover fell short of user expectations and acceptable performance,
DC911, Harris, and Motorola (supplier of some user radios) were slow to resolve issues.
Significant resources were not added to the resolution efforts until January 2018, five
months after cutover.
Why did this outcome occur?
Media reports and system stakeholders have focused on two items that have little to do
with system implementation and cutover issues.
DAQ 3.0 vs. DAQ 3.4
Delivered Audio Quality (DAQ) subjectively describes audio intelligibility. The industry
standard document, TIA/EIA TSB -88, provides definitions for DAQ ratings and
recommends DAQ 3.4 as the design goal for public safety radio systems. DAQ 3.0 is a
slightly less stringent audio rating, which is primarily recommended for commercial and
public service radio systems.
The Harris contract referenced DAQ 3.0 as the design goal, which is contrary to typical
public safety procurements. However, it is inaccurate to state, "the County bought a DAQ
3.0 system when they should have bought a DAQ 3.4 system". DAQ rating does not refer
to a grade of equipment or specific system type. The hardware used to achieve DAQ 3.0
is the same hardware used to achieve DAQ 3.4.
Per TSB -88, DAQ 3.0 is defined as "Speech understandable with slight effort. Occasional
repetition required due to noise/distortion". DAQ 3.4 is defined as "Speech
understandable with repetition only rarely required. Some noise/distortion." The
definitions for DAQ 3.0 and DAQ 3.4 are subtly different and more applicable to analog
systems, where voice quality will degrade gradually with audible noise and distortion. The
nature of a digital signal is to either "work or not".
To address DAQ beyond the original subjective descriptions, TSB -88 provides quantifiable
definitions in the form of Bit Error Rate (BER) and signal level (signal-to-noise ratio to be
Trott Communications Group, Inc. 3
After Action Review
02/25/2019
precise). The differences in BER and signal level between DAQ 3.0 and DAQ 3.4 are also
relatively small, but measureable. However, there was no coverage guarantee provided
by the Contract and no quantifiable coverage analysis was performed. Therefore, the
actual coverage performance delivered by the system at cutover is unknown. Although
the contractual reference to DAQ 3.0 reflects poorly on those responsible for the
Contract, the After Action Review concludes that the difference between DAQ 3.0 and
DAQ 3.4 is not the root cause of problems encountered by system users at cutover.
Mobile vs. Portable Design
There is a significant difference between the performance of mobile and portable radios
due to the lower power levels of portables and other technical factors. Since early 2018,
Harris has consistently maintained that the Deschutes County radio system was designed
for mobile radios and not portable radios. That claim is not supported by contract
documents, which clearly refer to "portable radios at hip -level'. System design
documents from June 2016 present balance calculations for portable radio performance
and provide coverage predictions for outdoor portables and well as portables operating
inside of buildings. DC911 staff and others attending the Detailed Design Review on
06/01/2016 would have reasonably concluded that the system was designed to provide
service to portable radios. With no contractual coverage guarantee, the Harris assertion
regarding mobile -only coverage is inexplicable and only serves to undermine their design
and DC9411 staff.
What was the actual cause of the outcome?
The purchase contract with Harris was exceptionally weak as described above and did not
include most of the recommendations from the Sparling Report. The Contract allowed
numerous errors and oversights to occur during implementation and failed to adequately
protect Deschutes County and the system stakeholders.
The County and Harris did not competently administer the Contract as written. Two
transmission sites were deferred and later removed from the initial implementation
without contract amendments, cost adjustments, or sufficient analysis of impact to
coverage performance. Other contract items were also overlooked or rushed without
proper due diligence or documentation.
DC911 appears to have been overconfident in their capabilities and staffing. In January
2017, as the project was entering a critical phase, ADCOMM was effectively phased out
of the DC911 technical team. The system activation date was accelerated in the summer
of 2017 based upon concerns from DC911 that the legacy law enforcement radio system
was in danger of catastrophic failure. These concerns caused DC911 to abandon necessary
cutover prerequisites and planning. Therefore, system activation was rushed without
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After Action Review
02/25/2019
proper testing, training, or planning. Sufficient assistance and resources were not added
to the DC911 team leading up to system cutover or in the months that followed. Overall,
DC911 operated autonomously without adequate oversight or accountability.
As a partner in the project, Harris was complicit in the cutover decisions, failing to advise
DC911 regarding critical steps or proposing additional services that were needed for a
successful cutover. The Harris implementation team was also responsible for system
configuration errors that contributed to communications issues and performance
problems encountered by the users. Furthermore, Harris' support was wholly inadequate
until receiving negative press from the 12/27/2017 OSHA complaint.
It was also noted that Bend PD and other agencies using Motorola user radios experienced
various performance and audio issues. Motorola was similarly slow to respond and
provide solutions. Little progress with Motorola subscriber units and accessories was
made before ADCOMM returned to the project in 2018. ADCOMM led efforts to identify
configuration settings, firmware updates, and speaker mic changes associated with
Motorola user radios.
This AAR report is highly critical of the contract terms, contract administration, removal
of ADCOMM from the technical team, acceptance testing, and cutover planning. In spite
of these significant oversights, the system cutover could have been largely successful
(from the perspective of the end-users) had the infrastructure and user equipment
operated in an acceptable manner. The various infrastructure configuration errors and
user radio programming/setting issues were the ultimate cause of the communications
problems that plagued system users for months.
DC911, ADCOMM, Harris, and Motorola collectively worked through the first half of 2018
to identify and resolve system and user equipment issues. All stakeholders interviewed
reported that the P25 system is now stable and providing acceptable service. Fire
protection agencies did not move to the P25 system initially. Fire users have been testing
for months and overall expressed a desire to transition to the P25 system as quickly as
possible.
The Fire service cutover is planned for April 2019 and will have the benefit of lessons
learned. Users have participated in system testing and "bought in" to the transition.
ADCOMM has performed BER coverage testing and will be submitting a report within the
next few weeks. DC911 is working with an experienced firm to prepare and execute user
training. DC911 currently enjoys strong partnerships with ODOT and its vendors, and by
all accounts, the P25 system is now "on the right track".
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After Action Review
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2.0 INTRODUCTION
Deschutes County contracted with Harris Corporation in 2016 to design and implement a
countywide P25 trunked radio system. The system was intended to replace various
inadequate and obsolete radio systems in use by public safety agencies throughout the
County. System design and implementation progressed throughout 2016 and into the
summer of 2017. The P25 radio system was activated for primary use by law enforcement
agencies on 07/27/2017. System users immediately experienced various operational and
performance issues. Deschutes County 9-1-1 Service District (DC911) worked with the
agencies and Harris attempting to resolve the issues.
System problems persisted throughout the remainder of 2017, resulting in a "Concern
Letter" signed on 12/07/2017 by seven associations representing Deschutes County law
enforcement officers and staff. The Bend Police Association filed a complaint with the
Oregon Occupational Safety and Health Division (Oregon OSHA) on 12/27/2017. The
OSHA complaint acknowledgement letter, dated 01/02/2018, stated that, "Since July,
there have been numerous officer safety concerns involving priority situations where
officers have been involved in fights, foot pursuits or calling for cover requests that have
not been transmitted because of radio failure." The OSHA letter goes on to say, "As of
today, 12/27/17, the system completely went down for a period of time with no contact
with dispatch."
Harris Corporation dedicated additional engineering resources to the project in January
of 2018. DC911 also re-engaged the services of ADCOMM, an independent engineering
consulting firm, to assist with resolution of ongoing issues. DC911, Harris, and ADCOMM
collectively worked to resolve user complaints and stabilize performance. Various fixes,
updates, and improvements were implemented from January 2018 through June 2018.
Users now report generally stable system operations and acceptable performance.
Trott Communications Group, Inc (Trott) was contracted by the Deschutes County Board
of Commissioners to conduct an After Action Review (AAR) of the P25 radio system
project. The scope of the review is to ascertain the facts surrounding the P25 radio project
and prepare an unbiased report of those facts. In a general sense, an After Action Review
seeks to document answers to the following:
1. What •- - ♦.
2. . actual
was the
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After Action Review
02/25/2019
4. What lessons were learned?
Trott is an independent consulting firm specializing in public safety communications and
has over 40 years of experience in the design, procurement, and implementation of radio
communications systems. Trott has completed projects in the recent past utilizing P25
radio systems from Motorola Solutions, Harris Corporation, E.F. Johnson, and others.
Trott maintains strict independence from all equipment manufacturers and has no vested
interest in the sale of equipment or any specific outcome of this review.
3.0 PROJECT BACKGROUND
3.1 Sparling Report
Although there were several other prior efforts, the P25 project principally started in June
of 2014 with the publication of the Deschutes County Regional Public safety Radio
Communications Technical Report, prepared by Sparling Incorporated. Known as the
"Sparling Report", the document provided a detailed analysis of the needs and
requirements of the public safety stakeholders in Deschutes County.
Technical recommendations included:
• Replace the various disparate, inadequate, and obsolete radio systems
• Utilize standards-based P25 digital trunking technology
• Improve coverage to portable radios countywide where possible
• Improve indoor (in -building) communications in developed areas including Bend
and Redmond
• Provide adequate system capacity to support all law enforcement and fire
protections agencies
• Provide technical training for users and operators
Procurement recommendations included:
• Utilization of a competitive Request For Proposals (RFP) process
• Inclusion of detailed functional performance requirements
Trott Communications Group, Inc. 7
After Action Review
02/25/2019
• Inclusion of coverage requirements with guaranteed performance
• Requirements for detailed and thorough system acceptance testing
• Complete warranty coverage
• Risk mitigation plans and processes
The overall goal of the P25 radio system upgrade project as stated in the Sparling Report
was: "The end result is acquisition of a reliable, high performance radio system that clearly
and openly reflects to the citizens of Deschutes County the efforts of responsible
stewardship of taxpayers' dollars."
a ...:.:,s. aye�:.ea , r ,.o.a�� r' ,.;..w...:h.�.c ..�., ,.., .. u. �,..::�... ,.:�ru;.:,..�.,.,..�.eo.�>;c.s7 rv,:.,.sm„o-,,..._✓:.�.:� �,:, w.nn �� ::,: .k
.e • ► result is acquisition of r reliable, high
citizens of Deschutes ►unty the efforts of ► •
stewardship of taxpayers" dollars.
Cost estimates for implementation of a P25 radio system were listed at approximately
$13 million for infrastructure and up to $12 million for replacement of end-user mobile
and portable radio equipment.
3.2 911 Director Steve Reinke
Steve Reinke was appointed Director of Deschutes County 9-1-1 Service District (DC911)
in September 2014, shortly after publication of the Sparling Report. Director Reinke led
the effort to centralize the disparate radio systems, and for DC911 to assume
responsibility for ownership, operation, and maintenance of public safety radio
infrastructures in the County. Several interviewees cited this radio system consolidation
as a critical prerequisite for the future countywide radio system upgrade.
As the owner and administrator of 911 dispatching and radio communications operations,
DC911, under Director Reinke, was responsible for facilitating the proposed upgrade to a
P25 digital radio system. Director Reinke's tenure continued through planning,
contracting, deployment, and cutover of the Harris P25 system. He left DC911 on
05/01/2018.
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Steve Reinke was also Principle Consultant and owner of Reinke and Associates prior to
and during his time with DC911. The consulting firm specialized in the structure and
governance of 911 and PSAP organizations. Per its corporate website, Reinke and
Associates ceased operations in August 2018 after Mr. Reinke accepted his current
position as Executive Director at Spokane Regional Emergency Communications.
3.3 Boards & Advisory Teams
3.3.1 Board of County Commissioners
The Board of County Commissioners (BoCC) is comprised of three elected officials
who serve four-year terms. The Board serves as the public's elected advocate, and is
the policy making body of Deschutes County government. The executive duties
include establishment of the budget, which is done with the aid of the three lay
members of the Budget Committee. To implement policy and manage the day-to-day
operations of the County, the Board appoints a County Administrator. The Board of
Commissioners is also the governing body for other boards such as the Deschutes
County 9-1-1 Service District, the Black Butte Ranch Service District, the Extension/41-1
County Service District, and the Sunriver Service District.
3.3.2 DC911 User Board
The 9-1-1 Service District User Board (User Board) provides advisory input into the
operational rules, policies, and procedures of DC911 that impact user agencies. The
User Board, formerly known as the Executive Board, consists of an appointee from
each user agency.
Per the amended DC911 Operating Agreement (dated 03/02/2016), the County
Administrator, or designee, chairs the User Board, which shall meet at least
quarterly. The agreement further states that User Board members may call a special
meeting for the purpose of addressing the County Administrator or Board of County
Commissioners regarding "any issues of District -wide concern".
3.3.3 Public Safety Radio Team
The Public Safety Radio Team (PSRT) advises DC911 on fiscal and administrative
aspects of the radio and data communications systems and makes decisions related
to its operational aspects. Each user agency (including DC911) appoints a
representative with voting privileges.
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3.4 ODOT State Radio Project
In late 2014, DC911 was aware that the Oregon Department of Transportation (ODOT)
was implementing a statewide P25 radio system through Harris Corporation. Harris is the
second largest provider of P25 systems and equipment. ODOT was open to partnerships
with local government agencies, which could provide improved interoperability and cost
sharing for system partners. Minutes from the DC911 User Board Meeting dated
12/16/2014 indicated Board concurrence with the concept of participating in the "State
Radio Project".
DC911 generally viewed a partnership with ODOT as an opportunity to:
• Reduce procurement costs
• Expedite construction of their P25 system
• Reduce capital investment
• Provide interoperability with ODOT and Oregon State Police (OSP)
• Provide statewide coverage to Deschutes agencies in areas served by the ODOT
system
Although a partnership with ODOT would bypass the Sparling Report recommendation of
a competitive RFP, it would not inherently prevent inclusion of the other technical,
procurement, and contract recommendations outlined in the Sparling Report.
3.5 ADCOMM
DC911 User Board Meeting minutes from 09/16/2014 indicate that Director Reinke
reported that the principle partner at Sparling and author of the Sparling Report had left
the company. Director Reinke recommended selection of another engineering consulting
firm to assist with the radio project. Concerns over changing firms were discussed, but
the concept received general agreement. ADCOMM Engineering (ADCOMM) was
recommended by Director Reinke as the replacement consulting firm at the 12/16/2014
DC911 User Board Meeting.
A contract with ADCOMM was executed in March of 2015. The scope of that contract
included (in summary):
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• ODOT Negotiation Phase 1 - Negotiate requirements development and initial
discussions with ODOT
• ODOT Negotiation Phase 2 - Continued negotiations, system design concept
development, and budget analysis
• ODOT Negotiation Phase 3 - Contract legal negotiations pertaining to technical
requirements or legal requirements that could affect technical issues
• Professional engineering services related to microwave system engineering, data
network engineering, radio site development, etc. as described in work orders
In February 2016, ADCOMM took on additional scope of work associated with VHF Fire
communications channels, FCC licensing, DC power systems, and tower site alarms.
ADCOMM remained a part of the radio project team until January 2017. At that time,
DC911 determined that internal staff could manage the remaining technical efforts.
ADCOMM was not actively engaged during the final months of system implementation,
system cutover, nor the post -cutover efforts through the end of 2017.
DC911
determined that internal staff could manage 'he
* technical efforts. ADCOMM 1ell
.,. age
•i
during the final months of system implementation, system
• • post -cutover • through • of
ADCOMM was re-engaged in January 2018, presumably triggered by the OSHA complaint.
3.6 Harris Proposal & Contract
Harris submitted a written proposal for a Deschutes County P25 radio system on
10/29/2015. Interviews with former Director Reinke, ADCOMM, and Harris indicate that
the proposal was based upon various meetings with Harris, the DC911 technical team,
and ADCOMM. No record of a formal requirements document could be found.
The System Purchase Agreement between Harris Corporation and DC911 was executed
on 03/02/2016. The Harris proposal was effectively converted into the Contract
Statement of Work. There are few if any substantive changes between the 10/29/2015
Proposal and the Contract SOW.
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The Purchase Contract in general failed to capture many of the Sparling Report
recommendations. It was grossly deficient in specifying performance requirements and
system acceptance criteria. DC911 assumed responsibility for installation and testing of
antenna systems at the transmission sites in both the Proposal and the Contract SOW.
Equipment installation is normally provided by the system supplier on a turnkey basis due
to the potential impact to site commissioning, system performance, and equipment
warranty. Acceptance of this responsibility and associated risk by the buyer is unusual.
The Purchase Contract failed to capture many of the Sparling
Report recommendations.
The Contract did not assign responsibilities associated with tuning and programing user
radios, end-user technical training, or system cutover planning. These items are critical to
project success and are typically addressed in the contract statement of work.
The Harris agreement did represent a significant cost benefit at approximately $4 million.
Collectively with other infrastructure costs (VHF upgrades, interoperability equipment,
microwave connectivity, etc.), Director Reinke presented a total radio project budget of
$5.8 million to the Board of County Commissioners in M^arch 201'6. This figure is less than
half of the $13 million infrastructure cost estimated in the Sparling Report.
4.0 PROJECT REVIEW
4.1 Investigations & Discovery
Trott conducted on-site interviews with 30 individuals the week of December 10, 2018.
Interviews included the Board of County Commissioners, County Administrator, County
Legal Counsel, DC911 staff, and representatives from ten public safety agencies. Trott also
interviewed Day Wireless and Motorola Solutions the week of December 10, 2018.
Telephone interviews were conducted in January 2019 with ADCOMM, Former Director
Reinke, Communications Northwest, ODOT, Harris Corporation, and additional public
safety agencies. A complete list of interviewees is included in Appendix A.
Trott was provided access to project -related documents including the Sparling Report,
contracts, meeting minutes, email correspondence, media reports, and trouble tickets.
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4.2 Expected Project Outcome
A key element of the After Action Review is to document the expected outcome of the
Deschutes County radio project. Based upon review of all available information, it is
reasonable to summarize the expected outcome as follows:
1. Execute a Contract with a system supplier that:
a. Meets the performance requirements of the users (per Sparling Report)
b. Utilizes P25 digital trunking technology
c. Provides coverage enhancements to system users per Sparling Report
d. Includes adequate capacity for all law enforcement and fire protection
agencies
2. Include the Contract elements recommended by the Sparling Report:
a. Functional performance requirements
b. Coverage requirements with guaranteed performance
c. Detailed Acceptance Testing
d. Warranties
e. Risk mitigation
3. System Supplier to execute a well-planned system implementation, meeting all
Contract requirements
4. Provide a training program to ensure that system users are knowledgeable in
system and subscriber equipment operations
S. System Supplier and DC911 to execute a well-planned system cutover
6. Per the Sparling Report, "The end result is acquisition of a reliable, high
performance radio system that clearly and openly reflects to the citizens of
Deschutes County the efforts of responsible stewardship of taxpayers' dollars."
4.3 Actual Outcome
Investigations indicate that the actual outcome of the radio project fell well short of
reasonable expectations. In summary:
1. The executed Contract:
a. Employed P25 Phase 2 digital technology
b. Included adequate system capacity
c. Provided only vague coverage and performance requirements
d. Failed to incorporate a coverage guarantee
e. Included only limited testing requirements
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f. Failed to address user training
g. Failed to address cutover planning
2. Project implementation failed to mitigate risks
3. The system cutover was rushed and included only limited technical assistance
a. Not all transmission sites were complete (five of seven)
b. Meaningful coverage and performance testing was not performed
c. User radios were not verified for proper tuning and programming
d. System users were not adequately trained for system or subscriber radio
operations
e. User issues were exacerbated by numerous undiagnosed system
configuration errors
4. Responsible parties (i.e. Harris and DC911) were slow to resolve reported issues
5. The confidence of system stakeholders was severely eroded
5.0 MISCONCEPTIONS
5.1 General
System stakeholders and citizens of Deschutes County deserve an explanation of what
went wrong in the execution of the radio project. This AAR report strives to present that
explanation. However, it is important to first address several misunderstood concepts.
5.2 DAQ 3.0 vs. DAQ 3.4
5.2.1 General
Delivered Audio Quality (DAQ) is a subjective metric for scoring the fidelity and
intelligibility of audio. DAQ definitions per the industry standard TIA/EIA TSB -88
document also include equivalences to measureable performance, i.e. Bit Error
Rate (applicable to digital systems) and signal level (based on signal-to-noise ratio).
TSB -88 recommends DAQ 3.4 performance as the design goal for public safety and
first responder radio systems. The less stringent DAQ 3.0 is the typical design goal
for commercial and public service radio systems. It is important to note that the
DAQ rating does not refer to a grade of equipment or specific system type. The
hardware used to achieve DAQ 3.4 performance is the same hardware used to
achieve DAQ 3.0 performance. The Harris Contract specifically stated that the design
standard for the Deschutes County radio system was DAQ 3.0.
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t„�.. ,m�,.�z.,.:,,N�� fz��...ru�sta�.. •kms i �,s�..�� �r�.<��,.:�s���,�t:.;.,;;riz� ae�,.�a,.:..c.,u:�z�_..�:�cru: a,v�.��'Ws.�.�.�.�ca.�,xz„�.�ur?z,.._, ,:F:�aa.�.zzz.�„z�:,-��scz
DAQ rating does not refer to a grade of equipment or specific
system type. The hardware used to achieve DAQ 3.4
performance is the same hardware used to achieve DAQ 3.0
performance.
t��:u:x.�,,, - :,,. r,...:., xss - .ri....n.;5,;. _,a:.�:�..�. ,r.-:,�xtat-7�..u,,.ss.,:��.,,:;:. �r tea; 's,.,ern..;�,�.=5.�srno-w�y�,•.,<;�;s.. �.�,ares,::,
5.2.2 DAQ Subjective Ratings
The subjective DAQ definitions per TSB -88.1-D, §5.4.2 are listed in Table 2 below.
DAQ
Subjective Performance Description
Rating
1.0
Unusable, speech present but unreadable.
Understandable with considerable effort. Frequent repetition due
2.0
to noise/distortion.
Speech understandable with slight effort. Occasional repetition
3.0
required due to noise/distortion.
Speech understandable with repetition only rarely required. Some
3.4
noise/distortion.
4.0
Speech easily understood. Occasional noise/distortion.
4.5
Speech easily understood. Infrequent noise/distortion.
5.0
Speech easily understood.
Table 2
The definitions for DAQ 3.0 and DAQ 3.4 are subtly different and are more applicable
to analog systems, where voice quality will degrade gradually with increased levels
of audible noise and distortion. However, the nature of a digital signal is to either
"work or not". Subjectively, the performance of a digital radio signal tends to fall
more accurately into the range of DAQ 4.0 (or better) for good performance, or DAQ
2.0 (or worse) for poor performance. Therefore, the subjective difference between
DAQ 3.0 and DAQ 3.4 is essentially meaningless in digital applications. DAQ voice
testing of a P25 system is more accurately scored with Pass/Fail criteria.
5.2.3 DAQ Equivalencies
TSB -88.1-D, Annex A does provide quantifiable, objective, and measurable
performance equivalences for DAQ 3.0 and DAQ 3.4 based upon Bit Error Rate (BER)
and Carrier/Noise performance. These are estimated performance figures but are
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generally utilized as the basis for design and evaluation throughout the public safety
communications industry.
For P25 Phase 2 modulation, DAQ 3.0 is specified as no worse than 3.1% BER, and
DAQ 3.4 is specified as no worse than 2.4% BER. Therefore, DAQ 3.4 requires 0.7%
fewer bit errors than DAQ 3.0. In terms of Carrier/Noise performance, DAQ 3.4
requires 1.2 dB stronger signal (i.e. carrier) than DAQ 3.0. These differences are
small but measureable through testing, given a large enough sample size and the
use of statistical averaging. However, due to signal variability and fading, the small
difference between DAQ 3.0 and DAQ 3.4 is not measureable for a single
transmission or stationary location.
5.2.4 Contract & Testing
The Harris Contract included both subjective DAQ voice testing and objective
automated drive testing. However, there is no guarantee of performance attached
to either test.
The DAQ voice testing involved placing a voice call in a test grid and scoring that call
for subjective DAQ performance. That testing was performed and documented in
!une 2017.
Automated drive testing, per the Contract, was based upon signal level
measurements but did not include the collection of BER performance data. P25
systems, especially those involving simulcast sites, are typically evaluated for both
signal level and BER. It is unclear why BER testing was not recommended by the
Harris contract team, Harris implementation team, DC911 technical team, or
ADCOMM.
The automated drive testing as specified in the Contract would have collected signal
level data within accessible test grids throughout the County. That data would then
have been averaged and analyzed within each grid to determine a Pass/Fail rating
and assembled into a coverage test report. There is no evidence that a
comprehensive drive test and associated coverage analysis was delivered.
Therefore, it is impossible to objectively evaluate the County for coverage
performance and make any meaningful determinations of where (geographically)
DAQ 3.0 or DAQ 3.4 was achieved. Although lacking BER data, the drive test report,
if delivered, would have also provided a valuable baseline reference for coverage
performance.
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5.2.5 Deschutes County DAQ Facts
1. DAQ 3.4 is the recommended and best -practice design goal for public safety
radio systems.
2. The Sparling Report based its assumptions on DAQ 3.4 performance.
3. The Harris Contract specified DAQ 3.0 as the design goal for Deschutes
County.
4. DAQ 3.0 and DAQ 3.4 does not specify a grade of equipment or system type.
5. Design differences between DAQ 3.0 and DAQ 3.4 are mostly academic, but
those differences can impact performance at the edges of coverage and in
marginal coverage areas.
6. The decision to reference DAQ 3.0 as the design goal in the purchase
contract has caused public relations and stakeholder confidence issues.
7. Differences between DAQ 3.0 and DAQ 3.4 are not the root cause of
problems encountered by users at system cutover.
8. The lack of meaningful coverage testing prevented the establishment of a
coverage baseline and a determination of locations where DAQ 3.0 and DAQ
3.4 performance was achieved.
Differences between DAQ 3.0 and DAQ 3.4 are not the root
cause of problems encountered by users at system cutover.
5.3 Mobile, Portable, & In -Building Design
Harris Corporation has stated publicly, in post -cutover documents, and in an interview
with Trott that the Deschutes County system was designed for mobile radios (mounted in
vehicles) as opposed to handheld portable radios. There is indeed a significant difference
between the performance of mobiles and portables. Portable radios operate at lower
power, with less efficient antennas, and their signals are attenuated by the body of the
user. The performance difference between mobiles and portables is much more
significant than the difference between DAQ 3.0 and DAQ 3.4.
Contrary to Harris' claim, both the proposal and Contract SOW state that the Harris -
produced coverage maps are based upon portable radios at hip -level (3.5'). The coverage
maps provided with the SOW include separate maps for mobiles, portables on street, and
portables in -buildings.
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Both the Harris proposal and Contract Statement of Work state
that coverage maps are based upon portable radios at hip-level.
(nr"'-�.s.:a�r..Cs....,✓s'v:.Y... M�.:='^«:C. :.Y.�.«..5;?,N�:. �cN .3"xrN.s: ... NakR"eJ:F:...tiC�:.,":��:'i���..iw;:'a. �.: �..:. P'.s', ��.zxP,�2.���D«v�..T`.�uyY�n�?M�,�Tr...h:Fad.'�2`x,£�_nr5�:�yawr2++;,_aN.4"�'
Section 2, Item B of the Contract states that the Detailed Design Documents shall be
incorporated into the Agreement after approval by the Buyer and shall "...supersede any
contrary provisions in the Statement of Work attached to this Agreement as an exhibit".
The Detailed Design Review package is dated 06/01/2016; the approval form with
signatures from DC911 is dated 02/24/2017. The Design Review included updates to site
locations, site configuration details, system diagrams, network connectivity, updated
coverage maps, and other relevant information. Per the Contract terms, these revisions
superseded and effectively amended the Contract SOW.
One element of the Design Review is discussion regarding the design and optimization of
inbound antenna systems for portable radio performance. In contrast to the mobile
design of the State System, Harris states that Deschutes County radio sites are designed
to, "Balance system for portable [radios] to give the best possible of mobile and portable
performance".
The Design Review further provides coverage prediction maps for portable radios
operating in buildings of various densities. Table 3 is an excerpt from the Design Review
showing the percentage of coverage predicted countywide, in the Bend metro area, and
Redmond area. "PoTb" refers to portable talk -back, normally the limiting path of a two-
way portable radio call.
Table 3
Trott Communications Group, Inc. 18
Scenario
County
Bend
Redmond
PoTb
92%
2 95%
>_ 95%
(Outdoor)
PoTb
73%
_> 95%
Z 95%
(24dB
indoor)
PoTb
81%
a 95%
Z 95%
(20dB
indoor)
PoTb
83%
>t 95%
>_ 95%
(18dB
indoor)
Table 3
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As seen in Table 3, predicted service in the highest density buildings (24 dB) is listed at
greater than 95% for Bend and Redmond, and 73% countywide. Outdoor portable
coverage is presented at 92% countywide.
The expectations set for any attendee of the Design Review would reasonably include
portable radio coverage throughout the County (>90%) and reliable performance inside
of buildings in areas depicted on the coverage maps, including Bend and Redmond.
tai.a. f(eia �i..ac„k5�_.F.,,z�F mN \',c�:,FSS;.s,Lwv✓h.F:,:�,:-.: �..�.e, �3c. a].. c;5:..:.e, .a{x:,�:;.,:.. ,,C, S �: X.:.'�,.1.�, �, \x:.:':,'ss,.2.;..,5,`2:,�,✓z?-�.;�,s.:..fi.,e3,..��.:. .::«.:, �:S"w^,6wS.:::...w....,. ,.. Si��...
The expectations set for any attendee of the Design Review
would reasonably include portable radio coverage throughout
the County and reliable performance inside of buildings...
There is no available evidence showing that the Deschutes County P25 system was
designed for mobile -only performance or that it would not support portable coverage
inside of many buildings in Bend, Redmond, and elsewhere. As noted in §5.2.4, had
meaningful BER and signal level testing been executed, the resulting baseline
performance would have shown the system performance achieved.
There is no available evidence showing that the Deschutes
that it will not support portable coverage inside of many
buildings in Bend, Redmond, and elsewhere.
6.0 WHAT CAUSED THE OUTCOME?
6.1 General
The expected outcome vs. actual outcome of the P25 radio system project is summarized
in §4.0. The cause of the outcome achieved is a complex matter resulting from a "perfect
storm" of oversights, over confidence, inadequate vendor support, and bad luck.
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6.2 Undocumented System Requirements
The stakeholders interviewed were familiar with the Sparling Report and frequently
mentioned it as the catalyst for the P25 project. The report documented many needs and
requirements and recommended specific items for inclusion in an RFP procurement
process. In early 2015, a decision was made to pursue a sole -source partnership with
ODOT and Harris Corporation.
The After Action Review finds no fault with the ODOT/Harris partnership decision, which
provided clear financial, interoperability, and statewide roaming benefits. However, this
procurement path did not eliminate the need to document system performance
requirements and develop contract terms, capturing the overall intent of an RFP.
The After Action Review finds no fault with the ODOT/Harris
partnership decision, which provided clear financial,
interoperability, and statewide roaming benefits.
A detailed requirements document would have established a basis for the project and
* •ty far stakeholder review and concurrence. it would have also given
provided a..� opportunity , L.. - -
Harris clear guidance on performance requirements, implementation responsibilities, and
system acceptance terms. Instead, Harris produced a system proposal from a series of
meetings and phone calls.
6.3 Weak Purchase Contract
Project initiation errors were compounded by an exceptionally weak purchase contract.
As noted in §3.6, the Contract failed to capture key contract elements and buyer
protections laid out in the Sparling Report. Contract inadequacies included:
• No enforceable coverage requirements
• DAQ 3.0 design reference
• No meaningful coverage testing
• Only basic system feature testing
• No requirements for development of a system cutover and fallback plan
• No requirements for user radio tuning and reprogramming
• No user training
• No system evaluation period prior to Final Acceptance
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Failings of the Contract cannot be overstated and served to allow, if not empower, many
of the future implementation mistakes that directly led to system cutover issues.
Contracting oversights and omissions appear to be the shared responsibility of DC911,
ADCOMM, County Administration, County Legal Counsel, and Harris.
--ailings of the Contract cannot be overstated and served t,2
allow, if not empower, many of the future implementation
mistakes that directly led to system cutover issues.
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6.4 Poor Contract Administration
The Contract was not administered competently by either party, allowing major system
changes to occur without proper vetting or contract adjustments. The contracted system
included seven transmission sites. However, at the time of system cutover on
07/27/2017, only five sites were constructed and active.
Multiple sections of the Contract addressed the addition and/or removal of items that
impacted cost, system performance, and/or schedule. Although the County took delivery
of all site equipment, two locations (Jack Pine and Cinder Butte) could not be constructed
due to tower conditions and permitting issues. See §6.6 for additional information and
consequences regarding incomplete system construction.
It should have been apparent to Harris and' DC911 that removal or deferral of two radio
sites would have an impact on system cost, performance, and schedule. However, no
contract adjustments or associated due diligence were performed. It was irresponsible of
DC911 and County Administration to allow a significant project change without
addressing impact to the Contract. Moreover, it is inconceivable that Harris Corporation
would proceed without contract adjustments and a full analysis of impact to
performance. Had adequate performance guarantees and testing been in place (see §6.3),
it is unlikely that Harris would have allowed this seemingly undocumented project change
to occur.
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n:X�.Lh�",3K+��:.:Fra',U:n'c.�"•aivnD;.ai'�*�'2�..G' b'�iXu':_� �n....eS.�?i�.:..�3`�.'Y�';SZa�-.L:'s�Z��;Y°.n.:}:�s3�rJ,«24K�S��:�v?��,'v"h`, 'v�SE"iaG'�*.'.�^,'4"�'i�, i":.Va:bi`Sf..,;�X'%ia<.:"ei�,}�a"`.-�€;vv�;� _Ce'C�sS_
It should have been apparent to Harris and DC911 that removal
or deferral of two tower sites would have an impact on system
cost, performance, and schedule. However, no contract
adjustments or associated due diligence were performed.
ft.�ti?�5".."xks}� PFY»'.La,��a,n..56a3.^:ao-��'ori-ar.S,a.,'.N.rc:;..,..v Sw..-.`sau.,.: `z..Fu<� .`5::. Zav etez'S'+.zti,,...*..x.M.:£.SaaS::-✓...3'CtiTMxY3.'am�w;Y.c..:uY.�N..3P;r3 !..:.P .G_`Tr: ti.YLv.Jri�ti
In June 2018, Interim Director Sara Crosswhite contacted Harris attempting to account
for the site discrepancies. The Interim Director was informed that Harris was owed
additional funds associated with extending the timeline of the project due to site delays.
However, those additional funds were exchanged for unused labor associated with
construction and commissioning of the two sites. It was further stated by Harris that the
removal of Jack Pine was addressed in Amendment 1 (dated 03/06/2017), and the
removal of Cinder Butte was addressed in Amendment 2 (dated 10/24/2017; 3 months
after cutover). The claims of contractual agreement regarding the unbuilt sites are
disputed by the facts.
Both Amendment 1 and Amendment 2 address adjustments to costs and services
unrelated to the two sites in question; neither address funds, services, or performance
associated with transmission sites. The only potential reference to Jack Pine in
Amendment 1 is its inconspicuous absence from the attached Gantt chart, as seen below.
Infrastructure Installation
70 days
Mon 112114
P25 RP Sito - Awbrey Butte (Simulcast Coil #1)
S days
Mon 10171
P23 RF Site • St Charles (Simulcast Cell !t1)
3.5 days
Mon 1116117
P25 RF Site - Cling Sutto(SimulCast Cell X2)
5 days
Mon 113011
Pts RF site - Hoodoo (Multicast)
6.5 days
Mon 211311 i
P25 RF Site - Pine Martin (Muitica t)
5 days
Mon 212711
P25 RF Sao - Cindar Butto(Simulcast Coil 02)
5 days
flan tl"11
i
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Similarly, the Gantt chart attached to Amendment 2 omits the Cinder Butte transmission
site.
infrastructure Installation
P25 RF Site - Avlbrey Butte (Simulcast Cell
P25 RF Site - Pine Martin IMulticast)
P25 RF Site- St Charles (Simulcast Cell 1f1,
P25 RF Site . Cline Butte (Simulcast Cell 172
P25 RF Site - Hoodoo (Multicast)
iticro are Ready
Simulcast System Final Optimization
Trott Communications Group, Inc. 22
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Tue 5r16117
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Tue 5116117
5.5 days Mon 3113117
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46 days Mon 3113117
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10 days Tue 5116117
Tue 5130117;
After Action Review
02/25/2019
Interviews with Former Director Reinke, County Administrator, County Legal Counsel, and
Harris did little to clarify the circumstances and details surrounding the contract
administration discrepancies. Harris specifically acknowledged that no other contract
record of the site removals exists beyond the amendments discussed herein. Therefore,
it is apparent that project funds/services were traded without clear and transparent
documentation.
A is apparent that project funds/services were traded without
clear and transparent documentation.
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6.5 DC911 Overconfidence
DC911 staff appears to have been overconfident in their technical abilities associated with
project planning and implementation. For high technology projects, it is typical to rely
heavily upon a subject matter expert such as ADCOMM. However, per meeting minutes,
ADCOMM was seldom if ever invited to participate in meetings of the DC911 User Board
or Public Safety Radio Project Review Team (PSRT).
At a critical point in the project, January 2017, ADCOMM was phased out of the DC911
technical team. Email correspondence between DC911 staff indicates a belief that all
necessary knowledge and expertise was available in-house, and outside support was no
longer needed. Even after post -cutover system issues lingered for months, ADCOMM was
not re-engaged until January of 2018. It remains unclear if ADCOMM's project
involvement was directed by DC911 technical staff or the 911 Director. However, it was
acknowledged by Former Director Reinke that the ultimate responsibility for this decision
belongs to the Director.
At a critical point in the project, January 2017, ADCOMM was
phased out of the DC911 technical team.
DC911 willingly assumed responsibilities that are normally within the scope of the system
provider. As noted in §3.6, DC911 was responsible for the installation and testing of base
station antenna systems, including transmission line, lightning suppressors, and tower -
mounted amplifiers. Work was actually performed by a third party contractor and
Trott Communications Group, Inc. 23
After Action Review
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supervised by DC911. Regardless of technical abilities, it is ill advised for the buyer to take
ownership of any scope associated with system installation. Interviews with DC911 staff,
Former Director Reinke, and ADCOMM were unable to provide a reason or specific
benefit for including base station antenna systems as a County responsibility.
DC911 tasks, responsibilities, and support associated with cutover planning and user radio
fleet readiness are discussed in §6.9.
6.6 Incomplete System Buildout
Issues with the Jack Pine Ridge tower were reported to the Public Safety Radio Project
Review Team (PSRT) per meeting minutes dated 09/06/2016. Structural engineering
studies determined that the tower exceeded acceptable capacity and was not suitable for
use with this project. DC911 explored replacement options including the construction of
a new structure and alternative site locations. On 11/01/2016, PSRT minutes indicate that
DC911 and ADCOMM met to review the Jack Pine situation and other matters. "Based
upon the review, it was determined an alternate site for Jackpine Ridge would not be
necessary as it would not provide any additional benefit to users. The portable coverage
without the alternate site will still meet the District's goals for going live. Cost analysis
work to develop Jackpine Ridge site in the future will continue. "ADCOMM was not present
at the meeting and characterizes their input differently. ADCOMM contends that their
analysis found that the P25 system would function better than the legacy system without
Jack Pine but never concluded that Jack Pine, "would not provide any additional benefit
to users".
Regardless of the opinions of DC911 and ADCOMM, Harris was contractually responsible
for system design and performance. As noted in §6.4, there is no evidence that Harris fully
analyzed the performance impact, issued recommendations regarding Jack Pine, or
properly addressed the contractual implications of a plan to defer construction of the site.
E .rs`,9 �;,, ,a._... ,.._,4.'..a ...,.J�F ab,� .�aF �."� vh nU. ���: �� .;w-.e3a.Sk.,.ea -�.: Yo. laY!.:<_:a .�.,n 2,S �.amZ., .. ..J -^! .✓^;e�,:
analyzedThere is no evidence that Harris fully performance
impact, • d recommendations Pine, o
properly addressed the contractual implications of a plan to
defer construction of the site.
It is also important to understand that Jack Pine was designed to function within a 3 -site
simulcast cell, supporting coverage in and around Bend. The removal of any site from a
Trott Communications Group, Inc. 24
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simulcast cell can potentially impact the performance of the cell as a whole. Therefore,
even if Jack Pine was determined to provide little benefit, modifications to the remaining
two sites in the cell may be necessary to allow its removal. It was determined in March of
2018 (16 months after eliminating Jack Pine and eight months after system cutover) that
the antenna design for the St. Charles Medical Center site in Bend was dependent upon
the presence of Jack Pine. The antennas were promptly redesigned and replaced.
Substantial coverage improvements in the Bend area were reported as a result. The Jack
Pine/St. Charles coverage issue is a disastrous example of the consequences that can
occur when proper vetting of system changes is ignored. Although DC911 was a willing
participant in this error, Harris was responsible for design and performance and should
not have allowed system changes without performing their due diligence.
6.7 Absence of Meaningful Acceptance Testing
The contractually agreed upon acceptance testing was inadequate in many ways. The
most glaring issue was the omission of Bit Error Rate (BER) drive testing. It is surprising
that neither Harris nor ADCOMM recommended BER testing, which is the norm for P25
simulcast systems. The Contract did include RSSI (i.e. signal level) testing although there
is no evidence that the specified test was completed. A combination of BER and RSSI
testing would have provided a base line of coverage and DAQ performance, verified
simulcast timing, and validated that the sites were performing as designed. Presumably,
a drive test would have identified the St. Charles antenna design issue described in §6.6.
Functional Testing per the Contract was restricted to basic trunking features and did not
fully exercise and demonstrate system performance. A system audit performed by Harris
in early 2018 identified several system configuration issues, contributing to user
complaints. System testing is intended to identify configuration problems prior to system
cutover but failed to do so in this instance.
6.8 Urgency to Cutover
In June - July of 2017 there was a perceived sense of urgency to move users off the legacy
Motorola radio system. It is factual that the Motorola system was obsolete, with limited
availability of parts and support. It appears that the fear of system failure was so strong
that reasonable efforts to plan a smooth and orderly cutover were abandoned. The
transition to P25 was executed in crisis mode without adequate preparation, testing,
organization, or training.
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DC911 strongly believed that the legacy system was at risk of catastrophic failure, as
confirmed by interviews with DC911 technical staff and Former Director Reinke. The
Former Director further stated that equipment failures were common and becoming
more frequent and more concerning throughout the first half 2017.
Motorola and Day Wireless (the local maintenance contractor) contend that system
maintenance was still possible. Motorola further stated that DC911 never contacted
Motorola or Day Wireless requesting service/maintenance for the legacy system during
the timeframe in question. As a direct competitor of Harris, Motorola's after -the -fact
assertion is less than reliable; however, DC911 cannot provide documentation
contradicting those claims.
There is no documentation showing that the User Board, PSRT,
or County Administration was fully briefed on the options and
potential risks associated with a system cutover in July of 2017.
Short of catastrophic failure of the legacy radio system, the decision to cutover to the new
P25 system without adequate testing, planning, and training can be characterized, in
hindsight, as trading a potential crisis for an actual crisis. Furthermore, there is no
documentation showing that the User Board, PSRT, or County Administration was fully
briefed on the options and potential risks associated with a system cutover in July of 2017.
That ill-fated decision falls squarely upon DC911 and Director Reinke. However, it is
impossible to know if the early cutover, for all of its faults, prevented a more devastating
outage of the legacy system.
6.9 Cutover Errors
6.9.1 Cutover Plan
The system provider is typically responsible for authoring a cutover plan with inputs
from the stakeholders. That plan should:
• Detail all prerequisites for cutover
• Identify all resources needed (equipment, staff, etc.)
• Provide a step-by-step process for execution
• Specify validation steps to ensure that expected results were achieved
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• Provide a fallback plan if it becomes necessary to abandon the cutover and
return to the legacy system
• Define criteria to execute fallback
There is no evidence that a comprehensive cutover plan was developed, approved,
or executed. Although the Contract did not specifically address a Cutover Plan, the
signed Design Review Form stated under "Transition Plan", "Plan to be developed
with Customer 04/2017". Based upon this acknowledgement, Harris should have
been engaged with cutover planning, with significant participation from DC911.
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There is no evidence that a comprehensive cutover plan was
developed, approved, or executed.
6.9.2 System Testing & Validation
As noted in §6.7, pre -cutover activities failed to include meaningful testing and
validation. The only coverage test performed was basic voice testing with mobile
radios. As established in §5.3 there was a reasonable expectation of portable radio
coverage yet no coverage testing with portables was performed.
A review of the mobile voice test results indicates that only a representative from
Harris and a representative from DC911 was present. A coverage test team for DAQ
voice testing would typically include at least one representative from the user
agencies and the technical consultant. As noted throughout this review, ADCOMM
was not involved with system testing or cutover planning.
§6.7 noted that the Contract also required RSSI (signal level) drive testing. Although
the inclusion of BER testing is preferred with digital simulcast systems, signal level
testing may have provided valuable data and identified site and/or system issues.
Trott's initial investigations found no indication that signal level drive testing was
performed. No drive test results were included in the Harris closeout package, and
DC911 staff had no recollection of a formal signal level drive test. Harris stated in an
interview on 01/31/2019 that the drive test was conducted, and offered to provide
the results.
Harris provided raw data and KMZ files to DC911 on 02/13/2019. Those files appear
to contain RSSI data but do not meet the criteria specified in the Contract. There is
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no test report, grid mapping, test grid analysis, or method for displaying the various
service levels described in the test plan. Furthermore, there is no indication of
performance or determination of system readiness associated with the raw data.
Follow-up discussions with DC911 staff indicated that the data in question was
originally provided in July 2017, just before system cutover. At that time, the data
was described as a troubleshooting effort for site adjacency/roaming
configurations. DC911 was not asked to sign off on the data, and they contend that
it was never represented as the official signal level drive test. The data remains
unanalyzed.
The facts support DC911's assertion that the signal level (RSSI) drive test specified
in the Contract was not delivered. However, DC911 cannot explain why the test and
associated analysis was not demanded prior to system cutover.
6.9.3 User Training
User training is an important element of any significant change in technology.
Although most of the agencies involved in the initial system cutover were familiar
with trunking technology and basic radio operations, the move to a new P25 system
ig not a trivial matter. Many agencies were transitioning to new radio units with
different layouts and features. There were also modified talkgroup (i.e. channel)
layouts and new talkgroups to capture the updated needs and requirements of the
agencies.
Most importantly, P25 digital systems function differently from the legacy analog
system. Digital audio has a different sound and the radio functions differently at the
edge of coverage. As discussed in §5.2.2, digital radios tend to operate normally
right up to the edge of service, and then experience a rapid drop-off in performance.
At the drop-off point, the user may experience garbled voice and other audio
artifacts. Additionally, noise -canceling features require modifications to user
behavior and habits. Therefore, it is critical that users undergo a training program
to understand the digital radio, its features, and the required operational
differences.
A majority of the agencies transitioned to the P25 system with
no detailed user training.
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A majority of the agencies transitioned to the P25 system with no detailed user
training. Therefore, changes in radio operations, audio performance, positioning of
noise canceling microphones, and radio performance in marginal coverage areas
were unknown or largely misunderstood by the users.
User training was not addressed in the Contract and appears to have been the
responsibility of DC911. However, Harris could have proposed additional services
for additional costs in the interest of project success. They did state (in an interview
with Trott) that in hindsight, they would like to have been more involved with end
users for training and setting of expectations. It is also noted that ADCOMM could
have been an important resource for user training had they remained on the DC911
team in 2017.
6.9.4 User Equipment Programming
Investigations and interviews repeatedly found that errors in the programming and
configuration of the user equipment (mobiles and portables) played a significant, if
not dominant role in cutover and post -cutover problems. The programming errors
caused a multitude of radio performance issues including:
• Roaming to ODOT sites instead of Deschutes sites
• Slow radio registrations
• Failure to roam to stronger (i.e. geographically closer) sites
• Frequency and control channel errors
• Inconsistent button/channel layouts
• Talkgroup errors (missing, misplaced, Phase 1 vs. Phase 2, etc.)
In addition to blatant errors, audio configuration issues (impacting audio levels and
balancing) were also widespread.
Investigations• interviews repeatedlyo• that errors
programming and configuration of the user equipment (mobiles
• portables) played • dominant role
cutover d post -cutover problems.
Although some radio "tweaking" post -cutover is normally required, the quantity of
user radio issues found and corrected show that the radio programing templates
(i.e. configuration files) were not tested prior to rollout. Had the most significant
Trott Communications Group, Inc. 29
After Action Review
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programming issues been discovered and rectified prior to system cutover, the
overall user experience would have been much better.
Per reports from DC911 and their subcontractor, Harris provided many of the radio
settings used in the initial programing files for the Harris radios. Harris stated in
interviews that no radio programming services were included with the user radio
procurements. DC911 confirms that user radios were purchased by the individual
agencies through a state contract mechanism. There was no global purchase
agreement between Harris and Deschutes County for user equipment.
Harris was not contractually responsible for the physical programing or live testing
of the radio templates. The decision to proceed with system cutover without fully
verified user equipment falls to DC911. However, it is reasonable to have expected
Harris to advise DC911 on such matters. They could have also proposed additional
services that may have been omitted or overlooked in the original Contract. As
noted in §6.5, ADCOMM was not actively engaged at this point in the project.
6.9.5 Vendor Support
Serious performance issues were apparent immediately upon cutover. It was
initially unclear if issues were caused by the system infrastructure, user equipment
compatibility, user equipment programming, or a combination of items. Witnesses
from various agencies and contractors stated that DC911 worked diligently to
resolve issues but received slow support from Harris and Motorola (the
manufacturer of user radios used by Bend PD and other agencies). As stated by
several interviewees "911 was on their own". Recommendations for changes to user
equipment programing required weeks to obtain. Meanwhile users were struggling
with preventable communications problems. See §6.11 for additional vendor
support details.
As stated by several interviewees "911 was on their own".
6.10 Installation/Configuration Errors
§6.6 described an antenna system issue at the St. Charles site, impacting coverage
performance in the Bend area. Harris also identified and corrected other infrastructure
items including but not limited to:
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• Software revision alignment
• Network Access Codes (NAC), impacting site roaming
• Transcoding
• Server reconfiguration
• Quality of Service settings
• Receiver voter settings
A majority of the recommended infrastructure changes were not implemented until early
2018, six months or longer after system cutover. Harris was ultimately responsible for
infrastructure errors and any delays associated with corrective actions.
6.11 Inadequate Vendor Support
It was stated in §6.5 that the DC911 technical staff appeared to be overconfident in their
capabilities and resources. However, that overconfidence does not excuse the lack of
resources and inputs provided by Harris during the final months of implementation,
cutover planning, and cutover execution. DC911 may have been conformable with the
following:
• Rushed and inadequate system testing
• using unverified radio programing templates
• Foregoing a detail system cutover plan
Harris should have been concerned and advised DC911 against these choices. Harris was
not contractually responsible for many of these items. However, as industry experts and
a long term partner of both DC911 and ODOT, it was in Harris' best interest to provide
guidance and/or propose additional services that might have been recommended or
deemed necessary for project success. It is possible that such recommendations and/or
proposals were informally offered but not documented.
It is also noted that DC911 reached out to Harris many times to address issues in the
weeks and months after cutover. Harris sent a team of experts to Deschutes County to
perform a system audit and take necessary actions after the 12/27/2017 OSHA complaint
and subsequent negative press.
It is similarly noted that it was difficult for DC911 to obtain support from Motorola to
address possible issues with user radio configurations. It took weeks to address relatively
minor issues. Significant improvements in audio performance of the Motorola radios did
not occur until ADCOMM was re-engaged in 2018.
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6.12 Insufficient Oversight & Accountability
The Board of County Commissioners (BoCC) and public at large were generally unaware
of the P25 radio system issues until the Concern Letter and subsequent OSHA complaint
in December 2017, nearly five months after activation and cutover. This review also
revealed that the BoCC and County Administration had only limited knowledge of key
project decisions such as the deferral of two transmission sites, removing ADCOMM from
the DC911 technical team, and expediting the system cutover date.
The Board of County Commissioners (BoCC) and public at large
were generally unaware of the P25 radio system issues until the
Concern Letter and subsequent OSHA. complaint in December
2017, nearly five months after activation and cutover.
A common theme emerged from the interviews. The BoCC only knew what the County
Administrator reported to them. The County Administrator only knew what that the 911
Director reported to him. The 911 Director only knew what his technical team told him.
it is normal In public safety radio projects that the Elected officials (City Councils, Co,inty
Commissioners, etc.) are not directly involved or knowledgeable in the day-to-day
activities of project implementation. It is the responsibility of municipal staff and/or
stakeholders to report critical information to the governing body. If there is a breakdown
in reporting, the elected officials remain uninformed.
Former Director Reinke acknowledged responsibility for not knowing or understanding
the magnitude of system problems at cutover. Although some issues were reported to
the County Administrator by DC911, those issues were generally presented as normal
challenges associated with a high technology rollout.
It was established in §6.9.5 & §6.11 that DC911 did not receive adequate` or prompt
support from Harris or Motorola. However, issues and support challenges were not
officially escalated to the County Administrator. Some stakeholders stated in interviews
that concerns were conveyed privately to the County Administrator and those concerns
went unaddressed.
The User Board provides oversight to DC911 in the form of advisory input. However, nine
of the twelve monthly meetings of the User Board in 2017 were canceled by the 911
Director. The only meetings occurred in February, March, and July of 2017. No meetings
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After Action Review
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were held after system cutover through the end of the year. As noted in §3.3.2, the
Chairman of the User Board is the County Administrator (or designee). A review of
meeting minutes indicated that the 911 Director served as the Chairman, with authority
to set the agenda and cancel meetings. Therefore, DC911 was effectively in control of the
board that was intended to exercise oversight of DC911.
It was also noted in §3.3.2 that the User Board is empowered to call a special meeting to
express concerns directly to the County Administrator and/or Board of County
Commissioners. However, User Board members may not have been properly informed of
this option, may have felt that such action would undermine DC911, or did not recognize
the severity of the issues. Therefore, this available mechanism for additional oversight
was not exercised.
The Public Safety Radio Team (PSRT) as described in §3.3.3 was specifically focused on
radio communications and was in the best position to provide inputs on the project.
Although the team met regularly and discussed project issues, the PSRT had no oversight
authority or reporting path to the User Board, County Administrator, or BoCC. Per the
PSRT Charter, all external communications occur through the PSRT Chairman. Meetings
were chaired by DC911 technical staff.
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Overall, DC911 was allowed to operate without adequate
oversight. This autonomy prevented issue escalation and the
assignment of additional •
Overall, DC911 was allowed to operate without adequate oversight. This autonomy
prevented issue escalation and the assignment of additional resources. That barrier was
only broken after the OSHA complaint.
6.13 In Spite of Everything...
Section 6.0 (herein) details 15 primary reasons that the initial outcome of system cutover
fell short of expectations. This AAR report is highly critical of the contract terms, contract
administration, removal of ADCOMM from the technical team, acceptance testing, and
cutover planning. In spite of these significant oversights, the system cutover could have
been largely successful (from the perspective of the end-users) had the infrastructure and
user equipment operated in an acceptable manner. The St. Charles antenna design,
various infrastructure configuration errors, and user radio programming/settings issues
Trott Communications Group, Inc. 33
After Action Review
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were the ultimate cause of the communications problems that plagued system users for
months. These unforced errors were primarily the responsibility of the equipment
vendors and their subcontractors.
The St. Charles antenna design, various infrastructure
configuration errors, and user radio programming/settings issues
were the ultimate cause of the communications problems that
plagued system users for months.
These facts in no way relieve responsibility from those charged with developing and
administering the project program on behalf of Deschutes County. Their oversights
created the environment that allowed equipment and performance issues to go
undetected. However, Deschutes County did not directly cause many of the equipment
problems that led to the negative end-user experience. As described in §7.0, once the
various equipment issues were largely resolved in 2018, the P25 system as designed
provides stable and acceptable performance according to the member agencies
interviewed.
7.0 2018 CORRECTIVE ACTIONS
7.1 Harris Audit & Corrective Actions
Harris performed a comprehensive system audit as documented in the Deschutes County
System Review Report dated 01/09/2018. That audit discovered several configuration
errors and identified other recommendations to optimize system performance. As noted
in §6.10, configuration changes included:
• Software revision alignment
• Network Access Codes (NAC), impacting site roaming
• Transcoder correction/reconfiguration
• Server reconfiguration
• Quality of Service settings
• Receiver voter settings
• Site Adjacency/Roaming parameters
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Both DC911 and ODOT reported that resolution of a transcoder configuration error was a
critical item towards improving system stability. Adjustments to roaming parameters
were also cited as yielding major performance improvements.
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Both DC911 and ODOT reported that resolution of a transcoder
configuration error was a critical item towards improving system
stability.
Interviews with Harris minimized the impact of the audit and associated configuration
changes. They further stated that the system was appropriately certified by the
contractually mandated acceptance testing.
7.2 ADCOMM Support
ADCOMM was re-engaged in January 2018 and played an important role in the diagnosis
and resolution of user radio audio performance issues. ADCOMM worked with
representatives from Motorola to identify audio settings, level adjustments, and
alternative microphone accessories to normalize the Motorola mobiles and portables
with other radios on the P25 system.
ADCOMM also worked with DC911 and Harris to identity and resolve the St. Charles
antenna situation, Harris infrastructure corrective actions, and Harris user radio
programming changes. ADCOMM remains engaged with DC911, providing assistance with
the replacement site for Jack Pine Ridge and coverage testing.
7.3 Motorola Programming, Firmware, and Microphones Accessories
DC911, Harris, ADCOMM, and Communications Northwest all reported various
configuration and equipment issues with the Motorola subscriber units utilized by Bend
PD and other agencies. The Motorola devices were in use on the legacy system but
required feature upgrades and reprogramming for utilization on the P25 system. The
manufacturer also recommends performance specification testing and retuning when
converting existing field units from analog to digital operations.
Motorola user radios have successfully operated on numerous Harris P25 systems and are
currently operating on the DC911 system with acceptable performance. At the time of
system cutover, however, there were significant issues with the programming of the
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After Action Review
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Motorola radios along with documented challenges with device firmware and
microphone accessories.
According to interviews with ADCOMM and DC911, incidences were also discovered
where the existing Motorola radios were operating at a fraction of the rated output
power. As noted above, Motorola recommends specification verification and retuning of
user radios during feature upgrades, reprogramming, and activation of digital operations.
In 2018, ADCOMM worked with DC911, Motorola, and Day Wireless to identify and
document the various issues associated with the Motorola units operating on the DC911
system. Corrective actions included:
• Firmware updates
• Programming modifications
• Audio configurations/adjustments
• Replacement speaker microphone
• Additional user training
Bend PD and other Motorola radio users reported significant performance improvement
as a result of these actions. Had these items been addressed before system cutover, it is
likely that these users would have seen much better radio performance at the time of
system activation. Likewise, timely resolution of the radio problems would have
prevented months of unreliable communications.
Had these items been addressed before system cutover, it is
likely that these users would have .. much better rR r
performances.
f system activation.
7.4 St. Charles Antenna Replacement
The investigations in early 2018 revealed that the antenna design of the St. Charles
transmission site assumed a three -site simulcast cell for the Bend area. The coverage
pattern for St. Charles was directional to minimize simulcast interference. Resulting gaps
in coverage were intended to be filled by the Jack Pine Ridge site. As described in §6.6
and elsewhere, construction of the Jack Pine Ridge site was deferred and ultimately
canceled due to structural and permitting obstacles. Unfortunately, the St. Charles
antenna pattern was not redesigned to account for the site configuration change. The
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collective efforts of ADCOMM, DC911, and Harris identified the issue and replaced the
directional antennas with omnidirectional antennas. Immediate coverage improvements
were realized in the Bend area.
The collective efforts of ADCOMM, DC911, and Harris identified
the issue and replaced the antennas... immediate coverage
improvements were realized in the Bend area.
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7.5 Overturf Butte Site
ADCOMM worked with DC911 and Harris to re-examine potential replacement sites for
Jack Pine. An alternate location known as Overturf was determined to provide superior
coverage to Jack Pine. There is no suitable antenna structure available at Overturf,
requiring complete site development. The Overturf Butte area was previously
recommended by Bend PD technical staff and was entertained early on in the P25 radio
project. However, the requirement to develop a new site resulted in the selection of lack
Pine for schedule and economic reasons.
DC911 erected a temporary antenna structure at Overturf and activated the site in June
2018. ADCOMM continues to pursue the design, permitting, and environmental study
efforts for a permanent structure at the location. The temporary site is providing a
coverage benefit in Bend, but the permanent site is at a better (i.e. higher elevation)
location and will be a taller structure. Therefore, the permanent site is expected to further
improve communications in Bend, especially at schools to the west of Overturf Butte and
to the southeast, where signals are currently blocked by terrain. DC911 estimates that
the site will be completed in the summer of 2019, pending all necessary regulatory
approvals.
8.0 CURRENT STATUS
8.1 P25 Radio System
Radio system related trouble tickets to DC911 have dropped to routine levels. All
stakeholders interviewed reported that the P25 system is now stable and providing
acceptable service. They also report that DC911 has made major improvements with their
responsiveness to stakeholder needs and concerns, and with transparency of
Trott Communications Group, Inc. 37
After Action Review
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information. As stated by one interviewee "It's not perfect but we are definitely moving
in the right direction".
G3�._i.Fl4deh:fi�E`EE��:n'M1S�a.�.�£�3'4-WSE::'�.��'a;S�S.,�Cva..e'..:�.}��.,'�ci,S Jais..b.'.ci'.��'+.�x;4'<a��'rtvP�.%c4.;�:3v,ec`."„v-5*:e'n:ss"c.��.ai05�,'aS2✓�:X4G. �"�ncK"„4�e..ss,��iee�._�l::,tiX�"i,�...�a�
All stakeholders interviewed reported that the P25 system is
now stable and providing acceptable service.
8.2 Coverage Testing
After re-engagement in 2018, ADCOMM also noted that no meaningful coverage testing
had been performed prior to system activation. ADCOMM recommended the execution
of both voice (DAQ) testing and BER drive testing. In the fall of 2018, DAQ testing was
performed in the Bend area with participation from Bend PD, Bend FD, and DC911.
Although this testing showed stable system operations and significantly improved
performance in Bend, it was agreed that countywide BER testing was necessary to provide
an accurate baseline of performance.
ADCOMM worked with DC911 to develop a test plan and test configuration to
characterize performance for both mobile and portable radios. The test included
attenuation factors to account for portable radio body loss and any portabie/mobile site
performance imbalance.
The BER test was completed in January 2019 with test analysis underway; a results report
is expected within the next few weeks. ADCOMM is optimistic that the test results will
show DAQ 3.4 coverage performance to portable radios in many areas in the County.
F D; t • _ . r
�;.. �- r•
; � �•11
8.3 Deputy Director of Technical Systems
DC911 created a new position, Deputy Director of Technical Systems, to provide
oversight, leadership, and overall management for all of the 9-1-1 Service District's
technical systems, including the digital radio system, phone system, and computer-aided
dispatch systems. The position was filled by Will Mullins on 10/29/2018. Mr. Mullins has
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After Action Review
02/25/2019
more than 15 years of experience with public safety communications and has an
engineering background with multiple P25 system vendors. System stakeholders
overwhelmingly support the creation of the new position and express a high degree of
confidence in the selection of Will Mullins.
��srs.��,.�.,,:,�r,.u'�..,,>..;,.�:.:��..,:�sss»��,::,�,���:.,:-�..,c;a�..�.�.�at��a�aa✓aa_l��u,.s:.la�az;..-s;:.ar,.sas.P.�sxc:����s.-as.,.rm,_... <. ,�tr�t.�a�rs��.,k:
System stakeholders overwhelmingly support the creation of the
new position and express a high degree of confidence in the
selection of
t��:�...;.� �5� �a� � s.,�i.: � :,,.a�.ry k.. �.;�;�✓.��"';-�;:a�pu:.� �.::.,.�,. � �,�e::...,.. ��. �.;.�� z.r, �,.r;�.,,. ttet��af.:a,-u.�ir� ��e!cuv...� .�ti: -_ ��.�s_� a;: ..�,.:
in his short time with DC911, Mr. Mullins has led an effort to institute new P25 user
training programs and developed a 2 -year Radio System Enhancement Plan.
8.4 Seventh Site
The Harris contract included seven transmission sites. Five of the seven sites were
constructed and operational at the time of system activation in July 2017. As noted in
§7.5, a temporary site at Overturf Butte was activated in June 2018. DC911 has targeted
summer of 2019 for completion of a permanent site at Overturf.
DC911 has taken delivery of equipment for the seventh transmission site. However, a final
location has not been selected. Zoning and permitting issues led to abandonment of the
planned location near Cinder Butte, which would have served the Redmond area.
However, other suitable property may be available nearby. There has been discussion of
an alternate site at the Fairgrounds. Bend PD has suggested a site in the vicinity of Awbrey
Butte to further improve coverage in areas serviced by Bend agencies.
ADCOMM recommended that the User Board work with DC911 to prioritize areas for
coverage improvements. The BER test results and other user data can be utilized to
identify areas of need, and the User Board can democratically set the priorities for
coverage enhancements and future budgeting.
9.0 LESSONS LEARNED
The radio project started with many wise decisions:
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After Action Review
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• A comprehensive study was commissioned (Sparling Report)
• Political and governance obstacles were removed by consolidating system
responsibilities under DC911
• A subject matter expert was retained (ADCOMM)
However, once the project began in earnest, it was critical that the previously vetted
findings and requirements were incorporated in the procurement process. As noted
throughout this report, the Contract terms were never reconciled with the findings of the
Sparling Report or the expectations of the stakeholders. Future projects should ensure
that all relevant efforts prior to purchase are fully addressed by the procurement process.
These include any bid documents, contract terms, warranties, and acceptance criteria.
The implementation phase of any project must ensure that the contract terms are
faithfully administered. Changes to the deliverables must be documented. Furthermore,
if it becomes apparent that there are gaps between the contract deliverables and user
expectations, those gaps must be fully understood and addressed by the parties.
System acceptance is a critical phase of any project and must validate that all project goals
are met, and that the expectations of the stakeholders are delivered. It is often
advantageous to involve stakeholder representatives in the final acceptance process. If
the users have "bought in", the odds of a successful system cutover are much higher.
User training is an essential prerequisite for activation of a new system. As discovered by
DC911, users cannot be expected to effectively transition to new technology without
gaining proper knowledge of operations and performance.
Finally, the cutover of a new system must involve detailed planning. As described in
§6.9.1, a cutover plan should:
• Detail all prerequisites for cutover
• Identify all resources needed (equipment, staff, etc.)
• Provide a step-by-step process for execution
• Specify validation steps to ensure that expected results were achieved
• Provide a fallback plan if it becomes necessary to abandon the cutover and return
to the legacy system
• Define criteria to execute fallback
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After Action Review
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If critical system issues occur, it is vital that those issues are escalated to the appropriate
resources for resolution. Had P25 radio system problems been promptly escalated with
Harris and Motorola, and had ADCOMM been re-engaged sooner, radio system issues
could have been resolved in a timely manner.
10.0 FIRE SERVICES CUTOVER
10.1 General
The 2017 P25 radio system cutover only involved law enforcement agencies, which were
transitioning from the legacy Motorola system. Fire protection agencies have remained
on their various VHF radio channels. DC911 is now planning to move fire services to P25
starting April 2019. DC911 is approaching the fire cutover with the benefit of lessons
learned.
10.2 User Buy -In
Fire agencies have been testing with P25 radios for months. Fire users have conducted
call testing within their service areas. Cross -patching of audio between the P25 system
and legacy channels has allowed users to monitor live fire traffic for evaluation of both
audio and coverage performance.
As a result of this subjective testing and evaluation process, all departments interviewed,
excluding La Pine, are comfortable with current system performance, and expressed a
desire to transition to P25 as quickly as possible. La Pine will remain on analog VHF for
mutual aid reasons and a general preference for conventional analog technology.
10.3 Training
DC911 has prepared a series of short training videos for system users. These videos
demonstrate basic radio functions and are available to all system stakeholders.
DC911 is currently developing a train -the -trainer course for fire agencies, in preparation
of the April 2019 fire services cutover. Per Harris' recommendation, Communications
Northwest has been contracted by DC911 to assist with the course curriculum and
conduct the training program, scheduled for the week of March 11, 2019. The train -the -
trainer sessions will be video recorded and made available to system users.
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After Action Review
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Each agency will assign at least one participant to receive user training. This designated
trainer will then conduct training with other users within its agency. Train -the -trainer
methodology is a common practice for public safety radio system deployments.
10.4 Recommended Verifications
10.4.1 System Performance
Although fire agencies have been testing with P25 radios for months, there are
additional verifications that can be performed to ensure that anticipated coverage
is delivered. It is noted that only five of the seven sites are fully operational as
designed. A sixth site is functional in a temporary configuration at Overturf, but the
seventh site remains unplanned.
The User Board and DC911 should carefully analyze the BER test results and
understand the coverage delivered. ADCOMM should be utilized as resource to
ensure that coverage performance is thoroughly and accurately presented. The User
Board representative for each agency must determine if the BER test results reflect
sufficient performance to allow system cutover. Likewise, each agency should
formally report on its independent testing and certify that the system is performing
in an acceptable manner for their areas of responsibility.
10.4.2 User Equipment Readiness
It has been noted throughout this AAR report that user radio settings and
programming led to significant communications issues during the law enforcement
cutover to P25. Fire agencies have been testing with their radios, providing an
opportunity to verify that radio programming is consistent and proper.
It is recommended that testing/verification of each unique radio template (i.e.
profile, codeplug, personality) become a prerequisite for cutover of the agency.
Equipment verifications should not only include testing of radio programing and
functions, but also demonstrate acceptable operations with radio accessories and
microphones. The radio and any accessories must be capable of operations with
specialty equipment such as SCBA masks, protective clothing, and fire apparatus
intercom systems.
If any user radios have been in service for longer than 24 months, those radios
should be fully serviced to ensure that all performance specifications are met.
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After Action Review
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10.4.3 Training Certification
DC911 has committed to providing user training. System users must similarly
commit to participate in the training program. It is recommended that each agency
provide a certification that all users have successfully completed user training and
are competent to utilize the P25 user radios and system.
10.5 Cutover Plan
DC911 should prepare a cutover plan for the fire services cutover, and submit that plan
to the User Board for review, comment, and approval. The cutover plan should include
the elements described in §6.9.1.
10.6 Past -Cutover Reviews
The User Board must meet regularly during and after the fire services cutover process.
Any issues must be promptly documented and resources assigned. If resolution is not
achieved quickly, the User Board and DC911 must escalate the problem and seek
additional assistance from ODOT, Harris, Motorola, ADCOMM, etc.
The User Board should report cutover status, system performance, and problem
resolution activities to the County Administrator and/or BoCC.
11.0 RECOMMENDED OVERSIGHT IMPROVEMENTS
The Board of County Commissioners remain concerned that radio project issues and
challenges were generally unreported prior to the Concern Letter and OSHA complaint in
December 2017. There is particular interest in reviewing oversight mechanisms in place
for the 911 Director and department as a whole.
As described in §6.12, the 911 Director provides general oversight for the department and
its staff. The County Administrator performs primary oversight of the Director. Therefore,
the County Administrator's official source of DC911 project information is the 911
Director. Although some individual stakeholders stated that concerns were reported
directly to the County Administrator, those discussions (as described) were conducted in
private with no direct transfer of information to the BoCC.
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After Action Review
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As further noted in §6.12, the DC911 User Board is empowered to call a special meeting
to address the County Administrator and/or the BoCC with any concerns. This oversight
ability was not executed, missing an opportunity to address problems sooner. However,
User Board members may not have been fully informed of this option, or may have
considered it an extreme and undermining action. As also discussed in §6.12, the 911
Director was allowed to serve as the Chairman of the User Board, with full authority to
set the agenda and cancel meetings. Only three of the twelve monthly User Board
meetings were held in 2017, none of which occurred after system cutover.
The PSRT was focused on radio communications and the P25 radio project. However, the
PSRT had no oversight authority. The PSRT Charter stated that all communications occur
"by or through the Chair". A review of PSRT minutes indicated that meetings were chaired
by DC911 technical staff. There should have been a mechanism in place for the PSRT to
report to the User Board and County Administrator.
Overall, normal oversight mechanisms were in place surrounding the radio project.
Information transfer broke down at multiple levels, removing the ability of the governing
body to take action. One possible improvement is to modify the Chairmanship position of
the User Board. Per the DC911 operating agreement, the County Administrator, or
designee, serves as the Chair. The designee has traditionally been the 911 Director.
t ��n a. U +' 1, a I f + cam h nrrl that
holds
Therefore, DC911 sets 'Lille agenda an -I meeting �iiieuu�e for the Ju,,,e �i- That of
oversight responsibilities over DC911.
If the existing chairmanship structure remains in place, it is recommended that the County
Administrator resume Chairman responsibility or designate a qualified third party or
stakeholder to serve as the Chair. As an alternative, the User Board could be restructured
to elect a non-DC911 stakeholder to serve as the Chair. With such an arrangement, the
911 Director could still serve as a Vice Chair or Secretary, providing critical reports, inputs,
and updates on DC911 projects.
A further improvement is to ensure that the User Board is fully briefed on its oversight
responsibilities and authority. This oversight could be mandated by requiring a periodic
User Board report to the County Administrator and to the BoCC. Providing scheduled and
mandated reports removes political obstacles and improves transparency for all parties
involved.
It has been acknowledged by Former Director Reinke that he conducted some
independent consulting work during his tenure. This fact was known by County
Administration, who believed that this outside work involved wrapping up existing
contracts, with minimal time commitments and had no impact on job performance.
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After Action Review
02/25/2019
However, independent research found outside engagements initiated as late as spring
2017, a few months prior to cutover. No records are available to show specific time
commitments associated with these outside consulting projects or if they contributed in
any way to oversight deficiencies within DC911. It is recommended that the County
review its policies and enforcement mechanisms for outside employment, especially for
directors, administrators, and executive management.
Trott Communications Group, Inc. 45
APPENDIX A
Interviewee List
APPENDIX A
Deschutes County P25 Radio System
After Action Review
Interviewee List
Name
Title
Agency/Company
Dave Doyle
Legal Counsel
Deschutes County
Phil Henderson
County Commissioner
Deschutes County
Tammy Baney
County Commissioner
Deschutes County
Tony DeBone
County Commissioner
Deschutes County
Tom Anderson
County Administrator
Deschutes County
Tim Beuschlein
Systems Specialist
DC911
Rick Silbaugh
Programs Manager
DC911
Chris Perry
Interim Operations Manager
DC911
Sara Crosswhite
Interim Director
DC911
Will Mullins
Deputy Director Technical Systems
DC911
Steve Reinke
Former Director
DC911
Rick Allen
Consultant
RL Allen Group
Joe Blaschka
Principal Engineer
ADCOMM
Rob Reish
Communications Manager
ODOT
Kurt Chandler
Radio System Administrator
ODOT
Richard Wilson
Communications
ODOT
Joseph Messman
Communications
ODOT
Todd Cox
Service Manager
Day Wireless
Steve Wynn
Sr. Systems Technologist
Day Wireless
Eric Arnsberg
Sales Representative
Day Wireless
Ron Spenser
Account Manager
Motorola Solutions
Larson Davenport
Motorola Solutions
Motorola Solutions
Scott Tangeman
Dir. of Public Safety Programs
Harris Corporation
Jennine Weber
Account Manager
Harris Corporation
Jim Ramsay
Senior System Technologist
Harris Corporation
Scott Reilly
President
Communications Northwest
Patrick Hoover
Communications
Communications Northwest
Shane Nelson
Sheriff
Deschutes County SO
Jim Porter
Police Chief
Bend Police Department
Nick Parker
Captain
Bend Police Department
Ben Gregory
Captain
Bend Police Department
Paul Kansky
Captain
Bend Police Department
Dave Tarbet
Police Chief
Redmond Police Department
Chris Duchatean
Forensic Examiner
Redmond Police Department
Denny Kelley
Police Chief
Black Butte Ranch PD
Larry Langston
Fire Chief
Bend Fire Department
Jeff Blake
Battalion Chief
Bend Fire Department
Bob Madden
Operations Chief
Bend Fire Department
Bill Boos
Administrative Chief
Bend Fire Department
Ken Kehmna
Fire Chief
Redmond Fire & Rescue
Dave Prickhardt
Former Deputy Chief
Redmond Fire & Rescue
Tim Moor
Fire Chief
Sunriver Fire Department
Page 1 of 2
APPENDIX A
Deschutes County P25 Radio System
After Action Review
Interviewee List
Name
Title
Agency/Company
Roger Johnson
Fire Chief
Sisters Fire Department
Thad Olsen
Fire Chief
Cloverdale Fire Department
Dan Tucker
Fire Chief
Black Butte RFPD
Dave Phillips
Deputy Fire Chief
Black Butte RFPD
Mike Supkis
Fire Chief
La Pine RFPD
Harry Ward
Fire Chief
Crooked River Ranch RFPD
Page 2 of 2
u� ES
441 °-A Deschutes County Board of Commissioners
1300 NW Wall St, Bend, OR 97703
(541) 388-6570 - Fax (541) 385-3202 - https://www.deschutes.org/
AGENDA REQUEST & STAFF REPORT
For Board of Commissioners Work Session of March 4, 2019
DATE: February 28, 2019
FROM: Matthew Martin, Community Development, 541-330-4620
TITLE OF AGENDA ITEM:
Public Hearing Preparation - Appeal of Marijuana Retail Approval (19855 8th Street, Bend
(Tumalo))
ATTENDANCE: Matthew Martin, Associate Planner
SUMMARY: The Board of County Commissioners will conduct a work session on March 4,
2019, to prepare for a public hearing regarding an appeal the Deschutes County Hearings
Officer's approval of marijuana retail at 19855 8t" Street, Bend (Tumalo).
MEMORANDUM
DATE: March 6, 2019
TO: Board of County Commissioners
FROM: Matthew Martin, Associate Planner
RE: Appeal of Marijuana Retail Approval
(File Nos. 247-18-000-545-CU/546-SP/811-MA / 247-19-000141-A)
I. PURPOSE
The Board of County Commissioners (Board) will conduct a work session on March 6, 2019, to
prepare for a public hearing regarding an appeal the Deschutes County Hearings Officer's approval
of i i iar ijuana retail at 198855 8th Street, Bend (Tumalo). The appeal materials identify several
objections listed in Section III below.
111. BACKGROUND
On July 5, 2018, the applicant, Mike Hayes, submitted an application for conditional use and site
plan review to establish marijuana retail, one food cart, and a farmers' market at 19855 8th Street,
Bend in the Commercial District of the Tumalo Rural Community. On September 28, 2018, the
applicant submitted a modification of application eliminating the originally proposed food cart and
farmers' market uses. In lieu of a staff administrative review, this application was referred to a
public hearing before a Deschutes County Hearings Officer.
On November 29, 2018, the Deschutes County Hearings Officer held a public hearing to receive
testimony and written evidence. The Hearings Officer issued a decision on January 29, 2019,
determining the application met the applicable criteria.
On February 7, 2019, an appeal, filed by Joel & Julia Gisler and J's 4 LLC, was received. On February
8, 2019, the Board reviewed the appeal and issued Board Order No. 2019-008 agreeing to hear the
appeal.
The complete record for the project, including the notice of appeal, was provided to the Board for
the work session on February 8, 2019.
The public hearing before the Board regarding this appeal was originally scheduled for February 25,
2019. This hearing was cancelled to inclement weather and the related closure of County offices.
III. APPELLANT'S OBJECTIONS SUMMARY
The appellant states several reasons for the appeal that are fully described in the Notice of Appeal.
The appellant's arguments are summarized below:
A. Adequacy of and legal right to access
B. Separation distance from school, state park, and youth activity center
C. Compatibility with existing and projected uses on surrounding properties
D. Required widening of driveway
E. Adequacy of traffic study and analysis
F. Requirements of Federal Controlled Substances Act and the doctrine of Federal preemption
G. Risk and liability the subject application places on the Appellant
IV. NEXT STEPS
The public hearing before the Board is scheduled on March 13, 2019.
247-18-000-545-CU/546-SP/811-MA / 247-19-000141 -A
" Deschutes County Board of Commissioners
1300 NW Wall St, Bend, OR 97703
(541) 388-6570 - Fax (541) 385-3202 - https://www.deschutes.org/
AGENDA REQUEST & STAFF REPORT
For Board of Commissioners Work Session of March 4, 2019
DATE: February 28, 2019
FROM: Erik Kropp, Administrative Services, 541-388-6584
TITLE OF AGENDA ITEM:
Administrative Policies: Reissue and Housekeeping
RECOMMENDATION & ACTION REQUESTED:
Staff recommends Board approval of County Administrator signature of HR -10, Non -
Harassment and Non -Discrimination Policy; GA -19, Title VI of the Civil Rights Act; and GA -
13, ADA Policy.
ATTENDANCE: Erik Kropp, Deputy County Administrator
SUMMARY: See attached staff report.
vI Es cb
4
-Y COUNTY ADMIMSTRATOR
DEPUI
ERIIK KROPP
Date: February 27, 2019
To: Board of County Commissioners
From: Erik Kropp, Deputy County Administrator
Re: Administrative Policies: Reissue and Housekeeping: 3-6-19 Work Session
The Oregon Health Authority (ORA) conducts a comprehensive review of local public health
authorities every three years for most programs. The review assesses compliance of public health
authorities with state requirements, evaluates overall program effectiveness, and recommends
program modifications or corrective actions. As part of the last review, ORA recommended that the
following three policies be reviewed/updated due to the time period since they were originally
approved.
1. HR -10, Non -Harassment and Non -Discrimination Policy — this policy was approved April
16, 2007. The draft policy has the following updates: "Personnel Department" is changed to
"Human Resources Department" and "Personnel Services Manager" is updated to "Human
Resources Director."
2. GA -19, Title VI of the Civil Rights Act — this policy was approved on January 27, 2016. The
draft policy updates Appendices D and E to reflect the most current demographic data.
3. HIPAA — this policy was last updated April 16, 2007. A substantial update to the policy will
come to the Board separately in the next couple of weeks.
In addition to the policies discussed above, the format for Deschutes County's ADA (American with
Disabilities) policy needs updating. The ADA policy was approved October 27, 2004. Attached is
the current ADA policy as well as the re -formatted ADA policy (GA -13). There are no proposed
edits to the ADA policy.
Attachments:
HR -10, Non -Harassment and Non -Discrimination Policy draft update
GA -19, Title VI of the Civil Rights Act draft update
ADA Policy, current format
ADA Policy, updated format
1300 NW Wall Street Bend, Oregon 97703
Q1 (541) 388-6584 �,7a erik.kropp4 deschutes .org 0 www.deschutes.org
0 4c
Deschutes County Administrative Policy No. HR -10
Effective Date: March _, 2019
NON -HARASSMENT AND
NON-DISCRIMINATION POLICY
STATEMENT OF POLICY
It is the policy of Deschutes County to implement and enforce a "zero tolerance" policy
prohibiting any form of harassment or discrimination, and to maintain a work environment that is
professional, respectful and accessible to its employees and to protect the rights of its employees.
APPLICABILITY
This policy applies to all Deschutes County personnel, and to agents of and contractors to the
County.
POLICY AND PROCEDURES
Title VII of the Civil Rights Act of 1964, ORS 659A.030, and other Oregon and federal laws
prohibit harassment or discrimination on the basis of certain protected classes. This policy
establishes Deschutes County's commitment to provide a work environment which is free from
harassment or discrimination.
GENERAL STATEMENT:
..1. t * is o fessional respect fUl and accessible to its employees
To iiiairitairi a work, eriJiroiiTien. ,l^.at �U professional, , . Y.,,,..». employees
---
and to protect the rights of its employees, Deschutes County continues to implement and enforce
a "zero tolerance" policy prohibiting any form of harassment or discrimination.
DEFINITIONS:
A. Harassment: For purposes of this policy, "Harassment" is defined to mean behavior that
is unwelcome, personally offensive, or fails to respect the dignity of co-workers and which is
based on gender, race, color, age, religion, disability, marital status, family status, national origin
or any other "protected class" established by Oregon or federal law.
B. Sexual Harassment: For purposes of this policy, "Sexual Harassment" is defined to mean
harassing behavior based on sex or gender and includes, but is not limited to sexual advances,
requests for sexual favors, and other verbal or physical conduct which is of a sexual nature or is
based on gender, where:
Submission to such conduct is made, or implied to be, a term or condition of
employment;
Submission to, or rejection of, such conduct is used as a basis for employment decisions;
or
Such conduct has the effect of interfering with an employee's work performance, or
creates a work environment which is intimidating, uncomfortable or offensive.
Policy # HR -10 Non -Harassment and Non -Discrimination Page i of 5
RESPONSIBILITIES:
Elected officials, department heads, managers and supervisors are charged with the responsibility
of implementing, enforcing and making employees aware of the protections and procedures of
this policy. Department heads, managers and supervisors who become aware of conduct which
may violate this policy are required to report the alleged conduct as soon as reasonably possible,
not exceeding seven (7) calendar days, to the Human Resources Director. Department heads,
managers and supervisors who do not report to the Human Resources Director conduct that may
violate this policy will themselves be subject to disciplinary action, up to and including possible
termination of employment.
The Human Resources Department is responsible for reviewing all complaints of alleged
harassment or discrimination, all complaints of alleged retaliation, for providing oversight of the
investigation of all complaints of alleged harassment, discrimination or retaliation, for
determining if a violation of this policy has occurred and, if it is determined that a violation of
this policy has occurred, for implementing any corrective action.' The Human Resources
Department is also responsible for coordinating and overseeing all training of County managers,
supervisors and employees regarding this policy. When a complaint of alleged harassment,
discrimination or retaliation is received by the Human Resources Director, the Human Resources
Department shall consult with County Legal Counsel and, if practicable, with the County
Administrator and the County Risk Manager to determine an appropriate course of action before
initiating any investigation, before determining if a violation of this policy has occurred and
before approving any corrective action.
All employees have a shared responsibility with management to work towards the elimination,
cor cctlon and prevention of harassment and discrimination in the workplace. it is the
responsibility of each employee who feels that he or she has been subjected to any form of
harassment or discrimination to bring the situation to the attention of Deschutes County
management so that management can appropriately investigate and address the situation.
Any employee who has questions or concerns regarding this policy at any time is expected to
address such questions or concerns to his or her supervisor, department head or to the Human
Resources Director.
PROCEDURES:
A. Reporting Harassment or Discrimination
Employees who personally experience, witness or obtain knowledge of conduct they believe to be
harassment or discrimination shall report such conduct to any of the following, and need not
proceed through any applicable chain of command:
The immediate supervisor of the employee who is the
alleged victim or of the employee who is the alleged
harasser or discriminator.
I In any case in which alleged conduct that may violate this policy involves the Human Resources
Department, the conduct shall be reported to the County Risk Manager who will assume all responsibilities
under this policy of the Human Resources Director and the Human Resources Department regarding review
of complaints or reports of alleged harassment or discrimination, regarding investigation and regarding
implementing corrective action.
Policy 4 HR -10 Non -Harassment and Non -Discrimination Page 3 of 5
D. Corrective Action
After an investigation is conducted, appropriate corrective action will be taken in all cases in
which it is concluded by the Human Resources Department that a violation of this policy has
occurred.
Corrective action options include, but are not limited to, counseling, warning, further training or
instruction, reassignment, oral or written reprimand, suspension without pay, dismissal from
employment or other disciplinary action which is consistent with any applicable collective
bargaining agreement or the County Personnel Rules given the nature and seriousness of the
conduct and all relevant circumstances. After the written investigation report is submitted, the
responsible department head or manager will confer with the Human Resources Department to
determine what corrective action is appropriate. Any corrective action must be approved in
advance by the Human Resources Department. The implementation of corrective action must be
documented in writing by the department implementing the corrective action.
Deschutes County retains its authority and prerogative to take corrective or disciplinary action to
address any behavior which does not constitute a violation of this policy. The alleged victim and
each complainant shall be informed whether any corrective action has been taken.
E. Appeals
If any alleged violation of this policy is made the subject of a grievance under a collective
bargaining agreement or the Deschutes County Personnel Rules, the appeal of any determination
made under this policy shall be made in accordance with the grievance procedures established by
the applicable collective tu,argaiiiig agreement or the Deschutes County Personnel Rules.
.
If any alleged violation of this policy is complained of but not through filing a grievance, then the
appeal of any determination made under this policy shall be made to the Deschutes County Board
of Commissioners. Any such appeal must be submitted to the Board in writing within ten (10)
calendar days after the date the complainant and the alleged victim are notified of the
determination. The Board shall consider and decide any such appeal within thirty (30) calendar
days after the appeal is submitted in writing to the Board. The Board will issue a written decision
concerning the appeal. The Board, at the sole discretion of the Board, may, but is not required to,
convene a hearing to consider the appeal before the Board issues a decision regarding the appeal.
Appeals of any corrective or disciplinary action imposed pursuant to this policy shall be taken in
accordance with the grievance procedures established by the applicable collective bargaining
agreement, or, if no collective bargaining agreement applies, by the Deschutes County Personnel
Rules.
Approved by the Deschutes County Board of Commissioners October 27, 2004 and reviewed on
March , 2019.
Tom Anderson
County Administrator
Policy # HR -10 Non -Harassment and Non -Discrimination Page 5 of 5
I E S (`0
Deschutes County Administrative Policy No. GA -16
Effective Date: Draft
•■r
TITLE VI OF THE CIVIL RIGHTS ACT
STATEMENT OF POLICY
Deschutes County is committed to providing programs and services that are free of all forms of
discrimination based on factors that include, but are not limited to, race, ethnicity, age, disability
status, and sexual orientation. The County will take preventive, corrective, and/or disciplinary
action when necessary against behavior that violates this policy or the rights and privileges it is
designed to protect.
APPLICABILITY
This policy applies to all Deschutes County departments, divisions, programs, staff members,
and elected officials, and, as applicable, to agents of and contractors for the County.
DEFINITIONS
For the purpose of this policy, unless otherwise specified, the following definitions shall apply:
• Color: Skin color or complexion
• Discrimination: An intentional or unintentional action through which a person, solely
because of race, color, national origin, religion, gender/gender identification, or sexual
orientation has been subjected to unequal treatment under a program or activity offered by
the County.
• National Origin: A person's, or his or her ancestor's, place of birth. May also refer to the
physical, cultural, or linguistic characteristics associated with ethnicity or ancestry.
• Race: A social classification of people which includes, but may not be limited to, White,
Hispanic or Latino, Black or African American, American Indian or Alaska Native, Asian,
Native Hawaiian or Other Pacific Islander as defined by the U.S. Census.
• Limited English Proficiency (LEP): One who does not speak English as a primary language
and who has limited ability to read, speak, write, or understand English.
PROCEDURES
Title VI Coordinator:
The Deputy County Administrator serves as Deschutes County's Title VI Coordinator and acts
as the focal point for Title VI implementation and monitoring.
Public Notice:
A Title VI Notice to the Public will be posted on Deschutes County's website at
www.deschutes.or and in a public area within each County facility. A copy of the Deschutes
County Title VI Notice to the Public is attached to this document as Appendix A. The
Department of Administrative Services will also provide paper copies to individual departments
for posting.
Complaints:
Any person who believes she or he has been discriminated against by Deschutes County on the
basis of race, color, or national origin may file a complaint by completing and submitting a Title
VI Complaint Form. Complaints must be complete in both form and content to be reviewed and
must be submitted within 180 days of the alleged incident of discrimination to be considered. A
copy of the Deschutes County Title VI Complaint Form is attached to this document as
Appendix B. To request a separate Title VI Complaint Form:
• Call 541-388-6570
• Visit the Deschutes County Department of Administrative Services located at:
1300 NW Wall Street, Suite 200
Bend, OR 97703
• Write to:
Department of Administrative Services
Deschutes County
PO Box 6005
Bend, OR 97708-6005
• Download the document from Deschutes County's website at www.deschutes.or
Complaints must be submitted to the Deputy County Administrator by hand -delivery at the
physical address or by U.S. postal service to the mailing address shown above.
When applicable, a complainant may also file a Title VI complaint directly with any federal
agency that supplies funding to Deschutes County in support of the applicable program or
service in which the alleged incident occurred. Examples of federal agencies that provide
funding to the County include, but are not limited to, the U.S. Environmental Protection Agency,
Department of Agriculture, Department of Justice, Department of Health and Human Services,
Department of Homeland Security, and Department of Transportation. Contact information for
the Office of Civil Rights operating in such agencies may be found online.
At such time as the complaint is received, the Department of Administrative Services will review
it to determine if Deschutes County has jurisdiction over the matter. Within 10 business days,
the County will return an acknowledgment letter stating whether the complaint will be
investigated by the County. Deschutes County will make every effort to investigate complaints
within no more than 90 days following the date on this letter. However, in the event of complex
complaints which address multiple issues and/or involve legal action, the County may require an
extended period to fully investigate and respond. In such cases, the complainant will be
informed of the delay.
If more information is needed to resolve the case, the assigned investigator may contact the
complainant. The complainant has 10 business days from the date of the letter to return the
requested information to the investigator. If the investigator is not contacted by the complainant
or does not receive the requested information within 10 business days, Deschutes County will
administratively close the case. A case will also be administratively closed upon withdrawal by
the complainant.
After the investigator reviews the complaint, she or he will issue one of two letters to the
complainant: A closure letter or a letter of finding (LOF). A closure letter summarizes the
allegations and investigation, indicates that a Title VI violation did not occur, and states that the
case will be closed. An LOF summarizes the allegations and investigation and explains whether
any disciplinary action, staff training, or other action will occur. If the complainant wishes to
appeal the decision, she or he has 10 business days following the date of the letter or the LOF to
do so. To submit an appeal, complainants must deliver a written letter explaining the basis of the
appeal to the Deputy County Administrator. County officials will review the factors presented
and issue a final formal decision within 30 business days following the date of the appeal letter.
The County will provide, upon request, a list of all active investigations, lawsuits, or complaints
made on the basis of race, ethnicity, age, disability status, gender/gender identification, and
sexual orientation. A copy of the Deschutes County List of Title VI Investigations, Complaints,
and Lawsuits form is attached to this document as Appendix C and contains a name, date of
nling, Summary of the allegittlon�S), Stalu3 0l ute -investigation, and aeuoii�S) taker..
Public Participation:
Deschutes County employs a wide variety of strategies to solicit, consider, and incorporate the
perspectives of diverse populations in policy and decision-making processes. Such opportunities
for involvement are designed to engage all segments of the public in an early, open, continuous,
and effective manner and include:
1. Complying with all applicable laws, rules, and regulations concerning public involvement
and public meeting protocol.
2. Maintaining buildings and facilities that are fully accessible and compliant with the
Americans with Disabilities Act (ADA).
3. Providing notice and information regarding issues, processes, and decisions in a timely
manner which allows for adequate public review and participation.
4. Ensuring that printed materials, such as public notices and records, meeting and hearing
schedules, minutes and supporting documents, web content, and other written
communications can be made available in both traditional and alternative formats, including
large text, electronic, audio, braille, and foreign languages upon request.
5. Facilitating access to meetings and interviews through conference calls and video-
conferencing, sign and foreign language interpretation.
6. Holding meetings and hearings in diverse geographic locations throughout the County on a
periodic basis.
7. Inviting all members of the public to enroll in County College, a multi -week course designed
to educate participants about elections, governance, infrastructure, finance and budgeting,
public safety, land use, health services, and other County operations.
8. Seeking age, physical ability, ethnic, cultural, economic, and geographic diversity in
appointing members to quasi-judicial and advisory committees, such as:
• Audit Committee
• Bicycle/Pedestrian Advisory Committee
• Board of Property Tax Appeals
• Budget Committee
• Dog Control Board
• Fair Board
• Investment Advisory Committee
• Historic Landmarks Commission
• Mental Health Advisory Board
• Noxious Weed Advisory Board
• Planning Commission
• Public Health Advisory Board
• Public Safety Coordinating Council
• Special Transportation Fund Advisory Committee
Language Assistance:
Deschutes County takes reasonable steps to offer assistance for LEP clients and residents seeking
meaningful access to services and opportunities. When appropriate, the County will use
population composition and client needs in regard to language for the purpose of developing and
providing programs and services, disseminating information, conducting outreach, and
encouraging public involvement. A copy of the most current data is included with the
information attached to this document as Appendix D.
The County has also implemented a variety of strategies to help serve LEP persons:
Recruitment, hiring, and personnel practices. The County has established an Interpreter
position within its job classification system which can be employed by departments with
high levels of LEP clientele to translate and interpret policies, procedures, program
information, and service options on-site. Additionally, and when warranted, general
recruitments may specify a preference for bi-lingual capabilities. If approved by
management, and subject to any applicable collective bargaining agreement, staff filling
bi-lingual positions may be eligible for supplemental pay.
Training. The County periodically offers Spanish language classes within its catalog of
training opportunities that are open to all staff members with supervisor approval.
Additional training opportunities in language and interpretation may also be offered on
occasion at the discretion of individual departments.
Written Communications. Many brochures and informational materials are routinely
translated and printed in Spanish. Public notices and records, meeting and hearing
schedules, minutes and supporting documents, and other printed information may be
translated into alternative languages upon request.
Verbal Communications. Departments may access independent interpretation services,
including private contractors and consultants, computer software, and language lines to
communicate with clients and customers in-person, during group meetings, and on the
telephone.
Minority Representation:
A copy of the Deschutes County Minority Representation table is attached to this document as
Appendix E. More information regarding minority representation can be found in the County's
Equal Employment Opportunity Plan.
Reporting:
Deschutes County will report information required to determine compliance with Title VI of the
Civil Rights Act as required by federal and state government agencies for grant funding and
other purposes. The contents and format of such reports will be determined by the requesting
parts'.
Approved by the Deschutes County Board of Commissioners on January 27, 2016 and reviewed
on March 2019.
Tom Anderson
County Administrator
Appendix A
DESCHUTES COUNTY
TITLE VI NOTICE
Deschutes County operates its programs and services without regard to race, color, or national
origin in accordance with Title VI of the Civil Rights Act. Any person who believes she or he
has been subjected to an unlawful discriminatory practice as defined under Title VI of the Civil
Rights Act may file a complaint with the Deschutes County Department of Administrative
Services.
For more information about Deschutes County's civil rights program and the obligations and
procedures required to file a complaint:
• Call 541-388-6570
• Visit the Deschutes County Department of Administrative Services located at:
1300 NW Wall Street, Suite 200
Bend, OR 97703
• Write to:
Department of Administrative Services
Deschutes County
PO Box 6005
Bend, OR 97708-6005
• Download the document from Deschutes County's website at www.deschutes.orp,.
When applicable, a complainant may also file a Title VI complaint may also be filed directly
with any federal agency that supplies funding to Deschutes County in support of the applicable
program or service in which the alleged incident occurred. Examples of federal agencies that
provide funding to the County include, but are not limited to, the U.S. Environmental Protection
Agency, Department of Agriculture, Department of Justice, Department of Health and Human
Services, Department of Homeland Security, and Department of Transportation. Contact
information for the Office of Civil Rights operating in such agencies may be found online.
If this information is needed in another language or format, please call 541-388-6584.
Si se necesita esta informacion on un idioma o formato diferente, por favor llame a
541-388-6570.
Appendix B
DESCHUTES COUNTY
TITLE VI COMPLAINT FORM
Section I
Name:
Address:
City, State, Zip Code:
-Telephone
Telephone home : work):
Email Address:
Check the box if you require
Large Print
TTY
Audio Tape
Other
this form in an alternative
❑
❑
❑
❑
format.
Section II
Are you filing this complaint on your
Yes
No
own behalf'?
F-1
El
If yes, skip to Section III.
If no, please supply the name and
relationship of the person you are
representing.
Explain why you have submitted a claim
on behalf of a third party.
Confirm that you have obtained
Yes
No
permission to submit this claim by the
third party.
❑
❑
Section III
Identify the factor(s) on which you
believe the alleged discrimination was
based.
Date of alle ed discrimination:
Name of County department and/or
facility where alleged discrimination
took lace:
Explain as clearly as possible what
happened and why you believe you were
discriminated against.
Describe all person(s) who were
involved, including the name and
contact information for the person(s)
who allegedly discriminated against you
if known.
List name(s) and contact information for
any witnesses to the alleged
discrimination.
Section IV
Have you previously filed a Title VI
complaint against Deschutes County?
Yes
FJ
No
Section V
Have you filed this complaint with any
other federal, state, or local agency, or
with any federal or state court?
Yes
❑
No
❑
If yes, check all agencies or courts in
which a complaint was filed and enter
the name of the agency or court.
Federal
Agency
Federal
Court
State
Agency
State
Court
Local
Agency
Name:
Name:
Name:
Name:
Name:
Provide contact information for the
Name:
Title:
person at the agency or court who
Organization:
received and/or investigated this
Address:
complaint.
City, State, Zip Code:
Tele hone:
if you need more space to complete the in orfnation above, please attach additional sheets and Iabcl your
responses to correspond with the section number and question shown on the form. If you have other written
materials or supporting documentation that you believe is relevant to your complaint and should be considered
during the investigation, please attach it to this form.
Sign and date this Title VI Complaint Form below:
Signature
Printed Name
Hand deliver this form to:
Deputy County Administrator
Department of Administrative Services
Deschutes County
1300 NW Wall Street
Bend, OR 97703
Date
Or mail it to:
Deputy County Administrator
Department of Administrative Services
Deschutes County
PO Box 6005
Bend, OR 97708-6005
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DESCHUTES COUNTY
LIMITED ENGLISH PROFICIENCY (LEP)
Analysis:
Appendix D
The language proficiency information shown in the table below is based on the U.S. Census
Bureau 2013-2017 American Community Survey and represents residents five years and older.
The data indicates that the most significant number of LEP persons residing in Deschutes County
is Spanish-speaking. This factor is expected to remain constant as the Hispanic/Latino group
continues to be the fastest-growing minority group in Deschutes County.
Language Spoken
At Home
Speak English Less Than Very Well
English
155,403
3,460
Spanish
7,520
2,508
Other Indo-European
1,720
265
Asian/Pacific Islander
1,234
641
Other
204
46
Frequency:
The most frequent exposure to LEP individuals occurs within the County's Health Services
Department. The Department offers services in more than 40 locations, including public schools
and school-based health centers, hospitals, social -service organizations, health clinics, care
facilities, and homes. As a result, the Health Services Department employs the largest number of
English -Spanish speakers within the County organization. Bi -lingual staff members are recruited
on an ongoing basis in the roles of both clinical and support staff to ensure that LEP clients can
access services and have their health care needs met. The Department also offers Equity and
Inclusion training to all employees and supports staff members who wish to become certified as
Healthcare Interpreters. Additionally, the Department prints and posts public notices and
informational brochures in both English and Spanish and uses external translation and
interpretation services when needed.
Importance:
Although many programs and services offered by Deschutes County are vital to the LEP
community, health care appears to be the most significant. The Health Services Department
offers disease prevention, chronic illness treatment, family planning, child wellness, women,
infants, and children (WIC) nutrition, immunizations, substance abuse treatment, suicide
prevention, and emergency preparedness. Additionally, many of the Department's clients come
from disadvantaged, vulnerable, or underserved populations and require special accommodations
to access the same services that are more widely available to others.
Resources and Costs:
Although not unlimited, Deschutes County does provide adequate resources, upon identified
need, within the annual budget for bi-lingual recruitments, Spanish language courses, printing,
and translation and interpretation services.
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DESCHUTES COUNTY GENERAL POLICY NO.: 2004-113
SUBJECT: AMERICANS WITH DISABILITIES PUBLIC NOTICE AND GRIEVANCE
PROCEDURE
PURPOSE: The purpose of this policy is to adopt Americans with Disabilities (ADA)
requirements of selecting an ADA Coordinator and adopting Department of Justice
Public Notice and Grievance language.
SCOPE: All Departments and all County locations.
POLICY: The County will adopt the attached Americans with Disabilities Grievance
Procedure and Public Notice. Deschutes County selects its Risk Manager as the
ADA Coordinator.
A. Public Notice - In accordance with the requirements of Title lI of the Americans
with Disabilities Act of 1990, Deschutes County will not discriminate against
qualified individuals with disabilities on the basis of disability in Deschutes
County's services, programs; or activities.
B. Grievance Procedure - 'The Grievance Procedure attached .hereto and
incorporated, is established to meet the requirements of the Americans with
Disabilities Act of 199^0. it may be used by anyone Arno v iShes to f"al-
V R
complaint alleging discrimination on the basis of disability in the provision of
services, activities, programs, or benefits by Deschutes County
C. ADA Coordinator _ Deschutes County selects the Risk Manager to Coordinate
ADA activities and to serve as the primary contact for ADA issues.
DATED this��:day of '2004
ATTEST:
Recording Secretary
BOARD OF COUNTY COMMISSIONERS OF
DESCHUTES COUNT, OREGON
Tbiri-DeVO if Commissioner
Commissioner
LEGAL COUNSEL
DESCHUTES COUNTY, OREGON
NOTICE UNDER THE AMERICANS WITH
DISABILITIES ACT
In accordance with the requirements of title H of the Americans with Disabilities Act of 1990,
Deschutes County will not discriminate against qualified individuals with disabilities on the basis
of disability in Deschutes County's services, programs, or activities.
Employment: Deschutes County does not discriminate on the basis of disability in its hiring or
employment practices and complies with all regulations promulgated by the U.S. Equal
Employment Opportunity Commission under title I of the Americans with Disabilities Act
(ADA).
Effective Communication: Deschutes County will generally, upon request, provide appropriate
aids and services leading to effective communication for qualified persons with disabilities so
they can participate equally in the County's programs, services, and activities, including
qualified sign language interpreters, documents in Braille, and other- ways of information
and communications accessible to people who have speech, hearing, or vision impairments.
Modifications to Policies and Procedures: Deschutes County will make all reasonable
modifications to policies and programs to ensure that people with disabilities have an equal
opportunity to enjoy all County programs, services, and activities. For example, individuals with
service animals are welcomed in County offices, even where pets are generally prohibited.
Anyone who requires an auxiliary aid or service for effective communication, or a modification
of policies or procedures to participate in a County program, service, or activity, should contact
the ADA Coordinator at 388-6584 or his/her designee at 6174747, as soon as possible but no
later than 48 hours before the scheduled event.
The ADA does not require Deschutes County to take any action that would fundamentally alter
the nature of its programs or services, or impose an undue financial or administrative burden.
Complaints that a County program, service, or activity is not accessible to persons with
disabilities should be directed to the ADA Coordinator.
Deschutes County will not place a surcharge on a particular individual with a disability or any
group of individuals with disabilities to cover the cost of providing auxiliary aids/services or
reasonable modifications of policy, such as retrieving items from locations that are open to the
public but are not accessible to persons who use wheelchairs.
Deschutes County, Oregon
Grievance Procedure under
The Americans with Disabilities Act
This Grievance Procedure is established to meet the requirements of the Americans with Disabilities
Act of 1990. It may be used by anyone who wishes to file a complaint alleging discrimination on the
basis of disability in the provision of services, activities, programs, or benefits by the County. The
County's Personnel Policies govern employment-related complaints of disability discrimination.
The complaint should be in writing and contain information about the alleged discrimination such as
name, address, phone number of complainant and location, date, and description of the condition or
circumstances. Alternative means of filing complaints, such as personal interviews or a tape recording
of the complaint, will be made available for persons with disabilities upon request.
The complaint should be submitted by the grievant and/or his/her designee as soon as possible but no
later than 60 calendar days after the alleged violation to:
ADA Coordinator
1300 NW Wall Street, Suite 200
Bend, Oregon 97701
(541) 388-6584 or (541) 617-4747
Within 15 calendar days after receipt of the complaint, the ADA Coordinator or his/her designee
will contact or meet with the complainant to discuss the complaint and the possible resolutions.
Within 15 calendar days of the contact, the ADA Coordinator or his/her designee will respond in
writing, and where appropriate, in format accessible to the complainant, such as large print, Braille,
or audio tape. The response will explain the position of the County and offer options for substantive
resolution of the complaint.
Disputes: If the response by the ADA Coordinator or his/her designee does not satisfactorily resolve
the issue, the complainant and/or his/her designee may appeal the ADA Coordinator's response within
15 calendar days after receipt of the response to the County Administrator or his/her designee.
Within 15 calendar days after receipt of the appeal, the County Administrator or his/her designee
will meet with the complainant to discuss the complaint and possible resolutions. Within 15 calendar
days after the meeting, the County Administrator or his/her designee will respond in writing, and,
where appropriate, in a format accessible to the complainant, with a final resolution of the complaint.
All written complaints received by the ADA Coordinator or his/her designee, appeals to the County
Administrator or his/her designee, and responses from these two offices will be retained by the
County for at least three years.
Deschutes County prefers that complaints and disputes be filed directly with the County such to
expedite a response. However, complaints and disputes can also be filed with:
Office for Civil Rights
U.S. Dept. of Health and Human Services
2201 Sixth Avenue —Mall Stop RX -1l
Seattle, Washington 98121-1831
1-800-368-1019
TDD: 1-800-537-7697
If you are a member of the Oregon Health Plan you have the additional option of:
Contacting your managed care plan or
Oregon Health Plan
Omnibudpersons Office
1-800-442-5238
(-0
Deschutes County Administrative Policy No: GA -13
Effective Date: [DATE]
AMERICANS WITH DISABILITIES PUBLIC NOTICE
AND GRIEVANCE PROCEDURE
STATEMENT OF POLICY
The purpose of this policy is to adopt Americans with Disabilities (ADA) requirements of selecting an ADA
Coordinator and adopting Department of Justice Public Notice and Grievance language.
APPLICABILITY
All departments/offices and all County locations.
POLICY AND PROCEDURE
The County adopts the attached Americans with Disabilities Grievance Procedure and Public Notice.
Deschutes County selects its Risk Manager as the ADA Coordinator.
A. Public Notice — In accordance with the requirements of Title II of the Americans with Disabilities
Act of 1990, Deschutes County will not discriminate against qualified individuals with disabilities
on the basis of disability in Deschutes County's services, programs, or activities.
B. Grievance Procedure — The Grievance Procedure attached hereto and incorporated, is established
to meet the requirements of the Americans with Disabilities Act of 1990. It may be used by
anyone who wishes to file a complaint alleging discrimination on the basis of disability in the
provision of services, activities, programs, or benefits by Deschutes County.
C. ADA Coordinator — Deschutes County selects the Risk Manager to coordinate ADA activities and
to serve as the primary contact for ADA issues.
Approved by the Deschutes County Board of Commissioners [DATE]
Tom Anderson
County Administrator
LXX I E S COG
DESCHUTES COUNTY, OREGON
NOTICE UNDER THE AMERICANS WITH DISABILITIES ACT
In accordance with the requirements of title R of the Americans with Disabilities Act of 1990, Deschutes
County will not discriminate against qualified individuals with disabilities on the basis of disability in
Deschutes County's services, programs, or activities.
Employment: Deschutes County does not discriminate on the basis of disability in its hiring or employment
practices and complies with all regulations promulgated by the U.S. Equal Employment Opportunity
Commission under title I of the Americans with Disabilities Act (ADA).
Effective Communication: Deschutes County will generally, upon request, provide appropriate aids and
services leading to effective communication for qualified persons with disabilities so they can participate
equally in the County's programs, services, and activities, including qualified sign language interpreters,
documents in Braille, and other ways of making information and communications accessible to people who
have speech, hearing, or vision impairments.
Modifications to Policies and Procedures: Deschutes County will make all reasonable modifications to
policies and programs to ensure that people with disabilities have an equal opportunity to enjoy all County
programs, services, and activities. For example, individuals with service animals are welcomed in County
offices, even where pets are generally prohibited.
Anyone who requires an auxiliary aid or service for effective communication, or a modification of policies or
procedures to participate in a County program, service, or activity, should contact the ADA Coordinator at
388-6584 or his/her designee at 6174747, as soon as possible but no later than 48 hours before the scheduled
event.
The ADA does not require Deschutes County to take any action that would fundamentally alter the nature of
its programs or services, or impose an undue financial or administrative burden.
Complaints that a County program, service, or activity is not accessible to persons with disabilities should be
directed to the ADA Coordinator.
Deschutes County will not place a surcharge on a particular individual with a disability or any group of
individuals with disabilities to cover the cost of providing auxiliary aids/services or reasonable modifications
of policy, such as retrieving items from locations that are open to the public but are not accessible to persons
who use wheelchairs.
Deschutes County, Oregon
Grievance Procedure under
The Americans with Disabilities Act
This Grievance Procedure is established to meet the requirements of the Americans with Disabilities Act of
1990. It maybe used by anyone who wishes to file a complaint alleging discrimination on the basis of disability
in the provision of services, activities, programs, or benefits by the County. The County's Personnel Policies
govern employment-related complaints of disability discrimination.
The complaint should be in writing and contain information about the alleged discrimination such as name,
address, phone number of complainant and location, date, and description of the conditionor circumstances.
Alternative means of filing complaints, such as personal interviews or a tape recording of the complaint, will be
made available for persons with disabilities upon request.
The complaint should be submitted by the grievant and/or his/her designee as soon as possible but no later than
60 calendar days after the alleged violation to:
ADA Coordinator
1300 NW Wall Street, Suite 200
Lend, Oregon 97701
(541) 388-6584 or (541) 617-4747
Within 15 calendar days after receipt of the complaint, the ADA Coordinator or his/her designee will
contact or meet with the complainant to discuss the complaint and the possible resolutions. Within 15
calendar days of the contact, the ADA Coordinator or his/her designee will respond in writing, and where
appropriate, in format accessible to the complainant, such as large print, Braille, or audio tape. The response
will explain the position of the County and offer options for substantive resolution of the complaint.
Disputes: If the response by the ADA Coordinator or his/her designee does not satisfactorily resolve the issue,
the complainant and/or his/her designee may appeal the ADA Coordinator's response within 15 calendar days
after receipt of the response to the County Administrator or his/her designee.
Within 15 calendar days after receipt of the appeal, the County Administrator or his/her designee will meet
with the complainant to discuss the complaint and possible resolutions. Within 15 calendar days after the
meeting, the County Administrator or his/her designee will respond in writing, and, where appropriate, in a
format accessible to the complainant, with a final resolution of the complaint.
All written complaints received by the ADA Coordinator or his/her designee, appeals to the County
Administrator or his/her designee, and responses from these two offices will be retained by the County for
at least three years.
Deschutes County prefers that complaints and disputes be filed directly with the County such to expedite
a response. However, complaints and disputes can also be filed with:
Office for Civil Rights
U.S. Dept. of Health and Human Services 2201 Sixth Avenue —
Mail Stop RX -11
Seattle, Washington 98121-1831
1-800-368-1019
TDD: 1-800-537-7697
If you are a member of the Oregon Health Plan you have the additional option of:
Contacting your managed care plan
or Oregon Health Plan
Ombudperson
Office 1-800-442-5238
