Benefits and Challenges of a Regional Approach: Pennsylvania Commission on Crime and Delinquency
The Commonwealth of Pennsylvania has more than 1,200 local law enforcement agencies, which vary greatly in size and access to available resources. In 2018, the Pennsylvania Commission on Crime and Delinquency (PCCD) applied for and received a fiscal year (FY) 2018 Bureau of Justice Assistance (BJA) Body-Worn Camera (BWC) Policy and Implementation Program (PIP) grant on behalf of 50 law enforcement agencies throughout the commonwealth. In 2019, PCCD reapplied and was awarded a FY 2019 grant on behalf of an additional 35 law enforcement agencies. PCCD is a central source of planning, statistical analysis, and program development for the improvement of the state’s justice system. PCCD, acting in its role as the State Administrating Agency (SAA), is also responsible for the administration of state and federal grant programs to enhance the quality of justice for all Pennsylvanians.
PCCD applied for a BWC PIP grant to help qualifying Pennsylvania agencies acquire and implement BWCs using a regional approach. In developing this approach, PCCD staff worked with the Pennsylvania Chiefs of Police Association (PCPA) to survey all the local police departments on their BWC-related needs and expectations. They also helped agencies implement BWCs according to Pennsylvania law. Pennsylvania has specific laws regarding data-handling requirements, and §67A07 of Act 22 of 2017 amended the Wiretap Act to enable police officers to wear BWCs in Pennsylvania. It also created requirements related to policies, guidelines, and protocols. PCCD’s regional approach to BWC implementation includes a unique approach to grant management, collaboration, policy development, and procurement decisions.
Grant implementation and administration
In applying for the BWC PIP grant, PCCD found it essential to continue to collaborate with the PCPA to leverage equitable contracts that meet procurement requirements and to increase buying power through combined purchases. Upon the release of the grant announcement for the BWC PIP, the PCCD staff worked with the PCPA to survey Pennsylvania police agencies to determine their BWC needs. In their grant application, PCCD included these agencies’ interest in and commitment to participate in the program. PCCD also noted their plans to leverage their extensive history in grant administration, collaborative partnerships, and technology procurement experience to manage this larger grant. As the lead applicant for this project, PCCD maintained the primary responsibility in the management of the award, including administering funds to local agencies.
Pennsylvania agencies interested in receiving funding for the establishment or expansion of their BWC program could apply to PCCD to be a sub-grantee of PCCD under the BJA BWC PIP award. The funding opportunity was limited to municipalities, regional police departments, county law enforcement, and correctional agencies. These agencies were eligible to apply for funding even if they have received funding through the program in the past.
As sub-grantees, the dollar for dollar matching requirement of the federal grant remains and PCCD uses a reimbursement process to ensure that this stipulation is met. Reporting can be a taxing aspect of grant administration for smaller agencies, which are less likely to employ staff who can serve as grant managers. Accordingly, reporting requirements for agencies selected by PCCD to receive funding as sub-grantees differed from agencies that are the primary recipient of funding. Specifically, as opposed to directly to BJA, PCCD sites submit quarterly reports and performance measures directly to PCCD. PCCD compiles this information and includes it in its quarterly progress report to BJA. Sub-grantees are thus alleviating from considerable administrative and technological burdens of the federal grant system (e.g., acquiring financial management training or establishing credentials to access the federal grant performance tracking system).
Through the grant, PCCD sub-grantees are provided the same access to the training and technical assistance (TTA) available to other grantees. PCCD sub-grantees have a designated TTA team that works with each site on policy development, procurement, and implementation. PCCD sites also receive the benefit of the PCPA to aid them with local considerations, training, and other advice as they navigate these processes.
Regional BWC TTA meetings
In 2019, PCCD and CNA, the BJA BWC TTA provider, hosted a regional meeting for the FY 2018 PCCD BWC PIP sites in Harrisburg, Pennsylvania. This meeting was an opportunity for sites to network and discuss successes and challenges, and also to hear from BWC subject matter experts on best practices and lessons learned related to BWCs. For example, one session outlined best practice policy considerations, implications of poor policy development, lessons learned from the field, and the benefits of conducting policy review on an ongoing basis. Another session allowed agencies from Pennsylvania that had already deployed BWCs to discuss their major milestones, positive effects on their agency and communities, and BWC training efforts. Further sessions included Managing Community Expectations and Relations with BWCs, Maximizing BWC Video Utility for Evidentiary/Prosecution Value, and Legal Issues. The meeting was well received by sites, which were able to network with agencies from across the state.
In 2020, because of the COVID-19 pandemic, BJA and the BWC TTA team held the yearly BWC TTA National Meeting virtually; PCCD sites from all years were invited to participate. Three former PCCD BWC PIP sites were chosen as panelists for a “Voices from the Field” session, moderated by the PCCD BWC TTA lead. During this session, one panelist highlighted aspects of their program that increased both internal and external stakeholder acceptance of the cameras. Another panelist, whose agency had selected the same BWC vendor used by two neighboring agencies, highlighted the benefits of agency collaboration. The session addressed other important topics such as negotiation with unions and bargaining units, community buy-in, BWC effects on complaints against officers, and training. National meeting participants found the experiences and lessons learned shared by these panelists valuable.
In addition to the resources provided by the BWC TTA team, PCCD also offers resources to assist agencies in the policy development process, including samples of BWC policies that model operating procedures in similar law enforcement agencies throughout Pennsylvania. PCCD also created a guide that includes practical recommendations for the policy development process. These recommendations were created to help agencies develop policy that best suits their unique local needs while also ensuring that they are in compliance with Pennsylvania statutes on BWC policy. The policy guidelines cover a number of topic areas related to BWC implementation and operation including retention, activation, training, storage, and review of footage. These recommendations help agencies develop their policy in areas such as maintaining video evidence, establishing a training curriculum, and defining conditions of safe activation. These resources provide agencies with a BWC program model that is not only in line with state regulations but also developed by considering BWC best practices.
PCCD also encourages agencies to connect with neighboring jurisdictions to learn about their approach to BWC implementation. They share policies and lessons learned regarding necessary storage capacity, camera functions, integration abilities, and approaches to video review and report writing. Participating agencies have reported that seeing example policies from other departments in Pennsylvania has helped them to understand how other agencies of similar size, location, and governance manage their BWC programs through policy. This collaboration is important in the policy development process as it helps an agency understand what works for other agencies as it develops operating procedures to support an efficient and effective BWC program.
In January 2019, PCCD, in coordination with the PCPA, released a request for information (RFI) to learn more about police BWCs and other recording systems that could be implemented in accordance with Pennsylvania statutes and policy requirements. They were interested in gaining more information from BWC manufacturers and vendors to help the regional agencies understand the technology, products, and services available. The RFI covered Pennsylvania law requirements, available storage solutions, cost of services and products, and available cost reductions for bundled products. PCCD consolidated the RFI results into a report for agencies to assess their options for BWC technology. The compilation of this information allows Pennsylvania law enforcement agencies to make an informed decision in selecting a vendor that offers desired technology functions and allows them to meet state regulations.
PCCD agencies operate independently in making a purchase decision that fits the needs of their agency. For example, a number of PCCD agencies made their vendor decision based on officers’ familiarity with the BWC functionality from working in surrounding agencies that used the same camera. Some agencies selected a BWC that would sync with their in-car cameras made by the same vendor, allowing for easier integration when operating and reviewing the video recordings. In addition, a majority of sites made plans to store videos on their own servers, while other agencies decided to use a cloud-storage system. Because cloud systems are relatively newer platforms, many agencies decided to adopt a storage system with which their technology staff was familiar and had the capacity to maintain.
Benefits and challenges of a regional approach
One challenge of the regional approach is that each agency is still required to develop policies and select its own vendor. This proved to be a longer process for some agencies as they experienced delays for a variety of reasons. Furthermore, managing multiple agencies that exercised their own purchase decisions resulted in an increased workload for PCCD, requiring an intensive effort on the part of PCCD to track the agencies’ progress at various stages of their implementation. Understanding these challenges early has helped PCCD to develop processes to track this information efficiently. For example, PCCD and the federally funded TTA provider have developed processes and strategies for reviewing each agency’s BWC scorecards and policies. They have also developed systematic processes to regularly track the process and challenges of each agency.
One of the advantages of a regional approach is the ability to quickly and efficiently provide information about Pennsylvania-specific laws and regulations to the local law enforcement agencies. For agencies to receive funding from PCCD, they must ensure that their policies include guidelines and provisions that meet the PCCD recommendations and Pennsylvania statutes. Another advantage of the regional approach is the ability to assist agencies of all sizes. Smaller agencies with, for example, only two full-time officers may not have the resources to apply for a federal grant. This approach allows smaller agencies to participate in the program and receive resources to strengthen their implementation. PCCD also gathers all the necessary information from the sites to complete the federal grant reporting requirements with little burden on the police departments. PCCD has been a central coordinator for responding to questions and providing information that helps the agencies navigate their program. An additional benefit of this approach is that neighboring agencies can collaborate with each other on lessons learned from the implementation of their programs. Through the BWC program, PCCD has established its own network of agencies equipped to share important lessons learned and best practices that work for similar law enforcement agencies.
PCCD has developed a number of effective practices in managing their regional BWC implementation. They have created opportunities for smaller agencies to apply for funding to assist them with program implementation, receive assistance with cost and grant management, develop a regional peer network to assist others implementing BWCs, and receive information on how to develop a strong BWC policy. The resources provided to agencies by PCCD and the BWC TTA program, such as the regional BWC meeting and policy guidance, have helped agencies address common challenges that could impede successful BWC implementation and have helped 85 Pennsylvania law enforcement agencies implement successful BWC programs.
Keri Richardson is a Senior Research Specialist at CNA’s Institute of Public Research within the Safety and Security division. At CNA, she supports numerous projects including BWC TTA, SPI, and PSP. Ms. Richardson also has experience in leading and serving on teams that support on law enforcement auditing, assessments, and monitoring efforts. She has served in this capacity for cities such as Chicago, IL; Charleston, SC; and Methuen, MA. Ms. Richardson has worked to conduct assessments for police agencies and developed supportive recommendations that would improve operations to advance the goals of their agencies. Ms. Richardson also has experience fostering community engagement and involvement in order to fulfill police reform efforts. She continues to work closely with law enforcement agencies offering analytical and technical support to deliver resourceful assistance.
Monique Jenkins is a Research Specialist with CNA’s Center for Justice Research and Innovation. Ms. Jenkins has served as Deputy Project Manager role for a recent after-action review, analyzing the Philadelphia Police Department’s response to protests after the killing of George Floyd. She also serves as an analyst for multiple federally-funded training and technical assistance (TTA) projects, including the Strategies for Policing Innovation, Body Worn Camera Policy and Implementation Program, and the Justice Reinvestment Initiative. She aids in the delivery of and documents the impact of TTA based on the needs of various law enforcement agencies. In addition to TTA, Ms. Jenkins serves as an analyst for an assessment of Orlando Police Department’s community policing initiatives. She is also leading an internally-funded case study project which seeks to explore field training programs from agencies around the country in an effort to identify common themes, best practices, and areas for improvement. Ms. Jenkins produced literature summaries to support a Department of State research initiative.
This project was supported by Grant No. 2015-DE-BX-K002 awarded by the Bureau of Justice Assistance. The Bureau of Justice Assistance is a component of the Department of Justice's Office of Justice Programs, which also includes the Bureau of Justice Statistics, the National Institute of Justice, the Office of Juvenile Justice and Delinquency Prevention, the Office for Victims of Crime, and the SMART Office. Points of view or opinions in this document are those of the author and do not necessarily represent the official position or policies of the U.S. Department of Justice.