Call Boxes
Edward Steven Castoria, M.A., J.D., October 14, 2002
Thanks again for the opportunity to address the Access Board on the ADAAG Guidelines Section 1110 on call boxes. As promised, I'm attaching the electronic version of my testimony, as well as the electronic version of the Study Report I included with the written testimony.
Edward Steven "Eddie" Castoria, M.A., J.D.
Executive Vice President
TeleTran Tek Services
Executive Director
San Diego SAFE Call Box Program
SAN DIEGO SERVICE AUTHORITY FOR FREEWAY EMERGENCIES
COMMENTS ON DRAFT ADAAG SECTION 1110
PERTAINING TO CALL BOXES
Submitted to the Access Board In Conjunction with the Testimony of
Edward Steven Castoria, M.A., J.D., Executive Director, San Diego SAFE Call Box Program
October 8, 2002, Portland, Oregon
? Introduction Edward Steven "Eddie" Castoria, M.A., J.D., Executive Director, San Diego SAFE Call Box Program Former federal prosecutor for the Fraud Section, Criminal Division of DOJ Thanks for the privilege of addressing the Access Board today
? Overview My subject is California call boxes and ADAAG draft Section 1110 pertaining to them Will quickly cover the following areas this morning.
Facts and misconceptions about California Call box programs
Accessibility initiatives implemented by California call box programs
Suggestions on modifications and clarifications to draft Section 1110
? Facts about California Call box programs Motorist aid call box programs were initially established in California in the late 1980's in San Diego and Orange Counties. Since that time, call box programs have been implemented in over thirty of California's fifty-four counties. In total, these programs operate over 17,500 call boxes, ranging from a dozen call boxes in the smallest County to over 4,400 in
? Misconceptions about California call box programs Misconception: All call boxes in the United States operate in the same manner.
Fact: All California call boxes allow two-way voice communication between the caller and answering center. Call boxes installed in some other states do not provide voice communication at all, but rather simply transmit a message indicating the type of assistance needed (e.g., police, fire, medical, breakdown). Misconception: SAFE call boxes are a single system owned and operated by the State of California or the County within which they are located.
Fact: As noted previously, each SAFE call box program is a separate local government agency operated under a separate Board of Directors. SAFEs work cooperatively in sharing information and developing coordinated responses to common issues, but cannot mandate what each other must do or not do. In addition, SAFEs are separately funded through a $1.00 annual fee added to vehicles registered in that SAFEs County of operation.
Some SAFEs have Fund Balances, while other SAFEs have insufficient funds to cover necessary operations and administrative costs. As a practical matter, this means that the approaches to providing access to call box services to disabled individuals will vary widely around California, based on financial ability. By statute, SAFE funds can only be spent within that County, preventing SAFEs from pooling funds on projects such as disabled access. Misconception: Call Box programs may make any alterations to call box sites for accessibility or other purposes as they wish.
Fact: California call boxes are installed in the road right-of-way owned and maintained by the California Department of Transportation (Caltrans). Caltrans must approve these installations pursuant to an Encroachment Permit issued by Caltrans to the individual SAFE program. SAFEs therefore have no authority to require that the right-of-way be accessible in any manner. In essence, the right-of-way is "take it or leave it" for the SAFEs. Thus any Guideline that requires a modification to the right-of-way as it exists must at a minimum require Caltrans to cooperate in approval of that modification and bear some of the cost related to it. SAFEs cannot require, for example:
. That the shoulder along the freeways and state routes be a certain width that would allow for safe egress from vans fitted for the mobility-impaired, or not exceed a certain slope, or provide a clear path;
. That Caltrans not install drainage dikes in front of existing call box sites, making currently accessible sites now inaccessible, or
. That Caltrans authorize cutting those dikes to allow access at call box sites.
? Accessibility Initiatives by California SAFEs In the early 1990's, the Access Board promulgated Draft Guidelines that included criteria for "accessible" call boxes. Among those criteria were the following:
. Pedestrian pads at call box locations had to be at least 36" by 48" in size to provide a sufficient turning space for wheelchairs;
. The call box door had to open with no more than 5 lb. Pressure;
. The handset cord had to be at least 29" long;
. The path from the roadway shoulder to the call box pedestrian pad could not be obstructed by a drainage dike or berm; and
. A visible indicator such as a call connect light had to be provided to let the caller know an live operator had answered the call. Most California SAFEs have complied with these requirements as much as possible. The San Diego SAFE has taken a leadership role in doing so:
. The San Diego SAFE was one of the first to increase pad size from 30" x 30" to 36" x 48" on all new call box sites and any sites repaired from knockdowns or relocations. We then increased the pad size to 60" x 60" on sites included in our Phase I ADA retrofit in the mid-1990's. That project involved sites that were not at that time blocked by Caltrans drainage dikes. We also installed handrails at the back of those sites where a down slope away from the roadway might cause a wheelchair to roll away.
. All California call boxes have been configured from the beginning with operable parts, including the call box door, that can be operated with one hand using less than 5 lb. Of force. All call boxes also have 29" handset cords, and were installed with the handset at no higher than 54" with less than a 10" reach from the pedestrian pad.
. The San Diego SAFE conducted tests a number of years ago to determine whether call boxes were compatible with TTY devices available to speech-impaired or hearing-impaired individuals through state distribution programs or by private purchase. Those tests showed that call boxes are compatible with portable TTY devices.
. The San Diego SAFE was one of the original SAFEs to propose the Hearing-Impaired and Speech-Impaired Access Study funded by California SAFEs to evaluate available alternatives for providing such access. The San Diego SAFE Executive Director served on the Technical Advisory Committee that worked with the consultant conducting the Study. In order to ensure the involvement of members of the San Diego hearing-impaired and speech-impaired communities, the San Diego SAFE approved the use of the San Diego Call Box Answer Center to answer calls placed during the field-testing portion of the Study.
. Most California call boxes, and all San Diego SAFE call boxes, have a call connect light on the faceplate of the call box that illuminates when an operator has personally answered the call box call. The light can be changed to a flashing mode by the call taker to indicate that he or she understands the caller's needs and will arrange for assistance. The San Diego SAFE also pioneered improvements to the call connect light during its equipment upgrade project in 1999. Those improvements included installation of a higher intensity bulb and changing the light cover from clear to red to create a greater contrast in outdoor lighting.
. As discussed below, the San Diego SAFE, in cooperation with the MTC SAFE, developed the design for the Behind the Dike site design recently approved by both Caltrans and FHwA to provide easy access to call box services to mobility-impaired individuals.
? Suggestions for modifications and clarifications to Draft Section 1110 1110.2. Operable Parts. Operable parts of the call box (front door, push button, handset) must be operable with one hand without the need for tight grasping, pinching or twisting of the wrist. No more than 5 pounds of force can be necessary to operate those parts. SAFE call boxes comply with this requirement. (Technical Requirements Section 309.4)
Operable parts must be set within related height and reach parameters (Technical Requirements Section 308). For call boxes, the handset grip must be no higher than 54" where the reach from the wheelchair to the handset is 10". Where the height is as low as 46", the reach can be up to 24". San Diego SAFE call boxes are generally set at 54" of height or lower, and therefore comply with this requirement where Caltrans drainage dikes do not block the path to the call box site.
. Caltrans has made clear its strong preference that it's drainage dikes not be cut to provide mobility-impaired access to call box sites. Caltrans indicates that such dike cuts would negatively impact:
. the flow of highway runoff and create maintenance problems because of water pooling and silting; and
. motorist safety because the walls of the concrete pad built behind the dike cut would be a transverse wall barrier that could cause deceleration injury to motorists if hit.
. To solve this conflict between Caltrans and the needs of mobility-impaired individuals, the San Diego SAFE proposed a new call box site design that allows mobility-impaired access without cutting the dike. The Behind the Dike design places the call box and pole directly behind the drainage dike, with the call box turned 90 degrees
. A drawing of the Behind the Dike site design is included in the handout materials.
. The Behind the Dike site design has been crash tested for safety concerns by the Texas Transportation Institute at Texas A&M University, and subsequently approved for installation by both the Federal Highway Administration and Caltrans.
The San Diego SAFE requests that the Access Board determine that the Behind the Dike site design complies with the draft Guidelines.
Call Box Signs
. Call box signs (labeling referred to in Technical Requirements 703.2 and 703.3) currently provide the required contrast between the sign background and the lettering on it (e.g., white letters on blue background) required for individuals with impaired vision. These same sections appear, however, to also require that signs not have a reflective coating on them, as such coatings tend to make them harder for visually impaired individuals to read. Call box signs have such a reflective coating to make them easier to see at night when visual location of call boxes is the most difficult. The San Diego SAFE requests that the Access Board approve an exception on this point for call box signs.
. Line spacing on call box signs on the 17,500 call boxes in California is smaller than the requirement that the line spacing be between 135% and 170% of the 4" character height. Since call box signs are only installed 8 feet
. In addition to the information on the call box signs, many call box programs place instructions for either general call box use and/or operation of the call connect light for the hearing-impaired. Technical Requirements Sections 703.2 through 703.4, incorporated by reference in proposed Section 1110.2, would appear to require both visual and tactile lettering on signs. Again, the visually impaired for whom this requirement was written would not likely be driving and need their use. The San Diego SAFE requests that the Access Board clarify that call box signs and in-box instructions need not have tactile lettering.
? 1110.3. Turning Space. A turning space of up to 60" must be provided at the call box to accommodate wheelchairs (Technical Requirements Section 304). This would in essence require 60" by 60" pedestrian pads, which were installed during the Phase I San Diego ADA retrofit at about 300 sites without drainage dikes. For sites behind dikes, pedestrian pads would not be necessary since the roadway shoulder provides 8' width of paved approach and turning for wheelchairs, and the Behind the Dike design handles the height/reach requirements.
? 1110.4. Edge Protection. When the call box site sits near a slope that might affect someone in a wheelchair, an edge protection must be placed around the call box pad. This would be the case primarily at fill sites installed along down slopes. However, Caltrans will not permit fill sites with walls over 4" high, based on the crash testing recently completed at the Texas Transportation Institute, because of deceleration injury concerns. Instead, call box programs install as a matter of course a handrail at the rear of the call box pedestrian pad on such sites that effectively prevents unintended rollaway of wheelchairs. The San Diego SAFE requests that the Access Board modify the edge protection requirement for call box sites to indicate that a handrail placed at the rear of the site will be considered adequate edge protection.
? 1110.5. Motor Vehicle Turnouts. This Section sets out minimum length and width parameters for turnouts at call boxes. California SAFEs do not build motor vehicle turnouts at call box sites, since that falls under the purview of Caltrans. These turnouts are more common in other states. Some SAFEs do place call boxes at Caltrans maintenance turnouts, since these are now being built at approximate one-half mile intervals where installed. As noted above, SAFEs have no control over where maintenance turnouts are placed, or over their configurations. The San Diego SAFE requests that the Access Board clarify whether the motor vehicle turnout specifications are intended to apply to the situation where a call box is coincidentally installed at a Caltrans maintenance turnout.
? 1110.6. Two-Way Communication. This Section requires that, where two-way voice communication is provided, the call box must provide both visual and audible signals (Technical Requirements Section 708.2), and a handset cord at least 29" in length (Technical Requirements Section 708.3). As noted above, most California and all San Diego SAFE call boxes are equipped with a call connect light that provides such a visual signal. They provide an audible signal through the handset. The visually impaired for whom the audible signal requirement was written would not likely be driving and need this function. The San Diego SAFE requests that the Access Board approve an exception on this point for call box programs.
? 1110.6.1. Volume Controls. Like public telephones, call boxes would have to have a volume control available at the call box that provides at least a 20 dB increase, with an automatic reset (Technical Requirements Section 704.3). Current SAFE call boxes do have a 6 dB volume adjustment feature, but it is controlled at the Answer Center, not at the call box. The call box manufacturer indicates that this requirement could be met by using a different handset that has a compliant volume control built-in. The San Diego SAFE will investigate further this suggested retrofit to determine if it is indeed technically feasible.
? 1110.6.2. TTY. This Section requires that a TTY be provided within or adjacent to the call box. A height minimum and maximum of 30" to 34" respectively are made for the keyboard, as is a clear floor space for a forward approach (Technical Requirements Section 704.4). This requirement appears impractical when applied to a highway call box system.
At present, there are four call box options available to call box programs for providing access to call box services for the hearing impaired and speech impaired. Pictures of these devices are included with this document:
. The CWT TTY call box currently installed in Los Angeles and Orange Counties;
. The Denbridge TTY call box currently installed in Ventura County;
. The CWT Yes/No call box currently being tested by the MTC SAFE. This version contains the message screen and response buttons of the CWT TTY call box, but does not include a TTY keyboard. Callers answer a series of Yes/No questions about the problem they have and the assistance they need that allow the call taker to determine what assistance to dispatch;
. The call connect light call box that signals the caller when to speak or tap on the handset, with instructions on the inside of the door explaining what the solid and flashing light signals mean.
The California SAFE Committee (CalSAFE) is an informal association of California call box programs through which SAFEs work cooperatively on matters of common interest and share lessons learned. During 1999 and 2000, CalSAFE commissioned TelAdvisors, Inc. to perform a study to determine which of the four available options was preferred by members of the speech-impaired, hearing-impaired and non-impaired communities. A copy of the final report of that study is attached to this document for the Access Board's information.
. The study determined that most hearing- or speech-impaired individuals preferred the ease of use of the CWT Yes/No call box, while most deaf individuals preferred either the Denbridge or CWT TTY call boxes.
. Since many more individuals are hearing-impaired than are deaf, the preference for use of the TTY call box is actually expressed by a very small portion of the population. This finding comports with the information provided by Dr. Caren Stika, herself a hearing-impaired individual, who reported that most hearing-impaired but not deaf individuals have no experience using a TTY, and find them confusing to use. This would be exacerbated in the dangerous highway environment, and likely significantly slow down the communication necessary to receive assistance for the vast majority of motorists.
Only three SAFE call box programs have so far installed TTY's in their call boxes. The Los Angeles SAFE upgraded to Comarco Wireless Technologies (CWT) TTY call boxes about 4 years ago pursuant to a settlement agreement in a federal lawsuit brought under the ADA. The Orange County SAFE upgraded to the same TTY call box this year. The Ventura SAFE upgraded to Denbridge TTY call boxes about five years ago.
According to the California Highway Patrol Communications Centers that answer call boxes for the Los Angeles and Ventura SAFEs, virtually no call box calls have been received during those four years from hearing-impaired individuals using the TTY feature of those call boxes. For example, in Los Angeles County, where each of the 4,400 call boxes displays a TTY sign, CHP has reported that only about five calls out of 175,000 annual calls (.003%) came from hearing-impaired individuals using the TTY feature.
Most California freeways and state routes within SAFE Counties already have call boxes installed on them. SAFEs will likely do some retrofitting of affected call box sites to utilize the Behind the Dike design for mobility-impaired access, but no large-scale new construction or other alterations will likely occur.
. Since ADAAG requires accessibility modifications only for new construction or alterations, large portions of call box systems might not get TTY or Yes/No devices installed for some time, especially in SAFEs with limited funds available for that purpose. But the need to report mechanical breakdowns, crimes, requests for medical assistance and the other calls typically made from call boxes can occur anywhere along the roadway, making a haphazard installation of accessibility devices not particularly useful to the community they are designed to serve.
. By the same token, installation of these devices in all call boxes in a particular SAFE system to handle two or three calls per year may not be an appropriate use of public funds. At over $1,600 per call box, the cost to upgrade to the Comarco TTY call box would exceed $2.8 million for the San Diego SAFE alone, and tens of millions of dollars statewide.
. To add to this quandary, the Los Angeles SAFE has recently file a lawsuit against Comarco Wireless Technologies in federal District Court in the Central District of California alleging, among other things, that the CWT TTY call box is defective and has not been properly repaired by CWT. In addition, the suit alleges that the Los Angeles SAFE should be the beneficial owner of the patent CWT has on the TTY call box, since the LA SAFE provided the specifications and performance criteria upon which the TTY call box was designed. This action makes it very difficult, if not impossible, for any call box program to implement at TTY call box installation until these issues are resolved.
The San Diego SAFE requests that the Access Board review the information provided on alternative devices available for providing access to call box services to hearing- or speech-impaired individuals, and consider allowing use of any of the four options to do so, rather than requiring use of a TTY device.
[...] I support the proposed draft guidelines mandating that all emergency call boxes in the United States be accessible to motorists with disabilities. The requirement as drafted states that call boxes provide two-way voice communication and must be equipped with Teletypewriters for the Deaf, (TTY's) (proposed guideline 1110.6). To establish interactive communication with individuals who are deaf, hard-of-hearing or have speech impairments, the call boxes must be functionally equivalent and accessible. Accessible call boxes must include the "Yes/No" text/graphic displays, TTY keyboards and handsets with volume control. Detailed information is in the letter.
Please feel free to contact me [...], if you have any questions or require further information. In addition, if you have any problem opening the attached file, please let me know.
Thank you.
Richard Ray
[PDF version]
I would like to take this opportunity to provide comments in reference to Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002). I support the proposed draft guidelines mandating that all emergency call boxes in the United States be accessible to motorists with disabilities. The requirement as drafted states that call boxes provide two-way voice communication and must be equipped with Teletypewriters for the Deaf, (TTYs) (proposed guideline 1110.6). To establish interactive communication with individuals who are deaf, hard-of-hearing or have speech impairments, the call boxes must be functionally equivalent and accessible. Accessible call boxes must include the "Yes/No" text/graphic displays, TTY keyboards and handsets with volume control.
I would like to take this opportunity to provide you with background information on emergency call boxes that might assist the Department of Justice and the Access Board in the preparation of the proposed guidelines to impose compliance requirements for all states (Attachment A).
In 1994, Los Angeles County Service Authority for Freeway Emergencies (LA SAFE) Advisory Committee was formed to solicit input from a group of individuals who are deaf and hard-of-hearing for the implementation of accessible emergency call boxes. Subsequently, Anthony Ivankovic (from the National Center on Deafness at California State University, Northridge), Mark Apodaca, (now Assistant Vice President of Finance for Communication Services for the Deaf (CSD), South Dakota) and I served on this committee. The committee provided technical assistance, which included: bidding; evaluation and selection of the call boxes; and development of a Public Service Announcement (PSA). I was also involved with the City of Los Angeles, Department of Transportation, where call boxes equipped with Teletypewriter for the Deaf (TTY) were installed along the Los Angeles River and Ballona Creek Bikeways in the Fall of 2000.
LA SAFE has completed the installation of more than 4,200 emergency call boxes equipped with TTY on Los Angeles County Freeways, to provide accessible emergency services to stranded motorists who are deaf, hard-of-hearing or have speech impairments (Attachment B). The accessible call boxes were also installed on lightly traveled rural roadways and on heavily traveled urban freeways as well as on local and state freeways, metropolitan, highways expressways and highways with median strips or more than four traffic lanes.
The Los Angeles call boxes include both the "Yes/No" ATM-like functions and TTY keyboards. The accessible call boxes were designed to interface with the existing 911/E911 to enable users to communicate directly with a dispatcher at the California Highway Patrol (CHP) Public Safety Answering Points (PSAPs). This is a complete system and is consistent with the ADA because the system also allows users the option of establishing two-way communication to determine the types of emergency services that are needed to avoid time delays. As a result, this could prevent further injury or death. Also, those who use TTY equipment did not have to carry their own portable TTY equipment. Each enhanced call box is identified with a sign displaying the International TTY and Phone symbols. The options, Voice Carry Over (VCO) and Hearing Carry Over (HCO) TTY calls, are available to accommodate persons who are deaf, hard-of-hearing or have speech impairments. VCO calls are for persons who are deaf or hard-of-hearing and prefer to speak for themselves. The VCO user reads the message displayed on a screen as the CHP representative types responses on their TTY equipment. This allows the VCO user to speak directly to the CHP representative. The HCO calls are for persons who are speech impaired and who can hear. The HCO user listens as the CHP representative speaks through the handset. The HCO user types back and the CHP representative reads the responses displayed on their TTY equipment. Also included, is a procedure for processing Spanish Language TTY calls to accommodate individuals whose primary language is Spanish.
The installation of functionally equivalent and accessible emergency call boxes for Los Angeles County freeways resulted from a class action lawsuit. On September 30, 1994, Alexis Kashar of Newman, Aaronson, Vanaman; David Raizman, former Executive Director; and Carol Codrington, former Director of Litigation, both from the Western Law Center for Disability Rights brought a class action lawsuit (Thalheimer) in Los Angeles County Superior Court against LA SAFE, Caltrans, Metropolitan Transportation Authority (MTA), and California Highway Patrol (CHP). The action alleged that persons who are deaf, hard-of-hearing or have speech impairments have been denied equal access to the Los Angeles County freeway emergency call boxes. Users had to either carry their own portable TTY equipment or obtain service by tapping the mouthpiece of the telephone receiver, until a light came on in the call box indicating that the help was on the way. David Raizman's successor, Eve Hill and another law firm, Munger--Tolles later joined Alexis Kashar and proceeded with the case.
On March 23, 1999, LA SAFE, MTA, and Caltrans entered into a successful settlement agreement--a big step forward for the entire community with disabilities. The agreement required the defendants to include TTY equipment in the call boxes and to make them functionally equivalent and accessible to motorists with mobility impairments. A separate settlement agreement with CHP was reached on April 8, 1999, requiring CHP to install TTY equipment to process TTY calls at every call-taking position as mandated under Title II, Section 35.162 of the 1990 Americans with Disabilities Act (ADA).
In 1998, Ventura County SAFE installed TTY equipment in all of its call boxes (Attachment C). The Orange County Transit Authority (OCTA) is in the process of implementing the functionally equivalent and accessible call boxes for the Orange County area.
For many years, the deaf and hard-of-hearing communities have fought for services that function in an equivalent manner to those of the non-TTY user community. Individuals who are Deaf and hard-of-hearing are not the only individuals who use TTY equipment. Individuals with speech impairments also utilize this equipment to communicate. Two-way communication should be made available to accommodate all individuals. The keyboard allows TTY users to quickly communicate with dispatchers or other emergency personnel to determine the types of emergency services needed. Quick responses avoid delays, which may cause further injury or death. Also, no individual should be forced to carry his/her own portable TTY equipment or to tap the mouthpiece of a telephone, when non-TTY users communicate emergency needs with dignity and ease.
The Metropolitan Transportation Commission (MTC), SAFE installed ATM-like "Yes/No" call boxes without TTY keyboards on a small percentage of their call boxes in the San Francisco Bay area on a test basis (Attachments D and E). Since 1998, MTC has been installing the "Call-Connect" light in its call boxes as they are replaced (Attachment F). The "Yes/No" function does not render call boxes functionally equivalent and accessible to individuals with disabilities. Sacramento, Riverside and San Bernardino counties in California are utilizing these inaccessible call boxes. As illustrated by the example above, very little effective effort has been made to improve emergency call boxes since the passage of the ADA.
In some states, a very basic call box is being used and when motorists need an emergency service, they are required to press a button(s) to summon help (Attachment G). When a light flashes and the tones are heard, this indicates that the message was received. In addition, there is an engraved plaque alerting call box users that the call box is not a voice communication unit, and all users are required to push buttons only for services actually needed. This type of call box is currently used in Florida and Pennsylvania and it could be perceived as functionally equivalent because there is no interactive voice communication. Therefore, this procedure also applies to individuals who are deaf and hard-of-hearing.
If the policy and procedure are implemented requiring a TTY user to only access services by pushing a "Yes/No" button or tapping the mouthpiece until a light comes on the call box without any type of interaction, these options should also apply to voice users. If a basic system, "Call-Connect" is "good enough" for individuals who are deaf, hard-of-hearing or have speech-impairments, then the basic system should be "good enough" for everyone. If the system, such as the one currently used in California, allows a voice caller to interactively communicate fully with the emergency service provider, this option should also be made available to a TTY user. Such a system should not be limited to basic communication such as "Yes/No" inquiry or, even worse, to merely having a Call-Connect light call box.
Call boxes should include both the "Yes/No" ATM-like devices, handsets with volume control and TTY keyboards, and should also include graphics for visitors who speak languages other than English. This complete system allows motorists the option to establish two-way communications. Procedures for processing Voice Carry Over (VCO) and Hearing Carry Over (HCO) TTY calls need to be included for simultaneous use of TTY and voice communication to accommodate persons who are deaf, hard-of-hearing or have speech impairments. A procedure for processing TTY calls to accommodate an individual, whose primary language is Spanish, should also be included.
The California Service Authority for Freeway Emergencies (CalSAFE) program began in 1986 and a total of 17 SAFEs have been formed, covering 31 of California's 58 counties. It was created pursuant to California Streets and Highways Code, Section 2550 et. Seq. Each county established SAFE as an independent local government agency, which is funded through the collection of a $1 fee on all vehicles registered within their respective counties (Streets & Highways 2555; Vehicle Code 9250.10). County SAFE agencies, in cooperation with two oversight agencies, California Department of Transportation (Caltrans) and California Highway Patrol (CHP), are implementing call box systems within various county boundaries.
At each county's discretion, the distance between call boxes ranges from 1/4 mile (on heavily traveled urban freeways) to 2 miles (on more lightly traveled rural roadways). Highways with median strips or more than four traffic lanes require the installation of a call box in each direction at about the same postmile.
For several years, SAFE agencies have utilized taxpayer funds and spent many unnecessary hours evaluating call boxes for their county freeways. To date, the call boxes have not been modified in most counties. Motorists with disabilities are still unable to access emergency services, therefore these counties are not complying with Title II of the ADA.
In 1998, with the assistance of Ken Kresse of the California Center for Law and the Deaf (CalCLAD), Assembly Bill (AB) 2137 (Machado), was introduced to mandate installation of TTY equipment be included in all the SAFE's call boxes. With opposition from CALSAFE, the author dropped the bill.
The National Association for the Deaf (NAD), the California Association for the Deaf (CAD), the California Coalition of Agencies Servicing the Deaf and Hard-of-Hearing and the California Center for Law and the Deaf (CalCLAD) are supporting such guidelines. They are advocating for full inclusion of complete TTY-equipped emergency call boxes for all state and county freeways and highways to accommodate individuals who are deaf, hard-of-hearing or have speech impairments as well as, persons with other disabilities. In addition, it is being requested that taxpayer funds be used to implement of the emergency call box program rather than on merely evaluating the call boxes for their counties.
Please feel free to contact me at [...], if you have any questions or require further information.
Sincerely,
Richard Ray
cc: Mr. Deval L. Patrick, Assistant Attorney General
United States Department of Justice
Mr. James Raggio
The Access Board
Ken Kresse, Esq., Executive Director
California Center for Law and the Deaf
Mark Apodaca, Assistant Vice President of Finance
CSD, South Dakota
Nancy Bloch, Executive Director
National Association for the Deaf
Claude L. Stout, Executive Director
TDI, Inc.
Robert Roth,Chief Executive Officer
Deaf Counseling, Advocacy and Referral Agency
Ed Kelly, Chair
California Coalition of Agencies Servicing the Deaf and Hard-of-Hearing
Russ Bye, President
California Association for the Deaf
Anthony Ivankovic
California State University, Northridge
Attachment A
PROPOSED GUIDELINES
The Federal Guidelines mandate that if the state or local government provides emergency services to stranded motorists by way of emergency call box, then emergency services must also be made available for individuals with disabilities. To establish interactive communication with individuals who are deaf, hard-of-hearing or have speech impairments each call box must include the "Yes/No" text/graphic display, TTY keyboard and handset with volume control. Each enhanced call box must be identified with a sign displaying the International TTY and Phone symbols.
In some situations, a non-voice interactive call box is utilized which requires a stranded motorist to press a button(s) to summon help. The call box will light up and have a series of tones to confirm that the message has been received. A TTY keyboard is not required to interface with a non-voice interactive call box.
The policies and procedures should also include Voice Carry Over (VCO) and Hearing Carry Over (HCO) TTY calls for simultaneous use of TTY and voice communication to accommodate persons who are deaf, hard-of-hearing or have speech impairments. Also included is a policy and procedure for processing Spanish Language TTY calls to accommodate individuals whose primary language is Spanish.
Attachment B
Comarco TTY Call Box
The Comarco TTY Call Box provides a horizontal TTY keyboard on a retractable shelf mounted below the call box enclosure and a display screen mounted within the enclosure to send and receive messages. This device also allows for a push button response to "Yes/No" questions. Simultaneous voice communication with the operator is also possible to provide Voice Carry Over (VCO) and Hearing Carry Over (HCO). The call box includes graphics for visitors who speak languages other than English. This call box is currently in use in Los Angeles County and Los Angeles Bikeways.
Attachment C
Denbridge TTY Call Box
The Denbridge TTY Call box has a vertical text telephone (TTY) keyboard and a display screen mounted within the call box enclosure to send and receive messages. Simultaneous voice communication with the operator is not possible. This call box was developed in the mid-1990s and is currently in use in Ventura County.
Attachment D
Comarco Yes/No Call Box (San Francisco Bay Area)
The Comarco Yes/No Call Box device that allows for a push button response to "Yes/No" questions and it does not include a TTY keyboard.
Attachment E
Comarco Yes/No Call Box
The Comarco Yes/No Call Box device that allows for a push button response to "Yes/No" questions and it does not include a TTY keyboard.
Attachment F
Call-Connect Call Box
The Call-Connect Call Box displays a light indicating when the call has been received at the California Highway Patrol (CHP). A voice communication with operator is also possible. A user who may not hear the operator, but can speak, will be able to speak information through the handset to the operator. An individual who may not speak may require tapping the mouthpiece of a telephone receiver to alert an operator.
Attachment G
Blue Call Box
A very basic, Blue Call Box is being used and when motorists need an emergency service, they are required to press button(s) to summon help. When a light flashes and the tones are heard, this indicates that the message was received. In addition, there is an engraved plaque alerting call box users that the call box is not a voice communication unit and all users are required to push buttons only for services actually needed. This type of call box is currently used in Florida and Pennsylvania.
On behalf of the California Association of the Deaf (CAD), we are submitting this brief comment in full support of the draft guideline that would require TTYs on call boxes that provide for two-way communication (1110.6.2).
Here in California, highways in many counties have a system of emergency call boxes. Currently, three of these, including Los Angeles with thousands of call boxes, have installed or are installing call boxes equipped with TTYs. Nevertheless, most local systems remain virtually unusable by deaf motorists. The protocol is for these motorists to tap on the call-box handsets (call-connect lights are being installed on call boxes that are replaced), and the California Highway Patrol will be dispatched to the location. We have documented repeated instances where this simply does not work. Deaf motorists have been stuck waiting for long periods of time, sometimes in darkness and bad weather. Some have had to depend on hearing motorists acting as good Samaritans. As a result, deaf motorists have been placed at increased risk of harm and have been forced to endured frustration, anxiety and extreme inconvenience due simply to the inaccessibility of the systems.
CAD is a statewide membership organization that undertakes advocacy on behalf of its members and other deaf and hard-of-hearing people to advance and protect their rights to equal access and nondiscrimination.
Ken Kresse
Executive Director
California Center for Law and the Deaf