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, Im
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
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
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
Misconceptions about California call box programs
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).
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.
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
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.
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-1990s. 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 callers 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
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 its 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 so that an individual in a wheelchair can make a parallel reach of no more than 24 to the handset. To comply with ADAAG requirements, the call box is lowered on the pole so that the handset (the highest operable part) is set at no more than at 44 46 high.
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 above the ground on poles along roadways, 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 approve an exception on this point for call box signs.
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 Boards 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 TTYs 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.
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