|
Is it Safe? The Ventura County Callbox Accessibility Program
Click HERE for graphic. Introduction In California over the last half-dozen years, the roadside callbox has become a significant component of the highway network in major metropolitan areas. There are today over 14,000 callboxes across the state providing motorist assistance to the millions of California residents and visitors travelling within the state. Each day, over 100,000 motorists use the callboxes to obtain roadside services, such as towing, and to report accidents or unsafe conditions. This callbox "boom" began with the passage of state legislation in 1986 which authorized counties to levy a $1 fee on vehicles registered within their borders to support the installation, operation and maintenance of a roadside callbox system. Since that time, the number of callboxes in operation throughout the state has climbed steadily. However recent federal actions may "stem the tide" and significantly reduce the number of new callbox installations in California. Specifically, recently promulgated rules under the Americans with Disabilities Act Architectural Guidelines (ADAAG) require full physical site access at all new callboxes. While California's callbox agencies have supported site access within the confines of state highway design standards, encouraging or requiring mobility-impaired drivers to get out of their cars to use a callbox was not considered a good solution to the problem. In fact, a number of mobility impaired Ventura County residents pointed out that when their car was on the side of the highway, they simply were unable to get out of their car. Recognizing these problems, The Ventura County Service Authority for Freeway Emergencies (SAFE) set about trying to understand the basic issue and then develop a program which meaningfully improved callbox accessibility in a manner acceptable to the community. This paper discusses the Ventura County program and the "regulatory" environment in which it has been implemented. More specifically, the paper contains: 1) A brief overview of the recently issued callbox accessibility requirements; 2) a discussion of California's viewpoint and difficulties with these rules; and 3) Ventura County's program for improving accessibility to the callbox system and its services. While Ventura County, with its 700,000 residents and 550,000 registered vehicles, represents less than three percent of the state's people and cars, it has been "aggressive" in the area of callbox accessibility. For this reason, the programs described here may be the forerunners of future statewide efforts. Callbox Accessibility Requirements California's many SAFE programs have been grappling with the issue of callbox accessiblity repeatedly since the mid-1980's. In 1988, the Office of the State Architect declared that there iwere no State regulations governing access to callbox systems by disabled persons, with the exception of the height of the callbox unit and the length of the handset cord. Also, state callbox design standards require a level surface and installation of a concrete pad of a size sufficient to safely accomodate a wheelchair. Although it may seem narrow-minded or parochial, the SAFE's had in essence focused only on making their callbox sites accessible. It was universally accepted in California that the SAFE's did not have the responsiblity, authority, or financial wherewithal to address accessibility along the highway system. This viewpoint has, however, been under challenge since the passage of Title II of the Americans with Disabilities Act (ADA) of 1990. ADA extended protection of the civil rights of disabled persons to include state and local government agencies, and requires that existing programs and services be readily accessible and usable by individuals with disabilities. The ADA did not specifically address callbox accessibility and for the next two years a rather unfocused debate took place among the SAFE's, the State Department of Transportation (Catrans) and advocates for the rights of disabled individuals. Then, in December, 1992, the Architectural and Transportation Barriers Compliance Board (Access Board) released a Notice of Proposed Rulemaking (NPRM) that for the first time specifically addressed access to roadside callbox systems by physically challenged drivers. The 1992 NPRM identified the following specific requirements for callbox accessiblity: . Controls and operating mechanisms shall be operable with one hand and shall not require tight grasping, pinching or twisting of the wrist; . The highest operable part of the callbox shall not exceed 54 inches above the finished grade; . The force required to operate the callbox shall not exceed 5 pounds of force; . Both visual and auditory acknowledgment of call receipt (answering of the call) are required,while voice communications is not; . A firm, stable, slip-resistant surface area not less than 30"x48" shall be provided; and . The level callbox site is prohibited from being separated from the roadway by a ditch, gutter, curb or other barrier (including dirt, rocks, etc.). In the summer of 1994, the Access Board issued its Interim Final Rule (IFR) which contained the above elements with the lone substantive change of establishing a "highest operable part" maximum height of 48". The California Response While the issuance of the NPRM in late 1992 was intended to "provide guidance to the Department of Justice in establishing new standards," it also accomplished a second objective: it united California's disparate callbox agencies on the issue. This second accomplishment is not to be taken lightly. For several years the state's callbox agencies had discussed and debated callbox accessiblity and had failed to reach agreement on a state- wide approach. This disagreement existed not only among the SAFE's but also with Caltrans, the agency responsible for the state highway system, and the California Highway Patrol (CHP), the agency responsible for answering and often responding to callbox calls. This new unity in California callbox circles was based almost entirely upon one specific requirement in the NPRM: the requirement of an "unobstructed" pathway between the roadway shoulder and the callbox site. The California callbox and site design standard was developed with accessibility in mind and it substantially met most all of the other requirements. (The decision to change the operable height requirement to 48" in the IFR may create problems for the callboxes, which are set at the standard 54". If the 48" requirements is maintained, a redesign of the California callbox system may be required.) California's opposition to the requirement for a continuous pathway from shoulder to the callbox site was based upon concerns related to basic safety and functionality as well as highway design considerations particular to California. The basib concerns could be summarized as follows: . Standard freeway and conventional highway shoulders do not meet ADA Accessiblity Guidelines regarding slopes, ramps or passenger loading zones; . Freeway shoulder standards include berms and curbs for drainage and erosion control; . The SAFE's have no authority over the design and construction of roadway shoulders, nor do they have the financial capability to construct or maintain modified shoulders; and . There is along most highway a level of roadway debris (rocks, dirt, glass, etc.) which makes wheelchair operation particularly challenging if not impossible. These concerns are directed toward the roadway environment and not the callbox sites themselves. They are based on the fundamental notion that a freeway or highway shoulder is not a safe place to be, and it is an even less safe environment for a mobility-impaired individual. Interestingly, accessiblity "advocates" rarely argue that this is an untrue assessment. What they argue is that this fact is irrelevant. For most of the SAFEs in the state, as well as Caltrans and the CHP, these concerns were based on engineering practices, observations of pedestrian activities on highways, and the financial realities associated with highway construction. Caltrans' standards call for an eight-foot shoulder on most state highways. This does not provide sufficient width for a wheelchair user to safelypark a van or automobile and get out of the vehicle (tje standard width for safe operation of a wheelchair lift, for exmple, is thirteen feet). The problem is compounded by the fact that in many urban areas in the state, the standard eight-foot shoulder has been narrowed to make room for more travel lanes on congested freeways. In addition, the standard cross-slope for highway shoulders is five percent, which makes wheelchair maneuverability extremely difficul. This problem is compounded by any significant running slope which may be present. In Ventura County, for example, many lengthy sections of highway have been constructed at grades of three to five percent, with one of our busiest freeway sections at over eight percent. These roadway sections simply cannot be made wheelchair accessible. Finally, California's freeway design standards include berm and/or curbs at the edge of pavement to control drainage and thereby prevent erosion, which is viewed at best as a maintenance problem and at worst as a safety hazard. The SAFE for the San Francisco Bay Area has invested significant time and money in developing a solution to this problem. To date, their design solutions have carried with them a high price tag (in the neighborhood of $1000 per site) and a concern that they may compromise roadway drainage or create a hazard. For this second reason they have yet to receive Caltrans approval. For the Ventura County SAFE, these concerns were reinforced by the opinions of members of an Accessibility Committee which had been formed in mid-1991. The committee, made up almost entirely of mobility and speech and/or hearing-impaired county residents, had been evaluating callbox accessibility for over a year when the NPRM was relased. They had evaluated a number of possible methods for improving access to callbox services. In addition to physical site access, the committee evaluated the use of CB radios, distress flags, cellular phones, telecommunication devices for the deaf (TDD), and custom hand-held remote control units. The preference was for a "solution" that met the needs of both mobility and hearing/speech impaired drivers. However, it became clear that the needs of each group were very different and that any Accessibility Plan would involve two distinct programs. It is most important to mention in the context of this paper, however, that the primary desire of the two groups was the same. Namely, that neither the mobility nor hearing/speech impaired committee members wanted to be outside of their vehicles on the roadway shoulder. This was particularly true for the members with mobility impairments. While they encoraged, if not demanded, the construction of physical site access improvements where feasible, they also without exception stated that they would never leave the relative safety of their vehicle to get to a callbox, even if it was accessible. This viewpoint was shared by a number of individuals and groups in the state and many of them testified accordingly at the regional hearing held to solicit comments on the NPRM. Most importantly for Ventura County, this was the viewpoint expressed at our SAFE hearings, and it formed the basis of our Accessibility Plan. Prior to discussing in detail the Ventura County SAFE's accessibility programs, it is important to note that California's current standard callbox also does not meet the new requirement for a visual as well as auditory call acknowledgement. California's callboxes are essentially telephones which provide full voice communication between the user and the CHP. They do not provide any visual indicators. Unlike the pathway requirement, however, there was general agreement among the SAFEs that this requirement was reasonable attainable. This viewpoint was based on the anticipated "affordability" of the improvement and the fact that it was contained within the callbox itself and not a part of the roadway environment. In fact, callboxes currently being installed in the Sacramento metropolitan area are equipped with a call indicator light. Ventura County's proposed TDD callbox program, and a remote control device being developed in the San Francisco Bay Area, would also meet this requirement. Ventura County's Program As mentioned above, the SAFE's Accessibility Committee wrestled for almost a year with the development of a program to improve callbox accessibility. Ultimately, the recommendation of the committee, which was adopted by the SAFE Board, was to implement a program with two primary components: the distribution of portable cellular telephones and the develoment of a TDD callbox. The former program was implemented in mid-1993 and is on-going while the latter is currently in the field test phase. Each is dicussed in detail below. Portable Phone Program This program, formerly referred to as our "Cellular Telephone Program for the Mobility Impaired," can be described very simply as the distribution of portable cellular telephones to Ventura County drivers who cannot use a roadside callbox due to a mobility impairment. While this described the program well, it also raised a number of questions for the potential user: Where do I get the phone? How much does it cost? Can I use the phone for personal calls? What qualifies as a mobility impairment? All of these questions had to be answered before the program could be initiated. And the SAFE relied on our Accessibility Committee to help provide the answers. First, in keeping with the goal of "equivalent access," it was decided the phones would be provided at no cost to the user. After all, there is no charge to the motorist to use the roadside callbox. In addition, there is no deposit required. This decision was based not only on the desire for equivalent access, but also on the fact it was anticipated that many of those in the program would be on a fixed incomme, and any deposit, no matter how small, could pose a hardship. Selection of the type of phone to be distributed was also an issue to be addressed. The decision was made to use an off-the-shelf portable telephone. This was based on the desire to implement the program as quickly as possible with equipment which has proven its worhtiness and durability. A request for proposal (RFP) was prepared and bids solicited from phone manufacturers and distributions. The Ventura County Accessibility Committee was involved in developing the RFP and phone specifications, focusing primarily on size, weight, power source and ease of use. Three different phone models were tested over a period of several days by each of the committee members so that they could make an imformed recommendation as possible. The recommended unit, manufactured by Motorola, has been purchased over the past year at a cost ranging from $200 to $300 dollars. In California today, all 911 calls made from cellular phones are answered by CHP dispatchers. These same dispatchers are responsible for answering callbox calls. Using the equivalent access principle as a guide, it was decided that the phones distributed through this program would be limited to making 911 calls only. However, the option to subscribe for additional service, fully at the users expense, through the cellular service provider was left open. This was done for two reasons: 1) it did not seem logical to prevent additional services if there was no cost to the SAFE; and 2) it held out to the cellular service provider the potential for additional customers. Mention of the potential market for the service provider raises a very important point: This program could not have been put in place without the assistance and cooperation of Cellular One, our cellular service provider. To their credit, Cellular One recognized the value of the program to the community and public service "mileage" that it could gain them. As a result, they agreed to provide access to 911 calls at no cost. In addition, they have contributed to the cost of printing program information brochures which have been distributed across the county. Cellular One's cooperation has led to a program which, on the operational side, has been relatively simple and inexpensive to operate. Given the limited budget of the SAFE, the Accessibility Committee recommended the program be administered on a "first-come-first- served" basis. (Note: To date all eligible applicants have received a cellular phone.) Along these lines, the committee also recommended structuring the program so that those most in need of the service were eligible to participate. Based on this direction, and on the desire to keep the eligiblity requirements as simple as possible, the following eligibility criteria were adopted: The applicant must: . Have a disability which prohibits them from reaching a roadside callbox. . Be an independent driver. . Be a permanent resident of Ventura County or be visiting for at least six months. The SAFE relies on a combination of in-person interviews, referrals and recommendations from medical care providers and other health care and social service agencies in determining whether an applicant meets the first criteria. Specifically, after completing an application, which includes a referral section, an application is required to attend an in-person interview. The interview allows the certification coordinator to make an initial informal dtermination of the applicant's functional ability to use a roadside callbox. If the coordinator is unable to make a determination at that time, a verification form requesting additional information is sent to the reference listed in the application. An appeals process has also been developed but has as yet not been used. The second criteria is intended to make ineligible those persons who are mobility impaired but do not drive (i.e. those who travel at all times with a driver/attendant). In the event roadside asssistance is required for these individuals, the driver/attendant can access the system via the roadside callbox. Interestingly, this criteria was proposed and supported unanimously by the Accessibility Committee. They recognized not only that funds were limited but also that those funds were derived from a fee paid by drivers, and the callbox system was put in place for the drivers benefit. The third and final criteria is based upon the statutory restiction that SAFE funds be spent only on callbox programs (and a small number of other incident management activities) in the county within which the funds are collected. In other words, Ventura County cannot fund a callbox program in Los Angeles County, and vice-versa. In recognition of the needs of "long-term" visitors to the county, the Accessibility Committee recommended a six-month minimum stay for a visitor to be eligible for the program. To date, no visitors have applied for a cellular phone. The Cellular Telephone Program has been in place for over one year and has proven to be very successful. To date, we have distributed almost 250 phones to Ventura County residents. The program has been very well received, with extensive and positive local as well as national (CNN) and international news coverage. Local client groups and social service organizations have been provided marketing materials and information brochures to make potential participants aware of the program. The program has also proven very easy to administer. The simple eligibility criteria and application process are easily understood by the applicants and as a result much easier to explain and carry out. This is illustrated well by the fact that almost 10% of the applicants have been denied telephones yet there has not been a single appeal. These outreach, application and administrative functions are carried out by the county's ADA Coordinator, whose primary responsibility is certifying persons for ADA transit services. As expected, the telephone program tasks have meshed well with the ADA Coordinator's primary responsibilities. The result is a program which requires little administrative time other than the in-person interview. To further economize on administrative time, eligibility is typically determined at the in-person interview and equipment training is provided at that time to approved applicants. To complete the process, phone recipients are required to sign a simple "contract" which outlines their responsibilities and the SAFE's liability limitations. TDD Callbox Program: As mentioned above, the Ventura County SAFE accessibility program was guided in part by the objective of "equivalent access." The nature of the highway environment (i.e. steep grades, cross-slopes, drainage berms), unfortunately, made attainment of this objective very difficult for mobility-impaired drivers. However, the situation for hearing-impaired drivers was very different and "equivalent access," as a basic objective, seemed attainable. Roadside callboxes in California today are basically telephones which connect the user directly to the CHP. There are no lights, signals or other message systems; in the parlance of the industry, they represent "voice-only" communication. Moreover, this voice communication is also "full duplex," meaning that it is person-to- person with no limitations. This level of communication has been the State standard largely at the insistence of the CHP. The CHP does not wish to dispatch even one of its limited number of field units to a scene unless it has a clear and accurate understanding of the situation. Such an understanding cannot be gained through a "Help" or "Fire" button or a series of simple "yes" or "no" questions. With this level of voice communication, "equivalent access" was interpreted to mean an equal level of non-voice communication, which to date has only been demonstrated through the use of a TDD. The logical recommendation, from our Accessibility Committee's viewpoint, was to install TDDs in the callboxes. When this recommendation was approved by the SAFE Board in Mid-1992, the SAFE began its pioneering effort to develop the first tdd callbox. The challenges faced in the TDD Callbox Program were very different than those in the Cellular Telephone program. The basic question was: "Can we marry two existing technologies to create a new product that is effective and affordable?" To answer this question, the SAFE contracted with U.S. Commlink, an engineering/research & development consultant working in the callbox field. To guide their effort, the SAFE relied on the input and "expertise" of its Accessibility Committee. At the outset, a number of "design requirements" were established to ensure a usable product was developed. Specifically, the TDD unit needed to: . Not interfere with, nor necessitate a redesign of , the current callbox electronics/software; . Be weather-proof and substantially vandal-resistant; . Be compatible with both of the current callbox designs; . Not require any equipment or software change at the CHP dispatch center; . Be readily usable and easily understood by regular TDD users;and . Have reasonable installation and maintenance costs. The Accessibility Committee's participation in the project was directed toward making the unit usable and easily understood. While this appeared at first glance to be a relatively simple task, the comments and concerns of the committee members indicated otherwisa. In the end,U.S. Commlink spent almost one year designing the keyboard panel for the unit. Although during that time a number of committee members complained the process was taking too long, the committee is today unanimous in its support and enthusiasm for the product. The requirements for compatibility with current callbox and CHP electronics and software have also proven easy to attain. Our success in these more technical areas was due largely to the cooperation of the CHP and our callbox manufacturer, Cubic Communications, as well as U.S. Commlink's experience with callbox operations. Related to this, the operation of the TDD callbox is largely consistent with current CHP dispatch procedures and protocol. This is essential if CHP dispatch is to participate in the field test and if CHP management is to support the program in general. From a purely design perspective, the most daunting task was to develop a product which was vandal-resistant. Callbox vandalism is unfortunately a common occurrence in California. It ranges from graffiti to theft to the occasional shotgun blast. While it is impossible to design a TDD which can withstand all vandal "test," it is important that it resist basic vandalism so that operations are fairly continuous and maintenance costs are kept to a minimum. To accomplish this task, very strong and durable materials have been used and basic lab tests indicate they are reasonably effective. Their effectiveness, however, will not be known until the current field test and additional lab tests have been completed. The final design-related requirement is on its face fairly simple: The new TDD unit must fit into the existing callboxes. This requirement is complicated though by the use of two distinct callbox designs (and manufacturers) within the state. Both callbox types, manufactured by Cubic Communications and GTE, function internally much the same; they differ substantially in their housings. The Cubic callbox is oval-shaped and constructed of cast aluminum, while the GTE callbox is square and built of plastic. Until the issuance of the IFR by the Access Board, this design requirement had been addressed by U.S. Commlink. However, the IFR requirement for a 48" inch maximum height for operable parts may make it impossible to fit the TDD unit in the GTE callbox type. While we hope to overcome this hurdle, the lack of a statewide application of the product may doom its installation. Which leads to the final design restriction: Cost. As might be expected, it is not likely to be inexpensive to purchase and install a weather-proof, vandal-resistant and operating TDD in a roadside callbox. Also not surprisingly, the cost is directly related to the number of units to be purchased. Ballpark estimates by the design consultants, while still preliminary, indicate that if Ventura County were to "go it alone," its 500 callbox TDDs would cost roughly $1000 per unit to install. However, if all or a significant number of the other SAFEsjoined in the project, that cost could be cut in half. Obviously, the acceptance of the product by the "market" will have a signicant impact on its future. The size, if not the existence, of that market has also been effected by the IFR and its requirement for visual as well as auditory call acknowledgement. This has been interpreted in California to mean installation of a simple signal light in the callbox is adequate to meet ADA requirements and, more importantly, meet the needs of hearing-impaired drivers. While a signal light is certainly an improvement over the current equipment, it is also just as certainly not "equivalent access" to the system. Fortunately, a majority of SAFEs are postponing a decision until the TDD Callbox field test is complete in early 1995. Hopefully, local pressures for action in combination with the IFR guidance will not force these SAFEs to act before that time. Conclusion The issue of access to the roadway callbox system in California is not prone to an easy solution. In fact, it is clear there is no single answer, and access will be improved through a combination of different programs. In Ventura County, these programs include the distribution of portable cellular telephones to our mobility-impaired drivers, construction of physical site improvements where feasible, and the development of a TDD callbox. While only the former two programs have actually been implemented, we are hopeful in Ventura County that the third element of the program will survive its field test and be embraced by the callbox "marketplace." California's roadside callbox program has long served as a "model" for other states and regions pursuing roadside assistance programs. The TDD callbox will only continue that tradition.
