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Dear Members of the Board:

It is with pleasure and with great concern for the welfare and safety of the traveling public that Signal Communications Corporation (SigCom) of Woburn, Mass., offers these written Comments. We do so in support of the ADA Accessibility Guidelines' proposed Exception for emergency roadside call boxes -- which reads as follows under Section 1110.2 of the June 16, 2002 Draft Guidelines for Accessible Public Rights-of-Way:

"EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbs. (53.4 N) maximum."

In support of this proposed Exception, we set forth both the historical background out of which this issue has arisen and the compelling rationale for this result in the best interests of the traveling public.

1. User-powered emergency call boxes have been in use on U.S. highways for over 30 years -- where electricity is not available, where state and local transportation authorities have determined that solar and/or battery-powered devices present prohibitive maintenance and reliability problems and where, therefore, ADA disallowance of such devices would almost always result in no highway emergency call boxes at all.

2. In recent years, Signal Communications Corporation (SigCom) of Woburn, MA (a high-tech small business with about 40 employees) has emerged as the leading manufacturer of such devices and currently has over 10,000 call boxes in operation in 26 states -- used by more than 50,000 distressed motorists per year.

3. The SigCom device employs a highly reliable, environmentally safe mechanical power supply (batteryless and wireless). This mechanical power supply derives power entirely from the 90-degree downward pull of an easily accessible handle. The electromechanical power is sufficient to transmit and receive data radio signals between the call box and either the highway patrol or other road rescue personnel -- as selected by the motorist from one of four simple options.

4. "Accessibility" first became an issue in 1985, when the State of Delaware was called upon to evaluate both accessibility and usability of SigCom devices installed along I-95, I-295 and I-495. These devices, which featured a pull force of about 18 pounds, were independently tested by DuPont Laboratories, which included a variety of disabled subjects. The conclusion was that they required only minor modifications (installation height, visual call acknowledgment and color contrast for instructions) to be deemed acceptable.

5. In April of 1993, SigCom first approached the ATBCB for the purpose of clarifying and formalizing this de facto exception/variation to the pull force limitation of only 5 pounds -- a standard initially used for door handles and other devices inside of and attached to buildings.

6. At the recommendation and guidance of a very constructive and competent ATBCB staff, SigCom undertook a 2-year, $200,000 major re-design of its product and succeeded in reducing the necessary pull force by 35%, from 18 to approximately 12 pounds. The details of this remarkable achievement are available in technical documents which will be provided on request.

In total context, SigCom's highly-successful effort to reduce the requisite pull force was willingly undertaken despite the fact that in over 30 years of widespread use there has not been a single incident alleging user inability to operate the device due to its "pull force" requirement.

SigCom respectfully urges, therefore, that the ADA Board's final decision take the following factors fully into account:

a) the fact that these devices are "emergency-use" rather than repetitive-use;

b) the fact that during some 30 years of widespread usage there was no record of public complaints about even the 18-pound device;

c) the fact that the Delaware tests found even these units to be quite acceptable for use by the disabled;

d) the fact that the new 12-pound device has been tested (and applauded!) by ATBCB staff; and

In conclusion: For lack of such user-powered devices on remote stretches of highway, hundreds of thousands of distressed motorists (all of them temporarily "disabled" and many of them in physical danger) will have no access to emergency roadside call boxes at all.

Respectfully submitted, Robert E. Lapham, Senior Vice-President and General Manager, Signal Communications Corporation