March 25, 1998

Allen Muse
Emergency Communications Center Manager
Metropolitan Police Department 200 James Robertson Parkway
Nashville, Tennessee 37201

In Re: 911 Compliance Review

Dear Mr. Muse:

This letter is in regard to our compliance review of the Metro Emergency Communications Center [MECC] under Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. ァァ 12131-12134. Title II prohibits discrimination against qualified individuals with disabilities on the basis of disability in the services, programs, or activities of State and local governments.
MECC, as the creation of the Metropolitan government of Nashville and Davidson County, is an instrumentality of a local government and thus a public entity subject to the requirements of Title II and its implementing regulation. 28 C.F.R. ァ 35.104. Section 35.162 of the regulation requires that telephone emergency services provide direct access to individuals who use a TDD for telephone communications.
As you will recall, on August 1, 1997, my office conducted a site visit to your facility, and met with you and Joe Foster, Staff Director of the Emergency Communications District, at the MECC facility. MECC was found to be a primary dispatch center, answering all 911 calls originating in Davidson County, as well as calls to a seven-digit number advertised locally as an alternate to 911 for non-emergency calls for public safety services.
The center has ten call-taking consoles, no fewer than four of which are staffed at one time. All consoles are equipped with TDD's. A stand-alone Zetron System 3030F is currently used, but it is interfaced with the center's Computer Aided Dispatch [CAD] system. The interface allows the operators to use the same screen and keyboard for TDD calls that they presently use for voice calls when entering call information into the system. Thus, the operator can move from voice to TDD mode by using keystrokes on the keyboard. The operator can also call back using a TDD. A second, stand-alone unit is also used, an Ultra Tec Super Print. It is an acoustically coupled unit, and serves as a back-up. The back-up units are on a shelf underneath the calltaker's work station, and are readily available.
The computer system identifies TDD calls as they are received and prints a message on all console screens that a TDD call has come in. All operators have received comprehensive training on the TDD and know how to handle such a call. There is no time delay in switching from voice to TDD and back again. You reported that in the fall of 1995, there were two TDD calls that were not successfully handled, and the center recognized that they were not treating silent calls as potential TDD calls. You reported that you have since taken steps to remedy this, and with one touch of the keyboard, the center can identify whether a silent call is a TDD user. Standard Operating Procedures [SOP's] are in place which treat the silent call as a potential TDD call.
The system has automatic call distribution, but a TDD message on the recorded announcement has not been possible to date because the system needs an expanded memory to enable a TDD recorded message. You report that you are working on this problem, and persons with hearing disabilities have been consulted. The non-emergency calls also can be handled by TDD's. The same Automatic Number Identification/Automatic Location Identification [ANI/ALI] service is provided to all callers, including TDD users.
Regular maintenance checks are performed on all the center's equipment, including the TDD system. Test TDD calls are regularly made. The center keeps apprised of new technology, including TDD technology, and there is currently an advertisement of the center's TDD capability in the phone book, with plans to make that advertisement more prominent.
Because of the foregoing, we have no serious concerns regarding the level of access that the 911 system has provided for individuals who use TDD's. Thank you for your cooperation and assistance in this matter. If you have any further questions regarding this matter, do not hesitate to call me at (615) 736-5151.

Sincerely,



JOHN M. ROBERTS
UNITED STATES ATTORNEY
MIDDLE DISTRICT OF TENNESSEE


______________________________      Date: ____________________
By: MICHAEL L. RODEN
Assistant U.S. Attorney
(615) 736-5151




cc:   Ryan E. Warren
      Disability Rights Section
      Civil Rights Division
      U.S. Department of Justice
      P.O. Box 66738
      Washington, D.C. 20035-6738

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Updated August 6, 2015

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