KEITH E. MATHEWS                       5800 Wabash Avenue
     Administrative Judge                  Baltimore, Maryland  21215

November 25, 2002

The Honorable Martin O'Malley
Mayor of Baltimore
City Hall
100 N. Holliday Street
Baltimore, MD 21202


Dear Mayor O'Malley:

          As you know, the District Court of Maryland for Baltimore City hears citizens' challenges to the City's red light camera enforcement system.  As a result of various complaints from the public, I decided to research the red light camera enforcement system in general and in particular for Baltimore City. 

           I hope you find the enclosed report and recommendations helpful in your continuing effort to protect the public and ensure their confidence in the red light camera enforcement system in Baltimore City.

                                                     Very truly yours,
                                                     Keith E. Mathews
                                                     Administrative Judge


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Red Light Camera Enforcement System in Baltimore City:

For Revenue or Safety?



Keith E. Mathews
Administrative Judge
District Court for Baltimore City [1]


           Red light cameras can work to protect the public.  Unfortunately, the Baltimore City Red Light Camera Enforcement System (RLCES), as it is presently operated, can be seen as a revenue-producing measure instead of safety-oriented when examined against the following:

           1.          Contract between Baltimore City and Affiliated Computer Services, Inc. (ACS)
           2.          Contingency vs. Flat-fee Arrangement
           3.          Unclear Standards for Yellow Light Settings
           4.          Inconsistent and Short Yellow Light Times
           5.          Lack of Delay Times/Grace Period
           6.          Decreased Minimum Threshold Speed Limits
           7.          Lack of Clear Objectives and Measurement Data (especially accident data)
           These concerns greatly reduce the credibility of the RLCES and the City governing its operability.  Therefore, each of these concerns should be addressed in a timely manner to ensure citizen confidence in the use of the RLCES, the City, the police department, and the judicial body that enforces the citations.[2]




           The Insurance institute of Highway Safety estimates that each year more than 800 people die and 200,000 plus are injured in crashes that involve red light running.[3]  It is estimated that at a busy urban intersection, a motorist will run a red light every 20 minutes.  During peak travel times, the number of violations will increase.[4]

                To protect the public from accidents caused by red light running, Baltimore City has contracted with ACS, formerly known as Lockheed Martin IMS (LMIMS), to provide the technology and general operation of the red light camera system in Baltimore City.  Prior to camera placement, the Baltimore City Department of Public Works (DWP) initiates site selection in consultation with the Baltimore City Police Department.  ACS then performs site evaluations and installs the cameras. 

           A camera is first set up at chosen traffic signals.  It is then connected to the traffic signal and trigger sensors called "loops," which are buried in the road at a given intersection.  The system monitors the signal twenty-four hours a day, under all weather conditions.  The first picture is triggered by any vehicle passing over the sensors at both a predetermined minimum speed and a specified time after the light turns red.  A second picture is taken of the vehicle crossing over a second sensor.  Both pictures include the date, time of day, the time elapsed since the light turned red, the length of the yellow light, and the speed of the vehicle.[5]
           When ACS receives the photographs taken from the red-light cameras, it examines the photographs for clear violations.  ACS sends the violations to their New Jersey office to obtain registration information through the various departments of motor vehicles.  The violations are printed and are set aside to be viewed by a Baltimore City Police officer who approves and signs at the ACS facility.[6]  The signed violations are then mailed to the registered owner's residence.  This process takes approximately 14 days. [7]  The cost of a citation for running a red light in Baltimore City is $75.  ACS presently receives 15 to 36 percent, or $11 to $27 of each citation.  The more citations issued at an intersection in Baltimore according to ACS' contract with Baltimore City, the smaller ACS' cut.[8]

           Statistics provided by ACS show that 83,385 citations issued in 2001, generating $6,253,875 in revenue and 92,088 citations issued in 2000, generating $6,906,600 in revenue.  As of this date, Baltimore City has in place 47 operational red light cameras, making it one of the largest programs in the country.  See Attachment 1.



           After a detailed study of the RLCES, the following are recommendations for improving the functioning of the RLCES and increasing positive perceptions of the system in Baltimore City.

1)         Regarding the Partnership between ACS and the City of Baltimore

           One of the largest concerns for the RLCES is the contractual relationship that exists between Baltimore City's Department of Transportation (DOT) and ACS.  When questioned, a representative from ACS stated that Baltimore City is the only jurisdiction in the nation that has this type of relationship.  All other of ACS' contracts are with the police departments of each individual jurisdiction that employs the RLCES.  A glaring problem with the relationship is the amount of money the RLCES generates for the City.  Acting on behalf of Baltimore, the DOT has a political interest as in obtaining greater revenue by issuing more citations or enabling ACS to obtain more citations (i.e. by lowering the yellow light times, having no delay time, etc.).  To have the contract administered by the same department that controls the yellow-light times adds to the perception that the yellow light time is lowered to increase revenue for the City and ACS.  A contract with the police department is perceived as less political, as the police department is more independent and more concerned about safety than revenue.


           It is recommended that the contractual partners of the RLCES should be the Baltimore City Police Department and ACS, and not the Baltimore City Department of Transportation.


2)        Contingency Fee vs. Flat Fee Arrangement

           Critics of the RLCES frequently cite the contingency fee arrangement between the City and ACS.  As it stands, ACS receives $11-$27 per citation that is issued.  The City receives the rest.  Critics argue that, as ACS is a for-profit corporation, it issues more citations in order to generate greater revenue.  The City presently does not pay any out of pocket expenses for the RLCES.  ACS' fee comes out of each citation.  Other jurisdictions that employ the RLCES have sought to portray a fairer image to the community by eliminating the contingency fee arrangement and opting for a flat fee per camera/per month arrangement.  Both Howard County, Maryland and San Diego, California have switched to this system. ACS has encouraged this arrangement with Baltimore City, but it has yet to be adopted.

            It is recommended that the contingency fee arrangement be abolished and that a flat-fee system be adopted.


3)        Unclear Standards for Yellow Light Settings
           There exist several problems with the yellow light intervals at RLCES locations in Baltimore City.  A consistently raised argument in RLCES cases is that the yellow light (or amber) is short or inconsistent.  The DOT furnished the Court with a list of yellow light times at each intersection where the red light cameras are located. See Attachment 2.  When present at a red light camera docket in the District Court of Baltimore City, the ACS representatives testify that a yellow light, as noted on the citation, is set at a certain time and then explain that this time exceeds the federal guidelines of 3 seconds.  However, this statement is misleading in light of the fact that the federal guidelines state that a yellow light should be from 3-6 seconds in length, reserving higher intervals for use on approaches with higher speeds.[9]  In August of 2002, the DOT responded to the Court's May 22 inquiry regarding how yellow light times are determined.  In the letter, the DOT described using the following prescription to determining yellow light times; "if the speed is less than 35 mph the amber time is set to 3 seconds; if it is 35 mph or greater the amber time is set to 4 seconds… in accordance with MUTCD section 4D-10."[10]

           The current formula for determining yellow light times is suspect in light of the time required for cars to safely come to a complete stop.  In response to a citizen's inquiry regarding yellow light times, the State Highway Administration (SHA) articulated proper yellow light times necessary to avoid "dilemma zones" holding that "if the time needed to stop is greater than the yellow time a dilemma zone exists."  See Attachment 3.  The chart provided by SHA describes speeds of 45 mph and above needing more than the current 4 second maximum yellow time used by Baltimore City order to avoid a "dilemma zone." See Attachment 2.

           Similar complaints were echoed in San Diego.  Following the Final Report on the RLCES in San Diego, legislation was passed entitled SB 667, the Peace Bill.  This legislation set yellow light times at all intersections where a RLCES was present, taking into consideration the speed limit on each road preceding the red light.[11]  Prior to this bill, the yellow light intervals suggested by the Traffic Manual of California (CalTrans) were permissive and not mandatory. SB 667 required yellow light change intervals at intersections at which there is an automated enforcement system to be mandatory. For example, the manual recommends that a road with a speed limit of 25 mph should have a 3.1 [[website editor:  3.0]] second yellow light and a road with a 50 mph speed limit should have a yellow light interval of at least 4.8 [[website editor:  4.7]] seconds. Background discussion on the bill states that the DOT of California is responsible for developing specifications for traffic control devices, such as the time intervals for yellow lights.[12]  However, adherence to those standards was not required.

           Complaints by citizens in San Diego in particular suggested that the yellow light intervals at RLCES locations were too short, thus creating a red light speed trap.  Arguing in support of the Peace Bill, the California State Automobile Association (CSAA) stated that "standardizing yellow light intervals will assure that the yellow light time will be set for safety rather than revenue-generating purposes."[13]

            It is recommended that the Baltimore City DOT set forth published standards for determining yellow light intervals. In determining yellow light intervals, the DOT must take into account the speed limit and gradient of the road, along with the appropriate braking distance needed for a driver to safely come to a stop. It is further recommended that yellow light intervals set forth by the DOT with the above-listed considerations be mandatory for those intersections which employ RLCES. Standardization will ensure residents of Baltimore City that the yellow light time is set for safety rather than revenue-generating purposes.


4)         Inconsistent Yellow Light Times

           There are frequent reports that yellow light times are inconsistent.  There are reports that yellow light time variations occur on the same light. A rough analysis of several citations issued in Baltimore City documented this phenomenon.  A light at the intersection of Falls Road and Northern Parkway has a City listed standard of 3.5 seconds.  In four citations, the length of the yellow light on the citation was recorded at 3.2, 2.9, 3.2 and 3.0 seconds.  When asked about this at a meeting, both DOT and ACS stated that the problem had been noted and was "being looked into."  In response to the Court's written inquiry, the DOT described inconsistent yellow light times as being caused by "fluctuations in the voltage supply that cause minor variances in the timing circuits within the devices."[14]  However, the DOT's voltage explanation accounts for only a 0.1 second variance and not the 0.3 variance described in the Falls Road and Northern Parkway intersection example described above.[15]

           There is also a failure of the yellow light timings to adhere to the city's own set standards.  The DOT sent the court a list of its yellow light settings at the intersections where there are RLCES.  See Attachment 1.  A rough analysis of approximately 181 citations yielded the following statistic.  Approximately 39% of the citations had inconsistent yellow lights or a yellow light setting inconsistent with the city standard.  Most alarming are instances when the inconsistent yellow light times have been less than the 3 second federal minimum.  Nearly 10% of the 181 citations surveyed had a yellow light prior to the red light of 2.9 seconds. This is inconsistent with Federal standards and presents a grave danger to Baltimore City drivers.

            It is highly recommended that the standardization of yellow lights be enforced.  A grave danger exists when yellow lights are inconsistent and/or fall short of the minimum federal guidelines.

5)         Allowance of Delay Time/Grace Period

           A delay time is the amount of time that exists from the time the light turns red until the point where a red light citation will issue.  This time represents a "grace period" for motorists entering the intersection against a red traffic signal indication.[16]  As discussed above, a red light citation will issue once a car has passed over the first loop at a predetermined speed after a set time that the light has been red.  One representative from ACS stated that there is no delay time in Baltimore City.  Another ACS representative stated that there is a delay time of .1 second in Baltimore City.

           The following jurisdictions have delay times that very from .3 to .5 seconds, as illustrated in the following table:

Camera United Delay Time Settings
For Selected Photo Enforcement Programs [17]



Delay time (Seconds)



Howard County


New York City




San Francisco


           Although a person who runs a red light at .5 seconds does commit a violation, it is doubtful that a police officer using only the naked eye could discern that a violation has taken place in half a second or less. Therefore, allowing advanced technology to issue citations when a police officer would likely not do the same under the same circumstances, grants greater police power to the RLCES.  A grace period would give the public confidence in the program but would reduce revenue. 

           In a rough analysis of 181 citations issued by the Baltimore City RLCES, approximately 30% were issued with an infraction time of .3 seconds or less.  This is a large number, especially considering the fact that other jurisdictions employing RLCES have a minimum of .3 seconds delay time during which a citation will not issue.

            It is recommended that a uniform delay time be established in Baltimore City to instill confidence in the program. This delay time need not be made public information, but should be common knowledge of ACS, the police officers signing off on the tickets, and the judiciary that enforces the RLCES citations. 

6)        Maximum Speed Threshold

           The minimum speed threshold serves to avoid the inclusion of stationary or near stationary vehicles in the intersection that are stuck when the light turns red.[18]  In the report issued in San Diego, it was urged that the same minimum speed setting of between 12-19 mph for all intersections using the red light camera system is appropriate.  Further, the report stated that "the impact of using a lower minimum speed… is that more violators will be cited than if a higher minimum speed was used."[19] 

           When seeking information for the locations of the Baltimore City RLCES, ACS sent to the court a list of all RLCES as of March 27, 2002. See Attachment 1.  When speaking to ACS to confirm receipt of the faxed information, the court's law clerk inquired as to what the minimum speed column on the table meant and was told (as she wrote on the table) that the speed limit listed was the minimum speed threshold required for activation of the cameras.

           When being briefed on the RLCES, the Court was advised that the minimum speed threshold was to be 12 to 15 mph.  Therefore it was very surprising to see a number of the RLCES' minimum speed thresholds were set to 0 mph.  Also, two of the intersections have a minimum speed threshold of 25 or 35 mph.  When a follow-up question was posed to an ACS representative, the Court was told that the minimum speed threshold was 12 mph at the lowest.  When it was pointed out that the table illustrated over 16 intersections that had a threshold of 0 mph, the ACS representative requested where the Court had obtained this information and asked that it be faxed to ACS.  The Court then informed ACS that the information had been received from ACS.

           Although 16 intersections have a minimum speed threshold of less than 12 mph, none of the citations surveyed included a citation for a vehicle driving less than 12 mph.
            It is recommended that the city study the minimum speed threshold issue.

7)        Need for Clearly Stated Objectives and Measurement Data

           There are no clearly stated objectives as to the goal and purpose behind the RLCES in Baltimore.  As the standard operating procedure for any new project, especially in a program designed to increase citizen safety, clearly stated objectives and measurement standards must be in place to ensure that the program is operating as planned.  Most importantly, the increase and/or decrease in intersectional accidents at RLCES locations should be determined, as well as the increase or decrease in rear-end collisions at these intersections.

           A defense often cited in court by someone who has received a red light citation is that he/she ran the light in order to prevent being hit from behind.  Data from the Final Report on the City of San Diego Photo Enforcement System concluded that although red light running did decrease as did intersectional accidents, those decrease were outweighed by the 3% increase in rear end collisions occurring at red light camera intersections.[20]

           The DOT's response to the Court's written inquiry regarding any increase or decrease in collisions where red light cameras are in place was vague and incomplete.  Data for only 14 of the 47 intersections was available.  The 14 intersections were not named.  In addition, the limited data provided was presented according to the group of 14 intersections as a whole and contrasted with all signalized intersections in terms of percentage increase and decrease of collisions.

            Statistics should be collected, fully explained, and published as to the amount of rear-end collisions occurring at RLCES in order for the public and the City to determine if the benefits of the RLCES outweigh the risks of increased accidents.


           In order to increase citizen confidence and ensure that the RLCES is proven effective, clear cut objectives and measurement standards need to be implemented.  If the primary objective is to increase driver's safety, that objective should so be stated.  The objective should also be measurable.

            The following should be determined:

1)        An analysis of the existing program should be performed by an objective party.
2)        There is a need for clear cut objectives and continuing reassessment to see if objectives are being met regarding the implementation and enforcement of the RLCES.

3)        Accident data for all types of accidents at intersections where red light cameras are in place should be analyzed to conclude the number of collisions attributable to red light running, the reduction (if any) in the number of collisions, and also the number of rear-end collisions occurring at red light camera locations.

4)        How RLCES locations are selected should also be public knowledge.



           The central purpose of the Red Light Camera Enforcement System should be to ensure public safety.  If citizens feel protected from red light running and believe the RLCES is operating with integrity, they will support the RLCES. In order to achieve its purpose, the RLCES must therefore be operated in a consistent and fair manner.


[1]  Research and statistics provided by Melissa R. Alonzo, Esquire, Law Clerk.

[2]  Although a meeting has been held where representatives from the Department of Transportation (DOT) and ACS were present and subsequently, a tour of the ACS facility was held with a representative from DOT, obtaining follow-up information regarding the RLCES has proved difficult at best.  Therefore, most of the information on which this report is based came from outside sources, specifically a Final Report on the City of San Diego Photo Enforcement System (hereinafter "Final Report") that was prepared by an independent auditor, PB Farradyne.  This report has been referred to often in explaining the functioning of the RLCES, in noting problems with the operation of the Baltimore City RLCES, and in making recommendations for the fair operation of the Baltimore City RLCES.  The entire report can be found at http://www.sandiego.gov/police/newsflash/photoenforce.shtml .

[3]   See Insurance Institute for Highway Safety, "Q&A: Red Light Cameras as of November 2001." http://www.hwysafety.org/safety_facts/qanda/rlc.htm (last visited on July 18, 2002).

[4]   See id.

[5]   See Reni Gertner, "Cities Are Using ‘Red Light Cameras' to Catch Drivers." 2001 LWUSA 685 http://lawyersweeklyusa.com/feature. cfm (last visited Sept. 7, 2001) (for general explanation of how red light cameras operate). [[As of June 3, 2003, available at:   http://www.nossaman.com/db30/cgi-bin/pubs/Steve%20Roberts%20Lawyers%20Weekly.pdf ]]

[6]   A city police officer is paid two hours overtime to go to the ACS facility and approve and digest the violations presented for that day.

[7]   See Julie Bykowics.  "Police, workers say facility in Howard is Just the Ticket; Citations Processed for Red-Light Violations."  Baltimore Sun. Local Pg. 1B (Sept. 21, 2001).

[8]   See Julie Bykowicz.  "Red Light Cameras are Defended; Officials Say Programs in Area are Unlike One Ruled Illegal in California.  Officials Defend Red-Light Cameras."  Baltimore Sun, Local Pg. 1B (Sept. 6, 2001).

[9]   U.S. Department of Transportation, Federal Highway Administration.  Manual on Uniform Traffic Control Devices, Millennium Edition at 4D-15 (MUCTD 2000) (revised Dec. 28, 2001).
http://mutcd.fhwa.dot.gov/kno-millennium_12.28.01.htm . The Manual on Uniform Traffic Control Devices (MUTCD) is approved by the Federal Highway Administrator as the National Standard.

[10]   Letter from Alfred H. Foxx to The Honorable Keith E. Mathews of August 16, 2002.

[11]   See 2001 Cal Stat. 496.

[12]   See Automated Enforcement System, Hearing on SB 667 Before the Senate Rules Comm. On Unfinished Bus., Reg. Session 2001-02 (Sept. 4, 2001).

[13]   See id.

[14]   Letter from Alfred H. Foxx to The Honorable Keith E. Mathews of August 16, 2002.

[15]   See id.

[16]   See Final Report at 51.  In San Diego, the grace periods applied to the 19 photo-enforced intersections varied according to the intersection.  The report suggested that a uniform grace period be adopted.

[17]   See id. at 51.

[18]   See id. at 52.

[19]   See id.

[20]   See Final Report at 7-11.  For comparison purposes, the Final Report compared accidents which occurred in the first 3 months of the cameras operations as the before group.



Attachment 1 - "Amber Time at Red Light Camera Intersections" - An undated list of 47 Baltimore camera installations and the amber times programmed into the signal controllers. Twenty-seven of the 47 had amber times of 3.0 seconds, 4 were set at 3.5, and 16 were set at 4.0. Attachment 2 - "Location List" -

Attachment 3 (two Maryland State Highway Administration slides): ]]

Slide 7

Slide 8: Dilemma Zone

Document transcribed by www.highwayrobbery.net

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