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<DIV>Braille
Monitor
February 2016</DIV>
<DIV>WHAT PRICE ACCREDITATION</DIV>
<DIV>A Report to National Federation of the Blind Members on COMSTAC and NAC
</DIV>
<DIV>by Kenneth Jernigan, President</DIV>
<DIV>National Federation of the Blind</DIV>
<DIV>From the Editor: In the early 1960s the National Accreditation Council for
Agencies Serving the Blind and Visually Handicapped was formed, its major
purpose being to thwart the legitimate concerns of consumers by waving the
banner of accreditation in defense of agencies providing poor service to the
blind. The battles between NAC and the Federation are legendary, but to many new
Federationists, the reason for NAC’s creation and why we fought its attempts to
thwart the will of the organized blind are the stuff of myth and history,
lacking any reality or the need for action today. The assumption has been that
NAC is dead, and the threat is gone. Would that it were so, but it is not. The
state agency for the blind in Florida requires that any agency for the blind
there be accredited by NAC in order to use state money to provide services to
blind Floridians. The consortium that binds together small service providers for
the blind in the state of Pennsylvania also strongly encourages NAC
accreditation. NAC is actively encouraging guide dog training schools to
affiliate with it, and one prominent school has unfortunately lent its name and
quality services to an accrediting body which is widely frowned upon by involved
and informed blind people. </DIV>
<DIV>It seems time that we reeducate ourselves about NAC and prepare once again
to demand that any accreditation be meaningful and that it involve the voice of
the organized blind. Following is a speech delivered by Dr. Kenneth Jernigan in
1971 when he was the president of the National Federation of the Blind and a
member of the NAC board. This speech has appeared in the pages of the Braille
Monitor at least one other time, that being in 1991, and here is the way Dr.
Jernigan introduced it when he was serving as the editor of this
publication.</DIV>
<DIV>Kenneth Jernigan’s Headnote: I delivered this address at the 1971
convention of the National Federation of the Blind in Houston. NAC's president
and executive director had come to discuss what NAC was doing and why. My
remarks were meant to set the tone for the debate. In the context of NAC's
current maneuvering I think this 1971 analysis is still pertinent. Here it
is:</DIV>
<DIV>When the Commission on Standards and Accreditation on Services for the
Blind (COMSTAC) and its successor organization, the National Accreditation
Council for Agencies Serving the Blind and Visually Impaired (NAC), came into
being during the 1960s, the leaders of the organized blind movement sounded the
alarm. It was pointed out that the American Association of Workers for the Blind
had unsuccessfully tried, during the 1950s, to gain control of the field of work
for the blind by instituting what it called a "seal of good practices." Of the
several hundred agencies and organizations in this country doing work with the
blind only twenty or thirty ever applied for and received this "seal." Several
of those which did were not regarded by the blind as either very effective or
very progressive. As the decade of the '60s approached, the proponents of rigid
agency control apparently decided to change tactics. The American Foundation for
the Blind and certain other leading agency officials adopted the idea of
establishing a so-called "independent" accrediting system for all groups doing
work with the blind. Although individual blind persons who were agency officials
were involved in the establishment and development of COMSTAC, the blind as a
group were not consulted—that is, the representative organizations of the blind
were not given a voice, except occasionally as a matter of tokenism. Thus, the
consumers of the services were not heard in any meaningful way, and they had no
part in developing or promulgating the standards to govern the agencies
established to give them assistance.</DIV>
<DIV>Profiting by the earlier failure of the AAWB [American Association of
Workers for the Blind] "seal of good practices" experiment, the authors of
COMSTAC built more carefully. The American Foundation for the Blind appointed an
"independent" commission—the Commission on Standards and Accreditation for
Services for the Blind (COMSTAC). The full-time staff consultant for COMSTAC was
a staff member of the AFB, on loan to the group, purely as a means of
demonstrating the Foundation's concern with the improvement of services for the
blind. To add respectability, people of prestige outside of the field of work
with the blind were placed on the commission—public officials, business
executives, the dean of the Temple Law School, etc. These were people of good
will and integrity, but they were not knowledgeable concerning the problems of
blindness. Obviously they took their tone and orientation from the Foundation
appointees on COMSTAC. All of these appointees, it must be borne in mind, were
high-ranking officials doing work with the blind. Not one of them represented
the blind themselves. Not one of them came from a membership organization of
blind persons.</DIV>
<DIV>As its work developed, COMSTAC divided into subcommittees, involving
hundreds of people throughout the country, since the subcommittees further
subdivided into smaller groups. Again, the pattern was followed. The
subcommittees, or the subcommittees of the subcommittees, had, in every
instance, at least one of the COMSTAC agency officials as a member, plus people
of prestige and ordinary rank and file agency workers or board members. In fact,
at the sub-subcommittee level a few members of the organized blind movement were
even added.</DIV>
<DIV>The American Foundation for the Blind and COMSTAC were later to proclaim
with pride that they had sought and achieved a broad consensus throughout the
field of work with the blind. However, the method of arriving at that consensus
was, to say the least, novel. At Denver in the summer of 1965, for instance, the
AAWB convention was largely taken up with a discussion of the COMSTAC
standards—to gather opinions and achieve consensus, it was said. Only the
discussion leaders had copies of the standards (there had been a delay in
mimeographing), and any touchy point which was raised was answered either by the
statement that it was covered somewhere else in the COMSTAC standards or that
another group was discussing that matter and it was not properly the concern of
the group in which it had been raised.</DIV>
<DIV>Home teachers from throughout the country were present and were considering
the standards affecting their specialty. The overwhelming majority apparently
disagreed with a particular item in the COMSTAC document and suggested that a
vote be taken to determine the sentiments of the group. They were informed by
the discussion leader that a vote certainly would not be taken but that their
views would be reported to COMSTAC, which had the sole responsibility for
deciding such matters.</DIV>
<DIV>Throughout the summer and fall of 1965 promises were repeatedly made that
copies of the proposed COMSTAC standards would be made available. They were
forthcoming, hundreds of pages of them—three days prior to the final conference
in New York City, which brought together hundreds of agency representatives for
the announced purpose of arriving at a final consensus. Dr. Jacobus tenBroek and
I attended that conference. Again, the democracy and fair play with which it was
conducted were novel. One had to indicate in writing ahead of time which
particular group discussion he would like to attend. There was no assurance that
his choice would be honored. He might be assigned to another group. He could not
move from group to group at all. If he had not received a special invitation, he
could not attend the meetings. COMSTAC appointees were stationed at the door to
check credentials, and I personally witnessed the turning away of one agency
director who had been critical of COMSTAC.</DIV>
<DIV>It is no wonder that the blind people of the country felt apprehensive.
What type of standards were likely to emerge from a commission so appointed and
so conducted? Not only the blind but also many of the agencies expressed
concern. Many felt that the AFB and federal rehabilitation officials
(unwittingly aided by people of prestige in the broader community) would impose
a system of rigid controls—which would stifle initiative, foster domination, and
take the emphasis off of real service and place it on bureaucracy, red tape, and
professional jargon. It was further felt that what purported to begin as a
voluntary system would (once firmly established) become mandatory. The AFB and
other proponents of COMSTAC and its successor organization, NAC, vigorously
denied these assertions. COMSTAC and NAC were to be truly independent. Their
very watchword was to be objectivity. They were to be the means of improving
services to blind people throughout the country and the vehicle for progressive
thought and constructive change.</DIV>
<DIV>Readers of the Braille Monitor will remember that from 1965 through 1968 a
detailed analysis was made of the COMSTAC and NAC reports and activities. The
fact that the Federation has not called attention in recent months to COMSTAC
and NAC should not lead the blind to believe that the threat has passed or the
situation improved. Quite the contrary is the case.</DIV>
<DIV>The question of NAC's independence, for example, is no longer a matter for
serious debate. The Scriptures tell us that "where a man's treasure is, there
will his heart be also." In an official NAC document entitled "Budget
Comparison—1968 and 1969," dated April 15, 1968, the following items
appear.</DIV>
<DIV>"Total approved budget calendar year 1968, $154,034; total projected
calendar year 1969, $154,000. Estimated income 1968: grant from American
Foundation for the Blind $70,000; grant from Department of Health, Education,
and Welfare $75,000. Estimated income 1969: grant from American Foundation for
the Blind $70,000; grant from Department of Health, Education, and Welfare
$70,000."</DIV>
<DIV>Today (in 1971) the overwhelming majority of NAC's funds still come from
HEW and the American Foundation for the Blind. Many of the NAC meetings are held
at the AFB building in New York, and the executive director of NAC is a former
Foundation staff member, the same one who was on "loan" to COMSTAC. When the
first annual NAC awards were given, in 1970, it may be of significance that two
recipients were named: Mr. Jansen Noyes, President of the Board of Directors of
the American Foundation for the Blind; and Miss Mary Switzer, the long-time head
of rehabilitation in the federal Department of Health, Education, and Welfare.
Even more to the point may be Miss Switzer's comments upon that occasion as
reported in the NAC minutes of April 24, 1970: "She predicted that difficult
times might lie ahead if agencies accept the idea of standards but do nothing
about them. The expending or withholding of public money can provide the
incentive that is needed."</DIV>
<DIV>Thus spoke Miss Switzer, confirming what Federation leaders had predicted
and COMSTAC spokesmen had denied a decade ago. The full meaning of Miss
Switzer's statement was spelled out by Alexander Handel, Executive Director of
NAC, as reported in the NAC minutes of April 25, 1970: "Mr. Handel reported a
new and important step in encouraging accreditation. The Council of State
Administrators has passed a resolution that by July 1, 1974, state
rehabilitation agencies will require that agencies from which they purchase
services be accredited." The use of the word "encouraging" in this context is
almost reminiscent of George Orwell's double-think and new-speak of 1984—only
thirteen years away, at that. Perhaps sooner. The "encouraging" of agencies to
seek accreditation from NAC will probably be called by some by the ugly name of
blackmail. The pressure for conformity and the concentration of power could well
be the most serious threat to good programs for the blind in the decade
ahead.</DIV>
<DIV>Federationists who attended the 1966 Louisville convention will remember
that a report on COMSTAC and NAC was given at that time. I had been officially
asked to serve on the NAC board. The offer was, of course, tokenism of the most
blatant sort; and the question was whether to accept, leaving the Federation
open to the charge of approving NAC actions, or to reject, exposing us to the
charge of non-cooperation and leaving us with no means of observing and getting
information. Federationists will remember that it was decided that I should
accept the invitation. Thus, I have been a member of the NAC board since its
inception. In the spring of 1970 I was elected to another three-year term. There
are more than thirty NAC board members, of whom I am one.</DIV>
<DIV>While expressing my minority views, I have tried to be personally congenial
and friendly with the NAC board members. Nevertheless, tokenism remains
tokenism. The other members of the board not only seemed unconcerned with but
unaware of the non-representative character of NAC. It is as if General Motors,
Chrysler, Ford, and American Motors should set up a council and put six or seven
officials from each of their companies on its board and then ask the UAW to
contribute a single representative. What would the unions do in such a
situation? What would racial minorities do if their representative organizations
were offered such tokenism in the establishment and promulgation of standards
affecting their lives? I think we know what they would do. They would take both
political and court action, and they would instigate mass demonstrations.
Perhaps the blind should take a leaf from the same book. We cannot and should
not exhibit endless patience. We cannot and should not forever tolerate the
intolerable. I continue to sit on the NAC board, but I often wonder why. It does
not discuss the real problems which face the blind today or the methods of
solving those problems. In fact, NAC itself may well be more a part of the
problem than the solution. I repeat that tokenism by any other name is still
tokenism. In May of 1969, for instance, I received a document from NAC entitled
"Statement of Understanding Among National Accreditation Council, National
Industries for the Blind and the General Council of Workshops for the Blind."
This document was sent to all NAC board members with the request that they vote
to approve or disapprove it. It contained six points, of which one and five are
particularly pertinent. They are as follows: "1. By June 30, 1970, all NIB
affiliated shops shall have either: a. applied to NAC for accreditation and
submitted a self-study guide (or) b. applied to the General Council for a
Certificate of Affiliation with NIB and submitted a self-study guide. 5.
Certificates of Affiliation with NIB entitle shops to membership in the General
Council and to access through NIB to: a. Government business allocated by NIB,
b. Commercial business allocated by NIB, c. Consulting services of NIB, d. Any
and all other benefits of NIB affiliation." In other words if a workshop for the
blind wishes any contracts from the federal government, it had better get into
line and "volunteer" for accreditation by NAC. No pressure, of course, merely a
system of "voluntary accreditation!" As you might expect, I voted no on the NIB
agreement. Along with my ballot, I sent the following comments:</DIV>
<DIV>"I do not approve this statement because I do not believe government
contracts and other benefits to workshops should be conditioned upon their
accreditation by NAC. Rather, receipt of government contracts and other benefits
should depend upon the quality of performance of the workshop in question. Does
the shop pay at least a minimum wage? Do its workers have the rights associated
with collective bargaining? What sort of image of blindness does it present to
the public?</DIV>
<DIV>"Prior to NAC (in the days of COMSTAC) many of us said that NAC would
become a vehicle for blackmail—dressed out nicely, of course, in professional
jargon. It would appear that the prophecy is beginning to come true, earlier
assurances to the contrary notwithstanding."</DIV>
<DIV>As I say, I voted no. What do you suppose the final tally of the ballots
indicated? Twenty-seven yes votes and one no vote. How different the results
might have been if there had been equal representation of the blind themselves
and the agencies! Yes, tokenism is still tokenism.</DIV>
<DIV>In order that my position cannot be twisted or misinterpreted I would like
to say that the quarrel is not with the concept of accreditation itself. Rather,
we object to what is being done in the name of accreditation. Proper
accreditation by a properly accredited group is a constructive thing. What NAC
is doing is something else altogether.</DIV>
<DIV>There is, of course, not time here to go into the details of all of the
standards originally developed by COMSTAC and now being fostered by NAC, but a
brief sample is sufficient to make the point. Federationists will remember that
the Braille Monitor for February, 1966, carried an analysis of the COMSTAC
standards on physical facilities. That analysis said in part:</DIV>
<DIV>“The standards [on physical facilities] are perhaps notable chiefly in that
they are so vague and minimal as to be equally applicable to office buildings,
nursing homes, or universities by the simple substitution of the names of these
other facilities....”</DIV>
<DIV>Perhaps a brief run-down of the standards themselves would serve as the
best and most complete illustration (headings theirs).</DIV>
<DIV>1. Overall Suitability—The total facility is constructed to best serve the
needs of the particular agency. It will adequately serve everyone concerned. It
will meet the requirements of its governing body, the Department of Health,
Education, and Welfare, and the city building code. The physical facilities will
be helpful to the program. </DIV>
<DIV>2. Location—The facility is located where it can easily be reached by
staff, clients, and others who need to use it. The facility should be close to
shopping and other community interests. The location is reasonably safe, with
hazards minimized. </DIV>
<DIV>3. Grounds—The grounds will be large enough to allow for future expansion.
They will be pleasant ("free of undue nuisances and hazards,"), with parking
areas and roadways. Signs will be posted to help people locate the proper areas.
</DIV>
<DIV>4. Activity Area—The layout of the facility will be efficient. The facility
will be designed for the planned activities, will be large enough and well
organized (reception rooms next to entries, work areas together, etc.).
Sufficient maintenance will be provided for. </DIV>
<DIV>5. Privacy—People will have as much privacy as individual cases call for.
Confidentiality will be maintained. </DIV>
<DIV>6. Health and Safety—The health and safety codes of the community will be
met. Sufficient heat and light will be provided. Sanitary conditions will be as
good as possible. Suitable entries will be provided for wheelchairs, etc. Safety
features will be related to the level of competence of the occupants, the
activities undertaken, and the equipment used. Adequate first aid facilities are
provided. </DIV>
<DIV>7. Fire and Disaster Protection—All buildings will be so designed and
equipped as to minimize the danger of fire. The buildings will be inspected by
local authorities and/or independent authorities and records of inspection kept.
Smoking areas are clearly specified. Proper protection shall be provided the
occupants of the facility to minimize danger should fire or disaster occur.
Suitable fire extinguishers will be provided. Fire alarms will be installed as
to be heard throughout the facility. Fire drills will be held irregularly.
Special provisions will be made for fire warnings to deaf-blind. </DIV>
<DIV>8. Maintenance—"The condition of the physical facility gives evidence of
planful and effective maintenance and housekeeping." </DIV>
<DIV>9. Remodeling—When remodeling is undertaken, it should be to best suit the
needs of the program.</DIV>
<DIV>The preceding is an inclusive summary! One can imagine the breadth of
interpretation that can result from application of these standards. One can also
imagine the range of individual whim and axe-grinding, not to say blackmail and
favoritism, that can enter into the proposed accreditation of agencies for the
blind based on such vague and capricious requirements. The danger to be
anticipated is the possibility of varying application of standards to friends
and foes when "accrediting" agencies....</DIV>
<DIV>One is tempted to dismiss this entire report of "Standards for Physical
Facilities" with the single word, "Blah!" But more intensive study indicates
otherwise. Tucked away among the platitudes and the generalities are the age-old
misconceptions and stereotypes.</DIV>
<DIV>What, for instance, is meant by the requirement that a facility for the
blind be located near to shopping and other community interests, and that it be
in a location reasonably safe, with hazards minimized? The exact words of the
committee are, "Where undue hazards cannot be avoided, proper measures are
instituted to assure the safety of all persons coming to the agency. (For
example, where an agency is on a street with heavy traffic, a light or crosswalk
or other means is available for safe crossing by blind persons.)"</DIV>
<DIV>If this standard is simply meant to express the general pious platitude
that everybody ought to be as safe as possible, then what a farcical and
pathetic waste of time and money to assemble a committee to spell out what
everybody already knows. On the other hand, if the standard means to imply that
the blind are not able to live and compete among the ordinary hazards of the
regular workaday world and that they need more shelter and care than others, the
implications are not only false but they are insidiously vicious.</DIV>
<DIV>Of a similar character is the committee's statement that the grounds must
"provide pleasant and appropriate surroundings, and be free of undue nuisances
and hazards." Surely we do not need a special commission on standards and
accreditation to tell us that people should live in pleasant surroundings that
are free of undue hazards, if this is all that is meant. If, however, the
committee is saying that the blind require surroundings that are more "pleasant
and free from hazards" than the surroundings required by other people, one
cannot help but be unhappily reminded of the 19th century concept that the blind
should be entertained and provided with recreation, that they should be helped
in every way possible to "live with their misfortune."</DIV>
<DIV>If this type of analysis seems blunt, one can only reply that this is no
time for nice words and mousy phrases. The people who were formerly the
Commission on Standards, and are now the National Accreditation, hold themselves
out to the public at large as the qualified experts, the people who have the
right to make standards and grant or refuse accreditation to all and sundry.
These are not children indulging in the innocent games of childhood. They are
adults, playing with the lives of hundreds of people.</DIV>
<DIV>Federationists should review the Braille Monitor from 1965 through 1968 to
study the COMSTAC reports in light of present developments. I have not tried
here to analyze the content of those reports. Mostly it is bad, and the
standards and rules established by COMSTAC and NAC harmful. Let anyone who
doubts this assertion read the COMSTAC reports and the Monitor analyses. They
speak for themselves.</DIV>
<DIV>One final matter requires comment. At a recent meeting of the National
Accreditation Council I was telling a new member of the board (a prominent
businessman totally uninformed about the problems faced by the blind) that I
thought most of the actions of NAC were irrelevant. He seemed surprised and said
something to this effect:</DIV>
<DIV>"If you think what we are doing here is not relevant, what is
relevant?"</DIV>
<DIV>To which I said, "Last fall a blind man in Minneapolis (a person who had
worked for several years as a computer programmer at Honeywell and was laid off
because of the recession) applied to take a civil service examination for
computer programmer with the city of Minneapolis. His application was rejected,
on the grounds of blindness. The National Federation of the Blind helped him
with advice and legal counsel. As a result, he took the examination, and he now
has a job with the city of Minneapolis as a computer programmer.</DIV>
<DIV>"How many of the people who are on the NAC board," I asked, "are even aware
that such an incident occurred? How many of them think it is important?"</DIV>
<DIV>"Or," I went on, "consider another incident. A few weeks ago in Ohio a
blind high school senior (duly elected by her class) was denied the right to
attend the American Legion Girls' State. The story was carried nationwide by
United Press, and the matter is still pending. Do you see any of these people
here today concerned or excited about this case? Do you see them trying to do
anything about it?"</DIV>
<DIV>"Well," my companion replied, "your organization seems to be working on
matters like this. Maybe NAC is doing good in other areas."</DIV>
<DIV>"The difficulty," I told him, "is that the actions of NAC are helping to
create the kind of problem situations I have been describing to you."</DIV>
<DIV>"How?" he asked me.</DIV>
<DIV>"NAC," I said, "accredits workshops, for instance. What kind of standards
does it use in determining whether a shop should be approved and presented to
the public as a worthy and progressive institution? NAC is concerned about
whether the workshop has a good accounting system. It is concerned about good
pay and good working conditions for the professional staff (almost all of them
sighted). It is concerned with the physical facilities and (perhaps) whether
there is a psychologist or psychiatrist available to minister to the blind
workers. But what about minimum wages for those same blind workers, or the right
of collective bargaining, or grievance committees? On such items NAC is silent.
It will accredit a sheltered shop which pays less than fifty cents an hour to
its blind workers. By so doing, it puts its stamp of approval on such practices.
It helps perpetuate the system that has kept the blind in bondage and made them
second-class citizens through the centuries. It helps to slam the door on the
computer programmer in Minneapolis and the high school student in Ohio. Worst of
all, perhaps, it reinforces and helps to continue the myth that blindness means
inferiority, that the blind are unable to compete on terms of equality in
regular industry or the professions, that the blind should be grateful for what
they have and stay in their places. The workshop example is only that, an
example. The same theme is everywhere present in NAC's action and standards—and,
for that matter, in its very makeup."</DIV>
<DIV>As we talked, my businessman companion seemed shocked that there were
sheltered shops paying less than the minimum wage to blind workers. Yet, he is
on the NAC board, lending his name to the accreditation. I pointed out to him a
variety of other ways in which the work of NAC is helping to promote
misconceptions about blindness and add to our problems. I can only hope that the
seeds I planted will bear fruit.</DIV>
<DIV>To round out the picture we are considering today, one further item might
be mentioned. The April 25, 1968 minutes of NAC report as follows:</DIV>
<DIV>"Over thirty agencies and schools have indicated, in writing, an interest
in applying for accreditation. Official applications have been received from six
agencies. Some of these have already paid the application fee. The American
Council of the Blind is the first membership association to apply for membership
in the National Accreditation Council."</DIV>
<DIV>In a letter dated July 11, 1968, from Alexander Handel, Executive Director
of the National Accreditation Council for Agencies Serving the Blind and
Visually Handicapped, to members of the NAC Board of Directors an article is
discussed which appears in the July, 1968, issue of the Braille Forum (the
official publication of the American Council of the Blind). The article says in
part:</DIV>
<DIV>"It should be emphasized, however, that from the first, ACB officers and
members actively consulted with the various committees developing the standards,
and ACB was the only national organization of the blind which both participated
in and financially supported the National Conference on Standards which led to
the formation of the National Accreditation Council."</DIV>
<DIV>I give you this quotation without comment. It speaks for itself. So do the
actions of NAC. I presume all of you have read the exchange of correspondence
concerning the appearance of NAC representatives at this meeting today. The
contempt and condescension inherent in NAC's bland assumption that it was proper
to reject our invitation to appear at this convention because a debate might
occur are clear for all to see. Likewise, the agreement just concluded between
NAC and the American Foundation for the Blind whereby the Foundation will work
with agencies and help prepare them for accreditation is equally
revealing.</DIV>
<DIV>In any case the one central point which must be repeatedly hammered home is
the total irrelevance of NAC as it is now constituted and as it is now
performing. What we need today and in the years ahead is not more detailed
standards but a real belief in the competence and innate normality of blind
people, a willingness on the part of agency officials to help blind people
secure meaningful training and competitive employment, a recognition that the
blind are able to participate fully in the mainstream of American life. We need
acceptance and equality, not shelter and care.</DIV>
<DIV>When seen in this light, NAC must be viewed as one of our most serious
problems in the decade ahead. The blind of the nation should thoroughly inform
themselves about its activities and should insist upon a voice in determining
the character of programs affecting their lives. We should insist that state and
federal governments not delegate their powers of setting standards for state
agencies to a private group, which is not responsive to the needs or views of
the consumers of the services. It is true that many of the agencies doing work
with the blind need to be reformed and improved, but NAC is not the entity to do
it. We the organized blind intend (in the best tradition of American democracy)
to have something to say about the scope and direction of the reform and the
improvement. We are not children, nor are we psychological cripples. We are free
citizens, fully capable of participating in the determination of our own
destiny, and we have every right and intention of having something to say about
what is done with our lives. </DIV>
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