[nabs-l] [il-talk] [Fwd: Input Sought On Forthcoming Accessibility Changes To Currency]

[Bill Reif]

I normally don't forward Braille Forum articles to this list.  However, I believe this one needs to be shared, as accessible money is coming and we may want some input as to how that gets implemented.  
Contrary to popular misconception, the NFB is not, and has not been, against currency modifications that make it more accessible to us.  Our disagreements with the ACB have regarded only the means of getting there.  (I personally would love for the Feds to buy us all K-NFB Readers for money identification through the only nationally-authorized dealer. <g>)  I will post further if or when I determine the specific modifications the NFB may be proposing.

Cordially,
Bill

-------- Original Message --------
Subject:	Accessible Devices Input Sought On Forthcoming Accessibility Changes To Currency
Date:	Wed, 28 Jul 2010 19:03:22 -0500
From:	Accessible Devices <parker2745 at accessible-devices.com>
To:	Accessible Devices List <A-d at accessible-devices.com>

We believe this to be something many of you will want to take part in.
Braille Forum, July 2010
On May 20, the Bureau of Engraving and Printing (BEP) published a notice in
the Federal Register outlining the recommendations they propose to make to
the Secretary of the Treasury regarding how to provide people who are blind
and visually impaired with meaningful access to U.S. currency. Before
finalizing their recommendations, the BEP is seeking public comment on their
proposals. Comments are due by August 18 and both individuals and
organizations are encouraged to provide input.
Below is a summary of the BEP proposal, and a list of some of the specific
questions to which they are seeking answers. Space does not permit us to
publish the entire notice here, but if you would like to read it in its
entirety, visit
http://edocket.access.gpo.gov/2010/2010-12091.htm
 or contact
the ACB national office for a copy in electronic format or on tape. BEP
Recommendations
I. Tactile Feature: BEP will develop and incorporate a raised tactile
feature that will accommodate people who are blind and visually impaired.
This feature will enable blind and visually impaired individuals to identify
currency by touching the tactile feature. According to BEP, their study
demonstrated that raised tactile features allow most blind and visually
impaired individuals to denominate currency. Indeed, this kind of feature is
used in some foreign currency, and the study's data indicated that this
feature was more effective than virtually every other kind of accommodation
tested, including different-sized notes. Additionally, a raised tactile
feature would not cause a major disruption to the general population because
the notes will not appear substantially different from their current form.
BEP noted that the selection of the raised tactile feature will require
additional targeted research, testing, and consideration of the public
comments. Nonetheless, the significant benefits of notes with a tactile
feature, including the excellent accuracy results the blind and visually
impaired achieved with them, the ease of use evidenced both by the usability
tests and applicable scientific research, and the relatively minimal impact
on the general U.S. population, supports the inclusion of a raised tactile
feature as a recommended accommodation despite its challenges. Based on
experience, independent research, and the study, BEP believes it can develop
a raised tactile feature that is durable and can be incorporated into its
existing manufacturing systems at a reasonable cost, coincident with the
introduction of the next design series of U.S. currency.
BEP invites comment on its proposal to incorporate raised tactile features
in the next redesign of its currency.
II. Large, High-Contrast Numerals: BEP began incorporating large,
high-contrast numerals into Federal Reserve notes beginning with the Series
1996 design $50 note in October 1997. In March 2008, BEP increased the size
of the large high-contrast numeral with the introduction of the Series 2006
$5 note. The feedback received from visually impaired individuals has been
positive. This feature will be continued in the new-design $100 note, which
is the last in the Series 2004 family of designs. Because BEP has experience
printing this feature and the visually impaired community has provided
positive feedback on it, BEP proposes to continue using this feature in the
next design for U.S. currency. BEP is aware, however, that there may be a
number of options concerning the size, color, placement, background contrast
and other features for these large numerals that may improve accessibility
of currency for people with low vision. BEP invites comment from the public,
including people with low vision, about the best choices for the proposed
large, high-contrast numerals.
III. Supplemental Currency Reader Program: BEP will establish a supplemental
currency reader distribution program. The purpose of the program is to
provide blind and visually impaired people a means that can be used
independently to correctly identify the denomination of U.S. currency. In
compliance with legal requirements, BEP will loan a currency reader device
to all blind and visually impaired U.S. citizens and legal residents who
wish to avail themselves of this program. The individual may borrow the
reader for as long as the individual desires the assistance of the reader.
Before a reader is distributed, BEP first will verify that the requestor is
eligible.
Under the reader program, individuals who are United States citizens or
people legally residing in the United States who are blind or visually
impaired and who need a reader to accurately identify the denomination of
U.S. currency will be able to obtain a reader at no cost to the individual.
BEP will define blind or visually impaired under the same definition as the
study, with the following change to the study's definition of visual
impairment: The reader program will not extend to visually impaired
individuals whose impairment is corrected with ordinary eyeglasses or
contact lenses.
BEP is considering the scope of an appropriate verification framework to
determine eligibility to receive a reader. Specifically, it is considering a
framework inspired by the eligibility requirements that the Library of
Congress uses when loaning library materials to blind and other disabled
persons as set forth in 36 CFR 701.6. Under that framework, applicants may
submit verification of their eligibility from a "competent authority." BEP
would define a "competent authority" as one of the following: doctors of
medicine, doctors of osteopathy, doctors of optometry, registered nurses,
and licensed practical nurses.
Alternatively, if a person who is blind or visually impaired has
verification of visual impairment from another federal agency, including the
Social Security Administration, the Library of Congress, or a state or local
agency, that person need only submit a copy of that verification. BEP is
inviting comments on whether this verification system is appropriate, or
whether other frameworks would be more appropriate. Parents or legal
guardians of a blind or visually impaired child under 18, and caregivers,
legal guardians, or those with power of attorney for a U.S. citizen or
someone legally residing in the U.S. may act as a proxy on behalf of the
blind or visually impaired child or represented individual and request a
currency reader. BEP will require verification for the child or represented
individual.
BEP will solicit and award a single, long-term contract to implement the
currency reader program. The contractor will be designated as the Currency
Reader Program Coordinator (CRPC). Once the program is operational, a
potentially eligible person may request a currency reader by contacting the
CRPC and completing and submitting a request form. Depending on the
verification framework adopted, upon verification of eligibility, the person
will be provided a reader.
BEP is seeking answers to the following questions.
1. What would be the ideal placement of the raised tactile feature? In what
kind of pattern or patterns should the raised tactile feature be arranged?
2. How should the large, high-contrast numerals be incorporated? In other
words, what colors should BEP use, what is the optimal size of the numerals,
and where should the numerals be placed on the note?
3. What background colors would provide the highest color contrast for
people who are visually impaired?
4. What technological solutions should BEP explore to help people who are
blind and visually impaired denominate currency?
5. What is the nature of the burden, if any, on the general public of
including a raised tactile feature on U.S. currency?
6. If there are any burdens imposed on the public by a raised tactile
feature on currency, how can such burdens be minimized?
7. What is the nature of the burden, if any, on industry and business of
including a raised tactile feature on U.S. currency?
8. If there are such burdens, how can they be minimized?
9. Does the supplemental currency reader program impose a burden on the
blind and visually impaired?
10. If so, what are those burdens, and how can they be minimized?
11. Does a verification process of the currency reader program inspired by
the Library of Congress process impose too a great a burden on the blind and
visually impaired?
12. If so, what are those burdens, and how can they be minimized?
13. Alternatively, if a person who is blind or visually impaired has
verification of visual impairment from another federal agency (such as the
Social Security Administration or Library of Congress), or a state or local
agency, should BEP allow that person to submit a copy of that verification
in order to satisfy a proof of visual impairment requirement in order to
obtain a currency reader? If so, what burdens might this impose, and how can
those burdens be minimized?
14. Should BEP consider working with local governments and/or state agencies
to deliver the currency readers?
15. Should BEP consider additional or different criteria when determining
eligibility for the currency reader program?
16. What administrative and/or operational challenges does the currency
reader program create?
ACB will be filing comments, so readers should feel free to give us your
input on these issues. For further information about how to file comments,
or for a copy of the full proposal, contact Barbara LeMoine in the national
office either by phone, (202) 467-5081, or by e-mail,
blemoine at acb.org

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