I can hardly remember what happened last week, much less events from the mid to late 1970's when the California Council of the Blind, then an NFB affiliate, ceased to be part of that organization. During those tumultuous months, I attended meetings, was involved in strategy sessions, took actions, but it sometimes seems as if those things happened to another person. Someone will say, "Surely you remember the NFB Board meeting in Los Angeles when a bunch of us walked out." Well, vaguely. "Well you must remember those meetings in San Francisco when well . . .". Remind me! (In fact Winifred Downing did remind me, which is part of a point I'm getting around to in a few paragraphs.)
My observation is that memory is fragile and fickle. Things so important at the moment shift in our perspective over time. But so long as records exist, or people who were there are available to remind us, I could if necessary reconstruct the main details of those dacades-old events. This is why as an organization, we need to preserve our institutional memory.
Institutional memory starts with good records and good record retrieval mechanisms.
To me, good record keeping begins with good minutes. Taking good minutes is an art. Today we can record our proceedings which poovides a good backup option, but short of going to archival material, which may in fact not exist for local chapter meetings, and other organizational committees and subcommittees, minutes provide the key to our institutional memory. Having taken minutes for dozens of meetings, I suggest good minutes do two things: they clearly delineate action items, and they provide a sense of the discussion leading up to those actions. Who is going to do what when and how did we lead up to deciding the action?
Psst! A word to minutes takers. Do as I say not as I have done all too often in the past: write your minutes as soon as possible following the proceedings! Ideally, work from a recording of the event as the strain of taking notes on the fly produces anxiety, and besides you might miss something. Trust me, nothing is worse than going back to cold notes the night before the minutes are wanted.
Second, we need to know where those records are. This is perhaps more of a problem for statewide affiliates which rarely meet, but I know for a fact that I have taken minutes, read them at the next meeting and turned them over for official preservation to no one! This is sloppy recordkeeping at best and possibly illegal at worst! We must be vigilant in knowing where our precious records are and how to access them.
The other way to preserve our institutional memory is to talk with the people who were there. The value of the history articles Catherine Skivers wrote upon the occasion of CCB's 75th anniversary is incalculable. I've been giving a lot of thought to expanding upon this notion of preserving institutional memory. Just as Japan honors the people it considers its "national treasures," so I propose we honor and learn from our CCB "treasures". To that end, we begin a series of interviews in this issue which we will publish from time to time as space permits. Our first "treasure" interview is with Winifred Downing, the editor of the BC for ten years.
Earlier I mentioned the value of revisiting important documents. As an example of why such documents are so important, we publish again the editor's column Win wrote for the Winter 2005 issue of the BC. Her comments are as timely today as they were then.
Attention to our history gives us unique insight into how to address old and new problems.
Celebrating Recent Success, Taking On New Challenges At The 2011 ACB Legislative Seminar
by Frank Welte
The 2011 Legislative Seminar of the American Council of the Blind took place from Sunday, February 27 through Tuesday, March 1. CCB members Ardis Bazyn, Hazel and Roy Harmon, Rayanne Myers, Donna and Mitch Pomerantz, Richard Rueda, Frank Welte and Isabel Ybarra joined ACB members from throughout the United States to learn about current federal legislation of concern to blind Americans and to share this information with Congress. Isabel and Rayanne attended the Seminar for the first time; both performed like seasoned veteran advocates. While most of our many Congressional meetings were with staff members, Rayanne and Isabel both got to meet face-to-face with their respective congresswomen, and Isabel even got pictures of herself standing with Representative Linda Sanchez.
We spent Sunday afternoon and all day Monday in training meetings where a line-up of excellent speakers briefed us on current issues.
Sunday afternoon's first speaker was Jeanine Worden, Deputy Chief, Civil Rights Division, US Department of Justice. She gave an update on ADA regulations. CCB members will recall that Ms. Worden provided an ADA training seminar during our Fall, 2010 convention.
The next speaker was Donald L. Kahl, Executive Director, Equal Rights Center. The Equal Rights Center has helped thousands of individuals to obtain redress for acts of discrimination. ACB has recently worked with the Center to document a pattern of discrimination against guide dog handlers by taxi drivers operating in the Washington, DC metropolitan area.
Melanie Brunson, ACB's Executive Director, rounded out Sunday's program with a review of ACB's recent legal advocacy activities.
On Sunday evening, ACB's student affiliate, the National Alliance of Blind Students, hosted a game night fundraiser. During this event, teams of competitive, enthusiastic ACB-ERS strove to answer trivia questions that got tougher as the evening went along. It was noticed that the event became an unexpected demonstration of the power of access technology (when certain individuals from states other than California) surreptitiously demonstrated their skill at looking up trivia answers on their Internet-enabled talking cell phones.
Emily Khoury, Legislative Director, Office of U.S. Representative Edolphus Towns (D-NY), kicked off the Monday training session with the how-tos of having an effective meeting with your member of Congress. Then Mark Richert, Director, Public Policy, American Foundation for the Blind, talked about the issue of making prescription drug labels accessible and about the need to advocate for Medicare to pay for low vision devices. Steven C. Schwadron, Member, Cozen O'Connor Public Strategies, told us about the detrimental impact that IRS regulations have had on charities through their vehicle donation programs and about how we can advocate with Congress to change the law to revive car donation programs. CCB has experienced this situation first-hand, and we will be working hard to get our California congressional representatives behind fixing the problem.
Karen Peltz Strauss, Deputy Chief, Consumer and Governmental Affairs Bureau, Federal Communications Commission, was our luncheon speaker. She talked about how the FCC is working to prepare regulations to implement the 21st Century Video and Communications Access Act that ACB helped to enact last year.
After lunch, Blane Workie, Deputy Assistant General Counsel, Office of Aviation Enforcement and Proceedings, U.S. Department of Transportation, discussed the Air Carrier Access Act and what it means for blind travelers. (See Steven Mendelsohn's article in this issue.) Aaron Bishop, Executive Director, National Council on Disability, spoke about the future of NCD and its issues for 2011. Dan Sippl, President, Randolph-Sheppard Venders of America, provided an update on current issues of concern to blind vendors.
Speaking of vendors, on Monday morning Roy and Hazel Harmon accompanied Mr. Sippl to a meeting with members of the Committee for Purchase, the group that coordinates federal government buying from Ability One and agencies affiliated with National Industries for the Blind. This was an opportunity to educate members of the Committee on the Randolph-Shepperd program and how it differs from the Javitz Wagner O'Day program.
On Tuesday, our CCB team got a lot of exercise going to meetings in the offices of both of our senators and about 40 of the members of our California delegation in the House of Representatives. We also provided information packets for the dozen or so Representatives with whom we couldn't get meetings. We thank CCB members who called their members of Congress to help us get appointments. My guide dog, Jeep, did a lot of guiding, getting compliments and petting, while walking halls, riding in elevators and lying on office rugs.
While all this activity was going on, ACB President, Mitch Pomerantz, had the privilege of presenting awards to Congressmen and Senators who had sponsored legislation for ACB in 2010. Mitch also met with Ruth Scovill, interim Director of the National Library Service for the Blind and Physically Handicapped.
Summary of 2011 ACB legislative initiatives.
During our visits to Capitol Hill on March 1, CCB members shared information about ACB's three current legislative initiatives; Medicare coverage of low vision devices, access to prescription drug label information, and amendment of the Internal Revenue Code to promote charitable donations of qualified vehicles. Here is a summary of these issues.
I. Accessible Prescription Drug Labeling
The Issue: At least 25 million Americans experience severe vision loss impacting their ability to independently read prescription labeling and related information. Given that the incidence of vision loss is expected to dramatically increase, this poses a significant public health challenge.
The Food and Drug Administration (FDA) implements laws and regulations that govern the amount and nature of information provided to the public about prescription drugs. However, the FDA has never issued specific regulations or guidelines to guarantee that prescription drug information intended for patients is accessible to persons who are blind or visually impaired. In general, states are the primary regulators of the content and format of information provided directly on prescription bottles and/or pharmacy-provided packaging. Nearly all of the states in the union have statutory requirements pertaining to prescription labeling. However, no state law ensures that prescription labeling is accessible to persons with vision loss.
Legislative Action: ACB calls on Congress to introduce and pass The Prescription Drug Accessibility Act. This legislation would grant the FDA clear authority to regulate this area and develop standards to ensure that prescription labeling is accessible to individuals with vision loss. A number of existing solutions demonstrate the feasibility of providing access to prescription drug labeling, and pharmacies should be prepared to provide prescription labeling by multiple means.
II. Low Vision Aid Exclusion
The Issue: In November of 2008, the Centers for Medicare and Medicaid Services (CMS) promulgated a regulation that has had a detrimental impact on the lives of countless individuals who are blind or visually impaired.
To the dismay of the blind community, the Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Acquisition Rule contains a provision entitled "Low Vision Aid Exclusion" which states that all devices, "irrespective of their size, form, or technological features that use one or more lens to aid vision or provide magnification of images for impaired vision" are excluded from Medicare coverage based on the statutory "eyeglass" exclusion. ACB is well aware that this extremely restrictive reading of the "eyeglass" exclusion has resulted in the denial of vital assistive devices for seniors and other Medicare beneficiaries who may have disabilities, particularly those with vision loss, who need to use such devices to live healthy, safe and independent lives.
This proposal has had a significant impact on beneficiaries with vision impairments who depend on assistive technology that incorporates "one or more lens" to aid in their vision. The expansion of the eyeglass exclusion has prevented access to devices such as hand-held magnifiers, video monitors, and other technologies that utilize lenses to enhance vision. Unbelievably, CMS has also excluded coverage of inexpensive devices like white canes.
Legislative Action: ACB calls on the US House of Representatives and Senate to introduce and pass the Low Vision Devices Inclusion Act of 2011. This critical legislation would overturn the CMS regulation barring coverage for low vision devices and establish criteria for their provision. Such criteria would acknowledge other distinctive features employed by the most valuable low vision devices, other than their mere use of a lens, such as a device's integration of a light source, use of electrical power, or other distinctive features.
III. Vehicle Donation
The Issue: Since its original authorization in 1986, charitable vehicle donation has become a critical fundraising tool for over 5,000 large and small charities like ACB and its state affiliates. As these programs proliferated, so did concern about abuses. In November 2003, the Government Accountability Office (GAO) reported on the benefits to charities and donors that resulted from vehicle donations. Before 2005, a taxpayer could deduct the fair market value (FMV) of vehicles donated to charity. Under Section 170 of Title 26 of the US Code, a donor could claim FMV as long as it was under $5000. However, some donors were fraudulently claiming excessive deductions, and some charities were shortchanged by unscrupulous third-party contractors who managed their car donation programs. According to the GAO, these problems were exacerbated by insufficient IRS oversight to detect or police these problems. In its FY2005 budget request, the Administration proposed reforming the rules governing vehicle donations by requiring a qualified appraisal on all donated vehicles. The final changes, included in the American Jobs Creation Act of 2004, limited deductions over $500 to the proceeds of eventual sale of the vehicle by the charity, regardless of appraised value. Only if the charity keeps and uses the car to advance its own mission, rather than selling it for the resulting revenue, can the donor now deduct FMV exceeding $500.
A GAO report released in 2008, documented overall decreases in vehicle donations of 15 percent in 2005 and another 28 percent in 2006. Unfortunately, since 2005, ACB has felt the consequences of this regulation and has witnessed revenues from vehicle donations shrink by 85%; the number of donated vehicles has plummeted by 94%. CCB has experienced a comparable decline in revenues from car donations.
Legislative Action: Based on these reports and testimonials from charities, legislation was introduced in the 111th Congress to restore certainty to prospective car donors about the resulting deduction. That bill garnered 211 congressional cosponsors from across the political spectrum. At the beginning of the 112th Congress, Senator John Ensign (R-NV), a member of the Senate Finance Committee, introduced the text of that bill as S. 110, a bill to amend the Internal Revenue Code of 1986 to promote charitable donations of qualified vehicles. The bill permits donors to claim FMV up to $2,500 and requires the IRS to issue new guidance for donors and charities on how to properly calculate FMV. Claims of value exceeding $2,500 would require a certified appraisal. The bill would maintain IRS reporting requirements for both taxpayers and charities--and retain penalties for false reporting--without scaring away donors altogether. The ACB and CCB support this legislation.
She Helps Us Sound Good: Profile of Joy Tilton
by Bonnie Rennie
One of the best things about CCB Conventions is our fabulous programs. These programs present opportunities to learn useful information, feel connected to the blindness community, be inspired to self advocacy and more. Whether you're unable to attend, want to relive the experience, need the material for archival or notetaking purposes, or just want to skip over all the bad jokes, you can listen ! or download Convention archives on our website,
www.ccbnet.org (the direct link is
www.ccbnet.org/ConventionArchives.htm).
And when you do so, thank Joy Tilton for the good listening experience. Joy edits the sound on the archives, preparing them for the website and also dividing them into cassette-length segments. This volunteer work began in 2006, when she received a call from Dan Kysor saying, "How would you like a job?" Her sound editing includes things like adjusting the volume, removing the unnecessary pauses, noise, and fluff during our proceedings. This all serves to make the listening more pleasant and effective. Joy says that in the beginning, completing these tasks twice a year took her much longer than it does today. Her work can also be heard on the cassette version of the programs.
Ms. Tilton is currently a member of the ACB Capitol Chapter in Sacramento. Her involvement in CCB dates back to 1993. She has been a member of both the Bayview and East Bay Chapters. From that era, Joy remembers one volunteer job she took on: using her Brailler to label an entire roll of raffle tickets so sellers wouldn't run out. Joy also serves on the Publications Committee.
Joy moved to Sacramento in 1995 to take a job with the California Relay Service. This program assists persons who are deaf, hard-of-hearing, or have speech impairments, in making and receiving phone calls. This was a job she found very satisfying and demanding of her excellent Braille skills. Joy believes she got this job due to her persistence, her confidence that it was a good fit with her skills, and through networking with a hard-of-hearing acquaintance. Unfortunately, as with many good jobs, this one did not last forever.
Joy began to learn Braille early, in pre-school. Her exposure to the world of computers came in earnest at around age 13 while in junior high in the Bay Area. A teacher introduced her to the VersaBraille (one of the earliest stand-alone devices allowing braille input and output with the capability of sending and receiving from computers). From there, Joy says that she picked up all things computer quite easily. What started out for her as another volunteer job, developed into an avocation. She served as a systems operator at an early blind community bulletin board service, called BayTalk, an early precursor of the more advanced social networking sites of today.
Some technology tidbits were shared by Joy which might be of interest to those among us who are not so advanced as she. For sound editing software, she likes SoundForge. She finds it straightforward and accessible, also using it in her musical pursuits. Joy personally uses Twitter more than she does FaceBook. She finds a user product Qwitter helpful with using Twitter.
Her blogging activity began several years ago using LiveJournal. Joy states this site is still there but has been largely supplanted by FaceBook and others. Her several preferred ways of keeping current with things new and techno include word of mouth, some email lists, FaceBook, and other social networking.
Another major passion of Joy's is her music. She describes past participation in a band with other local CCB members, called MoJo Friday. They used to play various gigs around town, with Joy on keyboards. She and the band were often featured on ACB Radio's all blind artists Cafe Channel. From 2001 to 2004, Joy had her own twice-per-week morning show on ACB Radio Interactive. She called this eclectic program "The Joy Ride". She has since recorded some of her own music, also using SoundForge software. But she says she does this for the enjoyment, and not for the Big Money. She also has an extensive and varied recorded music collection.
Joy indicates that she finds her work on behalf of CCB very rewarding. She says of her efforts to help out, "It's all good, it's all fun!" We in CCB are grateful to Joy, whose considerable skills in sound editing really help us out.
Larry Swenson: Death Of A Warrior, A Mentor And A Friend
by Beryl Brown and Michelle Swenson-Aguirre
Saturday, February 26th, we held a Celebration of Life for Larry Swenson at the Earle Baum Center in Santa Rosa. February has been Larry Swenson Blind History month since 2003. He was a great historian and taught us so much. He was a warrior, a mentor, and a friend. So many of his friends came to share their experiences and memories of Larry: his daughter and son-in-law Ben and Michelle and their 3 daughters. They brought wonderful pictures of him with family and friends. Denise Vancil and Jeff Harrington, instructors at the center, are there because of Larry, and they told their stories.
Most were there as part of a group that flourished under Larry's leadership in the early days of the center called the Thursday Thinkers.
Things Larry will be remembered for: co-founder of Earle Baum Center; organizing Thursday Thinkers; involved in establishment of Redwood Empire Chapter of CCB; led the way in establishing the George Fogarty Memorial Scholarship/life Enhancement fund; taught travel class as part of adjusting to vision loss training at EBC; always working towards mentoring young people. We will miss him. I am pleased to forward the following obituary written by his daughter.
Lawrence Stanley Swenson peacefully passed away at the age of 78 on December 21, 2010 surrounded by his family and close friends. Larry was born on June 26, 1933 in Deer Lodge, Montana, to Charles Lawrence and Mary Beatrice Swenson. In his youth, Larry worked for the US Forest Service, the local mines, the icehouse, and the railroad. He loved the outdoors and spent much time with friends in the nearby mountains.
After graduating from Powell Co. High School in 1951, he bicycled through much of war-torn Europe. He graduated from Montana State University's Law School in 1958 with honors. After exploring much of rural Central and South America, he moved to San Francisco. He worked as an attorney for the Army at the Presidio. While celebrating passing the California Bar Exam with friends at the Tonga Room in the Fairmont Hotel, he met his future wife, Heidi Schaefer, a German immigrant attending a nearby beauty school.
Larry and Heidi married in 1961 and moved to Rohnert Park. They had two children, Greg and Michelle. Larry joined the Law Offices of Maurice Fredricks and Paul Golis in Rohnert Park. Larry was actively involved in the developing city of Rohnert Park. He served as President of the Cotati-Rohnert Park Lion's Club and was active in the 20-30 Club. He loved the ocean and spent many weekends diving and camping at the coast with family and friends.
He later opened his own law office in Rohnert Park. He continued to practice in Montana as well, and won an important land dispute case in the Montana State Supreme Court. He was an attorney for Sonoma State, and received an award for 30 years of Distinguished and Devoted Service to Sonoma State Enterprises, Inc in 1991.
Larry lost his sight in 1978 due to Glaucoma. He continued to practice law until 1991 when he retired. He became a strong advocate and role model for the blind and visually impaired. He learned to shop, cook, clean, sew, travel, ride horses, garden, without sight. He ran his farm and life very effectively showing many that a full life without vision is possible. He traveled alone to many areas of the world including India, Nepal, Thailand, Poland, Guatemala, Mexico, Greece, France, Germany, and hiked through the Himalayas without sight. He was an inspiration of courage and determination to many.
Larry was the co-founder of the Earle Baum Center of the Blind in Santa Rosa. The EBC is a nonprofit regional community center of support for the visually impaired, which teaches daily living, mobility, adaptive technology and sports/recreation. He served as President of the Redwood Empire Chapter of the California Council of the Blind. He established the George Fogarty Life Enhancement Scholarship Fund. This scholarship provides cell phones and other important devices to assist the blind in leading a full life.
Since 1993, the Earle Baum Center has proclaimed every February to be "Larry Swenson and History of the Blind Movement" Month. In 2009, he received the Humanitarian Award from the California Council of the Blind for his contributions to the blind community in Sonoma County, for working with local governments to improve accessibility for the visually impaired, for his outreach to visually impaired youth and for using his farm as a venue for teaching and outdoor experiences for the blind.
Larry was a devoted grandfather. His three granddaughters, Annie, Gigi and Katrina, were the joy and center of his life from the time of their birth until his death. He left his mark on many lives and many hearts. He is greatly missed and will always be remembered with great love and admiration. He is survived by his son, Greg Swenson, of Rohnert Park; his daughter, Michelle Swenson-Aguirre and husband, Ben, his granddaughters,
Annie, Gigi, and Katrina, of Sebastopol; his brother, Murray Swenson and wife Thea, of Helena, Montana; also many nieces and nephews.
A memorial service will be held on his birthday, June 26, 2011. Family, friends and associates are invited to this service at his home. Donations may be made to the George Fogarty Life Enhancement Scholarship Fund: c/o Beryl Brown, EBC, 4539 Occidental Rd, Santa Rosa, CA 95401.
Report on State and Federal Legislation
by Frank Welte, Director of Advocacy and Governmental Affairs
State Legislation.
Governor Brown and the members of the State Legislature have begun their new terms facing a $25 billion state budget through fiscal year 2011-2012. The governor's proposed budget contains about $12 billion in cuts to state programs. Among all of these possible cuts, the following will have particular impact on blind and visually impaired Californians: elimination of the entire MSSP (Multipurpose Senior Services Program; reduction in vision services from the Healthy Families program; Annual reduction of $500 million for In-Home Supportive Services (IHSS); 8.4% across the board cut in hours for all IHSS recipients; required doctor's certification for all IHSS recipients that they are at risk of institutionalization; elimination of domestic and related services for children under 18 living at home and for many adults living with another person; elimination of all state funding for IHSS advisory committees; $1.7 billion in cuts to Medi-Cal.; elimination of adult day health care services; a cap of 10 doctor visits per year; other Medi-Cal service cuts; cutting the individual Supplemental Security xx IncomestState Supplemental Payment maximum grants from $845 to $830 per month (the lowest allowed by the federal government); a $30.4 million cut in library programs which will cause a reduction in federal funding for the Braille and Talking Book Library and the Braille Institute Library in future years.
After numerous budget hearings at which CCB representatives testified to preserve vital services for blind and visually impaired Californians, the State Assembly and the State Senate passed versions of the budget that differ in particular items but largely follow the governor's recommendations. As I write this report a budget conference committee is working to resolve the differences in the Assembly and Senate version of the budget.
Because of the strong advocacy efforts made by supporters of state social services the proposed library programs have been cut in half, so the Talking Book program won't be impacted by the remaining cuts. Also, funding for vision services under the Healthy Families program will be reduced but not eliminated, and some of the proposed cuts to IHSS and MediCal services have been mitigated.
We can hope that more of these harsh cuts won't be included in the final version of the budget.
Please contact your members of the State Legislature, and tell them how these proposed budget cuts will impact you. Also, it would be a good idea to contact the members of the conference committee. I can provide contact information for the committee members upon request.
You may also send comments to the two Budget Committees at the following addresses.
California State Assembly Committee on Budget, California State Capitol
Room 6026
Sacramento, CA 95814
Fax: 916-319-2199.
California State Senate, Committee on Budget and Fiscal Review
California State Capitol, Room 5019
Sacramento, Ca 95814
CCB-sponsored Bills.
Assemblyman Sandre Swanson has re-introduced our regulations format bill this year. The bill, AB 410, will require state agencies, upon request, to provide screen reader-friendly versions of regulatory text in notices of proposed regulations. We have learned that the Department of Motor Vehicles is likely to begin allowing holders of state ID cards to renew their cards by mail, as is already the case for holders of driver's licenses. It appears that DMV will also begin sending renewal notices to state ID card holders. State regulations don't require DMV to send out these card renewal notices, and we're concerned that the Department could decide in the future to stop sending them. CCB is sponsoring a bill, AB 390 by Assemblymember Anthony Portantino, that will place a renewal notice requirement in statute. I'll provide information about the progress of these two bills in future Legislative Reports.
Federal Legislation.
Late last year, Congress passed (and the President signed) both the Pedestrian Safety Enhancement Act of 2009 and the 21st Century Video and Communications Access Act. The American Council of the Blind worked diligently for a number of years to get these two important laws enacted. With these successes behind us, ACB will continue to work to insure that the regulations implementing these new laws will reflect the concerns of blind and visually impaired Americans.
ACB is now turning its attention to several new federal legislative initiatives. These issues are described in my report of the 2011 ACB Legislative Seminar included in this issue.
CCB will hold our 2011 Capitol Day at the State Capitol in Sacramento on Thursday, May 12 from 10:00 AM to 2:00 PM in conjunction with our spring, 2011 state convention. Please mark that date on your calendar, and plan to join us at the Capitol to learn about important legislation and to share our concerns with our legislators. Contact Frank Welte in the CCB office if you plan to attend Capitol Day.
You can get detailed information about all of CCB's legislative activities by reading my legislative reports which will be posted regularly on CCB's web site and distributed on our various Email lists. You can listen to the reports by calling the CCB's toll-free phone number, (800) 221-6359, on evenings and week-ends. Check with the California Connection to find out when my next Legislative Report will be updated. For federal legislative information, please check with the Washington Connection 800-424-8666 or on the ACB website www.acb.org. Please write me at frank.welte@ccbnet.org if you would like me to send you my legislative updates and other advocacy information by Email.
NLS Celebrates Eightieth Birthday Of Braille And Talking-Books Program But Possible Budget Cuts Could Impact Ca Braille And Talkingbookk Library Funding
by Judy Wilkinson
What an irony that while we celebrate the 80th anniversary of the NLS Talking-Book program, the budget dealings here in California could threaten our state braille and talkingbook library beginning a couple of years down the line.
First the good news. NLS festivities, a special ceremony and press event to be held at the Library of Congress on March 3, will celebrate the 80th anniversary of the founding legislation of the braille and talking-book program. (Steven Mendelsohn, the historian in our family, says this legislation was enacted on the final day of a Republican Congress, 1931; the Democrats had gained a majority in the 1930 off-year election which they would maintain for all but four years until 1994.) The press release for the celebration promises as speakers and participants: Librarian of Congress, Dr. James H. Billington; Members of Congress; prominent authors, including blind 9/11 hero Michael Hingson; NLS patrons of all ages sharing their personal stories. A late-breaking email from Deanna Marcum, Associate Librarian for Library Services, informs us of the retirement as of February 28, of Frank Kurt Cylke, Director of NLS since 1973. The March 3 event will pay tribute to his "exceptional career and to his leadership in accomplishing the transition from analog to digital technology in 2009 with the launch of the digital talking book program."
Now the more sobering news. By the time you read this, the legislature's Budget Conference Committee will have decided the fate of 3 library programs: The California Library Services Act, The Public Library Foundation, and The State Literacy Program. The Senate Budget Committee proposes granting the governor's request to eliminate all three programs, (a projected savings of $30.4 million) while the Assembly Budget Committee proposes far more modest cutbacks for all three.
How do cuts in these programs affect the NLS program in California? Mike Marlin, Director, California Braille And Talkingbookk Library, explained it to me this way. The state must show "maintenance of effort" in paying the state's share of certain federally-funded programs. If "maintenance of effort" falls off, then down the line in a future federal matching cycle, the state may be granted fewer federal dollars. Mike said that we can't know a definite amount that may be cut from general library funding, (including our braille and talkingbook library) until we know how much these and other programs are cut. In an email from Friday morning, March 4, Mike Marlin writes, "looks as though the LSTA matching grant has been spared, for now! "
Here's what we can surmise. Since even the Assembly Budget Committee proposes some cuts to these 3 programs, they will be cut, possibly eliminated. At best we are facing probable cuts to the various agencies and programs which fund our braille and talkingbook programs here in California.
We must prepare to face these realities. Mr. Marlin plans to form an Advisory Council later this year including all appropriate stakeholders.
I am pleased to announce that Mike will be attending our spring convention and will be the speaker at the BRLC/CLUA luncheon on Friday, May 13. He will also attend the BRLC and CLUA sessions that morning. At that time he will bring us up-to-date on these grave financing issues.
We cannot dodge all the bullets. Inevitably budgets and programs vital to our interests will take some hits. Keep in touch with Frank Welte's bulletins; access the California Connection each week. More than ever we must be vigilant and ready to literally and figuratively, show up where we are needed.
CCB "Treasure" Winifred Downing
by Judy Wilkinson
She is 85 now and her health is frail, but her courage and spirit are as strong as ever. You know that memory thing I was talking about? Well I can't remember when I first met Win, but probably at a meeting for blind teachers or during one of those all-night resolutions-writing sessions.
"How, when and why did the organized blind movement become important in your life?"
"I was born and raised in Chicago; if there was at that time any kind of council of the blind, I didn't know about it. But when I came to San Francisco in 1954 to take a job at the Orientation Center, Allen Jenkins, Kenneth Jernigan, tenBroek, all those people were very much onboard, and we heard a whole lot about the organization. Kenneth Jernigan taught a course concerning blind law, and he certainly included information about the organization. I dropped in on a lot of those classes, because I was hired to teach home management, but when I got there, there wasn't anything to teach with: no desk, no ironingboard, no stove! I had to make myself look busy for quite a long time. At that time, the NFB paid the way to the convention of someone they hoped would be interested in the organized blind movement. At my first convention, I met Dr. Newell Perry. While we were talking, his sister was trying to get him to go to their room because she was tired; he chastized her, 'Don't interrupt me! I'm talking with a young lady!'"
While home with her new baby, Win says she learned a great deal about the organization by spending countless hours transcribing materials they wanted into braille.
When asked about people who inspired her, Win recalled Dolly Glass, one of the few blind people she knew of who operated her own business: an answering service. Win says she thinks the real "treasures" are those who work in the competitive world rather than those who like herself, worked in the blindness field her entire life. (I told her she wasn't going to get out of being a "treasure" that easily.)
Asked about other mentors, Win praised Lawrence (Muzzy) Marcelino (important in the Nfb we broke away from) who taught her to write resolutions. "And I've been on Resolutions Committees every place that I've been until two years ago."
Discussing other areas where she was active she says that what with the long illness of Glenn (her husband of 18 years, also visually impaired) and raising 4 children, she didn't attend many conventions until after his death in 1973. She served on numerous committees and projects relating to the education of blind children. For years she was a member of the Low Incidence Disability Advisory Committee, an organization put together by Phil Hatlen, long-time educator of the visually-impaired. She gained much information useful to the CCB's efforts on behalf of blind children.
When asked what she considers her most important contributions to the organization, "Without a doubt, editing the Blind Californian for 10 years. When you edit the BC you become part of everything that happens that is of any kind of note. You can't be lackluster in your enthusiasm; you have to be on all the way. So I think that was the thing I did that was the most valuable and also what I enjoyed the most, because I love to write."
Her thoughts on ACB or CCB's greatest achievements: "being able to stick to their guns." "We've learned we can never have a president for life." She mentioned how Acb and CCB fought off the nfb lawsuit against Bay Area Rapid Transit's providing detectable warning edges. In regard to the CCB particularly, she says the hardest thing is keeping dedicated people involved.
"I do think the organization doesn't work as much as we should on education; we're still pretty good about legislation, but we aren't very attentive to the education problem."
In response to a question about major challenges for the organized blind today, Win says "I don't think the challenges really changed that much. The things that we were distressed about when I was growing up, education and employment, are still issues concerning us today."
As to advice for advocates and emerging leaders, Win was adamant: "Well somewhere or other they have to get their blindness skills down." As an example she referred to New York's former governor David Paterson: "He made himself sound like he was great because he never fooled around with that braille; his parents paid for readers! He was really giving a lot of power to sighted people who he thought were doing his bidding. No one knows if they were, and he doesn't know either!" (She was referring to his technique of each night reviewing materials prepared for him.) "He had no ability to take notes! I don't know how he did what he did. So I think where we do ourselves the first damage is not saying we're blind, and we're not apoligizing for that. We're going to use our equipment; we need to and we're going to do that, and we may look blind or not, but that's not the issue. It's what you can do!"
The next question was "Away from Acb and CCB, who are you?"
Well that was hard because so many of her activities involved issues so dear to her heart. She served on the board of the San Francisco Lighthouse and volunteered at the San Francisco library. For the past 10-12 years, she has devoted countless hours to NUBS, (Nemeth Uniform Braille System) strengthening people's acceptance of it. This system binds together literary braille, computer braille and the Nemeth math system in such a way that the learner can start with literary braille and go on to the others if and when needed. A true enthusiast, Win points out that today, a braille learner must remember 3 different dollar signs and 2 percent signs, etc. BANA (Braille Authority of North America) is pursuing study of this code. While Win knows it can't make a difference for her, she feels that we must make the braille system easier to learn.
When pressed for other interests, without hesitation Win says, "My family always has come first, and the thing that I'm proudest of is my family. We have a very devoted family where the people are concerned with each other; where the brothers and sisters and the people they married liked all the other people. We don't have this business of well John won't come because Jane is coming."
Win recalls, "We were married in 1954 and in 1955, we had Christine; in 1956 we had Michael." Steve and Eileen followed soon after: "We had 4 children in five years." Widowed when her eldest was a senior in high school and the youngest in 7th grade, she supported them by increasing her employment as a teacher with the Hadley correspondence school to full time. She has 12 grandchildren, the oldest 28, and the 3 youngest 18, all freshmen at various colleges. She has much of her loving family nearby. Son Michael (a fine carpenter and voracious reader) takes her to church each week in her wheelchair and lives only a block-and-a-half away. Eileen is just over a mile away; Christine, (a nurse whose daughter also pursues the same profession) resides in Napa. Only Steve is far away in Montana.
Finally I asked Win about her health. "I can't really walk at all now by myself." For this reason, she has been unable to attend conventions in recent years, though we saw her for a few hours last spring in Burlingame. She uses a 3-legged cane in her home. Her nearby family often cooks for her, and just this week, she has hired some in-home help. She is in a great deal of pain. But just an hour before we spoke: she learned that she is a good candidate for a spinal cord stimulater, a device which allows the brain to block pain sensations.
Our thoughts and prayers are with you Win, and be in no doubt that the CCB will always be better off for the dedicated years you have given it.
Editor's Column, Blind Californian, Winter, 2005, Volume 49, No. 1
by Winifred Downing
[Editor's Note: We reprint the following column here because of the timeless concerns Win raises. Some of the articles she mentions may at first seem irrelevant today, but how many of you encountered difficulty with accessible voting machines in last fall's elections? Just last year in Missouri, a young blind couple had their newborn taken away from them solely because they were blind; they had to fight a court battle to get their baby back.]
Though blind and visually impaired people encounter a lot more problems in everyday life than do most sighted persons, our situation is still much improved now from what it was even just fifty years ago.
When I graduated from college with my teaching credential for the state of Illinois and approached the Board of Education in Chicago, I was told that people with severe physical problems such as blindness were not accepted in the Chicago schools. There was no avenue for argument; the matter was settled. I went on, then, to seek my Master's degree in social work; but, though I had what today would be a 4.0 record in college, the University of Chicago could just say that no blind persons were accepted in the school of social work. Loyola University, fortunately, was more amenable, but the directors there found it extremely difficult to find for me an agency that would accept me for advanced field work placement. The problem was solved by having me work in the same agency where I had done the first placement but assigning me to more difficult cases requiring cooperative efforts with additional agencies.
Again when I moved to San Francisco to teach at the Orientation Center, I found doors closed. There was a Catholic women's club
here then called St. Margaret's Club, and my parents and our parish pastor felt less worried about my adventure were I to have the stability of a women's residence club. Father Hishen called the club from Chicago, and fifty years ago long distance calls were not made lightly. St. Margaret's Club, however, refused even to interview me though I had by that time lived in a college dorm, rented a room with a family, and spent two years in an apartment with a friend. Again, there was no opportunity for debate; case closed!
Because young people don't have so many of these experiences today, it is often difficult to explain to them what the purpose of a local chapter, of the CCB, or of the ACB is. Many would prefer more social events, going together to a theater performance or movie, but not listening to a talk about rehab, social security, library service, legislative initiatives, or seminars on the IEP. Even though today's young people don't have things the way they'd like them, they don't see the blatant kind of injustice that used to be quite common.
The article in this issue on voting, even though it talks about Illinois, recounts experiences that people all over the country have had, some positive and some disappointing. Certainly, though, no one would be reporting anything were it not for the organizations of disabled persons that have intervened on this matter for some years now and particularly in the Help America Vote effort.
An even more direct and personal example of the necessity of thwarting discrimination and prejudice is described in "New Baby and His Parents," which you will read later. Within hours after the difficulty began, local chapters, the CCB president, and the ACB president were all involved. Television showed pictures and gave accounts of blind parents successfully raising children; and two days later, the subject was still being mentioned on newscasts. The little family is in their own apartment, and an attorney has been secured to assist them. Immediate help was available because of the organization we have and the willingness of everyone contacted to drop everything to address their problem.
Would we have the efforts to provide independent, private voting; to obtain justice for a young family in trouble; to interest a corporation in developing a fully accessible cell phone; to gain support for installing audible pedestrian signals; or to provide textbooks for visually impaired children at the same time that sighted students get theirs--would we have these encouraging developments without local chapters, state affiliates, and a national organization?
Update On Civil Rights In Air Travel
by Steven Mendelsohn
Twenty-five years ago Congress enacted the Air Carrier Access Act (ACAA), legislation intended to assure nondiscrimination against, and adequate services for, people with disabilities in air travel. In 2009 the federal regulations governing the Act (Code of Federal Regulations, Title 14, Part 382, cited as 14 CFR Secs. 382.1 through 382.153) were substantially revised ("refreshed" is the technical term). An overview of these changes and of the Act's overall impact are beyond the scope of this report. This article will focus on current issues of concern and recent developments of particular importance to travelers with visual impairments.
ACAA was enacted four years prior to the ADA, and the provisions of the two laws have never been reconciled. The existence of a separate disability rights law for air travel may seem strange, but in most areas of law, ranging from safety and security to taxation and the sale of alcohol, the aviation industry is governed by separate laws.
Despite separate laws, it seems fair to say that even after the regulatory revisions, the disability community continues to experience many frustrations under the ACAA. The major sources of these include:
(a) The lack of any private right of action allowing individuals to sue airlines for violation of the Act. Under ACAA the only remedy is an administrative complaint to the Department of Transportation (DOT).
(b) The existence of continued gaps between ACAA and the ADA, and of further complexities and uncertainties due to the potential role of state law under some circumstances. The gaps between the laws contribute to confusion over such issues as whether any law covers the accessibility of airport kiosks.
(c) The lack of aggressiveness on the part of federal regulators in enforcing the law. When the DOT levies fines against carriers for ACAA violations, it often waives collection of some or all of the money if the carrier agrees to use it to improve its ACAA implementation. A striking example of this occurred in February when the DOT levied a $2 million fine against Delta Airlines (the largest non-safety-related fine in history) for widespread deficiencies in service to passengers who use wheelchairs and for failure to maintain and report adequate records of ACAA complaints. DOT then waived $1.25 million of this sum, allowing the carrier to keep it "to improve its service to passengers with disabilities beyond what is required by law." (See, Dot Press Release and Consent Order, February 17, 2011, http://www.dot.gov/affairs/2011/dot2211.html).
Against this background, let us turn to the major subjects of interest:
(1) Dog Guides-- Considerable controversy has been generated in recent years over what animals and what uses of animals qualify for the designation of "service animal." The ACAA regulations bar airlines from denying carriage to service animals, and there is no question that dogs used as guides by persons who are blind fall squarely within the definition of this term. There are a few wrinkles to keep in mind though.
Carriers cannot demand advance notice of a passenger's intent to fly with a service animal, except in one case. If the trip includes a flight segment of 8 hours or more, carriers may (but are not required to) demand 48 hours notice (14 CFR Sec. 382.27). Flight segments of 8 hours or longer are rare to nonexistent in domestic travel but do still exist on long-haul international flights. In any event, if planning a long flight, you might inquire whether the carrier requests such advance notice.
If advance notice is required but not given, that omission on the traveler's part does not give the carrier the right to refuse passage to either the person or the animal. It does give the carrier the right to refuse passage if granting the last-minute request would delay the flight. In connection with a flight of this length, carriers are also permitted to demand evidence or assurances that a service animal can either endure without having to relieve itself, or that if it does need to relieve itself, this can be done in a safe and sanitary manner. It is not known if any carriers ask this question about dogs or what measures would be considered satisfactory if they do.
On the plane, the dog has the right to accompany the handler at any seat where the passenger sits (Sec. 382.117). However many blind travelers report efforts (occasionally quite insistent) by airline counter agents or crew members to assign them to or place them in bulkhead seats, apparently on the theory that this gives the dog more room, and in some cases on the claim that regulations require it. There is no such regulation. The only relevant regulations are that the animal cannot block floor space that needs to be kept free in case of emergency, and of course that the instructions of the pilot-in-command generally trump other authorities (Sec. 382.151).
Back in the airport after landing, carriers are required, in cooperation with airport operators, to provide animal relief areas and upon request to escort passengers to such areas (Secs. 382.55 and 382.91). Here the relationship and roles of air lines, airport operating authorities, and contract service providers becomes important.
The newest area of concern relates to airport security screening. People report enormous variation and unpredictability in how they are handled at checkpoints, including whether they are required to drop or remove the dog's harness, whether the dog is patted down, and if separated from the dog, whether they or the dog are sent through first. Almost everything to do with security falls under the jurisdiction of the Transportation Security Administration (TSA) and is not governed by ACAA. In a subsequent article we will discuss the TSA dimension.
(2) Access to Information-- Broadly speaking, there are 3 categories of information that passengers need. These are: pre-travel information of the sort now mainly available on the Web; airport information such as gate changes and flight delays; and onboard and in-flight information ranging from food choices to fasten-your-seat belt signs. Passengers also need access to automated service functions such as the use of airport kiosks.
(a) The Web: To date, no court has held that airlines' ticketing sites, boardingpass download or other web-based services are legally required to be accessible. An important lawsuit recently filed against JetBlue by the CCB and individual plaintiffs under the California state human rights law seeks to change this. Pending the outcome of this legislation, passengers should be urged to use their consumer power (families and friends included) by favoring carriers who do make their websites accessible, and by letting carriers know (through internet postings, letters and other means) how they feel about exclusion from access to resources that all passengers, including blind ones, are paying for with their ticket purchases.
Although the ACAA regulations say nothing about web accessibility, they do require that certain key information be posted on the web by carriers, as all now do, who maintain websites. These include information on the availability, "in an accessible format," of copies of the ACAA regulations (Sec. 382.45) and information on how to get in touch with complaint resolution officials (CRO's) (Sec. 382.151).
(b) In-Terminal Information: First, with respect to ticketing kiosks, the CCB suit, as well as a suit by the National Federation of the Blind against United Airlines, are challenging the inaccessibility of the kiosks increasingly used by airlines to issue boardingpasses and to reduce their need for counter agents. At present, the regulations address the issue by requiring that carrier personnel either help customers with disabilities to use the kiosks or allow them to move to the front of the line (Sec. 382.57).
Generally, carriers "must ensure that passengers with a disability who identify themselves as persons needing visual or hearing assistance have prompt access to the same information provided to other passengers at each gate, ticketing area, and customer service desk that you own, lease, or control to the extent that this does not interfere with employees' safety and security duties The information you must provide under paragraph (a) of this section includes, but is not limited to, the following: Information concerning flight safety, ticketing, flight check-in, flight delays or cancellations, schedule changes, boarding information, connections, gate assignments, checking baggage, volunteer solicitation on oversold flights individuals being paged by airlines, aircraft changes that affect the travel of persons with disabilities, and emergencies" (Sec. 382.53).
In this connection, the regulation dealing with staff training goes on to state that the carrier: "must also train these employees to recognize requests for communication accommodation from individuals whose hearing or vision is impaired and to use the most common methods for communicating with these individuals that are readily available, such as writing notes or taking care to enunciate clearly, for example. Training in sign language is not required. You must also train these employees to recognize requests for communication accommodation from deaf-blind passengers and to use established means of communicating with these passengers when they are available, such as passing out Braille cards if you have them, reading an information sheet that a passenger provides, or communicating with a passenger through an interpreter, for example" (Sec. 382.141).
Beyond this, the regulations require that carriers provide high-contrast captioning on all TV's in public areas of the terminal (Sec. 382.53). No comparable requirements exist for audio-description, or even for the use of TV's that are headphone-enabled so that blind passengers waiting for their flights can even hear the audio.
(c) Onboard: The law contains very specific requirements for the accessibility to persons with hearing impairments of all videos, Dvd's or other audio-visual materials shown on aircraft (Sec. 382.69). Once again, beyond general requirements, there are no specific provisions defining the parameters of onboard information accessibility for persons with visual impairments. Unless one has held a life vest in her hand, or had the opportunity to directly examine the handles and latches on an emergency door, it is unlikely that any blind person can feel confident about their ability to manipulate these devices, based on the standardized and highly visually-oriented safety briefings that precede every takeoff or based on even the braille safety information cards that are offered by most carriers.
The attention given to the accessibility of all audio-visual materials, including entertainment, to persons with hearing impairments, while highly laudable, stands in marked contrast to the indifference of the industry and its regulators to the comparable aspirations of passengers who are blind, passengers for whom virtually the entirety of customer-oriented in-flight technology, ranging from in-flight magazines and seatback TV's to emerging telephone and internet capabilities, are inaccessible.
(3) Escort Services-- This may be the area where blind and visually impaired passengers report the greatest difficulty. Because the provision of these services involve undocumentable and nonreplicable interactions between passengers and airport personnel, they are especially difficult to monitor or verify. While carriers are required to provide training to their employees, and to require in all their contracts with airports or third-party service providers that appropriate training be provided to their staffs who deal with the public, (Secs. 382.15 and 382.141), the extremely stressful conditions under which most airport employees work, the low wages and high turnover associated with contract airport service companies, and the persistence of stereotypes among the general public make it unlikely that this training, even if actually provided, has the desired effect.
For passengers with visual impairments, frequently reported difficulties include: insistence that they use a wheelchair, insistence that they have to be taken to or picked up from designated holding areas, assumptions that they cannot use moving walkways, escalators or stairs but must be taken by elevator, and conversations between escort personnel and screeners or gate agents that refer to the passenger in the third person and make it sound as if the passenger were a parcel.
There is no legal basis for any of this. The regulations are explicit about some of these, such as the right to free movement within the terminal (Sec. 382.33), but for many of the others one must rely on more general provisions such as the ban on mandating separate services or the requirements for effective and appropriate communication. In the end, regulation cannot mandate mutual respect, let alone commonsense, particularly in an environment where, as as several contract escort workers have told me at a number of airports, they are in fear for their jobs and believe they would be summarily fired if a passenger in their charge were to be injured. Regrettably, these workers, who appear to be disproportionately young, minorities or immigrants, are evidently considered quite expendable, and the consequences they suffer may be far more serious than the stress or indignity visited upon the passengers they push or escort.
In addition to specifying restrictions which may not be imposed, the regulations also list the locations to which passengers must be escorted upon request. These include rest rooms, including accessible rest rooms, but "only if the rest room is available on the route to the destination of the enplaning, deplaning, or connecting assistance and you can make the stop without unreasonable delay" (Sec. 382.91), and baggage claim areas. Surprisingly, perhaps harking back to the days when air lines still served food, there is no requirement that people be escorted to food sales locations, though one would assume that the ban on restriction of movement would cover such a case. This could become an issue for people whose visual impairment is associated with diabetes.
One obscure provision of the law must also be noted here. Ordinarily, an airline's liability for lost, damaged or delayed baggage is limited by law. But the ACAA regulations provide: "the limits to liability for loss, damage, or delay concerning wheelchairs or other assistive devices provided in Part 254 do not apply. The basis for calculating the compensation for a lost, damaged, or destroyed wheelchair or other assistive device shall be the original purchase price of the device" (Sec. 382.131).
Although it seems clear that transportation-related assistive technology (AT) was the object of this exception, the actual wording, "or other assistive device," is much broader. If AT is lost or damaged and the traveler has not been negligent in the matter, this provision could help to prevent some of the hardship that might otherwise occur.
(4) Contractors-- The modern airport is a complex bureaucracy. Passengers naturally think about and mainly interact with their airlines, but airport operating authorities, other federal agencies, and a host of private contractors and service companies are typically involved. Under these circumstances, identifying the key decisionmakers, vesting responsibility and enforcing accountability all become exponentially more difficult.
Broadly speaking, the regulations require that in all their contracts for airport operations and services, carriers require adherence to the same ACAA-related standards as they themselves must uphold, including standards of personnel training. The problems with this include: the failure of the DOT to hold carriers responsible for contract oversight as such, absent patterns and practices of ACAA violation of which they had or should have had actual knowledge, and the fact that many contracts are made not directly between carriers and service providers but between airport authorities and private firms.
(5) Complaints-- One of the key links in the ACAA process is the complaint resolution official (CRO). Each carrier is required to have a CRO on-duty, covering every airport where the carrier operates during the hours of its service, and available either on the airport premises or by phone. Passengers must be told of the availability of the CRO and facilitated in getting in touch with the CRO, whose role it is to resolve all disputes that cannot be settled by the carrier's employees (Sec. 382.151). The CRO is supposed to be knowledgeable about ACAA, and is authorized to make final and binding decisions (except that the CRO is not required to be given authority to countermand a decision of the pilot-in-command of an aircraft based on safety") (Sec. 382.151).
If a passenger is not satisfied with the CRO's decision, or for some reason does not contact the CRO immediately (say for lack of time), it is still possible to pursue a complaint later, either by contacting the CRO or by filing a complaint with the DOT's Aviation Consumer Protection Division. Complaints must be filed in writing, and there are requirements and timeframes applicable to carrier responses. The division has a toll-free hot-line number which is (800) 778-4838. Whatever the DOT decides, there is no appeal to the courts.
While nowhere officially stated, it is widely believed that DOT will actively investigate possible violations of the law only when the volume of complaints or other factors give reason to believe that "patterns and practices" of noncompliance exist. For this reason alone, it is important for consumers with bona fide grievances to file complaints, even if the likelihood of redress is small.
Most passengers, blind or sighted, make their way through the airport and get where they're going without incident. It is the times when things go badly that we remember. While there are all too many reasons why things can go wrong, there is no justification for the chronic and recurrent causes that are unique to the assistance and information needs of passengers with disabilities. With continued attention to the law and to personnel training, these problems can be significantly reduced.
