[AERNet] Accessible Currency Debate

[McInnis, Janet (DLEG)]

okay, I really don't have a strong opinion, but, as I noted before, I did not have a really strong opinion when the NFB fought so hard to get tactile labels on insulin bottles. Actually, I don't think it has to be an issue.  If it benefits the person, use it, otherwise, ignore the markings and fold, organize etc as you always have. 
Then, I scanned the articles cause I am on break and it is a short break.
 Now I am thinking that maybe it is the blind vending operators who may be opposed to the accessible currency, and they are offering its opponents lots of free  potato chips, snicker bars, and diet coke to  fight this fight and prevent loss of sales as machines are re-tooled to accept varying sizes, rounded corners, or punch dot paper currency.  I could not understand the response. Now, it makes sense.
However, let me be blunt.  I do not want to be in a grocery store line, behind someone using a "lightweight handheld reliable currency reader."  (perhaps it is the inventor of said device also behind the aversion to accessible currency.  Free cookies AND a free currency reader...hmmmm).  There is no such thing as such a device being reliable and quick.  Give me a customer who folds his money, keeps it organized or identifies by tactile difference anyday over the hand held device.  Perhaps a little trained monkey could be handed out to those who are more comfortable with warm furry creatures than technology.  I would stand in line behind the person with the monkey!!
Janet in Michigan
 
 

________________________________

From: aernet-bounces at lists.aerbvi.org on behalf of Ike Presley
Sent: Tue 3/20/2007 11:18 AM
To: AER; GA-VI at googlegroups.com
Subject: [AERNet] Accessible Currency Debate


Hi All,
 
I've been reading a good bit about the issue of accessible currency. It seems that there are good points on both sides. At times the information is somewhat contradictory so I guess it depends on whose facts you believe. In fact, I have not personally made up my mind on the issue. I'd still like some more facts but I'm not sure if that data will become available.
 
For those of you who are interested read on. If not, hit the delete button. I would like to call your attention to 3 articles that I found very helpful in addressing this issue. One is pro, one is con, and the final one is also somewhat con, but offers and interesting option. Since it seems that we talk about the pros and cons of an issue, I'll copy the pro article first. However, that doesn't mean that I totally agree with it or that in any way does my employer endorse it. I'm not certain that my employer has taken a definite stand on the issue, as an organization, I mean. Anyway, hopefully I want get into too much trouble for simply trying to provide information to our field about an issue.
 
www.acb.org/magazine/2007/bf022007-2.html

A MILESTONE FOR MONEY AND MEANINGFUL ACCESS 
by Melanie Brunson 


Tuesday, Nov. 28, 2006 was a historic day for ACB. On that day, U.S. District Judge James Robertson issued his decision in ACB's pending case against the United States Treasury Department. Judge Robertson found that the Department of the Treasury is violating federal law by failing to design, produce and issue paper currency that is readily distinguishable by people who are blind or visually impaired. Shortly after this decision was announced, the government announced its intention to appeal. As I write, we are awaiting a decision by the District of Columbia Circuit Court as to whether it will hear the government's appeal. 

In the meantime, as many of you know, Judge Robertson's decision has caused quite a stir! Discussion of the case has been widespread in both radio and television programs, as well as the print media. Interest in the case has not been limited to the U.S. media. Both Chris Gray and I were interviewed by reporters from the BBC shortly after the decision was announced and a film crew from French television visited the ACB office. While I was in Tokyo, Japan to attend a conference last month, I was informed that one of the conference organizers had just submitted an article on the American court decision to a Japanese publication for people with disabilities. 

We believe that continued public discussion of the accessibility of U.S. currency is beneficial and we hope that public discourse on the subject will continue. In an effort to facilitate that discussion and provide answers to some of the questions that have been raised thus far, ACB's Director of Advocacy and Governmental Affairs, Day Al-Mohamed, put together a fact sheet entitled Accessible Paper Currency -- Myth vs. Fact. I thought it would be helpful to readers of "The Braille Forum" to have the information in this fact sheet for their own reference, so, with Day's permission, I will include it here. Please read on and, if you still have questions after you finish, feel free to contact either Day or me. We will keep you posted as this case develops. 

Following this article, you will find a short survey on access to paper currency. We would appreciate it if you would take a few minutes to answer the questions in our brief survey and send them, in any format, to the ACB national office. We value your input on this important issue. Now, here's some additional information for your consideration. 

Accessible Paper Currency -- Myth vs. Fact TRUE OR FALSE? 

Making paper currency accessible to the blind and visually impaired is an extreme measure and an unheard-of accommodation. 

FALSE. Almost 200 countries issuing paper currency have made their currency accessible using various methods, leaving the United States as the only nation that prints bills that are identical in size and color in all their denominations. These include nations and groups with larger populations and currency printing needs such as Canada and the European Union, but also smaller countries such as Barbados, Namibia and Uruguay. 

TRUE OR FALSE? 

Making paper currency accessible isn't really necessary because it only affects a small group of people. 

FALSE. Cataracts, which result in cloudy or blurred vision, affect 20.5 million people in the United States today, but that number will rise to 30 million in 2020. Diabetes as a result of obesity is an increasing issue for millions of Americans, and for 5.3 million of them, diabetic retinopathy will cause vision loss. For seniors, age-related macular degeneration and glaucoma will affect 1.6 million and 2.2 million people respectively, and those numbers are expected to grow. What those statistics mean is that roughly 1 in 250 people will have some sort of visual impairment by 2020. 

In addition, making paper currency accessible will impact a much larger group of individuals than just those who are blind and visually impaired. The increased ease in differentiating money will work to the benefit of seniors, individuals with cognitive disabilities and even people without disabilities in environments where there is low lighting such as restaurants, taxicabs, and bars. 

Curb cuts were created for individuals who use wheelchairs, yet non-disabled pedestrians such as people with strollers, wheeled luggage and moving dollies have significantly benefited and make regular use of curb cuts. Closed captioning was initially thought of as an imposition forced on the public by the deaf community, and yet it is now widely used in places such as airports, hospitals, bars and gyms. Creating an additional means of identifying paper currency has the potential to be just as beneficial to society as a whole. 

TRUE OR FALSE? 

Making paper currency accessible makes it easier to counterfeit U.S. money. 

FALSE. The advent of computers, scanners and printers and other even newer technology has made counterfeiting even easier. However, tactile changes, such as a number of those proposed and utilized by other nations as a part of their accessible currency initiatives, also make it more difficult to counterfeit currency. 

TRUE OR FALSE? 

Making paper currency accessible is too expensive. 

FALSE. There are several ways to alter paper currency to make it accessible, such as varying sizes, raised symbols, intaglio, punched holes or even rounded edges, each of which would have a different cost estimate; therefore, there is some question as to the accuracy of any estimates proposed at this time. 

In addition, even if one were to accept the figures put forward by the Bureau of Engraving and Printing, then in the context of the amount spent annually, accessibility alterations would be less than 5 percent of their cost, perhaps even less if changes were made over time. Considering that U.S. currency is redesigned every few years, including accessibility in the next design change would not necessarily increase the cost significantly. It is important to remember that the latest redesign is already under way -- new $10 bills, with a new $5 bill due to come out in 2008. 

TRUE OR FALSE? 

Making paper currency accessible will be exorbitantly expensive to the vending machine industry. 

FALSE. There are a variety of methods to making paper currency identifiable that have been successfully implemented abroad. No specific change has been determined at this time and the American Council of the Blind does not endorse any single method, so it is impossible to determine how much costs and alterations to vending, ticketing or other machines will be. In addition, currently, there are no suggested changes to the $1 bill, which is the most commonly used bill in the industry and accounts for 50 percent of the bills minted by the Bureau of Engraving and Printing. 

TRUE OR FALSE? 

Portable note-reading devices are a better alternative to changing currency. 

FALSE. The use of a special machine that people who are blind and visually impaired would be required to use or possess is impractical and inefficient. Individuals would have to carry the machine with them everywhere. The current cost of such portable readers is around $300 per machine and they have been shown not to work well with worn, crumpled or dirty bills. Making sure the bill is in the correct orientation for the reading device can be difficult to do without vision and time-consuming. In addition, such readers are relatively slow at identifying bills; doing so one bill at a time would not be welcome in a busy line. And there is the question of the ability of such machines to continue to be effective over time for new currency design upgrades. Plus, the machines themselves wear out and break down. 

Also of concern is the fact that such portable devices announce the denomination out loud and require the identification of each bill singly, forcing a blind individual to more openly handle their money to identify it, a safety issue in today's crowded urban areas. Creating a requirement for a special note-reading device becomes the development of technology as a substitute for access instead of a means to achieve access. But perhaps just as important, requiring people who are blind and visually impaired to use a special note-reading device rather than making the currency itself accessible means that the potential benefit is denied to the larger population who would benefit from alternate access to paper currency such as seniors, individuals with cognitive disabilities, non-English-speaking immigrants, non-disabled individuals in low light situations and even blind or visually impaired tourists. 

 

www.nfb.org/Images/nfb/Publications/bm/bm07/bm0702/bm070202.htm

Is the Failure to Produce Tactile Currency 
Really a Matter of Discrimination?

by Marc Maurer

Marc MaurerBraille money has been a minor topic of discussion among blind people for as long as I can remember. The way blind people handle coinage and bills was the subject of a lesson (an informal one, as I remember it) that I received during my early grade school years. Coins are not difficult to distinguish from one another tactilely. The bills that form the majority of currency present a somewhat greater challenge, but it is largely a manageable one. Stories abound regarding blind people who insist that they be paid only in one-dollar bills, but the vast majority of blind people receive, manage, disburse, and use bills of higher denominations as a matter of routine. 

Most blind people have devised a system for keeping track of paper currency--folding different denominations different ways, separating different denominations into different pockets or different parts of a wallet or purse, or (in rare instances) creating tactile identification marks on bills of different denominations. In a customary transaction involving paper currency, a blind person transferring a bill identifies the denomination before releasing it to the person receiving it. In accepting paper currency, a blind person ordinarily asks that the bills be identified as they are received. Blind merchants ask that the bills they receive be identified publicly. In some instances blind merchants employ a paper money identifier to verify the denomination of a bill. However, in most cases the verbal exchange with the sighted person transferring the bill is sufficient for identification. 

>From time to time somebody gets the bright idea to ask the Congress to create Braille money. The National Federation of the Blind has been asked for its opinion regarding the creation of Braille money on many occasions. The response to this request for information usually includes these elements: 

1) Printing Braille on money has been tested. The Braille wears out with extreme rapidity. Money identified with Braille becomes unusable in its tactile form after only a very short time in circulation. 

2) Paper currency of different sizes or shapes could be made that would be identifiable by touch. However, unless the person managing the currency has the different sized or shaped bills to compare, it is frequently difficult to tell what denominations are present. The cost of modifying the currency management technology to accept bills of different sizes or shapes is high for the minimal benefit that would result. 

3) We believe that many legal changes are essential to ensure the right of the blind to full participation in society. Even if a change in the nature of the paper currency is desirable, it is not of sufficient importance to warrant our attention and the attention of Congress. Other things should be done first. Because the management of paper currency is well within the capacity of the blind, changing the currency to gain a minor convenience is not justified. For these reasons during the nearly forty years that I have participated in the National Federation of the Blind, we as an organization have consistently decided not to put substantial effort into changing the paper currency. 
In 1994 at the convention of the National Federation of the Blind held in Detroit, Michigan, the members of the Federation discussed changes in the currency. Our general approach to the currency was set forth in Resolution 94-07. That resolution says:

WHEREAS, the United States Department of the Treasury is examining alternatives to the present currency for the purposes of making counterfeiting more difficult and for making currency more compatible with modern technology; and 

WHEREAS, revisions to the present currency may include variations in color, raised markings, bar coding, or other electronically readable formats; and 

WHEREAS, it is a widespread misconception that blind people cannot handle their own money because they cannot see it; and 

WHEREAS, it is beyond dispute that blind people can, in fact, handle their own money; however, bills which can be identified by other than conventional print could be more convenient for everyone, may be a necessity to safeguard against counterfeiting, and may be desirable to take the best advantage of evolving technology: Now, therefore, 

BE IT RESOLVED by the National Federation of the Blind in Convention assembled this seventh day of July, 1994, in the City of Detroit, Michigan, that this organization express the interest of blind people in the discussion of a modernized form of currency so that any changes which may eventually be made will include methods of identifying money by other than strictly visual means; and 

BE IT FURTHER RESOLVED that this Federation, notwithstanding its expressed interest in the ultimate decisions on currency changes, do all in its power correctly to inform the public that blind people can and do successfully handle money in its present form.

In the spring of 2002 the American Council of the Blind and certain individuals sued the Treasury of the United States and others on the grounds that the paper currency of our country was not tactilely identifiable by blind individuals and that the failure of the Treasury to produce such currency constituted discrimination against the blind. Inasmuch as most of us who are blind have been using paper currency without major difficulty, the National Federation of the Blind thought the lawsuit was primarily an effort on the part of the American Council of the Blind (ACB) to gain publicity. Many thoughtful leaders of the blind felt that the ACB's publicity stunt was damaging to the blind not only because it focused attention on a putative problem that did not exist but also that it would present the capacity of the blind in a false and misleading manner. If blind people are incapable of managing paper currency, how devastating is the limitation of blindness? We felt that this kind of presentation would lead to the assertion that blind people were incapable of participation in commerce without substantial alteration of the documents or papers involved in financial transactions. To give only one example, if a check is not tactilely identifiable, is the signature of a blind person upon it valid? The answer to the question might be that the signature is not. If this were to become the result of the argument that the paper currency discriminates against the blind, the effect upon blind people would be devastating indeed. We in the National Federation of the Blind have fought for the proposition that the signature of a blind person is valid upon such documents, whether they are tactilely identifiable or not. To assert anything else would be to challenge the right of blind people to engage in the commerce of the world. 

Fundamental to the philosophy of the National Federation of the Blind is the belief that blind people can operate effectively within our society as it currently exists with only minor modifications of the tools used for participation in that society. How much alteration in the tools of participation is needed for our effective participation? This question is at the heart of the argument about creating a tactile currency. Tactile currency would be convenient and beneficial to the blind. However, it would cost a great deal to create it and even more to implement its use. The most frequently suggested method for creating a tactilely identifiable currency is to print bills of different sizes for different denominations. If this method of producing currency were to be adopted, the machines used to manage currency would require alteration. The cash registers employed throughout the country would need modified drawers. This is only the beginning of the cost. The bank machines, the vending machines, the currency-counting machines, and other paper-currency-managing tools would require alteration. If we who are blind expect our government, our businesses, and our citizenry to meet these costs, the benefit must be sufficiently large to justify the demand. What we said about the lawsuit brought against the Treasury was, "Show us a problem that exists. Then we'll join in urging that it be solved." 

Of course the currency contains identifiable visual markings for the sighted. Why could it not also contain tactilely identifiable markings for the blind? Undoubtedly such currency could be manufactured. However, if no need for it has been demonstrated, the decision to produce such currency is a matter for policy determination by the government rather than a requirement imposed by law. 

On November 28, 2006, the Federal District Court for the District of Columbia issued a Memorandum Order declaring that the Treasury of the United States discriminates against the blind when it fails to issue tactilely identifiable currency. In this decision, the court said, "Most people with low vision, and all blind people, are incapable of looking at American currency and distinguishing one denomination from another. In order to know whether the bill in her hand is worth $5 or $50, a blind person must ask someone else for help or use a machine that can identify the denomination and speak it out loud." Although the court decision is many pages in length, this passage is at the heart of the ruling. The paper money of the United States is not tactilely identifiable. Blind people cannot identify the paper money without the help of a sighted person or of a machine. The government could have produced tactilely identifiable money. The cost to do so is small when compared to expenditures for creating a national currency system. Consequently the court ruled that discrimination has occurred and that the government is required to adopt a plan to issue currency that the blind can identify without help. 

In 2002, shortly after the lawsuit had been initiated, the National Federation of the Blind considered the assertion of discrimination. As a result of the discussion, the Federation adopted Resolution 2002-25. This resolution states:

WHEREAS, on May 2, 2002, the American Council of the Blind (ACB) and two individual plaintiffs filed a lawsuit against the secretary of the Treasury of the United States and the treasurer of the United States alleging that the federal government is in violation of Section 504 of the Rehabilitation Act of 1973 as amended, 29 U.S.C. Section 794, by issuing all U.S. currency in an identical size, color, and texture, which renders various denominations indistinguishable by touch, alleging that the blind are thus largely excluded from enjoying the benefits of monetary transactions and seeking declaratory and injunctive relief by requiring the Department of the Treasury to implement design changes in the currency to make the various denominations distinguishable by touch and color; and

WHEREAS, this lawsuit is based on a false and misleading assumption that the inability to distinguish banknote denominations by touch largely excludes the blind from participating in commerce and other ordinary activities of life; and

WHEREAS, the theory of this suit is disproved by the lives of tens of thousands of blind persons who live normal lives and participate in commerce every day without difficulty; and

WHEREAS, more than having difficulty with money, blind people are apt to suffer great harm from the attendant publicity surrounding this suit, fostering and reinforcing the notion that the blind cannot easily handle currency as it now exists and, for example, needlessly creating an albatross around the neck of any blind person seeking employment in any position involving handling money; and

WHEREAS, to the extent that currency identification is truly a problem for individual blind people, various technological devices capable of identifying banknotes and audibly announcing their denomination are available for sale, and in fact giving every blind person in the country such a device would be simpler and cheaper than re-engineering the nation's cash-handling capacity; and

WHEREAS, in view of its false premise and lack of merit, there is little likelihood that the relief sought by this lawsuit will ever be granted, thus using the blind in a publicity stunt and showing little regard for the genuine needs and concerns of blind people; and

WHEREAS, more than the adverse publicity resulting from the filing of this suit itself, there is a substantial risk of a ruling that could nullify the potential benefits of Section 504 by narrowing its scope and coverage or the law altogether, as has happened with other recent court decisions in the area of disability: Now, therefore,

BE IT RESOLVED by the National Federation of the Blind in Convention assembled this ninth day of July, 2002, in the City of Louisville, Kentucky, that this organization take all appropriate and legally available steps to advise the court that the failure to have U.S. currency issued as sought by the plaintiffs in this suit is not an act of discrimination against the blind and in such a fashion that the accompanying ruling does not harm current and future efforts to achieve genuinely needed and desirable accommodations for the blind; and

BE IT FURTHER RESOLVED that this organization take steps to counter the adverse effects of the harmful publicity arising from this particular lawsuit and renew efforts to educate the public that the blind can participate in commerce on equal terms and fully enjoy the benefits of U.S. currency as it now exists.

What is the harm that this ruling of the federal court is intended to stop? Blind people use currency-most of the time without problem and even without much conscious worry. Can blind people be defrauded? Of course we can. The opinion of the court says, "Unable to identify the value of paper money without help from others, blind and low-vision individuals are always at risk of being cheated." What the opinion of the court does not say is that sighted people who can identify currency are themselves always at risk of being cheated. The assumption of the judge who wrote the opinion is that the inability to see increases the risk. Is this true, or is it simply an assumption? How often does cheating of the blind occur? Has anyone demonstrated that the blind are cheated more often than the sighted? If this demonstration has not been made, what is the basis for declaring that discrimination exists? 

The blind people with whom I have discussed the matter believe that cheating is rare. Comments to me indicate that blind people are cheated no more often than sighted people are. However, although the judge did not have evidence of a pattern of cheating, he did express an opinion. He said, "The frequency of such acts against blind and low-vision individuals [acts of cheating] is impossible to measure because victims may not know that they have been deceived unless someone tells them." This statement indicates the judge's fundamental misunderstanding of blind people. 

Blind people are not so lacking in discernment that we don't eventually discover when we have been defrauded. If somebody were to defraud me of my money, sooner or later I would notice. Part of the process of managing money is having a sense of how much there is. When the money is suddenly gone, it is not hard for me to know that it has disappeared. For the judge to assert that I wouldn't notice when my money is gone is an indication of the capacity he attributes to me as a blind person. Inasmuch as the judge has admitted that the record in the case does not contain evidence of a pattern of cheating, the decision he makes is based upon fear--his fear of the potential for fraud even though no evidence of it exists. Because blind people might be defrauded, the judge asserts that we face the inability to participate in the program of the United States which prints and distributes currency, and he determines that our inability to participate results from the failure of the Treasury to produce tactilely identifiable money. This failure, he says, is discrimination. The decision is based on speculation and emotionalism--not fact. 

Shortly after the issuance of the decision by the federal judge, I submitted a guest editorial to the New York Times for consideration, which was printed on December 18, 2006. It says:

In a ruling in a lawsuit last month, Judge James Robertson of Federal District Court said that United States currency discriminates against blind people because bills are all the same size and cannot be distinguished by touch. His decision was applauded by some advocates for the blind, including the American Council of the Blind, which brought the lawsuit. But as president of the National Federation of the Blind, the nation's oldest and largest organization of the blind, I believe that Judge Robertson's ruling is wrong.

Discrimination occurs when the blind are barred from enjoying benefits, goods, or services. This definition of discrimination is what most people understand the word to mean. If a landlord refuses to rent an apartment to someone because of race, color, creed, or disability, then discrimination occurs. Sometimes people with disabilities are barred from certain facilities or services because of the way they are designed. A person in a wheelchair cannot climb the steps of a public building; if the building does not have a wheelchair ramp, that person is prevented from entering it. In another example, my group is suing the Target Corporation because the company's Web site doesn't accommodate the special text-reading software that the blind use to surf the Internet. In both cases a person with a disability is kept out of a public place or denied use of a service, just as African Americans were not welcome at whites-only lunch counters.

But while blind people cannot identify paper currency by touch, that does not prevent us from spending money. When we hand merchants our money, they take it and provide us with the goods or services we have paid for, no questions asked. People with whom we transact business provide us with correct change if needed, and we then organize the money in a manner that allows us to identify it in the future. We transact business in this way every day. 

There is no evidence that the blind are shortchanged more often than the sighted; if a question does arise about a particular transaction, it is the responsibility of the blind person to sort out the matter. Identifying money by feel, as the blind are often able to do in many other countries, may be more convenient, but inconvenience is not the same thing as discrimination.

While it is crucial that minorities have a voice in society, it is also the responsibility of every minority group to use that voice wisely and not to cry "discrimination" when no discrimination has occurred. The blind of America will fight discrimination wherever we find it, but we achieve nothing by falsely portraying ourselves as victims and engaging in frivolous litigation.

Part of the nuisance of blindness is managing printed documents. Until print disappears (which I suspect will not be soon), blind people will have to find a way to read it. Print is everywhere, and getting at the information it represents is one of the elements of the problem that blind people have. When methods for managing the information that is presented visually have been devised, claiming discrimination to alter the printed matter is unreasonable. This is true even if it would be desirable to create tactile representations of the print. 

Charging the government, business owners, or individuals with violation of the law is a serious matter. It should not be done unless there is serious harm to redress. Built into consideration of discrimination based on disability is the notion of reasonable accommodation. Sometimes it is essential that print be modified for blind people to participate in a program. Unless the modification alters the nature of the program, the change is required. Reasonable accommodations are demanded by law unless they would cause an undue burden to the entity making them. Consideration of discrimination, therefore, incorporates the notion that an alteration in a program or activity must provide sufficient benefit to be worth the cost. If the cost is great and the benefit is small, no discrimination exists. In this case no demonstration of urgent need has been made. Consequently, the decision of the court is unsupported

 

www.washingtonpost.com/wp-dyn/content/article/2007/03/16/AR2007031602113.html <http://www.washingtonpost.com/wp-dyn/content/article/2007/03/16/AR2007031602113.html> 

Washington Post, USA

Saturday, March 17, 2007

Letter: Time to Fold the Dollar

By THOMAS E. McMAHON

Saturday, March 17, 2007; Page A18

The headline on Gordon Legge's March 10 letter, "U.S. Dollars: Feel the Difference," pointed to the solution to the problem our nation's 900,000 blind and visually impaired residents face in distinguishing among denominations of paper money. Replace the dollar bills with coins.

Half of all paper money in circulation is dollar bills. Hence, half of the problem blind people encounter recognizing money would be solved by phasing out the dollar bill and phasing in the presidential dollar coins now being issued. Mr. Legge, who is visually impaired, noted that coins are easier for the blind to use because of their two tactile features: variations in size and in edge.

He cited the euro currency's tactile features that make Europe's money more user-friendly for the blind. But he failed to mention the most important feature -- the euro, now worth about $1.30, is a coin, not a note.

Because dollar bills circulate for about 20 months, and dollar coins last more than 20 years, the federal government would save at least $600 million a year in paper and ink costs by substituting coins for bills.

These savings would yield more than twice the amount needed to provide every legally blind person in the country with a lightweight, hand-held, reliable currency reader. Currency readers would enable blind people to conduct transactions quickly and confidently.

If Mr. Legge's solution -- the redesign of U.S. currency -- is adopted, bill acceptors in at least 1.5 million food and beverage vending machines, most of which are already capable of accepting dollar coins, will have to be retooled or replaced at a cost of between $150 million and $500 million.

THOMAS E. McMAHON

Senior Vice President and Chief Counsel

National Automatic Merchandising Association

Herndon