Visually impaired deserve better currency

New York Times: ?In a decision that could drastically change the appearance of American money, a federal appeals court panel ruled ? that the United States discriminates against the blind because the country?s paper currency is the same size regardless of a bill?s value.? (May 20, 2008, nytimes.com)

The court of appeals decision is momentous. The decision upheld a November 2006 ruling of a Federal District Court. That is two favorable decisions out of a possible three (circuit court) or four (Supreme Court). However, both decisions went a bit further than the New York Times? lead paragraph. Both courts stated that the visually impaired could not distinguish U.S. currency by touch. That is different than stating that the size of U.S. currency must be changed.

The Treasury Department, through the Department of Justice, could appeal further the latest decision. But should they? What options are available to the Bureau of Engraving and Printing?

The BEP and the Federal Reserve System have wrestled with a change of currency to accommodate the visually impaired for at least 30 years.
Frankly, I thought some of the recent changes to currency beginning in the 1990s would offer an additional accommodation for the visually impaired.

In 1985, as I remember, I was practically hooted off the stage at a national convention of the blind in a cavernous hall at a Holiday Inn just off the Strip in Las Vegas. I had the temerity to suggest we use some form of sensor to read the denomination of currency, similar to a minimal change to currency and the use of a device as Canada had recently done. Before I could proceed, there were guffaws from the crowd and a shout, ?We do not need another device to carry.? The rest of my talk was downhill. My conspicuous, well-groomed attire as director of the BEP made no impression either.

The question and answer period did offer interesting bits of information, ?Braille markings are not the best alternative, because most people become blind as adults and do not learn Braille.?

?Some of the blind might be able to decipher raised dots as used on some European currency.?

?There is a unique distinction between being blind and being visually impaired. The totally blind are a relatively small number, while the visually impaired in various degrees are much more numerous and a remarkable statistic.?

I mentally filed this information along with the ??no new devices that we have to carry.?

I returned from Las Vegas quite chastened by the event. I met with Theodore ?Ted? Allison, the former secretary to the Fed board and now the senior Fed management person and Peter ?Pete? Daly, BEP deputy director. We agreed that I should speak with Katherine Davalos Ortega, treasurer of the United States, and chair of the inter-agency Counterfeit Task Force, and ask the treasurer to make the issue a priority at the next Task Force meeting. The director of U.S. Secret Service was the third member of the Task Force and would have to concur on changes to currency.

Treasurer Ortega too was in agreement that something should be done and she directed that the BEP should increase its effort to find a solution that would be an accommodation to the visually impaired and be of a minimal expense. Thus began an intense effort that followed actions taken by our predecessors, Task force chair, U.S. Treasurer Angela ?Bay? Buchanan, William ?Bill? Wallace of the Fed, Director Harry Clements of the BEP, and Director Stuart ?Stu? Knight of the Secret Service.

Lenore Clark, BEP, de facto lead staff member of the Task force, had to research previous attempts to allow U.S. currency to be accommodating to the visually impaired. She was assisted by Thomas Ferguson, chief of currency printing, who subsequently became BEP director in the late 1990s.

The Task Force initially thought of changing the size of U.S. currency in the manner as delineated in the 2006 decision by Judge James Robertson of the Federal District Court. However, it was reasoned that there would be an insurmountable expense of retooling the BEP presses, inspection machines, and overprinting and packaging equipment; and the cost to change consumer equipment would be monumental ? such as money-changing machines, food and merchandise dispensing machines , and other assorted vending machines ? if such a change of currency was initiated by Treasury.

The most obvious secondary means to distinguish currency were: (1) clip the corners of currency, a total of five potential changes; (2) notch the currency on the top or bottom; (3) punch holes in the printed currency; and (4) raised intaglio dots on the portrait side of the currency. Unfortunately, these four changes were quickly discarded. U.S. currency would degrade at a perceptibly higher rate and most of these devices could be quickly counterfeited. Clipping, punching holes and notching would quickly degrade U.S. bank notes. Raised intaglio dots would also break down with use and add to confusion if one or more dots were suppressed.

U.S. currency is probably the longest currency to remain in circulation due to the 90-gram paper weight, the extensive intaglio printing, and the care that U.S. consumers show their currency. Long periods of circulation save the Fed considerable funds when purchasing currency from Treasury. Also, the higher denominations are hoarded in many other countries primarily as a hedge against inflation.

Frankly, I would disagree with the court?s thesis that the denominations of U.S. currency should necessarily be of different sizes. That simply is not the best means to accommodate the visually impaired. Even as Judge Robertson wrote in 2006, that the government discriminated against the blind by printing its currency as a single size. He cited the statistic that the U.S. was the only one of 180 countries that issue paper currency that utilizes one size for all of its denominations. However, most of these countries print a relatively low volume of currency and their currencies are printed by commercial printers. Those countries that do print their own currency have relatively few presses in comparison to the United States and run those presses for periods sometimes but four hours per day.

Virtually all commercial printers charge extensive amounts for printed currency and those countries that print their own currency have a much higher cost ratio than does the United States.

The same size for all U.S bank notes is not the problem. Rather, it is establishing a means or more than one method by which the visually impaired can distinguish the denominations of U.S. currency. The convenience of a single size can be a blessing to the visually impaired as it is of commercial value to the Fed and BEP.

Twenty-five years ago, before the advent of the yellow pen that detects counterfeit U.S. bank notes, 85 percent of counterfeits were detected by store clerks or bank tellers who recognized money by touch ? the feel of the intaglio printed cotton fabric and the weight of the fabric.

It impresses me that the visually impaired wish to concentrate on the feature of ?feel? first and then look for another identifier. It is similar to the intaglio portrait on U.S. currency. Users look at the portrait first to ensure that the portrait is intact, imposing and striking. Most users do this unconsciously as the visually impaired would do by touch or by the ?feel? of currency.

Today, there are many sensory authenticators that are available that can be recognized by one or more of the human senses. Albeit, the number of sensors are limited for the visually impaired are somewhat limited.

What immediately comes to mind are sophisticated holograms that can have an anti-counterfeiting advantage as well as an identifier for the visually impaired. H olograms can be produced that will withstand the BEP?s vaunted crumple test, but have a raised image that can be identified by the visually impaired. They can also have an identifier that can be read by a machine for those visually impaired that run the Randolph Shepherd (Act) stores.

The BEP has a small arsenal of devices that will benefit the visually impaired. When implemented on currency they can resolve the problem that confronts the visually impaired as how to identify both U.S. currency and distinguish the denominations.

As the New York Times article cited above stated, ?A lawyer for the American Council of the Blind, which brought the lawsuit in 2002, said it hoped that the government ?instead of litigating the issue, would solve the problem.??

There is an Authentication Connections Forum, by Reconnaissance International, Shepperton, U.K. (www.reconnaissance-intl.com) in Prague, Sept. 16-18, 2008, that will explore the technical features and benefits of both sensory and digital authentication. (The author consults with Reconnaissance on authentication.)

Robert J. Leuver is a former director of the Bureau of Engraving and Printing.