From: gtrapp@abq.com
Subject: braille production
Mike Thompson, my friend and neighbor to the South, has posed a
interesting series of questions that raise legal, practical, and
philosophical issues.  While he probably already has an idea of my
thoughts, I would like to weigh in on the discussion. 
Legal Considerations
The ADA does not require that braille be produced by persons who
are certified.  The requirement for an institution such as a state
university like NMSU is that the governmental entity communicate
with persons with disabilities as effectively as with persons who
are not disabled.  It does not matter  who produced the braille,
only that the braille which is produced effectively communicate the
information.
The regulations implementing the sign language requirements of
Title II may be helpful at this point.  The regulations do not
require than an interpreter be certified.  Instead, the regulations
require that a interpreter be qualified to do the interpretation. 
The ADA regulations (and guidelines) indicate that an interpreter
who is certified is not necessarily qualified, and that a qualified
interpreter is not necessarily certified.
I believe that this can also be the case when looking at braille
production.  For instance, I have known certified braille
transcribers who had not kept up their skills, and who were not
qualified.  Also, it must be kept in mind that certification in
literary braille would not mean that the person was qualified to
produce Nemeth or music braille.  In addition, there are a great
many braille transcribers who are not trained to use a computer
translation program to produce braille.  By contrast, there are
certainly many blind persons who are not certified, but who are
capable of producing high quality braille.
The public policy reasoning behind the ADA requirements is clear. 
The purpose is to encourage to the maximum extent possible the
broadest range of effective communication.
Practical and Philosophical Considerations
As Federationists, we believe that blind persons can compete on
terms of equality with sighted persons.  For example, we believe
that blind persons can be qualified cane travel instructors without
having AER certification.  Indeed, the requirement for
certification has historically stood in the way of blind persons
obtaining quality cane travel instruction, and has kept many
qualified blind cane travel instructors from obtaining work.  In
this case, the requirement for certification has clearly hurt blind
persons.
In addition, and perhaps most importantly, if the task of braille
production becomes too specialized, we may reduce the availability
of braille.  There are just not enough certified and qualified
braille transcribers to go around.  This is also the case for sign
language interpreters.  For example, it is often difficult to find
interpreters who can work in rural areas of New Mexico.  Also, the
cost of sign language interpreters typically ranges from 25 to 40
dollars per hour, with a 2 hour minimum.  As might be imagined,
raising the requirements for braille production could create a
serious obstacle to braille availability.
I believe that we should take advantage of modern braille
production technology to maximize the amount of braille that is
available.  I do think that certification should be a goal that is
strived for, but lack of certification should not be an obstacle to
braille production.
It is my belief that a college or school should normally be able to
produce adequate braille through the conscientious use of  a good
braille translation program, and with the help of a capable blind
proof reader to review documents as a quality assurance check.  I
also believe that most of the problem begins with the format of the
original source file, and that some simple word processing rules
make for much better braille translation.  For instance, many
secretaries use a word processor like a typewriter, using tabs,
spaces, and hard returns  to align words and sentences.  Obviously,
this can lead to garbled braille.  However, by following some basic
formatting rules, most of the braille production problems can be
eliminated at the source.  Of course, some braille projects, such
as upper level math or science, may be beyond the capability of a
translation program and a proof reader.  In such cases, the college
or school should send the project to be brailled by qualified
outside professionals.
A comment in one of Mikes messages deserves some clarification.  In
his NFB-talk message, he said that "...nobody at NMSU reads
braille, much less holds any transcriber's credentials."  I am
confused by this comment, as it is different from my understanding
of the situation at NMSU.  One of the persons responsible for
braille production at NMSU was at the NFB convention in New
Orleans, where he used a slate to write a braille math equation for
my fiance, Tonia Valletta.  In addition, the proof reader who works
for this person at NMSU is a native braille reader, a former
student at the New Mexico School for the Visually Handicapped, and
Secretary of her NFB chapter.
Conclusion
I believe that NMSU has all of the elements for an excellent 
system of braille production and services.  Mike Thompson has done
a commendable job of facilitating universal access to computer
stations, including computer station access to braille printers. 
NMSU is also home to a program designed to make math more
accessible to blind and visually impaired students.  It seems to me
that all that is needed is to work together and coordinate
services.  Indeed, it is exciting that NMSU is giving such a
significant amount of attention to accessible computers and braille
production.  As the kinks are worked out, the result will hopefully
lead to an increase in the amount of quality braille available to
students.
Greg Trapp
Please Note: the foregoing comments are only my personal opinions. 
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