              ARCHITECTURAL BARRIERS FOR THE BLIND:
                    THE MYTH AND THE REALITY

     On Friday afternoon, July 3, the delegates to the 1992
convention of the National Federation of the Blind settled down
to examine the vexed question of dealing appropriately with the
alleged architectural barriers that are supposed to endanger
blind people on every side. Studying and then stipulating methods
of warning us about these hazards has consumed time and attention
from the American National Standards Institute Committee on
Accessibility for several years. 
     The Federation's position has been that most of these
supposed dangers are imagined and the rest can be easily and
efficiently detected by proper use of the long white cane or
guide dog. Since society can never install warnings at every
location in which some person with insufficient vision might be
hurt, we would do far better to concentrate our efforts on
improving the quality and availability of travel training in this
country so that all Americans with limited vision can move about
safely.
     Almost a year ago, President Maurer asked the Federation's
Second Vice President Peggy Pinder to attend the upcoming
meetings of the ANSI Committee on Accessibility as the NFB's
representative. In her Friday afternoon speech, Miss Pinder told
the audience what happened when she took that assignment. Here is
what she said: 

     ANSI has long been a sort of joke in the National Federation
of the Blind. I first heard of ANSI in the mid-seventies as the
people who thought that the blind needed detectable tiles and
knurled doorknobs. For years, ANSI (which stands for the American
National Standards Institute) symbolized misguided officialdom--
people who decided how to rebuild the world to take care of
problems they thought the blind had without ever once consulting
the blind ourselves. 
     Knurled doorknobs were invented by somebody as a tactile way
of alerting the blind that they were about to enter a hazardous
area. These included stages, boiler rooms, and loading docks--all
places where blind people I know work. The concept was that the
blind didn't know where they were, didn't know where they were
going, and wouldn't find out until it was too late unless the
sighted people around them built cues into the environment to
warn them of danger. We laughed and used ANSI as an example of
willful wrong-headedness. 
     Detectable tiles emerged from the same premises. These were
defined as deliberately shaped or roughened areas within the
walking surface, placed to alert the blind that there was danger
ahead. The dangers included those same loading docks as well as
transit platform edges, streets, and parking lots. As the concept
of detectable tiles grew, it metastasized into a cure-all for all
the travel ailments of the blind, not only warning us of dangers
but also providing what is called "wayfinding," the marking of a
path so that the blind can detect it with cane or foot and follow
the markings to the destination. Again we laughed. Didn't these
people know that canes or dogs, used and controlled by the blind
person with good training and experience, already provided us
with all the information we needed for safe travel and for
wayfinding?  Didn't they care?  Apparently not. They never asked
us if we wanted the detectable tiles. They just standardized them
and supported their installation. 
     All of this had long been part of my background when
President Maurer called me last November to give me an
assignment. He said that he needed me to go to an ANSI committee
meeting. 
     I didn't actually refuse to go. I tried to temporize, to
suggest alternatives, to raise doubts as to whether anybody
really, really needed to go. Mr. Maurer waited me out, every now
and then patiently reiterating the assignment. When I got done, I
had, of course, agreed to go. I thought one of the two of us must
have flipped, and I was pretty sure it was me. Go to ANSI, that
group of narrow-minded, humorless, professional custodians who
had entertained us for the past fifteen years with their updates
of the new paternalism and whose 1986 standard had suddenly been
adopted more or less complete in the federal accessibility
regulations? I couldn't really think of very many places I'd less
rather be! And I went. 
     Through conversations with other ANSI accessibility
committee members, I learned that my assessment of the ANSI
committee had once been accurate. However, as the building code
and manufacturer communities began to take accessibility more
seriously in the mid-'80's, ANSI had decided to assign one of its
veteran trouble-shooters to the accessibility committee, Mr.
Richard Hudnut. Although he has never said this himself, I gather
from the bits and pieces of history I have heard from others that
Mr. Hudnut reached much the same conclusion we in the Federation
had reached about the ANSI accessibility committee, and he dug in
to make changes. He recruited fine minds and strong people from
all sectors affected by the accessibility standard, using his
long service and distinguished stature in the standards community
to attract others who shared his commitment to effective,
cost-efficient problem solving. When I arrived for the meeting in
December as the representative of the National Federation of the
Blind, the ANSI standard was much improved from the almost
archaic 1986 version now largely copied in federal law. The only
parts that hadn't changed much at all since the mid-seventies
were those dealing with the blind. Knurled doorknobs were gone,
but the detectable tiles were there in profusion, now grown to
cover the edge of every parking lot and reflecting pool and the 6
feet in front of every corner in the country where there is a
ramp. Detectable tiles are now defined scientifically as "raised
truncated domes with a diameter at the base of nominal 0.9
inches, a height of nominal 0.2 inches, and center-to-center
spacing of nominal 2.35 inches and shall contrast with adjoining
surfaces, either light on dark or dark on light."      In
addition to all these protections for the blind, I found that
ANSI had somehow gotten the wrong standard for Braille, a
standard which lacked the specification of all five dimensions
necessary to define Braille. The Braille standard required
production of a dot much higher than we see in books, yielding
signs that are actually painful to read, and it failed to
prohibit what amounts to proportional spacing in Braille,
allowing a signmaker to push cells together to save space, and
actually making the Braille incorrect. For example, alarm if you
push it together in Braille becomes tharm. And I've seen a sign
that said exactly that.
     The Braille was no problem. I had with me a copy of the
National Library Service for the Blind and Physically Handicapped
Specification 800 from its engineering manual. I also did a
little drawing, tracing around a penny to create a diagram of
three Braille cells. On this penny drawing, I then displayed the
various relationships that had to be defined and controlled. I
told the committee that the NLS specifications had been the
standard for Braille in this country for more than fifty years,
for so long, in fact, that NLS no longer has records about when
it was first adopted. Wherever the other standard came from, it
wasn't the one everyone used, and it was producing Braille
different from that to which we are all accustomed. The ANSI
committee promptly and a little irritably adopted the NLS
standard with some muttering under its breath about who had
foisted off upon it some other standard than the standard
standard. 
     In light of the Braille discussion, it is interesting to
review the committee membership. In addition to people
representing the three model building codes, numerous disability
groups, manufacturers of various products, and state and federal
accessibility officials, membership has long been held on this
committee by the American Foundation for the Blind and the
American Council of the Blind. The American Foundation
representative served as chairman of the membership committee and
strongly opposed the NFB application for membership on the ground
that ACB already represented the blind on ANSI. Although no one
from the NFB was in the room, the ANSI committee voted thirty-
three to three to admit the NFB to membership. During the Braille
discussion at the December meeting, both AFB and ACB remained
silent, and neither chose to answer the questions regarding where
the wrong standard had come from or why the right one was never
presented before. 
     During the week-long December meeting, I spoke to anyone who
would listen about the NFB's objections to truncated domes. Many
of the people with whom I spoke indicated that they had no idea
that the domes were unnecessary, hazardous in themselves, and
expensive. They said that they would be glad to remove them. In
addition, people who had worked with the domes waxed quite
eloquent about problems of installation and maintenance. The dome
discussion at the December meeting took place on Friday afternoon
with a thin crowd present, and my motion to delete the whole
section failed by one vote. I was horrified since I could count
at least four or five people who would have voted for the motion
if they had still been there. Well, I thought, there will be
another meeting in June. We can work between now and then. 
     I discussed the setback with Mr. Maurer and told him that I
thought there was probably a group of other people in the same
position we were--knowing that the current draft of the standard
wasn't right yet. I suggested that, if we cooperated with these
other committee members by voting negatively on the standard and
working for further change, our combined strength might prevail.
I suggested that the same group might serve as a broad-based and
strong force for advocating change in the Architectural and
Transportation Barriers Compliance Board (ATBCB) rules based on
the improved ANSI standard. He told me to try it. 
     The NFB worked with building owners and managers, state
building code officials, and other disability groups in voting no
and seeking further change. At the same time, our arguments had
taken root, and the committee leadership had decided that ANSI
should be published as it stood and used as the basis for asking
ATBCB to change its rules. Our group of negative votes threatened
both the consensus and the plan for immediate publication. I got
numerous calls, assuring me that "we can get the tiles out next
time." But, if we wanted to get rulemaking started, we would have
to go along and play by the rules and let the detectable tiles
stay in this standard since any change in substance would delay
publication of the standard for at least a year.
    Again I discussed all this with Mr. Maurer, and he decided
that the Federation should vote against the draft standard anyway
and seek elimination of the domes before we agreed to the
standard. As he put it: "The Federation isn't afraid of making
people mad. What we are afraid of is failing to stand up for the
dignity of blind people. We won't ever do that. Go for it." 
    My job was to take Mr. Maurer's instructions and translate
them into reality. As usual, he told me to do the thing which
would build the best future for blind people. I went for it! The
problem was to find a way of getting the domes out without
triggering a backlash against the Federation. One track for this
activity involved helping the building code people see that they
could play an important role in changing the federal regulations
which also have domes in them. It was necessary to get the power
of a broad array of support for eliminating the domes from the
federal regulation. In fact, we had been so successful in
convincing the code people to work to change the federal regs
that they began pushing hard for immediate publication of the
existing ANSI standard as promised without removing the dome
language. They argued that, having delivered the ANSI document on
time, the Committee would have a solid position from which to
pressure the federal government into changing its regulations.
The second track was yet to be found. 
    I went to Chairman Hudnut. I just plain told him what the
problem was:  the Federation could never support a standard with
the domes in it, and yet the Federation didn't wish to cause
unnecessary trouble. I asked him if he, with his long experience
on ANSI committees, saw any way out of the dilemma. I did not
know Mr. Hudnut's position on truncated domes then, and I do not
know it now. He has never said, and he has never voted. But I had
confidence in him that, as an active and committed chairman, he
would provide advice to any committee member who sought it. He
did, explaining to me the method to use to dump the domes and
still publish this year.
    Mr. Hudnut also pointed out that, using the same procedure, a
member such as the Federation which had voted negatively could
decide to change its vote to affirmative, thereby strengthening
the consensus which ANSI seeks for its standards. 
     The truncated dome discussion at the June meeting a month
ago took almost three hours. The AFB and ACB explained how
necessary these tiles were and how important it was to have
precise measurements. Here is the summary of the Federation's
arguments against the domes as I filed them in voting negatively
on the standard:
     1. Truncated domes in particular and detectable tiles in
general are unnecessary for the blind and unsafe for everyone.
Without tiles and domes blind persons now move safely throughout
the current environment, proving that tiles or domes are
unnecessary to achieve access. 
     2. When achieving their intended purpose (interrupting
normal cane use), tiles or domes actually pose a hazard to the
blind cane user since they deliberately break the normal flow of
information through the cane at precisely those points in which
normal information is most vital. 
     3. Tiles or domes potentially pose a safety hazard to all
persons since they will stubbornly retain ice, snow, and debris;
pose an ongoing maintenance problem; and catch the heels or
wheels of unwary passers-by. The domes are sort of like
symmetrical little cobblestones, a surface we have given up for
many good reasons, including safety and maintenance. 
     4. The studies which claim to show the necessity and value
of domes or tiles are methodologically flawed and are all based
on the assumption that tiles or domes are necessary, the exact
point that is not yet proven. 
     5. The Federation is supportive of accessibility for all
disabled people and is concerned that the domes or tiles, applied
widely, will constitute an accessibility barrier for persons
using wheelchairs and for those with other mobility impairments. 
     6. The Federation is vigorously opposed to the installation
of domes or tiles on subway platforms and specifically urges that
these not be installed unless and until there is specific
evidence that they are needed because: 
     a. Locations with known drop-offs such as subway platforms
are areas in which cane users are particularly sensitive about
interference with normal cane use, and interference is
specifically intended by installation of the domes or tiles; and 
     b. The Federation believes strongly that accessibility
should be affordable as well as effective. Recent estimates from
a large metropolitan transit authority indicate that retrofitting
a single station will cost at least $40,000 (for the tiles alone,
not for any of the additional retrofitting) and that ongoing
maintenance of the installation will, over time, cost even more. 
     Once again, the blind are being forced to insist that we are
already safe; can already handle the responsibility of watching
out for our own safety; and do not need others to take care of us
under the guise, this time of that new buzz word of the '90's,
"accessibility."  In other words, I said to ANSI that we blind
people have the tools and the knowledge and the ability to find
our way ourselves, that we take this responsibility for ourselves
as other Americans do and gather the information we need from the
current environment to do it safely and efficiently just as other
Americans do. We don't need the world re-engineered for us. We
use it as it is. What we need is good training and good attitudes
about ourselves. Then just turn us loose and leave us alone. We
will be fine.
     Others at the ANSI meeting joined in. Numerous committee
members indicated that they simply were not convinced that the
expense and disruption were necessary. For example, you
Californians know about the BART statistics. In the San Francisco
subway system detectable tiles were installed on every platform
edge. But the statistics show large decreases in accidents before
the tiles were installed and actually showed an increase after
installation. A representative of people using wheelchairs said
that the people he represents believe the tiles may very well
pose a difficulty and even a complete barrier to persons in
wheelchairs and with other mobility impairments. 
     The elevator guy pointed out that his industry has been
compelled to spend millions on devices to level elevator cars
precisely; why then, he asked, are others being instructed
deliberately to unlevel walking surfaces? The hotel guy pointed
out that experience in his industry shows that the occurrence and
severity of slip-and-fall accidents can be inversely correlated
with the amount of foot surface one has in contact with the
walking surface. The domes are designed to reduce the walking
surface on purpose. 
    When the vote was finally taken, the count was nineteen
against the domes and only seven in support. The domes and
detectable tiles of any kind are out of the standard. 
    With the ANSI standard much revised and strengthened in
general, with Braille correct, and with the "detestable" tiles
(as I have heard several federal officials call them), removed,
the ANSI standard is now for the first time something close to
what we in the Federation would like. There are still problems,
but they are minor compared to the ones we have already solved.
The next step is to help to bring about changes and improvements
in the federal regulation by teaming up with other like-minded
folks whom we have found through ANSI. 
    So, President Maurer, I went as you asked and did as you
directed. We now can look forward to a day when detectable tiles
are in nobody's standard anywhere. There is work to do, but we
now have friends and contacts all across the country with whom we
can work to make these changes. So far as I'm concerned, nobody's
laughing at ANSI any more. 

     Richard Hudnut, Chairman of ANSI's Committee on
Accessibility, followed Peggy Pinder to the podium. He confessed
later that he had not been sure when she began her remarks where
she was heading. He was much relieved when it became clear that
she had been pleased by the Committee's recent activity. 
     In addition to chairing the Committee on Accessibility, Mr.
Hudnut serves on the American National Standards Institute Board
of Directors and chairs its Appeals Committee. He has also served
as an independent consultant retained by the Builders Hardware
Manufacturers Association for the past twenty-seven years, and he
has occupied a number of other positions that demand shrewdness
and practical good sense. Here is what he had to say: 
 
     I understand now why Peggy didn't tell me what she was going
to say; I'm not sure what I'm going to say. But I'll struggle
through it just the same. I was going to say that my introduction
was more generous than it was deserving; however, with some of
Peggy's remarks I'm going to be very modest and say, "Yeah, it
was deserving." Although I have met a few blind people in my
life, this is the first time I have had a chance to speak to an
audience largely composed of blind persons. I am glad that so
many of you have gathered, have made the decision to take your
lives into your own hands and to make decisions for yourselves. I
also know that there are far too many people in our country who
have not yet realized that our fellow citizens who are blind are
and should be fully welcomed into our society. There is
unfortunately still a great deal of prejudice, misunderstanding,
and inequality in our society. I hope that this message today
will describe for you at least one step toward the elimination of
these.
     My topic is the activities of the American National
Standards Institute A117 Committee on Accessibility. When one
thinks of access, people in wheelchairs generally come to mind,
and indeed the arrangement of building elements to make travel
and building usage possible for these people is more obvious to
most, for example, than Braille on elevator car controls.
     The Committee responsible for writing the ANSI A117.1
Standard is made up of a number of special interest groups both
from the building user and the building owner points of view.
Additionally, there are representatives of the building code
enforcement community, manufacturers of products being regulated
in some fashion, and various groups involved with disability. At
present the committee membership is made up of organizations
representing these constituencies. We have recently determined
that individuals not sponsored by a specific organization, but
with expertise not presently represented, should be eligible for
committee membership. In short, the objective is to offer
participation to every entity having a direct and material
interest in the content of the Standard and who can contribute to
its worth.
     The genesis of the ANSI process is consensus, a word also
very important to your organization. ANSI has worked for decades
on approving standards for almost anything you can think of. When
an ANSI standard is desired, ANSI requires the people who would
be affected by the standard (i.e., manufacturers, users,
builders, building code people, experts in the area) to be
represented. Under the ANSI banner, these people are gathered
into a single room and encouraged to reach a consensus, forging
the concepts and phrases which will literally standardize safe
and efficient design and use of whatever the standard covers. In
effect we use the country's motto: Out of many, one. ANSI has
been very successful in supporting this over the years, and the
standards it approves are used daily in numerous areas. When
accessibility became a topic of discussion, ANSI accredited the
A117 committee in the early seventies to begin the forging of a
standard that would distill into usable words the how-to of
access.  
     The content of the Standard covers a very broad array of
subjects, and it is for this reason that the committee membership
is quite large, about fifty as a matter of fact. This entails
presentations by those with mobility impairments, those who are
deaf, those who are blind, those with restricted use of their
limbs, and those who speak as advocates without having any of
these disabilities. Those of us on the Committee who are not
identified with a cause or type of disability sometimes find
ourselves in the difficult position of listening to disagreements
among the advocates of the people we are attempting to serve.
This is part of what happened in the detectable tile discussion.
     We also hear from those with a different sort of self-
interest involving the required use or non-use of products or the
configuration, size, and placement of such products. We can at
least to an extent overcome the zealous product manufacturer
looking for what I call the legislated sale. While there are many
products that undeniably may make things somewhat more
convenient, these products are not necessarily essential for
access or egress. However, when these products are championed by
a segment of those interests we are attempting to serve, such as
a disability group, we must then pay attention. This is another
part of what happened in the detectable tile discussion.
     As so eloquently expressed by your leadership, people with
sight are not the experts on blindness. People who are blind are
the experts on blindness. But when two organizations, each made
up of people who are blind, flatly disagree on a given issue, it
poses a problem. We then find ourselves in the unenviable
position of choosing sides. Naturally this involves listening to
the two or possibly more points of view and deciding which is the
more persuasive. 
     While blindness is obviously a disability in the strict,
descriptive sense of the term, it certainly does not strike me as
a devastating, life-ruining condition. Instead, I find your
position that it is nothing more than a nuisance is much more
accurate. It reminds me of a process we are going through in
revising the building codes by mainstreaming the provisions in
A117.1 that are regarded as equally beneficial to all people
whether physically disabled or not. I know that the most common
use of the term "mainstreaming" in your organization refers to
choices of educational settings. However, in the building code
context we use "mainstreaming" to mean the insertion of
requirements in a building code that are applicable to everyone.
One example in the accessibility context for which some people
have resisted another kind of mainstreaming is emergency building
evacuation. As for me, I totally reject and resent some emergency
evacuation plans I have seen prohibiting people with disabilities
from using the exit stair enclosures. And who are these disabled
people?  Those who are blind, among others. The justification? 
"The guide dog might cause problems. The cane might trip people.
The disabled would slow egress for those who are not disabled." 
And other silly reasons. What is even more distressing is the
understandable lack of outcry by disabled persons victimized by
these silly restrictions for fear of losing employment.
     The controversy over tactile cues symbolized by the use or
non-use of truncated domes was an especially difficult problem
for the A117 committee. They are required by the Access Board
Guidelines. They were proposed and tentatively adopted by the
A117 Committee, and it was not until the National Federation of
the Blind became active on the Committee through the very
effective participation of Peggy Pinder that we became aware of
the disagreement among people who are blind as to the usefulness
of truncated domes--difficult because it went beyond an argument
among people who are blind. It included concerns expressed on
behalf of people in wheelchairs, people who use walkers or canes,
and others who saw what they perceived as a possible tripping
hazard.
     In other words the whole truncated dome discussion taught me
that we have not yet perfected the networking method necessary to
bring all of the views we need to everyone's attention in time
for enlightened study and action. Without the full range of
views, which most certainly includes the expertise and advocacy
of the National Federation of the Blind, the ANSI Committee on
any given issue is in danger of adopting criteria based on
emotional gut reaction, even if it seems instinctively incorrect.
In this instance, the NFB position will likely prevail because it
was felt by most to be the most enlightened. At any rate, a
substantial majority of the Committee (Peggy gave you the vote)
chose to agree with the NFB position and removed the requirement
for truncated domes, as did the Board for the Coordination of
Model Codes, a group under the Council of American Building
Officials, which also serves as the Secretariat of the A117. 
     Let me talk a moment about my frustration over the lack of
coordination among the provisions of the ANSI accessibility
standard, the Access Board guidelines, and the ADA itself. The
Access Board guidelines were largely based on pre-existing Board
criteria and the ANSI standard published six years ago. Members
of the ANSI Committee updated, revised, improved, and
strengthened our new accessibility standard using the ANSI
consensus process. So the new standard about to be published is
somewhat different and we think better than the Access Board
guidelines. We would like to help the Access Board further
improve its guidelines as well as bringing about standardization
among standards. With this in mind, both the A117 Committee and
the Board for the Coordination of Model Codes (BCMC) will be
recommending to the Department of Justice to begin rule-making
procedures to resolve this and other issues.
     I know that your organization knows about ANSI, ADA, ADAAG,
BCMC, and DoJ. The Americans with Disabilities Act itself is
certainly the most widely discussed civil rights enactment, with
more impact than any such legislation since the original Civil
Rights Act in 1964. I know that your organization had
reservations about the ADA from the beginning and insisted on the
inclusion of a provision which allowed any disabled person to
refuse special treatment of any kind. Without this provision you
believed that the ADA could become a source of segregation of the
blind. With it you have determined to work hard to make sure that
the ADA does not come to separate and stigmatize the blind. You
are in the forefront of working to make ADA a true civil rights
act instead of another link in the chain keeping the blind out of
full participation in society. That President Bush consulted with
your Executive Director Dr. Jernigan relative to this Act and
conferred upon him the Distinguished Service Award is a great
tribute to him, but more important, to all of you--the members of
the National Federation of the Blind.
     Thank you so much for listening, and I hope you will go away
from this session with hope for the future and the knowledge
that, working together, we are making significant progress. 

     That is what Richard Hudnut said in his remarks at the NFB
convention. Until a last-minute illness kept him at home,
Lawrence W. Roffee, the executive director of the Architectural
and Transportation Barriers Compliance Board (ATBCB) was to have
taken part in this panel presentation. He subsequently sent Peggy
Pinder a copy of the remarks he had intended to make, and they
are particularly interesting because they express the views of
the man who heads the ATBCB. He began by observing that "The NFB
has the reputation of being one of the better organized and
articulate advocacy organizations." He went on to summarize the
NFB's philosophical position on architectural barriers as he
understands it: "For too long many people--those with various
disabilities and those without disabilities--have made
assumptions about the relationship of people who are blind to the
built environment. There have been too many incorrect assumptions
about the abilities of people who are blind.
     "Ms. Pinder's comments to the Board on our recent request
for information on our research agenda are particularly
appropriate. She wrote: `My plea to the ATBCB is to begin, not
with studies, but with careful thought about what is being
studied and why. Assumptions about blindness and its effects on
the abilities of the people whom it affects are so deep in the
human psyche that they must be consciously identified and
rejected before proceeding with any study.'
     "The same," Mr. Roffee continued, "can be said about
assumptions about any person with any kind of disability. The
Access Board is now finding that assumptions about the abilities
of a variety of people with disabilities are incorrect or at
least need to be closely questioned. It is becoming quite evident
that many of the early studies that underlie most current
accessibility standards are based on questionable assumptions....
The Board will be examining and giving careful thought to the
basic assumptions that underlie many of the technical standards."
     A little later he said, "I think it is becoming more and
more accepted that legislation cannot be passed for people with
disabilities, regulations cannot be developed for people with
disabilities, accessibility standards cannot be developed for
people with disabilities, and local businesses cannot make their
establishments accessible for people with disabilities." He went
on to state his hope that the time is coming when everyone will
recognize the necessity of doing these things with disabled
people. He summarized his thought by saying: "The [ATBCB]
standards must be based on reality and cannot stigmatize any
sector of the public." 
     Mr. Roffee's prepared remarks concluded with a paragraph
that, even in his absence from the convention session, captured
the view of everyone in the room at the close of this fascinating
agenda item. He said, "I think that it is possible to take the
myth out of accessibility. There are many indications that it is
starting to happen. You and I know that it will not happen
overnight. We also know that there will be numerous political
battles along the way. On behalf of the Access Board, I look
forward to working with this organization, the ANSI Committee,
and many other organizations to make it happen and get rid of the
myth."
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