The acuity listings which have been used for many years are based on a Snellen acuity. The Snellen chart has no measurements between 20/100 and 20/200. Thus, anyone with acuity of less than 20/100 has been considered eligible. Many low vision assessments not have many increments between 20/100 and 20/200. If the Administration is going to move away from the Snellen acuity measurement, then the standard for legal blindness based on acuity should be anything less than an acuity of 20/100. 20/100 minus one should thus qualify as legally blind.
I do not support the idea that someone would be considered legally blind for many years, and then suddenly, because the listings change, find that they are no longer legally blind. Changes in listings should not be used to knock people off of the roles.
Currently, distance acuity is the measurement used. As people who are legally blind age, like many normally sighted individuals, they often become more far sighted. Thus, it is possible for a person to gain vision as they pass middle age from an acuity standpoint, but then at the same time, lose reading and close work visual acuity and function. This situation should not knock a person off of benefits either. Legal blindness should thus be considered a loss of either best corrected distance vision or best corrected reading vision at eight to ten inches, or whatever number of inches are normally used in measuring reading and close work acuity.
Testing should be based on functional vision. Many people, if they stare at a chart for an extended period of time, can achieve greater acuities than are present by an initial look at the chart. The vision which should be evaluated is the functional level of vision that a person can access without extreme straining and concentration not normally available on the job or in practical use of vision in our society.
Fatigue factors should also be considered. It is possible to place a low vision eye under extreme magnification and get additional measures of acuity for that eye. It is usually not possible, however, for an individual to achieve that level of acuity through extreme magnification over an eight hour work day.