Introduction Slide: Speaker Presentation

NASA CIO Perspectives on Section 508 Implementation
by Lee Holcomb, NASA Chief Information Officer

Slide 1: Introduction
Section 508 touches all areas of Electronic and Information Technology and its implementation is proving to be complex
For this discussion, we will consider four key implementation areas:
Acquisition considerations
Applicability of Section 508
Web pages
Training and education of our workforce

Slide 2: NASA CIO Perspective on Acquisitions / the first of 2 slides
The Federal Acquisition Regulations (FAR) specifies that requiring offices conduct market surveys to determine whether products are available in the market place that conform to specific provisions of the Access Board Standards.
Both government and industry are concerned about potential legal action associated with Section 508-related acquisitions since at least some of the Access Board Standards are subject to interpretation: yes">today we lack objective measures to determine conformance.
The Voluntary Product Accessibility Template (VPAT) was developed by industry to assist the Government in conducting market surveys

Slide 3: NASA CIO Perspective on Acquisitions / the second of 2 slide
While the VPAT is a reasonable transition approach, our early experience indicates VPAT is not the final answer.
Excessive resources expended by requiring offices to interpret and deal with VPAT entries.
Some major vendors do not mention VPATs for their products on their web site.
Some major vendors require contacting their sales representatives to obtain information on Section 508 compliance of their
products.
When exception for micro-purchases expires, problem will be greatly magnified for credit card buyers.
We believe aggressive effort to define objective measures for determining conformance, leading to certification, is critical

Slide 4: NASA CIO Perspective on Applicability / the first of 2 slides
Section 508 applies to all electronic and information technology with a very few exceptions, e.g.,
Undue burden
Lack of market availability
National security crypto systems
However, there are applications of technology where perhaps it is not reasonable or practical to expect conformance with Access Board Standards
Inevitable given the scope of Section 508

Slide 5: NASA CIO Perspective on Applicability / the second of 2 slides
By analogy, design of space suits for Extra-Vehicular Activity (EVA) cannot practically accommodate all extremes of physical demographics (height, weight, etc.)
We suggest that similar exceptions for electronic and information technology applications are appropriate and should be added.
Would reduce unnecessary costs and delays.
Would allow focusing on procurements where Section 508 can make a real difference.

Slide 6: NASA CIO Perspective on Web Access / the first of 2 slides
NASA has huge, distributed, web resources
FirstGov cites over 4 million .nasa.gov web pages (about half publicly accessible)
Each center operates own sub-domain with multiple web hosts
Management of web content is distributed
Process underway to aggregate hosting of web resources at specific locations
Effort underway to put in place strong content management tools, at all sites, that will include evaluation of Section 508 compliance
NASA creates new and has major archives of multimedia
Formats include Flash, QuickTime, AVI, MPEG, PDF, PPT specialty image formats
Accessibility encoding of live data streams technologically limited
Alternative access not always possible in same time frame as media-rich stream
Accessibility encoding of production multimedia hampered by diversity of media players

Slide 7: NASA CIO Perspective on Web Access / the second of 2 slides
NASA challenges with respect to accessible legacy web pages
Consolidation of disparate web resources
How to bring archive sites up to accessible status
Elimination of duplication
Multiple “kids” pages, multiple “live data” sites, multiple stale web sites
Improving web-structure hierarchy and navigation capabilities
Space Science, Earth Science, Human Spaceflight and Aerospace web sites located at multiple NASA centers, allied universities
Multimedia
Some multimedia content creation tool vendors lagging
NASA solutions being worked or piloted
NASA Centers have submitted plans for web page remediation per our policy
New content-management solutions
Portal technology
Improve navigation capabilities
Focus on different audience segments
Allows for possible major improvement in accessibility

Slide 8: NASA CIO Perspective on Education / the first of 2 slides
NASA has distributed management and skill sets
10 Centers, HQ, and additional facilities
Multiple IT support organizations
Despite current best efforts better awareness of Section 508 needed
Education approaches
CIO-led training effort
Cross-cutting team includes IT groups, EEO offices, training offices, procurement
Agency-wide awareness online training module under development

  1. Phase 1 is awareness for all NASA and contractors
  2. Subsequent phases aimed specifically at supervisors, contracting and EEO officers

CIO-led Agency working group
Leveraging best practices for PDF, JavaScript, Java, Cold Fusion and other CGIs
Piloting and testing vendor solutions

Slide 9: NASA CIO Perspective on Education / the second of 2 slides
Topics for future training modules include improved/expanded guidance for:
Best value
Vendor self-assessment of conformance
Compliance certification
Training, purchase and distribution of vendor tools
Site licensing and individual licensing works against NASA with its distributed approach
Some assessment and repair tools not very useful because of limited MIME support
Rapid evolution of tool sets mitigates against any major investment in acquisition and training just at the time global
distribution of these tool sets would be useful
Not all tools provide operability across all relevant platforms
Some work uniquely on Unix systems, others on NT