LETTERS TO THE EDITOR

LETTERS TO THE EDITOR



Another group comes up short

I read with interest 'Feds shoulder burden of technology worker shortage' [GCN, March 5, Page 16]. One bone of contention is the lack of mention of Series 334 computer specialists within the Defense Department's Civilian Acquisition Workforce Personnel Demonstration Project. We also were excluded from the January specialty pay increase.

It should be noted that most of us are not actually in acquisition billets but suffer the consequences as if we were. Although GCN, as well as numerous other publications have reported on Federal Aviation Administration employees who did not receive the pay raise, we in DOD without the benefit of a union to represent us are seldom mentioned.

I have attempted to get an explanation for our exclusion from the raise. The latest word is that our current appraisal system would be used as the forum for catching us up on pay. But that hasn't occurred.

I am writing to request that you give us due coverage on this issue. We are without a voice.

June M. Helligrath

Head, Systems Branch and program manager for ammunition

Marine Corps Systems Command

Quantico, Va.

Read Section 508's fine print

Your recent article, 'Section 508 becomes this year's Y2K' had a lot of good information [GCN, April 2, Page 1]. And Section 508 certainly is a Y2k-like issue.

The story, however, is built around an assumption, stated near the end, that I don't believe to be true. The story said: 'If an agency system is not compliant by the deadline, a disabled user can file a complaint with the Access Board, a federal unit that can grant injunctive relief. The user can also take civil action against an agency.'

I have done some research and attended some forums, both to learn about the issue in general and to learn when it is to take effect. The following are my conclusions.

There seems to be some confusion about how quickly agencies are required to be compliant with Section 508 accessibility requirements and also what items are covered. Clearly, this coming June 21 is a key date, being six months after the Access Board published its standards, as required by the law.

Some people are rushing to have everything in place by June 21. That is not required.

The first place to go to resolve this question is the statute itself. The entirety of the Section 508 statute may be viewed at www.section508.gov/docs/508law.html. The section relevant to 508 effectiveness reads:

'(f) ENFORCEMENT.'

'(1) GENERAL.'

'(A) COMPLAINTS.'Effective six months after the date of publication by the Access Board of final standards described in subsection (a)(2), any individual with a disability may file a complaint alleging that a federal department or agency fails to comply with subsection (a)(1) in providing electronic and information technology.


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'(B) APPLICATION.'This subsection shall apply only to electronic and information technology that is procured by a federal department or agency not less than six months after the date of publication by the Access Board of final standards.'

People reading only the complaints paragraph might conclude that all government agencies must be ready by June 21 or else.

Any individual with a disability can complain after June 21, but the question is what they can complain about. What they can complain about is defined in the application paragraph and is limited to procurements made after June 21.

The term 'procurements' definitely refers to contracts or task orders signed after June 21, either for new electronic and information technology or for modifications to existing technology. Section 508 clearly does not apply to items placed in service prior to June 21. It has no retroactive requirement.

The only fuzziness here might be about items purchased before June 21 but placed into service after June 21. It should also be noted that because the relevant language in the Federal Acquisition Regulation has just been finalized, 508 compliance probably has not been written into any contract, task order or request for proposals so far.

Jim Battle

Consultant systems engineer

Electronic Data Systems Corp.

Herndon, Va.

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