Accessibility regulations: disproportionate burden assessment

This is the disproportionate burden assessment for digital accessibility conducted for www.medway.gov.uk.

This assessment was last updated on 21 April 2023.

Having carried out a detailed check of www.medway.gov.uk, and assessed our resources and the cost of fixing issues, it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix all documents published on www.medway.gov.uk since 23 September 2018. 

This means we are not able to create fully accessible versions of these documents. The individual assessments set out our reasons.

Typical accessibility issues

The inaccessible documents typically do not meet the following WCAG 2.1 success criteria:

  • success criterion 1.3.1 info and relationships (Level A)
  • success criterion 1.3.2 meaningful sequence (Level A)
  • success criterion 2.1.1 keyboard (Level A) including merged table cells
  • success criterion 1.4.3 contrast (minimum) (Level AA)
  • success criterion 1.4.5 images of text (Level AA)
  • success criterion 1.4.10 reflow (Level AA)
  • success criterion 1.4.12 text spacing (Level AA).

Documents with multiple complex accessibility issues

Some documents are more complex and would need specialists to fix them. These are listed below:

Planning policy documents

There are about 190 inaccessible planning policy documents on medway.gov.uk. The main accessibility issues are merged table cells, formatting, and insufficient level of detail of alt text on maps, charts and diagrams.

They include:

  • 66 Local Plan evidence base documents with a combined total of 1,386 unique page views over the last year. We estimate it would take 100.27 working days to make these documents accessible. The staff costs would be £10,565.
  • 18 Local Plan development option consultation responses documents with a combined total of 31 unique page views over the last year. We estimate it would take 37.56 working days to make these documents accessible. The staff costs would be £5,012.
  • 21 Local Plan development options documents with a combined total of 669 unique page views over the last year. We estimate it would take 13.78 working days to make these documents accessible. The staff costs would be £1,452.
  • 14 Local Plan consultation responses documents with a combined total of 94 unique page views over the last year. We estimate it would take 38.64 working days to make these documents accessible. The staff costs would be £4,072.
  • 20 Medway Strategic Land Availability Assessment documents with a combined total of 907 unique page views over the last year. We estimate it would take 65.27 working days to make these documents accessible. The staff costs would be £6,877.
  • 28 Development strategy documents with a combined total of 2,374 unique page views over the last year. We estimate it would take 15.4 working days to make these documents accessible. The staff costs would be £1,623.
  • 7 Planning issues and options documents with a combined total of 128 unique page views over the last year. We estimate it would take 33 working days to make these documents accessible. The staff costs would be £3,481.
  • 7 Environmental appraisals documents with a combined total of 44 unique page views over the last year. We estimate it would take 9.4 working days to make these documents accessible. The staff costs would be £989.
  • 9 Development plan saved policies documents with a combined total of 194 unique page views over the last year. We estimate it would take 5 hours to make these documents accessible. The staff costs would be £71.
  • 4 parts of the Medway Aimsun Local Model Validation Report. Previous versions of these documents had 25 unique page views over the last year. We estimate it would take 10.8 working days to check these documents and make them accessible. The staff costs would be £1,134.

Innovation Park consultation and Masterplan documents

Many of the Innovation Park consultation and Masterplan documents were supplied by a third-party design agency. We asked the agency to provide a quote to fix the accessibility issues with the Innovation Park Medway Design Codes document. We've based costs for the other documents on their estimate.

Accessibility issues include small fonts, colour contrast, layout issues, and insufficiently detailed alt text for photos, diagrams and maps. To fix the documents they would need to create new documents from scratch.

These following documents are inaccessible:

Statement of accounts documents

Statement of accounts from 2015 to 2019 are not accessible. There was a combined total of 15 unique page views for these documents in the last year. It is likely to take 22.7 working days to make these documents accessible (based on a 7.4-hour working day at Medway Council). The staff costs would be £2,392.

Resilient Network Map

The Resilient Network Map is not accessible as all map points are not described. The document has had 12 unique page views in the last year. We estimate it would take 3 working days to make this document accessible. The staff costs would be £305.

Allotments sample invoice

The allotments sample invoice is not fully accessible. We cannot easily make it accessible as it must look exactly like the printed version that has already been sent to those who need to pay their invoice. Last year's document had 137 unique page views. We estimate it would cost about £500 to make an accessible version of this document.

Bus service improvement plan

The Bus service improvement plan is not fully accessible. The previous version of the document had 38 page views over the last year. The document is 85 pages long, with charts, maps and graphs which do not include alternative text. We estimate it would cost about £1,000 to make an accessible version of this document.

Cost of fixing other inaccessible documents

There are about 520 other inaccessible documents on medway.gov.uk.

It's difficult to know how long it would take to make every document on www.medway.gov.uk accessible without first reviewing each one. 

However, if it took an average of 2 hours to review and fix each document within scope, fixing 520 would take 140 working days (based on a 7.4-hour working day at Medway Council). The staff costs would be £14,700.

Assessment of costs and benefits

We believe that:

  • the costs of fixing all documents on www.medway.gov.uk would be a disproportionate burden on our organisation
  • the benefit to users of paying for and assigning staff to fix all documents on www.medway.gov.uk (taking into account the low level of usage for most documents) would not be justified and would impose a disproportionate burden on Medway Council.

In reaching this decision, we have considered the following:

Our organisation’s size and resources

Medway Council is a local council managing increasing front-line service demands (for example, adult and children's social care) but reducing annual budgets.

Between 2020 and 2022 we have also been forced to re-prioritise resources owing to the coronavirus (COVID-19) pandemic, ensuring business continuity of essential services.

The nature of our organisation

We do provide services aimed at people with a disability. The documents provided to help disabled people use those services are all accessible.

The estimated costs and benefits for our organisation: in relation to the estimated benefits for persons with disabilities, taking into account the low level of use

We believe that:

  • maintaining statutory and essential front-line services should be prioritised over paying for little-used documents to be made accessible
  • it would be reasonable within the meaning of the No. 2 Regulations for us to use any available budget to fix the inaccessible documents.

Our Digital team is leading the detailed check of www.medway.gov.uk. However, the team is small, and the scale of fixing inaccessible documents - in addition to their other essential functions - means they lack the capacity to fix all inaccessible documents.

How much users with a disability would benefit from making all documents accessible

Our users will benefit from us making our websites and online documents accessible.

However, we do not believe that for most of our inaccessible documents the extra improvements that could be gained from making the documents accessible would justify the cost.

We also believe that users will benefit most from us focusing our available resources on fixing the most used documents on www.medway.gov.uk and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities.

How to get information in an accessible format

If you need information on this website in a different format like accessible PDF, large print, easy read, audio recording or braille you can fill in our online form:

Request information in an accessible format

Or you can phone 01634 333 333.

We’ll consider your request and get back to you in 20 working days.