Air Quality Annual Status Report documents - Disproportionate burden assessments for digital accessibility

Accessibility legislation (on legislation.gov.uk website) states

that public sector websites must publish content in an accessible format, unless doing so would impose a disproportionate burden on the organisation. If that is the case, an assessment of the extent to which compliance with the accessibility requirement imposes a disproportionate burden must be carried out.

This is a Disproportionate Burden Assessment for each of the Annual Air Quality Status Reports which are in PDF format:

The benefits of creating an HTML version of this PDF would be:

a fully accessible version for all users to access
an easily searchable and indexable version

We are required to make the Air Quality Annual Status Reports available for consultation on our website as part of our commitment to transparency and because of our statutory duties on air quality under the current Local Air Quality Management Framework (LAQM).

The reports are produced by Oxford City Council, but follow a strict report template and structure, which is provided by DEFRA. This makes compliance with accessibility rules and formats much more difficult to control.

The reports are also quite extensive (approximately 90 pages each) and very complex in nature, with a significant amount of technical analysis, charts and data tables, which would take a huge amount of time to convert into accessible formats.

We estimate that it would take around 7 working days to make each document fully compliant with accessibility rules based on an estimated time of around 30 minutes per page. This would place an undue burden on the work of the Environmental Quality Team, who would be tasked to do all this work.

Also relevant to this decision are that:

We are legally required to produce this report on an annual basis, and to make the document available to the public (under the Environment Act 1995 and the LAQM regime), so the document must be published on the Council’s website
This document follows a specific report template that is sent to us by DEFRA, and that Oxford City Council is required to follow
Given the nature of its content and that it contains the results of the latest status of air quality levels in Oxford, as well as the latest progress on the delivery of local air quality measures, which are both of valuable interest to members, officers and members of the public, there is the need to publish this document in a timely fashion, so we took the decision to publish the PDF
Every year we publish an Air Quality Status Report on our website and to date we have never received any requests for an accessible version of the report
Should any data from the report be requested in an accessible format, we will be happy to assist

Due to the nature of the document it contains a high number of charts and tables which take more time to convert to an accessible format than text alone.

We assess that the time it would take to convert the document to an accessible version would place an undue burden on the council.

However, should there be a request for information contained within the document in an accessible format, we will be able to provide the data in text format.

We will also make the key findings from the report available to the public via a detailed press release.

19 June 2025

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