Oxford Waterways Air Quality Guidance document - 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 the Oxford Waterways Air Quality Guidance document which is in PDF format.

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

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

This guidance document has been produced by Oxford City Council, but is funded by the DEFRA Air Quality grant, and has already been approved for publication by DEFRA.

The report is quite extensive (almost 40 pages in total), and has lots of information including charts, graphs and images. It would take a significant amount of time to convert this into accessible formats.

We estimate that it would take around 3 working days to make the document fully compliant with accessibility regulations.

This would place an undue burden of work on the Environmental Quality team who would be tasked to do all this work and would result in the delay of our publishing target of 22 January 2026 to mark Clean Air Night.

Also relevant to this decision are that:

• We are legally required to make the document available to the public as per the grant funding agreement with DEFRA, so the document must be published on the Council’s website
• Due to the nature of this content, there was a need to publish the document quickly, so we took the decision to publish the PDF
• Interest in the document is expected to be low - it was developed for boat dwellers in Oxford, which we think numbers about 200
• The document does meet accessibility requirements for a large number of users, although some groups will find it disproportionately difficult
• We have and will always assist with accessible versions on request

Due to the time constraints in publishing this document - which has already been delayed as part of the DEFRA grant fund from 2022 - 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 in the document in an accessible format, we will be able to provide the data in text format.

We are also raising awareness of this document by social media (LinkedIn) to mark Clean Air Night, so we need the document published immediately.

22 January 2026