Scope

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 following Air Quality Action Plan documents which are in PDF format.

Benefits of making accessible

The benefits of creating accessible versions of these PDFs would be:

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

These statutory documents have been produced by Oxford City Council, following a DEFRA template.

The most recent document was formally approved by Cabinet on 11 February 2026 and officially signed off by DEFRA on 18 February 2026.

The reports are quite extensive (84 pages + 26 pages - 110 pages in total), and have lots of data analysis and relevant 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 5 working days to make each document fully compliant with accessibility rules. 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 25 February 2026 (for the most recent document).

Other factors
  • We are legally required to make the documents available to the public as per the air quality statutory duties that have been brought by Environment Act 1995 and DEFRA's Local Air Quality Management Regime, so the documents must be published on the Council's website
  • Given the nature of their content and that it contains detailed analysis and assessment of current air quality levels in the city and the complete list of future air quality measures that City and County anticipate to be delivered between 2026 and 2030, all of which is of valuable interest to councilors, officers and members of the public, there is the need to publish these documents in a timely fashion, so we took the decision to publish them as PDFs
  • We had already published on our website an earlier version of the city’s Action Plan (in 2021) 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
Assessment

Due to the nature of the documents, they contain a high number of charts and tables which take more time to convert to an accessible format than text alone.

We estimate that it would take 5 working days to create a fully accessible version of each of the documents and this would place an undue burden on the Council, given the small number views received per year.

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.

Date of assessment

20 February 2026

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