We are fully committed to making documents accessible, ideally creating them as HTML web pages, or where PDF documents are required, making sure they meet accessibility guidelines. This would ensure that information is fully accessible to all users and content would be more easily searchable.
Having carried out a detailed check of www.norwich.gov.uk we've assessed that it would be a disproportionate burden within the meaning of the accessibility regulations to fix the accessibility issues of all PDF, Word and Excel documents published on www.norwich.gov.uk since 23 September 2018, unless they are required for essential services or used by people with disabilities.
As the situation changes this will be reviewed as to whether it continues to remain a disproportionate burden.
PDF documents
There are approx.1,500 PDFs published from 23 September 2018 (not including council meeting documents and planning application documents) that have accessibility issues.
It would be beneficial for everyone if all the documents were accessible, but the majority of them are rarely viewed and therefore unlikely to negatively impact users with disabilities or impairments. However, we will provide alternative versions of them when requested.
For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified.
Cost of fixing documents
A sample of PDFs suggests approximately two hours of officer time is required, on average per PDF, to review and make it fully accessible. Therefore, to make the 1,500 PDFs (since September 2018) accessible would take 405 days (if working on nothing else) at a cost of approximately £40,000, which is beyond current resources, given the need to ensure ongoing council services.
Assessment of costs and benefits
The cost of assigning staff or procuring external support to fix these documents would be a substantial burden on us and not a justifiable use of public money.
The benefit to visitors with disabilities to our website of this work being carried out would be limited due to the low usage of the majority of the documents.
Instead, we believe that they would benefit most from us focusing our available resources on fixing the most frequently used documents published since January 2021 or making them into web pages, and ensuring that any new documents are compliant.
We will prioritise fixing any documents that are essential for services or used by people with disabilities irrespective of the publication date. We will then concentrate on reviewing our less frequently used documents.
Our organisation's size and resources and nature
Norwich City Council is a local authority managing increasing front-line service demands (eg waste and recycling collection, housing, planning, environmental health) but reducing annual budgets.
From 2020 we have been forced to reprioritise resources owing to the Covid-19 pandemic, ensuring business continuity of essential services focusing mainly on Covid-19 response.
We have very small, dedicated teams resourcing web content management and web development and additionally have had to help deliver a variety of projects as well as maintaining the existing website and functionality.
Examples of PDFs and other documents on our website
We aim to provide an alternative accessible version of documents if requested to.
Consultation documents
Nearly 25 per cent of the PDFs published during 2018 and 2021 are for consultations and a public Inquiry. Many of these documents are complex with maps and charts and tables or are scanned responses from the public.
In some circumstances, for example responses to planning consultations or inspections, there is a legal requirement to publish documents in restricted timeframes.
We have concluded that as these consultations are closed the work involved to make them accessible would be a poor use of staff time and represents a disproportionate burden on the organisation.
For new consultations we will aim to provide accessible formats where possible.
Food hygiene Inspection reports
We have approximately 950 food hygiene reports on our website, many of which are only partially accessible. It would not be in anyone's interest to spend time making all these compliant as premises inspections are carried out very regularly and reports are updated.
Every PDF is run through the Adobe Acrobat accessibility checker and easy fixes are carried out. We will prioritise making any new reports from January 2022 fully compliant and work back through the 2021 reports ensuring each business has an accessible version.
Fully accessible templates for these reports are currently being worked on and are expected to be completed by end of March 2022.
Licencing applications
We are required to publish applications for premises/tables and chairs/pavement licences for 28 days to allow for comments. These documents are initially scanned so redactions can be made before being saved as PDFs and are needed to be published quickly for consultation.
Due to the complex nature of the elements of these documents and the short length of time they are placed on the website, along with a low demand for them, we have concluded that the work involved to make them fully accessible would be a poor use of staff time and represents a disproportionate burden on the organisation.
Planning applications
Documents that support planning applications are provided to us by third parties (eg architects and members of the public) and may include scans of plans or handwritten letters. We may not be able to confirm the accessibility of these documents.
Forms
We have forms published as Word documents and PDFs which are essential to providing our services. These are under review to either fix or replace them with accessible online forms irrespective of their original publication date. Expected completion date end of May 2022.
Transparency documents
We publish monthly financial reports for transparency purposes as PDF, Excel and CSV files. We are working to ensure that all documents since 2018 are accessible. Completion date end of April 2022.
Committee documents
These PDFs are located within a document management system provided by an external supplier, which is currently being upgraded to address accessibility issues. Timescales to be confirmed.
We are reviewing procedures for making the committee documents fully compliant. We aim to have this completed by end of April 2022.
Although we are unaware of any requests for fully accessible versions of these documents, we will always assist with such requests.
17 February 2022
