Accessibility regulations: disproportionate burden assessment
This disproportionate burden assessment is part of our website accessibility statement.
Designated sites search
The Designated sites search area of our website holds collections of management plans and supporting documents. There are over 1,400 of these sites and the library of documents has been built up over many years. There are now over 10,000 documents most of which would either be difficult to transform or could not be changed as they are signed documents drafted to support the application of the designated status and the formation of the management plan.
While most of these documents pre-date 23 September 2018, we class these as guidance documents and we need to support accessible access.
Our assessment
As part of our assessment for disproportionate burden in relation to the collection of 10,000 documents for designated sites, we've identified two activities that we believe would be necessary in order to comply with the accessibility requirements:
1. Cost of a full and complete analysis
We would need to review all the documents through a manual, visual review, to understand whether a full conversion to an accessible version was possible based on content. This would enable us to define a set of actions for each document to ensure there was either a new accessible version or appropriate explanatory notes to ensure accessible users were fully catered for.
Time/Cost
- 1 extra person reviewing 2 sites per day (assuming a minimum average 6 documents per site) would take 700 working days to complete
- at least 3 extra people would be needed to deliver this analysis in a year
- at least 6 extra people would be needed to deliver this analysis in 6 months
- cost would be at least £83,000 (based on appropriate NRW PayScale)
2. Cost of execution following the complete analysis
Time/Cost
- 1 extra person updating 2 documents per day would take at least 21 years (based on updating or providing text alternative for all 10, 000)
- at least 21 extra people would be needed to deliver this in a year
- at least 42 extra people would be needed to deliver this in 6 months
- cost would be at least £580,000 (based on appropriate NRW PayScale)
Note: We are not aware of any requests for accessible formats relating to any of these documents and we attribute this to the low download rate we see for most designated sites documents.
Summary
The combined cost of the above activity is high and the relative benefits for users is small. We need to keep focused on high use documents and application forms, especially those that would immediately be more beneficial for our customers that have accessibility needs.
NRW is committed to support accessible needs as much as possible and we will respond to all requests from users that relate to these Designated Sites to support them with their needs.