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Disproportionate Burden


East Lindsey District Council is committed to meeting the requirement to make websites accessible, set out by The Equality and Human Rights Commission (EHRC) who is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the 'accessibility regulations'). 

However, we have a complex collection of websites and limited resources to check them all for accessibility issues.

You can read our approach to checking our websites, and how we've assessed what we consider a disproportionate burden.


Our approach to carrying out accessibility checks

We've decided to use a combination of methods for our organisation, as set out in GOV.UK guidance on deciding how to check your websites and in compliance with the No.2 Regulations.

Checks included:

·       Manual testing based on GOV.UK's guidance on doing a detailed accessibility check

·       Automated testing of the new website using accessibility monitoring software (Silktide)

·       Audited by Shaw Trust Accessibility Services

Our Accessibility Statement for East Lindsey District Council covers problems highlighted by the checks and our plans to fix them.  


Disproportionate Burden


Many of the PDFs that are inaccessible on our website consist of legal documents and guidance documents containing maps from the 1970s - 1990s.

Whilst the guidance documents could be transcribed, this would cost an estimate of £5,000 per document and as there are 57 documents in need of transcribing, this would total = £285,000.

There are currently no funds to do this, and we propose any funding made available would be better spent towards commissioning updated documents given some are nearly fifty years old.

The legal documents which also do not comply with Accessibility Regulations have to be the original signed copy and cannot be altered in any way. By law these documents need to be accessible to the public. Whilst the mitigation would be to encourage the public to ring and ask if they are within a conservation area, this increases phone calls to the Council and increases unnecessary workload.

Therefore, having the legal documents online, in their inaccessible format allows more people to access them should they need to. It is likely that these documents will need to be replaced in the future and if funding is obtained the Council would look to transcribe remaining documents or commission new ones in accessible formats.


The Council has no budget towards commissioning accessibility experts and has no in-house resource to make each PDF on the website accessible. Although we understand updating the PDFs would dramatically improve the accessibility of the website, many of these PDFs are not viewed regularly and/ or are third party documents. Therefore, we do not believe the cost of time, effort and resource needed to fix these issues are justified.