Why Digital Accessibility for Transportation Agencies Is a Different Conversation

Most digital accessibility guidance assumes you have a website and you need to make it accessible. That advice is not wrong. But if you are a state DOT, an MPO, or an AEC firm delivering content under a DOT contract, it is incomplete. In this first episode, Becky Rehorn walks through four factors that make digital accessibility for transportation agencies a fundamentally different conversation: federal funding that creates a second layer of accountability through FHWA and FTA, public involvement mandates under NEPA and 23 CFR 450 that make online participation a legal prerequisite, contractor-produced content that leaves the compliance obligation with the agency and the relationship risk with the firm, and document libraries with hundreds or thousands of PDFs that have never been reviewed for accessibility. Read the full post and download the ADA Title II Readiness Checklist at aogaccess.com.

Transcript

SPEAKER_00 0:00

This is Access Brief from Accessible Organizations Group. I'm Maya Carter. Each week we look at a different dimension of digital accessibility for transportation agencies, public engagement processes, and the AEC firms that support them. Today, why the Digital Accessibility Conversation for Transportation Agencies is fundamentally different from the generic guidance you'll find elsewhere.

SPEAKER_01 0:27

And that difference matters because a lot of the advice out there is written for a regular business website. Useful, sure, but for a state DOT or an MPO, it leaves out the stuff that actually keeps people out of trouble.

SPEAKER_00 0:43

Exactly. The standard itself is not different. Under the DOJ's ADA Title II final rule, WECAG 2.1 level AA is the target, but the ecosystem around that standard is a whole lot more complex for transportation agencies than it is for, say, a retail brand or a local library website.

SPEAKER_01 1:06

Right, four factors really change the conversation. And the first one is federal funding. DOTs are not just dealing with ADA Title II, they are also operating in a federal highway administration and federal transit administration environment, with Title VI and Section 504 obligations layered in.

SPEAKER_00 1:25

So accessibility is not just a website issue. It becomes part of the agency's federal relationship.

SPEAKER_01 1:33

Exactly. When an agency cannot show that its public information and participation processes are accessible, the risk isn't limited to a DOJ complaint. It can ripple into grant oversight, Title VI planning, and the broader trust that sits underneath every federally funded project.

SPEAKER_00 1:53

That's a big distinction. For transportation agencies, this isn't a nice-to-have compliance checkbox. It's tied to how the whole funding and oversight system works.

SPEAKER_01 2:05

And the second factor is public involvement. Commercial websites engage the public because they want to. Transportation agencies engage the public because they are required to.

SPEAKER_00 2:17

Which is a huge difference.

SPEAKER_01 2:20

Huge. Federal law, including NEPA and 23 CFR 450, requires public participation in environmental review and transportation planning. So when those processes move online, which they absolutely have since 2020, every comment portal, virtual public meeting, story map, and interactive dashboard becomes part of the agency's Title II scope.

SPEAKER_00 2:46

So an inaccessible online comment form is not just a broken form. It is evidence that a required public participation process may have excluded people who rely on assistive technology.

SPEAKER_01 3:01

Exactly. And public involvement plans matter a lot here, too. They are not just internal guidance, they are public-facing documents that also need to be accessible themselves, and they shape how staff and consultants carry out every downstream engagement activity.

SPEAKER_00 3:18

If the plan doesn't address digital accessibility, the gap gets inherited by everything that follows.

SPEAKER_01 3:26

That's the domino effect. One missing policy can become a recurring accessibility failure across meetings, document libraries, and public comment workflows.

SPEAKER_00 3:38

The third factor is the one that changes the conversation most for AEC firms. Most of the content is not actually produced by the agency. Right.

SPEAKER_01 3:50

A lot of the environmental documents, project pages, public involvement materials, design reports, and meeting assets on a DOT website are produced by consulting firms under contract. The DOT is the covered entity under Title II, but the firm is producing the deliverable.

SPEAKER_00 4:09

So the compliance obligation belongs to the agency, but the relationship risk lands on the firm.

SPEAKER_01 4:16

That's the tension. A lot of firms do not yet have a mature accessibility process built into proposals, scopes, or QAQC. Not because they don't care, more because this specific risk was not really visible until the DOJ's final rule made it unavoidable.

SPEAKER_00 4:34

And once it becomes visible, every deliverable that goes to a DOT client without meeting WCAG 2.1AA puts the client relationship at risk.

SPEAKER_01 4:47

Exactly. It's not theoretical. It can affect review cycles, revisions, credibility, and whether the agency starts asking tougher questions about who owns accessibility remediation.

SPEAKER_00 5:00

So, yes, accessibility is now a deliverable quality issue, not just a legal one.

SPEAKER_01 5:07

That's a good way to put it.

SPEAKER_00 5:09

And the fourth factor is the document problem. Most people think of accessibility as code, color contrast, and screen reader support on a web page. Transportation agencies have that problem, plus a massive PDF inventory.

SPEAKER_01 5:26

Massive. A state DOT's public document library can have hundreds or even thousands of files, environmental impact statements, categorical exclusions, design reports, bridge inspection summaries, construction notices, public meeting materials, long-range transportation plans, appendices. The list goes on.

SPEAKER_00 5:51

And many of those documents were built in Word or InDesign, exported to PDF, and posted with no accessibility review.

SPEAKER_01 6:02

Which means missing tags, poor reading order, unlabeled tables, broken headings, all the usual issues, multiplied by scale.

SPEAKER_00 6:11

And under the final rule, documents that are still actively used to access or participate in agency services are in scope, even if they were created years ago.

SPEAKER_01 6:24

That's what makes this so different from fixing a 20-page marketing website. You are not remediating a handful of pages. You are looking at an entire information ecosystem.

SPEAKER_00 6:36

So when people ask, is this just about making the website accessible? The answer is no. It's about the website, yes, but also the documents, the public participation workflow, the contractor pipeline, and the federal oversight context around the work.

SPEAKER_01 6:57

And that is why generic accessibility advice often falls short. It tells you what WCAG says, but not how a transportation agency actually operates.

SPEAKER_00 7:10

Exactly. None of this means the standard is different. WCAG 2.1AA still applies equally to a DOT website and a retail website.

SPEAKER_01 7:22

What changes is the environment around it. Federal oversight, legal mandates for public participation, contractor-produced content, and the sheer volume of documents that need attention.

SPEAKER_00 7:35

So transportation agencies and the firms that serve them need accessibility guidance that understands their workflow, not just the technical criteria.

SPEAKER_01 7:46

They need partners who know what a public involvement plan is, who understands why an environmental document library is different from a blog archive, and who have sat in the room where deliverables are reviewed and returned.

SPEAKER_00 8:00

That is the conversation this show exists to have. Each week we'll explore a different dimension of digital accessibility as it applies specifically to transportation agencies, public engagement processes, and the AEC firms that support them.

SPEAKER_01 8:17

Practical, specific, and grounded in how the work actually gets done.

SPEAKER_00 8:23

If you're not sure where your agency or firm stands on these issues, the ADA Title II Readiness Checklist covers 36 dimensions of digital accessibility preparedness, from leadership and ownership to procurement language to staff training. You can download it at aogaccess.com. That's it for this week. If you want to assess where your agency or firm stands, the ADA Title II Readiness Checklist is available at AOGAccess.com. You can also find the written version of everything we covered today on the blog. Thanks for listening.