Disproportionate Burden - Planning Documents


This assessment relates to PDF published by the Council before 2018. PDF documents published after this date are tagged to ensure they can be read by screen readers and are available digitally.

PDF documents supplied to and published by the Council by agents and applicants may not always be fully accessible.

We are fully committed to providing all information in any accessible format on request. For example, we can audio-describe planning documents for the visually impaired.

There are approximately 4.5 million planning documents held by the Council dating back to 1947. Documents produced before 1998 are held in paper or microfiche formats at the Council's head office.

Planning applications were routinely digitised/scanned from 1998 onwards. When the Council receives a request to view a paper-based planning document from before this date, we have scanned the file at the same time to ensure a digital copy is available for future requests.


The benefits of making these PDFs into accessible HTML formats would be:

  • Historical materials would be fully accessible to all users
  • Historical materials would be more easily searchable and indexable


Our assessment of the burden of making these PDFs into accessible HTML formats is that:

  • There are millions of historic documents created by the organisation, dating back over 70 years.
  • Many of the documents are currently paper-based and would need to be scanned.
  • Each document would require a number of hours of work to be recreated in a fully accessible version. This estimate is based on extensive experience of converting the active documents at between 2 and 30 hours per document, depending on length and complexity. It would take several years, possibly decades, for the documents to be fully converted.
  • Many of the documents contain complex elements which are difficult to retrospectively convert, such as detailed maps, plans and drawings.

Other factors

Also relevant to this decision are that:

  • The documents do meet accessibility requirements for most users, although some groups will find them disproportionately difficult; for example, visually impaired persons.
  • Requests for additionally accessible versions of planning documents are rare
  • We have and will always assist with accessible versions on request


Where documents are no longer in active use, or no longer being updated, there is a high cost in terms of employee hours to convert. These documents are part of the public record, but interest is limited. We always respond to requests for our publications in different formats on a case-by-case basis, so accessible versions are available on demand, with a short lead-time.

We consider that the costs of converting older documents would be a poor use of limited staff time, and would represent a disproportionate burden on the organisation in terms of cost.

Assessment date:

30 December 2020

Reviewed 10 August 2023