ERBM Recreation & Park District
Digital Accessibility Plan
Updated October 10, 2024
Introduction
ERBM Recreation & Park District is committed to providing accessible services and technology, including website accessibility, to all of its users. To that end, the District strives to continually evaluate its website and technology, and to improve their accessibility for all abilities.
The District’s accessibility efforts aim to adhere to the Web Content Accessibility Guidelines v2.1 (WCAG 2.1), conformance levels A and AA. These guidelines help make technology accessible to users with disabilities.
This Digital Accessibility Plan highlights our efforts to comply with Colorado’s accessibility laws. This plan provides:
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An overview of Colorado’s online accessibility laws and compliance requirements
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Our efforts, testing tools and techniques, and best practices for media and files
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Contact options for the Compliance Officer and accommodation requests
Overview of Colorado's Accessibility Laws
The District seeks to align with compliance rules set forth by HB21-1110, Colorado Laws for Persons with Disabilities, and HB24-1424, Grace Period Noncompliance Digital Accessibility.
HB21-1110 added language to strengthen current Colorado law related to protections against discrimination on the basis of disability for persons with disabilities, specifically as those laws relate to accessibility to government information technology. The added provisions include:
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Prohibiting a person with a disability from being excluded from participating in or being denied the benefits of services, programs, or activities of a public entity or a state agency;
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Clarifying that such prohibition includes the failure of a public entity or state agency to develop an accessibility plan and fully comply, on or before July 1, 2024, with accessibility guidelines established by the office of information technology (office);
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Any Colorado agency with the authority to promulgate rules shall not promulgate a rule that provides less protection than that provided by the "Americans with Disabilities Act of 1990".
HB24-1454 provides a one-year extension to July 1, 2025, of immunity from liability for failure to comply with the digital accessibility standards for an agency that demonstrates good faith efforts toward compliance or toward resolution of any complaint of noncompliance. To be eligible for the extension, the act requires the agency to post quarterly reports on progress and create a process for redress for inaccessible digital products.
The Governor’s Office of Information Technology (OIT) has developed accessibility technical standards with the intent of providing standard configurations for technologies which provide service to those with disabilities, in accordance with the technical standards provided by:
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World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.1 Level AA or higher
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Section 508 of the U.S. Rehabilitation Act of 1973 Chapters 3,4,6
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and following C.R.S. 24-85-101 to 24-85-104, ARTICLE 85
Other Considerations
Although HB24-1454 extended the compliance deadline, ERBM has been hard at work ensuring accessibility of our customer-facing website, forms, and documents since 2022. As of June 26, 2024, our website is testing fully compliant with WCAG guidelines, level A and AA. The site is also compliant with level AAA guidelines, and all documents in the Document Center are fully accessible based on Microsoft’s Accessibility Checker guidelines.
Our Efforts
The District is committed to providing equitable access to all Coloradans. Our ongoing accessibility effort works towards the day when all services, programs, and activities are accessible, providing equal access to information and services to all Coloradans.
To that end, the District is consistently prioritizing, evaluating, remediating and continuously improving every digital touchpoint within our services, programs, and activities. Below, you’ll find some of our accessibility measures.
Accessibility Maturity
The District is at the following accessibility maturity level for 2024.
Stage1: Inactive
No awareness and recognition of need. At this stage organizations are inventorying their technology, have begun to make investments, etc.
Completed 2022
Stage 2: Launch
Recognized need organization-wide. Planning initiated, but activities not well organized.
Completed 2023
Stage 3: Integrate
Roadmap including timeline is in place, overall organizational approach defined and well organized.
Completed 2023
Stage 4: Optimize - Current Stage
Incorporated into the whole organization, consistently evaluated, and actions taken on assessment outcomes.
Why we are at this Stage
After HB21-1110 was passed in 2021, the District began efforts for a complete website redesign. This was completed in 2022, with compliance testing conducted in 2023. The website was fully compliant by December 2023, leaving only documents and forms to be remediated.
This final step was finished, along with robust testing of public-facing documents and forms, in June 2024.
Accessibility work is continuing in the following areas:
- inventory of applications
- inventory and remediation of internal forms and documents, with estimated completion date of July 1, 2025
- training of current staff on techniques for creating accessible documents and workflows to better serve our community
Testing Tools and Techniques
ERBM has incorporated a variety of tools, techniques, methods, and processes to identify accessibility barriers and provide robust remediation of identified issues. The site is tested using these tools at least quarterly, and often more frequently, to ensure continued accessibility.
Website
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IBM Site Accessibility Checker
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The website’s code is tested quarterly for errors with the IBM Site Accessibility Checker for Chrome. The IBM Equal Access Accessibility Checker is an open-source tool for web developers and auditors that utilizes IBM's accessibility rule engine, which detects accessibility issues for web pages and web applications.
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Userway Accessibility Widget
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The District runs Userway’s accessibility widget on our website to provide additional accessibility options for users. Userway also offers real-time remediation of identified issues using AI, as well as WCAG compliance reports detailing these remediations for levels A, AA, and AAA. These reports are run quarterly and are available in our Document Center.
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WAVE Evaluation Tool
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The website is checked weekly for accessibility issues with WebAIM’s WAVE Browser Extension for Chrome. This extension identifies errors, contrast errors, alerts, features, structural elements, and ARIA tags. Any issues are promptly corrected by our webmaster.
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Forms
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WAVE Evaluation Tool
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Forms are checked weekly for accessibility issues with WebAIM’s WAVE Browser Extension for Chrome. This detects missing form fields and other potential issues for disabled users.
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Documents
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Microsoft Accessibility Checker
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District documents provided to the public are remediated with Microsoft’s built-in Accessibility Check.
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Portable Document Files (PDFs):
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Adobe Acrobat Pro DC Accessibility Checker
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District PDFs are checked for accessibility with Adobe’s built-in technology and remediated as needed.
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PAC2021
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PDF documents are also run through the PDF Accessibility Checker 2021 (PAC2021), Version 21.0.0.0. This tool was initially released in 2010 and was the first automated PDF/UA compliance validation tool. Having had three previous versions before PAC 2021, PAC is designed to easily identify all of the machine verifiable success criterion of ISO 14289-1 (PDF/UA) and WCAG (Web Content Accessibility Guidelines).
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Accessibility reports for specific documents are available upon request.
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Screen Reader Tool
The District website was last tested with NVDA in June 2024 with no identified issues.
Document Workflows and Best Practices
District documents will, whenever possible, be produced and offered in their native format (.docx, .xlsx, etc.), or on a webpage with proper HTML mark-up.
If for some reason a document cannot be made fully accessible, the District will, to the best of its ability, provide accommodations. This is particularly true for PDF documents, which were originally designed to creating standards for hard copy printing. Although the District has generally converted documents to PDFs in the past, our best practices have changed to better align with accessibility standards for all users.
Undue Burden, Fundamental Alteration, or Direct Threat
The District is committed to providing accessible services to all individuals, including those with disabilities. However, there may be instances where full compliance with all accessibility standards might not be achievable due to:
• Undue Burden: Implementing certain accessibility measures may pose an unreasonable financial, technical, or administrative burden on our limited resources, potentially impacting our ability to deliver essential services effectively.
• Fundamental Alteration: Strict adherence to accessibility standards could fundamentally change the nature of some of our programs, services, or activities, rendering them unfeasible or ineffective.
• Direct Threat: In rare cases, full accessibility might pose a direct threat to the health or safety of individuals, requiring specific risk assessments and alternative solutions.
In such situations, the District will:
• Demonstrate the Burden or Risk: We will transparently explain the specific reasons why full compliance is not achievable in a particular instance.
• Explore Alternative Solutions: We will actively seek alternative solutions or reasonable accommodations that effectively address accessibility needs without causing undue burden, fundamental alteration, or direct threat. This may include providing different formats of information, alternative communication methods, or accessible technology solutions.
If you encounter any barriers accessing our services, please contact our Compliance Officer/ADA Coordinator Shelly Rogers at 970-878-7415 or shelly@erbmrec.com. If you prefer, you may also complete our Accommodation Request Form on our website.
Third-party Documents, Websites, or Technology
Please note that the District’s website or technology may link to third-party documents, websites, or technology that do not provide accessible content or an accessible user interface. While the District cannot control the accessibility of services and information provided by third parties, the District welcomes reports of accessibility barriers encountered with respect to any third-party documents, websites, or technology that is linked by the District, so that the District can evaluate any remedial actions it may reasonably be able to take.
Compliance Officer and Accommodation Requests
The District has designated Shelly Rogers, Recreation Manager, as its Compliance Officer for website and technology disability-related accommodations. Users also may contact the Compliance Officer to provide feedback on the accessibility of the District’s website or technology. The District can often resolve accessibility issues in a timely manner if they arise.
If you encounter accessibility barriers on the District’s website or technology, or would like to request an accommodation, please contact Compliance Officer Shelly Rogers at:
970-878-7415
101 Ute Road, Meeker CO 81641
If you prefer, you may also complete our Accommodation Request Form below.
The District is committed to providing a timely response to reports of accessibility barriers and requests for accommodation, and seeks to respond to all reports and requests within two business days.
Accommodation Requests versus Grievances
What is the difference between submitting a grievance versus an accommodation request/online issue?
A request for accommodation is when an individual or their representative requests a change or modification in order to participate in an event or service. A grievance can be filed if the individual disagrees with the ADA Coordinator's decision on the accommodation or to report a violation of the ADA.