Consultation

52 The Guidelines represent the collective effort of many government web professionals, specialists in web access for people with disabilities, and members of the website design industry to adapt international best practice standards to New Zealand requirements. Consultation on both versions of the Guidelines has been wide, with version 2.1 drawing more than 140 responses.

53 Consultation on this paper has occurred with all agencies for which mandatory adoption of the Guidelines is recommended. Twenty-two agencies made formal responses. There was strong support for the intent of Guidelines. The most common concern expressed was over costs of achieving Guidelines-compliance. Modifications have been made to this proposal to constrain these costs, especially through limiting the retrospective application of the Guidelines.

54 The most significant concerns were expressed by the Ministry of Economic Development (MED), which requested that they be noted in this paper. While strongly supporting the Guidelines as a whole, the MED raised concerns regarding their application to the non-informational elements of its transactional websites and the significant costs and time required to achieve full compliance in the timeframe originally stipulated (and subsequently extended). In particular, it raised:

• the need for these websites to give effect to legal requirements;
• significant cost and timeframe impact of achieving Guidelines-compliance;
• belief that users of its transactional sites do not generally have problems of accessibility and that, where they do, they are adequately catered for by other mechanisms;
• risk that the Guidelines will be too slow or unable to keep pace with changing technology; and
• perceived weaknesses in the guidelines with respect to transactional functionality.

55 Other agencies operating transactional websites did indicate similar concerns, and both the Ministry and these agencies offered to work with the EGU to refine the Guidelines as necessary.

56 My view is that this is preferable to the alternative of a blanket exclusion of transactional websites from the Guidelines, which would be short-sighted. Our E-government Strategy calls for many more transactional websites in future. If these sites are not widely accessible many New Zealanders will be denied the benefits of e-government. It is better to include all websites under the Guidelines, and then take an even-handed and forward-looking approach to the question of how far particular websites should comply with the Guidelines, and by when. If agencies feel that a website can't or shouldn't comply with the Guidelines then they are free to apply for an exemption, providing time for any problems to be sensibly addressed.