oregon-stories · records quality × 28 CFR Part 35, Subpart H
Documents that exist only as pictures — beside the federal rule on government web accessibility
A law you cannot read by machine is a law screen readers cannot read either. Across the mirrored corpora: 13 state instruments whose official copies contain no machine-readable text — including 9 current statewide policies whose official page serves a literally blank placeholder PDF — plus 598 county documents whose text exists only because this project ran OCR on image-only sources, and 12 executive orders held as stubs because even OCR could not usably recover them.
State instruments with no machine text
13
from ERF's generated review ledger, reasons stated below
…of which blank placeholders
9
current DAS statewide policies whose official page serves an empty PDF
County documents recovered by OCR
598
the public copy carries no machine-readable text; the text exists because this project ran OCR
What federal law now requires — cited, not characterized
The Department of Justice's ADA Title II web rule (89 FR 31320, Apr. 24, 2024) added 28 CFR Part 35, Subpart H: state and local governments' web content must meet WCAG 2.1 Level AA (§ 35.200; the standard is incorporated by reference). Compliance dates, by the rule's own population threshold: April 24, 2026 for public entities of 50,000 or more — which includes the State of Oregon and its agencies — and April 26, 2027 for smaller entities and special districts. Under WCAG 2.1 AA, non-text content requires a text alternative (SC 1.1.1) and images of text are constrained (SC 1.4.5) — a scanned page with no text layer gives a screen reader nothing to read.
The rule has exceptions (§ 35.201), and they matter here: archived web content (kept only for reference, unaltered, in a designated archive) and preexisting conventional electronic documents (PDFs and similar posted before the compliance date) are excepted — but the preexisting-document exception does not apply to documents currently used to apply for, access, or participate in the entity's services or programs. Whether any document on this page falls inside or outside an exception is a legal determination this page does not make. What it shows is narrower and factual: these are currently-operative public instruments whose published copies carry no machine-readable text.
One more measured fact: 28 CFR Part 35 is itself cited as legal authority by 7 Oregon administrative rules (20 citations in all, including the Department of Human Services' own nondiscrimination rules) — the accessibility rule is part of Oregon's regulatory fabric, not an external imposition.
The state instruments, with the ledger's own reasons
| document | why no text exists |
|---|---|
| oam-55-30-00-appendix-b.md | binary form/workbook (no text representation) |
| oam-75-35-12-fo.md | binary form/workbook (no text representation) |
| oam-75-40-01-fo.md | binary form/workbook (no text representation) |
| das-105-001-0000.md | official page serves a blank placeholder |
| das-105-001-0005.md | official page serves a blank placeholder |
| das-105-020-0001.md | official page serves a blank placeholder |
| das-105-020-0015.md | official page serves a blank placeholder |
| das-105-040-0001.md | official page serves a blank placeholder |
| das-105-050-0003.md | official page serves a blank placeholder |
| das-105-050-0004.md | official page serves a blank placeholder |
| das-105-050-0025.md | official page serves a blank placeholder |
| das-105-050-0030.md | official page serves a blank placeholder |
| (12 documents) | image-only scan |
OCR-recovered county documents, by county and applicable compliance date
| county | OCR-recovered documents | population | federal web-accessibility compliance date (by the rule's own size threshold) |
|---|---|---|---|
| yamhill | 328 | 110,886 | April 24, 2026 |
| wasco | 138 | 26,507 | April 26, 2027 |
| curry | 56 | 22,774 | April 26, 2027 |
| deschutes | 36 | 211,535 | April 24, 2026 |
| malheur | 11 | 32,315 | April 26, 2027 |
| coos | 8 | 64,326 | April 24, 2026 |
| marion | 8 | 352,867 | April 24, 2026 |
| klamath | 5 | 70,438 | April 24, 2026 |
| lincoln | 3 | 51,212 | April 24, 2026 |
| gilliam | 2 | 1,971 | April 26, 2027 |
| grant | 2 | 7,093 | April 26, 2027 |
| multnomah | 1 | 795,897 | April 24, 2026 |
Read this before quoting the chart
No compliance determination is made or implied for any document. The federal rule's exceptions are stated above and could cover some of these documents; that analysis belongs to lawyers and the entities themselves. Counts derive from the corpora's own generated ledgers at build time; the ERF ledger's reasons are quoted verbatim from its review file. OCR recovery means this PROJECT could machine-read the document after processing — it says nothing about what assistive technology encounters on the official site, beyond the measured fact that the source PDF carried no text layer. Compliance dates are the rule's own, applied mechanically by population threshold; nothing here interprets them.