2026-05-17 · 9 min read

Boone County Kentucky Government Website Accessibility: CVG Airport, TANK, and the April 2027 DOJ Title II Deadline

# Boone County Kentucky Government Website Accessibility: CVG Airport, TANK, and the April 2027 DOJ Title II Deadline

Boone County is the economic gateway between Kentucky and metropolitan Cincinnati. Sitting directly across the Ohio River from Greater Cincinnati, it is Northern Kentucky's most populous county — approximately 145,000 residents — and one of the fastest-growing counties in the Commonwealth. It is also the home of Cincinnati/Northern Kentucky International Airport (CVG), a major public authority that serves three states and operates entirely within Boone County's borders.

The DOJ Title II Final Rule assigns compliance obligations to each covered entity independently. Boone County government, CVG Airport, and the Transit Authority of Northern Kentucky (TANK) each face the April 26, 2027 deadline. Florence, Erlanger, and Boone County Schools — all below the 50,000-person threshold — face April 26, 2028. Understanding which entities face which deadline, and what digital properties are within scope for each, is the starting point for any credible compliance program.

---

What the DOJ Rule Requires

In April 2024, the U.S. Department of Justice finalized a rule amending 28 CFR Part 35 under Title II of the Americans with Disabilities Act. The rule requires state and local governments to bring their websites and mobile applications into conformance with WCAG 2.1 Level AA.

The technical standard — WCAG 2.1 Level AA — is published by the W3C Web Accessibility Initiative. It consists of 50 success criteria organized under four principles: Perceivable, Operable, Understandable, and Robust. The criteria address how content is presented to users relying on assistive technology, how all functionality can be operated without a mouse, how content is structured for comprehension, and how content is built to be interpreted reliably by current and future technology.

The rule covers websites, mobile applications, PDF documents, and any digital service offered by or on behalf of a covered public entity. Vendor-operated platforms — payment portals, permit systems, utility billing interfaces — are within scope when they support government service delivery. The covered entity is responsible for vendor accessibility regardless of who hosts the tool.

The deadline structure by population threshold:

• Entities serving populations of 50,000 or more: April 26, 2027
• Entities serving populations under 50,000: April 26, 2028

---

Covered Entities in Boone County: Two Deadlines

Boone County's compliance picture is multi-layered. Several large public entities operate from overlapping geographic and service footprints, each carrying independent compliance obligations.

Boone County government — April 26, 2027. At approximately 145,000 residents, the county government is well above the 50,000-person threshold. The county's digital footprint includes property records, planning and zoning, elections, emergency management, court records, and county commission communications. All are within scope.

Cincinnati/Northern Kentucky International Airport (CVG) — April 26, 2027. CVG is a public authority jointly governed by Kenton and Boone Counties. It is one of the busiest airports in the Midwest by cargo volume, and it serves passengers from Kentucky, Ohio, and Indiana. Its digital footprint includes flight status information, parking reservation systems, ground transportation scheduling, accessibility service request forms, vendor and concessionaire portals, and real-time flight display systems. CVG operates as an independently covered entity under Title II of the ADA, carrying its own compliance obligation separate from either county government.

For travelers with disabilities — screen reader users booking accessible transportation, individuals with hearing impairments relying on visual flight information systems, wheelchair users scheduling mobility assistance — CVG's digital accessibility directly determines whether they can use the airport independently. The DOJ rule closes the gap between what is required of federal services and what airports have historically provided.

Transit Authority of Northern Kentucky (TANK) — April 26, 2027. TANK provides fixed-route bus service across Boone, Kenton, and Campbell Counties and connects to Cincinnati Metro across the river. As a transit authority, TANK is an independently covered public entity under Title II. Its route schedules, real-time arrival tools, trip planning features, paratransit scheduling, transit app, and any rider communications must conform to WCAG 2.1 Level AA. For riders with disabilities who depend on public transit for access to employment, medical care, and essential services, accessible digital schedules and tools are not convenience features — they are the mechanism of independent mobility.

City of Florence — April 26, 2028. Florence is Boone County's largest city at approximately 35,000 residents. It falls below the 50,000 threshold and faces the April 26, 2028 deadline. Florence's digital footprint includes the city website, utility billing, permit applications, parks and recreation registration, and public meeting notices.

City of Erlanger — April 26, 2028. Erlanger has a population of approximately 24,000 and faces the April 26, 2028 deadline. Erlanger's online presence includes municipal services and permit portals.

Boone County Schools — April 26, 2028. Boone County Schools serves approximately 24,000 students. The district falls below the 50,000-person threshold and faces the 2028 deadline. The school district's digital footprint includes the district and school-level websites, parent portals, enrollment and registration systems, IEP documentation, student handbooks, board meeting materials, and communications platforms.

The 2028 deadline is not a relaxed standard — it is the same WCAG 2.1 Level AA requirement, with one additional year to achieve conformance. Entities with the 2028 deadline should plan their compliance programs now, given that auditing and remediation timelines are identical regardless of which deadline applies.

---

CVG Airport: The Scope Question Every Airport Misses

Airports create a compliance scope question that most government IT teams have not worked through: which digital systems are the airport's obligation versus an airline's obligation?

Under Title II of the ADA, CVG's obligation covers the digital services it operates or offers on its behalf. That includes:

• CVG.com and any mobile application — flight status, wayfinding, transportation options, accessibility services
• Parking reservation systems — including third-party-operated parking portals integrated into CVG's web presence
• Ground transportation scheduling — shuttle booking, taxi dispatch, rideshare integration where CVG controls the digital interface
• Accessibility service request tools — forms through which passengers with disabilities request wheelchair assistance, visual accommodation, or other airport-provided services
• Digital flight information displays — the DOJ rule covers public-facing digital content, and the standards for displays accessible to individuals with hearing impairments are within scope

What is not CVG's direct Title II obligation: airline-operated booking systems, airline apps, and individual airline accessibility programs. Those obligations run under a separate regulatory framework (Air Carrier Access Act). The boundary matters because airport IT teams sometimes undercount their scope by assuming airline-facing systems are out of scope, while simultaneously over-counting by assuming airline systems are their problem to solve.

Getting the scope right is the first step in an accurate audit. An audit that misdefines scope produces findings — and a remediation plan — that do not match the actual compliance obligation.

---

Where Government Sites Most Commonly Fail

The WebAIM Million 2024 report tested one million home pages and found that 95.9% had detectable WCAG failures, with an average of 56.8 distinct errors per page. Regional government sites operating on older content management platforms typically run above that average.

The failure categories most common on Northern Kentucky government and airport sites:

Low contrast text. Navigation menus, site footers, and secondary content areas frequently fail WCAG 1.4.3's 4.5:1 contrast ratio for normal text. Airport sites commonly use light gray text on white backgrounds in informational panels — a design choice that fails at standard zoom levels.

Missing image alt text. Airport sites use heavy image content: terminal maps, gate diagrams, ground transportation imagery, construction notice photos. Maps and diagrams that convey spatial information — "departures on left, arrivals on right" — require meaningful alt text under WCAG 1.1.1, not decorative image treatment.

Form label failures. Parking reservation forms, accessibility service request forms, and permit applications frequently have input fields labeled only by placeholder text. Placeholder text disappears when a user begins typing, leaving screen reader users with unlabeled fields. WCAG 1.3.1 and 3.3.2 require persistent, programmatically associated labels.

PDF documents. County governments maintain large repositories of PDFs: meeting minutes, zoning ordinances, budget documents, permit applications. Airport authorities publish terminal maps, construction notices, and concessionaire procurement documents. Most are posted as scanned images or unstructured PDFs that screen readers cannot navigate.

Transit real-time tools. TANK's real-time arrival displays and trip planning tools use JavaScript-rendered dynamic content. Screen readers cannot read dynamically updated content unless it is announced through ARIA live regions (WCAG 4.1.3). Most transit real-time displays fail this criterion.

Third-party vendor integrations. TANK's mobile payment system, CVG's parking vendor portal, and county permit payment processors are within scope under the DOJ rule. A comprehensive audit must include these third-party-operated touchpoints, not only the primary government domain.

---

The Cincinnati Metro Context and Enforcement Risk

Boone County and its public entities do not operate in a rural isolation context. They are part of a large metropolitan area with a substantial professional workforce, a significant disability rights advocacy community, and regular federal agency interaction.

The Cincinnati metro's tech and professional services sector — accounting firms, healthcare systems, logistics companies — includes a significant population of workers with disabilities who use assistive technology regularly. Employees at government contractors adjacent to Greater Cincinnati have Section 508 familiarity. Individuals who encounter inaccessible government websites in Northern Kentucky — and who know they are encountering an inaccessible website — are more likely to file a DOJ complaint than their counterparts in more isolated rural counties.

The DOJ does not require an individual complaint to initiate a compliance review, but individual complaints are the most common trigger for DOJ investigation of local government digital accessibility. The complaint rate in metro-adjacent counties consistently runs higher than in isolated rural jurisdictions.

---

Compliance Timeline

The deadline for Boone County government, CVG Airport, and TANK is April 26, 2027. From May 2026, that is approximately eleven months. A realistic compliance program works backwards from the deadline.

| Date | Milestone | |---|---| | Now (May 2026) | Baseline audit; inventory digital properties across Boone County, CVG, and TANK | | July 2026 | Complete audit; prioritize findings by impact on service access | | September 2026 | Begin remediation; initiate PDF remediation and vendor review | | November 2026 | Third-party vendor accessibility confirmation | | January 2027 | Mid-point verification testing | | March 2027 | Final conformance testing | | April 1, 2027 | Publish DOJ-compliant accessibility statements | | April 26, 2027 | Deadline — Boone County government, CVG, TANK | | April 26, 2028 | Deadline — Florence, Erlanger, Boone County Schools |

Entities with the 2028 deadline should initiate baseline audits now. Remediation timelines are the same regardless of deadline year — audit findings take time to remediate, and a 2028 deadline does not mean a 2027 audit is early.

---

The Parallax WCAG Audit

Morton Technology Consulting offers the Parallax WCAG audit at a fixed fee of $9,500.

The audit covers 200 representative pages across an agency's digital footprint. Testing combines automated scanning using axe-core against the full WCAG 2.1 Level AA ruleset with manual testing using NVDA on Windows and VoiceOver on macOS. Keyboard-only navigation testing is conducted separately from screen reader testing to surface failures that automation cannot detect.

Deliverables include a full findings report with severity ratings (critical, serious, moderate, minor), a remediation roadmap prioritized by impact on service access, and a DOJ-compliant accessibility statement draft ready for legal review and publication.

At $9,500, the Parallax audit fits within most Kentucky government agency written-quote thresholds without requiring a full competitive bid process. For Boone County's multi-entity compliance picture — county government, CVG, TANK, plus the 2028-deadline entities — the audit scope can be structured to address each covered entity's independent obligation.

For the full Kentucky compliance picture, see the Kentucky government website accessibility guide. See also Jefferson County Kentucky government website accessibility, Fayette County government website accessibility, and Warren County Kentucky government website accessibility for comparable Kentucky county coverage.

A sample audit report is available at morton-digital.com/parallax-sample-audit. Full service details at morton-digital.com/products/parallax.

To discuss your agency's timeline and scope, contact [email protected].

---

*Morton Technology Consulting LLC, Tallahassee, FL. Southeast and Midwest government website WCAG 2.1 compliance audits for the April 2027 deadline. [email protected]*

Morton Technology Consulting LLC — WCAG 2.1 AA audits for Florida government agencies. Parallax audit → · WCAG Readiness Kit → · All posts →