We fetched 82 pages of the public site and found 422 links to documents on them. The crawl reached the end of the site.
We downloaded a random sample of 120 of them. 120 opened as PDF files, and of the 105 we could read, 30 (28.6%) had no tag tree, which is the structure a screen reader needs to read a document in order. 24 were pictures of pages with no text layer at all.
As an independent check, 105 documents from the sample were also validated with veraPDF against the full PDF/UA-1 standard; 100% failed at least one rule. That number is always higher than ours: a document can have a tag tree and still fail on reading order, table structure or missing text alternatives. The grade uses the stricter, simpler fact, no tag tree at all.
Of the documents missing structure, about 26.7% look, from their names and location on the site, like forms, notices and guides that residents use today. Those are the ones the Title II rule reaches first. The rest are largely archives, which the rule exempts unless they are still used to obtain a service.