Who Owns the Website? A JPA Guide to Web Procurement and ADA Compliance

Joint powers authorities are the part of California local government most likely to have an accessibility problem nobody has noticed. Not because JPA staff are less diligent, but because of how the entity is structured: every member agency assumes somebody else owns the website.

This is a short guide to who is actually accountable, why JPAs get missed, and how to get the work procured when the authority has a board but not much of a budget.

A JPA is its own public entity

That is the whole point of the structure, and it is why a JPA belongs in the same conversation as the districts that formed it. Member agencies form a joint powers authority so it can act in its own name — hold its own meetings, adopt its own budget, enter its own contracts. It has its own board, its own Brown Act obligations, and its own website carrying its own agendas.

It also has its own obligation under the ADA Title II web rule. A JPA does not inherit compliance from its members. If the authority makes web content available to the public — and if it is posting agendas, it is — that content has to conform to WCAG 2.1 Level AA.

On timing, joint powers authorities are usually the sort of small public entity that falls in the later cohort, with a compliance date of April 26, 2028. Both compliance dates were extended by one year in the Justice Department's interim final rule of April 20, 2026, so the earlier cohort is now April 26, 2027 and the later one April 26, 2028. Where a particular authority lands is worth confirming rather than assuming, because it turns on the entity and the population figures involved — but no JPA is exempt, and none has a date earlier than its members.

Why JPA sites get missed

Four patterns, and most authorities will recognise at least two.

The site lives on a member agency's platform. The authority's pages are a section of a member city or district site, or a subdomain of it, maintained by that agency's staff as a favour. When the member agency remediates its own site, the JPA section is frequently out of scope — a different budget, a different project, sometimes a different vendor.

Nobody's job description includes it. JPA staffing is often a contract manager, a part-time clerk, or an executive borrowed from a member agency. The website is a residual duty. There is no one whose performance review mentions it.

The budget is contributions, not a line item. A JPA funded by member contributions has to go back to its members to spend money it did not plan for. That is a governance conversation across several boards, and it takes a cycle or two. Started in 2027, it will not finish in time.

It was built once, for the formation. Many JPA sites were stood up when the authority was formed and have been posting agendas untouched since. Nobody has looked at them with fresh eyes in years.

Establish accountability in writing, at a board meeting

This is the step that actually unblocks everything else, and it costs nothing.

Put an item on the agenda that answers three questions and records the answers in the minutes. Who maintains the authority's website? Which entity's budget pays for accessibility remediation? And who is responsible for confirming conformance before the compliance date?

If the site sits on a member agency's platform, get the arrangement written down — ideally as an amendment to the administrative services agreement, or at minimum as a board-adopted memorandum. Informal arrangements are exactly how this obligation falls through the gap between two agencies that each believed the other had it.

While you are at it, ask a fourth question: is the authority's content actually in scope of the member agency's remediation project? The answer is often no, and it is much better discovered now than in 2028.

Three procurement paths

A JPA rarely needs a full competitive solicitation for work at this scale, and there are usually easier routes.

Ride a member agency's contract. If a member city or district is already procuring accessibility remediation, the cheapest path is to have the authority's site added to that scope. This requires the member's contract to permit it and the JPA to reimburse, but it avoids a separate procurement entirely. Ask before the member's contract is awarded, not after — adding scope to a signed contract is harder than including it in the solicitation.

Use a cooperative purchasing agreement. Many authorities can buy from a cooperative contract their members already participate in. Confirm what your own JPA agreement and purchasing policy permit.

Procure directly under your own threshold. An audit, and often the remediation itself, will fall under the informal purchasing threshold in the authority's own policy. For a small JPA site this is frequently the fastest route and needs nothing more than quotes and a purchase order.

Whichever path you take, keep the audit separate from the build. An audit the authority owns is a document you can attach to a board packet, share with member agencies, and use to write a scope. An audit bundled into a build proposal is a sales instrument and cannot do those things.

What to look at first

Four things, in this order, and the first two you can do yourself this week.

Find every page the authority publishes, including anything hosted under a member agency's domain. Authorities are often surprised by what turns up.

Inventory the documents. Agendas, minutes, board packets, budgets, agreements. Note how many are scans rather than exported text, because that is the expensive category.

List the third-party systems — agenda management, video streaming, any portal. Email each vendor asking for a current accessibility conformance report. Their answers, and their silences, are your risk picture.

Then get an audit, and take the findings to your board with a recommendation and a cost. Two budget cycles is enough time to do this deliberately. One is not.