As passionate as I am about accessibility, I try not to use an accusing tone. There's no way we can know the state of mind, priorities, and constraints of the developer in question. Even large companies don't have unlimited resources. So we can't fault developers for looking for ways to do more with less. We just need to do what we can to make sure developers are informed about the pitfalls, and plead with them to consider important user experience factors like accessibility.