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Really just depends on the site. Some sites just do not lend themselves well to accessibility standards.
Your first question before designing a site should be "who is going to look at this". That answers a whole list of various questions including the accessibility one for the most part.
Sometimes of course you also have to look at legal implications as well. I have worked on a number of state funded websites and with them it is actually required by law to have basic accessibility standards built in. This will vary from state to state however.
Above all though just remember the larger the website(and client you are designing for) the more likely you are to piss someone off about something, so just make sure your bases are covered. That is pretty much what happen to Target.
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