Succession Criteria 3.2.4

I have advised the Working Group my site does not contain any forms, or scripts. 
 
However, I a member of WAI advised me, even with links it is applicable.
 
Therefore, my follow up question is this:
 
If I template my page based on ada.gov and/or disabilityinfo.gov will the links pass Succession Criteria 3.2.4.
 
The difference between the two sites is ada.gov has links at the top and the bottom.
Disabilityinfo.gov has links at the left, which are also at the bottom.
 
Are these a good starting template?