Fairport Police Department ADA Communication Policy Audit
Monroe County Interpreter Access Audit
Executive Summary
The Fairport Police Department maintains a written policy (GO 430-20) governing interactions with Deaf and hard-of-hearing individuals, along with a related professional services agreement intended to support communication needs.
The policy reflects awareness of communication barriers and outlines expectations for interpreter use, communication methods, and officer conduct. However, the structure relies heavily on situational judgment and informal escalation rather than clearly defined, auditable systems.
Records produced in response to Freedom of Information Law (FOIL) requests do not identify a structured interpreter access system, any mechanism for tracking interpreter use, documented training implementation, or the presence of an ADA Coordinator or formal governance framework. The department further indicated that dispatch-related processes “do not pertain” to the Village, despite the policy explicitly relying on dispatch to initiate interpreter access.
Interpreter access is contemplated at a policy level, but the materials provided do not show a system capable of delivering or documenting that access in practice.
A notice regarding this review has been issued to the Village of Fairport. [Read the notice]
Scope and Methodology
This review is based on records obtained through the New York Freedom of Information Law, including the Fairport Police Department’s General Order on Deaf Community Interactions, a professional services agreement related to Deaf community support, and correspondence associated with multiple FOIL requests and administrative appeals.
The analysis examines how interpreter access is structured, implemented, and documented, with particular attention to whether the systems described in policy are visible and verifiable in practice.
Policy Framework
The Fairport Police Department maintains a written general order addressing communication with individuals who are Deaf or hard of hearing. The policy recognizes that such encounters are a routine and foreseeable part of policing and provides guidance on identifying communication barriers, determining preferred communication methods, and selecting appropriate accommodations.
Interpreter use is framed as dependent on the length, importance, and complexity of the interaction. In routine encounters, officers may rely on written communication, while more complex or custodial situations generally require the use of a sign language interpreter. The policy also permits, in limited circumstances, the use of family members or friends as interpreters, particularly where an interpreter is not immediately available.
This structure reflects an attempt to balance operational flexibility with communication needs, but it leaves key decisions to officer discretion rather than a defined and consistently applied standard. The materials do not describe how communication preferences are documented, how decisions are reviewed, or what limits apply when non-professional interpreters are used.
Interpreter Access Pathways
The policy describes a two-part pathway for obtaining interpreter support. Officers are instructed to notify dispatch, which is expected to identify available “on-duty ASL police resources.” If such resources are not available, the policy directs officers to rely on a professional services agreement for communication support.
On its face, this creates a layered system: internal identification of resources followed by escalation to an external provider. The professional services agreement establishes that an ASL-fluent provider may be contacted on an on-call basis, with response times dependent on availability and operational need.
The agreement is with a clinical psychologist whose scope is defined in psychological terms — crisis intervention, assessments, psychotherapy, and training — with communication support as a secondary function. It was structured with an initial term ending December 31, 2020, subject to annual renewal by mutual agreement. The materials provided do not indicate whether the agreement remained in effect during the period under review.
The records do not document how either component of this system operates in practice.
No materials were provided describing how dispatch identifies ASL-capable personnel, how such availability is tracked, or what criteria define an “on-duty” resource. When asked directly for records describing this process, the Village indicated that dispatch-related information does not pertain to it.
Similarly, while the professional services agreement establishes that an external resource exists, nothing in the record shows when or how that resource has been used, how often it has been activated, or how it integrates into field operations.
The policy describes a system that depends on both internal coordination and external support, but the materials provided do not show that either pathway is implemented in a way that can be verified.
Implementation and Documentation
The policy sets expectations for officer conduct during interactions with Deaf or hard-of-hearing individuals, including determining preferred communication methods, confirming comprehension, and avoiding reliance on lipreading for critical information. It also includes operational considerations intended to reduce miscommunication in high-stakes situations, such as delaying handcuffing where feasible and modifying field sobriety testing practices.
These provisions reflect awareness of communication risks at the encounter level. The record contains no corresponding system for documenting how those requirements are carried out.
FOIL requests specifically sought records showing how interpreter requests are tracked, how communication accommodations are recorded in incident reports, and whether any reporting or audit mechanisms exist. No such records were produced.
The Village did not identify any tracking system, reporting mechanism, or summary data reflecting interpreter usage. There is no indication in the materials of when interpreter services are used or how frequently they are requested.
Without documentation requirements or tracking systems, the policy’s operational expectations cannot be verified.
Training
The policy presumes a level of officer awareness and competency in communicating with Deaf or hard-of-hearing individuals, including understanding the limitations of lipreading and the conditions under which interpreters are required.
No training materials, training records, or documentation of implementation were produced in response to FOIL requests. The materials do not indicate whether personnel have received training or are evaluated on their ability to apply the policy in practice.
ADA Governance
FOIL requests sought records identifying an ADA Coordinator or comparable Title II point-of-contact, along with any grievance procedure or administrative structure supporting ADA compliance.
No responsive records were produced, and no ADA Coordinator was identified.
Without a designated coordinator, there is no identified official responsible for managing compliance, receiving complaints, or overseeing communication access. The materials also do not describe who has authority to approve or deny communication accommodations or how those decisions are documented.
Responsibility for compliance remains diffuse, and there is no defined pathway for review or correction when issues arise.
Procedural Visibility
The system described in policy depends on coordination between officers, dispatch, and external service providers. It presumes the existence of procedures governing how interpreter resources are identified, requested, and deployed.
The materials produced do not include those procedures.
No dispatch protocols, internal standard operating procedures, interpreter activation workflows, or vendor coordination processes were provided. The Village’s position that dispatch-related information does not pertain to it further limits visibility into how the system is intended to function.
Because the policy relies on dispatch as the initial step in obtaining interpreter resources, the absence of dispatch-related records prevents evaluation of whether that pathway is consistently available or operational in practice.
Evidence of Implementation
In response to a request specifically seeking records of interpreter tracking and implementation, the Village produced the same General Order already provided as policy documentation.
No additional records were produced showing interpreter requests, usage, training, or system operation.
This response provides no evidence of how the policy is implemented in practice.
Conclusion
The Fairport Police Department maintains a written policy addressing communication with Deaf and hard-of-hearing individuals and has established at least one mechanism intended to support interpreter access.
The materials provided reflect a system that is policy-defined but not operationally documented. Interpreter access appears to be availability-based, dependent on dispatch coordination and a single external provider. That provider’s contractual scope is defined in psychological rather than general-purpose interpretive terms, and the materials do not address whether the arrangement is sufficient for routine law enforcement communication.
The record contains no evidence of a tracking framework, documentation standards, training implementation, or a formal ADA governance structure. Communication access is contemplated, but the system described cannot be observed, measured, or verified based on the materials provided.
Policy Framework: Present
ADA Governance: Not Identified in Records
Operational Implementation: Not Established in Record
This review is part of the Monroe County Interpreter Access Audit (MCIAA), an ongoing Transparent Law Enforcement project examining how local agencies document interpreter access for Deaf or hard-of-hearing motorists.