FOIL Submission Audit: Town of Gates (High Friction / Mandatory Disclosure)
→ This post is part of the Monroe County FOIL Submission Audit.
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TL;DR
The Town of Gates requires FOIL requests to be submitted through a standardized application, either online or via a downloadable PDF. Submission is conditioned on providing personal identifying information and contact details that FOIL does not require.
While Gates provides clear statutory timelines, fee information, and identifies the Records Access Officer, the intake process itself imposes high friction through mandatory form completion and disclosure.
How FOIL Requests Are Submitted in the Town of Gates
The Town of Gates allows FOIL requests to be submitted by:
- Completing an online FOIL submission form, or
- Downloading and submitting a FOIL Application (PDF) by email or mail
The website instructs requesters to:
“Please answer all of the questions provided completely, accurate, and specific as possible to expedite your request.”
Both submission paths rely on the same standardized application structure.
Records Access Officer Identified (Strength)
The Town of Gates states that FOIL submissions are automatically routed to:
- Town Clerk / Records Access Officer
- Address and contact information provided
This satisfies a core FOIL accountability requirement.
Online and PDF Form Requirements
Both the online form and the downloadable FOIL Application require the requester to provide the following information in order to submit:
- Name
- Mailing address
- City, state, and ZIP code
- Phone number
- Email address
- Description of records requested
- Selection of electronic vs. paper delivery
- Signature (PDF form)
The downloadable FOIL Application explicitly includes a signature line and is labeled as an “Application for Access to Public Records”
⚠️ High Friction Identified
Submission is conditioned on personal identifying information and completion of a signed application, neither of which are required by FOIL to submit a request.
Mandatory Disclosure at the Point of Submission
FOIL does not require a requester to provide:
- A name
- A physical mailing address
- A phone number
- A signature
The Gates FOIL intake model nevertheless conditions submission on all of the above, creating unnecessary disclosure requirements at the entry point.
This places the burden of compliance on the requester rather than on the agency’s records system.
Timelines, Fees, and Process Information (Strength)
The Town of Gates clearly discloses:
- Five (5) business day acknowledgment requirement
- Twenty (20) business day disclosure framework
- Copying fees ($0.25 per page)
- Electronic delivery option
This information is clearly stated and accessible on the FOIL page.
Alternative Submission Methods
While Gates allows submission by:
- Online form, or
- Emailing/mailing the completed PDF
…the Town does not document a method for submitting a FOIL request without completing the standardized application.
All documented paths are form-dependent.
Anonymous or Low-Disclosure Submission
As presented, the Gates FOIL process does not clearly support anonymous or low-disclosure FOIL submission. All documented submission paths require personal identifying and contact information as a condition of intake.
Assessment
The Town of Gates demonstrates procedural FOIL compliance but relies on a form-centric submission model that introduces high friction at the point of request.
Key findings include:
- Mandatory FOIL application (online or PDF)
- Required personal identifying information
- Signature requirement (PDF)
- Clear timelines and fee disclosures
- Records Access Officer identified
Summary Scorecard
- FOIL form required: Yes
- Online submission available: Yes
- Email/mail submission allowed: Yes (form-dependent)
- Records Access Officer identified: Yes
- Personal information required: Yes
- Signature required (PDF): Yes
- Anonymous submission clearly supported: No
- Overall assessment: High Friction – Mandatory Disclosure
Conclusion
As presented on its website, the Town of Gates conditions FOIL submission on completion of a standardized application requiring personal identifying information and, in some cases, a signature. While Gates provides clear FOIL timelines, fees, and accountability information, the submission process itself imposes unnecessary barriers at intake.
Within the Monroe County FOIL Submission Audit, Gates represents a high-friction, form-dependent FOIL submission model.
Legal & Reference Notes
- New York Public Officers Law §§ 87–89
- Town of Gates FOIL webpage
- Town of Gates FOIL Application (PDF)