By Cadhla McBride in ADA Title II — 08 Mar 2026

East Rochester: No Written Interpreter Access Policy Identified

Key Finding
East Rochester officials stated in FOIL responses that the Village maintains no written policies, training materials, or interpreter service agreements governing communication with Deaf or hard-of-hearing motorists, instead describing informal practices such as voice-to-text communication or locating a “sign-language-trained officer.”

Executive Summary

Through a Freedom of Information Law request, Transparent Law Enforcement asked the Town/Village of East Rochester to identify policies, training materials, and interpreter access procedures governing communication with Deaf or hard-of-hearing motorists during traffic stops and crash investigations.

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.

The Village responded that it does not maintain specific written policies or records governing those interactions and instead described informal practices such as:

using cellphone voice-to-text communication
contacting the county to request assistance from a “sign-language-trained officer.”

No written policies, training materials, interpreter service agreements, or public-facing materials were produced.

A separate FOIL request seeking records identifying the municipality’s ADA Title II coordinator designation and grievance procedure also did not produce records identifying those structures.

Following the FOIL responses, Transparent Law Enforcement issued a Notice of Population-Level ADA Communication Risk to municipal leadership documenting the governance implications of the absence of identifiable structure.

Records Produced

East Rochester produced no written records responsive to the requested categories.

The Village did not produce:

policies governing communication with Deaf or hard-of-hearing motorists
training materials related to communication access
interpreter service contracts or agreements
memoranda of understanding with outside agencies
public informational materials for Deaf or hard-of-hearing drivers.

Instead, the Village stated that it does not maintain specific policies or records governing contacts with Deaf or hard-of-hearing individuals.

The response described an informal operational practice:

officers may use cellphone voice-to-text communication
dispatch may contact the county to locate a “sign-language-trained officer.”

No documentation governing those practices was produced.

Governance Considerations

Availability-based communication access

The Village’s response reflects what Transparent Law Enforcement has observed in several Monroe County FOIL responses: communication access may depend on locating an available individual rather than activating a predefined system.

Transparent Law Enforcement examines this distinction in more detail in the analysis: “ASL Interpreter Access, Stop Duration, and Governance Design.”

That analysis discusses the governance implications of availability-based communication models, including interpreter qualification ambiguity, traffic stop duration considerations, and documentation limitations.

East Rochester’s FOIL responses fit the availability-based pattern described in that analysis.

Interpreter qualification ambiguity

The response references the possibility of contacting a “sign-language-trained officer.”

No documentation was produced identifying:

qualification standards
certification requirements
training expectations
proficiency evaluation.

Without documented standards, the meaning of “sign-language-trained” cannot be independently evaluated after the fact.

Under the ADA, public entities must ensure effective communication with individuals with disabilities, including provision of qualified interpreters where necessary. Federal regulations define a qualified interpreter as someone able to interpret effectively, accurately, and impartially using any necessary specialized vocabulary. (28 C.F.R. § 35.160; § 35.104)

Without documented qualification standards, it is not possible to evaluate whether the described “sign-language-trained officer” model satisfies that standard in practice.

ADA administrative governance uncertainty

A separate FOIL request sought records identifying:

the municipality’s ADA Title II coordinator
the ADA Title II grievance procedure.

No records identifying those structures were produced through the FOIL process.

Public payroll records reviewed by Transparent Law Enforcement (SeeThroughNY, 2025) indicate approximately 70 individuals on the Town/Village payroll, suggesting the municipality likely meets the 50-employee threshold under 28 C.F.R. § 35.107, which requires designation of an ADA Title II coordinator and adoption of a grievance procedure.

Documentation limitations

Structured interpreter access systems typically generate administrative artifacts such as:

interpreter service contracts
deployment procedures
training documentation
activation records.

No such documentation was produced in response to the FOIL requests.

The absence of those artifacts does not establish that communication failures occurred. It does limit the ability to independently evaluate how communication decisions are made or whether they occur consistently.

Notice of Population-Level ADA Communication Risk

Following the FOIL responses, Transparent Law Enforcement issued a Notice of Population-Level ADA Communication Risk to municipal leadership.

The notice documented that the Village currently reflects:

no documented interpreter activation framework
no documented ADA Title II coordinator designation
no documented ADA grievance procedure
no documented public communication materials for Deaf or hard-of-hearing motorists.

The purpose of the notice is documentation of governance risk rather than an incident-based complaint.

FOIL Process Timeline

July 2025 — TLE submitted a FOIL request seeking policies, training materials, interpreter agreements, and public-facing materials relating to Deaf or hard-of-hearing motorists.
July 3, 2025 — East Rochester responded that no responsive records exist and described informal practices involving voice-to-text communication and requesting a county “sign-language-trained officer.”
February 2026 — TLE filed a FOIL appeal after the July response had been overlooked.
February 20, 2026 — East Rochester clarified that it had already responded in July 2025 and re-sent the prior response. The clarification was appropriate and the appeal was unnecessary.

A separate FOIL request regarding ADA administrative structures did not produce records identifying a coordinator designation or grievance procedure.