Notice of Population-Level ADA Communication Risk – Town of Greece
Transparent Law Enforcement has issued a formal notice to the Town of Greece regarding conditions identified through a records-based review of the Greece Police Department’s communication access framework for individuals who are Deaf or hard of hearing.
This notice follows the publication of the Greece Police Department audit as part of the Monroe County Interpreter Access Audit (MCIAA).
The notice is population-level and structural in nature. It is not based on any single incident and does not request enforcement action. Its purpose is documentation of observed conditions relevant to compliance, governance, and risk exposure.
Notice of Population-Level ADA Communication Risk – Town of Greece / Greece Police Department
from: Cadhla McBride admin@transparentlawenforcement.com
to: supervisormccann@greeceny.gov
cc: Deaf Equity DeafEquity@monroecounty.gov,
mail@drny.org,
GPDChief@greeceny.gov
date: Mar 9, 2026, 6:30 AM
subject: Notice of Population-Level ADA Communication Risk – Town of Greece / Greece Police Department
mailed-by: transparentlawenforcement.com
This correspondence serves as formal notice of population-level ADA Title II communication risk within the Town of Greece and the Greece Police Department.
The notice is based on the Town’s written FOIL responses, the department’s written acknowledgment of a policy discrepancy, and the absence of governance records required by the department’s own directive governing communication with persons with disabilities.
This notice is not incident-based. It concerns structural governance and operational risk.
I. FOIL-Confirmed Governance Posture
The Greece Police Department maintains a written directive — Policy 333: Communications with Persons with Disabilities — establishing administrative and training requirements governing communication with Deaf and hard-of-hearing individuals during law enforcement encounters.
Based on the Town’s written FOIL responses, the Town has affirmed that it possesses no records responsive to requests for:
Records identifying a designated ADA Title II Coordinator for the Town or the Greece Police Department, as referenced in Policy 333 §333.3 and required by 28 C.F.R. § 35.107
Administrative designation records for that role
Training materials related to Policy 333
Training attendance records or documentation of training provided to department personnel
Administrative implementation documentation associated with the policy
With respect to records documenting communication assistance during law enforcement encounters involving Deaf or hard-of-hearing individuals, the Town declined to search several request categories, characterizing portions of the request as “description insufficient.”
The only interpreter-related record produced was a contract associated with Tellmorr International held by the Greece Town Court, not the police department, which was identified as the department’s only responsive interpreter services record.
Separately, in a written response to a complaint submitted through the department’s Internal Standards & Compliance Bureau, Deputy Chief Aaron Springer provided the following statement:
“I have reviewed your complaint, entered as tracking number 26QSI-004, and determined this is not a personnel complaint. Please note the policy discrepancy you brought to our attention is being addressed by the Deputy Chief of Administration in coordination with the Town. Policy will be updated upon final resolution.”
This written acknowledgment — issued through the department’s formal complaint process — confirms that a policy discrepancy exists and that remediation is underway. It does not identify what documentation currently governs communication access during law enforcement encounters while that process is ongoing.
The Town’s FOIL responses and the department’s written complaint response therefore establish the Town’s documented governance posture as of March 2026.
II. Population-Level Risk Implications
The combination of a written policy establishing specific obligations and a confirmed absence of documentation demonstrating those obligations have been implemented creates systemic risk across law enforcement interactions involving Deaf or hard-of-hearing residents and visitors.
- Effective Communication Risk (Operational Level)
Policy 333 establishes that the Greece Police Department will provide communication assistance to individuals with disabilities during law enforcement encounters.
Without documented interpreter activation procedures, a designated ADA Coordinator, or training records demonstrating that officers understand their obligations:
Officers are left to individual discretion during encounters where effective communication is legally required.
The department’s own written policy establishes a standard of care that the absence of implementation documentation prevents the department from demonstrating it is meeting.
Critical advisements — rights, instructions, and safety commands — may not be reliably conveyed or documented.
The existence of the written policy, combined with the absence of implementation records, creates a documented gap between stated obligation and confirmed operational practice.
- Governance and Compliance Risk (Administrative Level)
Policy 333 §333.3 requires the Chief of Police to delegate responsibilities to a designated ADA Coordinator appointed by and directly responsible to the Operations Bureau Deputy Chief.
28 C.F.R. § 35.107 independently requires public entities employing 50 or more persons to designate at least one responsible employee to coordinate ADA Title II compliance.
Public payroll records (SeeThroughNY, 2025) reflect that the Town of Greece employs substantially more than fifty individuals, indicating that the federal designation requirement applies.
The Town’s FOIL responses confirm that no records identifying a designated ADA Coordinator exist for either the Town or the Greece Police Department.
- Auditability and Defensibility Risk
Structured interpreter access systems typically generate administrative records including:
ADA coordinator designation records
written operational directives
interpreter activation procedures
vendor agreements governing interpreter services
training materials and training records
documentation of interpreter deployment
The absence of these records limits the department’s ability to demonstrate consistent compliance in the event of a complaint, administrative review, or legal proceeding.
Because Policy 333 establishes affirmative obligations, those obligations now define the standard against which operational practice will be evaluated.
III. Risk Category Summary
Based on FOIL-confirmed representations and the department’s written acknowledgment, the Greece Police Department currently reflects:
A written policy establishing ADA communication obligations with no documentation demonstrating that the administrative structure required by the policy has been implemented
No documented ADA Title II Coordinator designation for the Town or the Greece Police Department
No documented training associated with Policy 333
No independent police-department interpreter services agreement governing field operations
A written departmental acknowledgment that a policy discrepancy exists
This combination creates population-level communication risk that is structural in nature and not dependent on any individual encounter.
IV. Notice Function
This correspondence serves as formal documentation that:
The absence of documented implementation of Policy 333 has been identified through the FOIL process;
The department has acknowledged in writing that a policy discrepancy exists;
The governance and operational risks associated with that discrepancy have been articulated in writing to municipal and departmental leadership; and
The Town of Greece and the Greece Police Department are now on notice of the structural exposure created by the current governance posture.
No specific action is requested in this correspondence.
The purpose of this notice is documentation of risk and preservation of the administrative record.
Respectfully,
Cadhla McBride
Transparent Law Enforcement
admin@transparentlawenforcement.com
This notice has been provided for documentation and public record purposes. Any clarification or additional materials provided by the Town will be reflected in future updates.