Notice of Population-Level ADA Communication Risk – Irondequoit
Transparent Law Enforcement has issued a formal notice to the Town of Irondequoit regarding conditions identified through a records-based review of the Irondequoit Police Department’s communication access framework for individuals who are Deaf or hard of hearing.
This notice follows the publication of the Irondequoit 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 – Village of Fairport / Fairport Police Department
Cadhla McBride admin@transparentlawenforcement.com
to Bryan, bcc: jmancuso
Village Manager White,
This correspondence serves as formal notice of population-level ADA communication risk affecting routine law enforcement interactions within the Village of Fairport.
This notice is based on records produced in response to Freedom of Information Law (FOIL) requests and the governance and implementation posture reflected in those records. It is not incident-based. It concerns structural conditions reflected in the current record.
I. FOIL-Confirmed Governance and Operational Posture
The Fairport Police Department maintains a written policy governing communication with individuals who are Deaf or hard of hearing. That policy establishes interpreter access pathways through dispatch coordination and, where necessary, through a professional services agreement.
The materials produced in response to FOIL requests do not include procedures describing how dispatch identifies or maintains interpreter resources, and the Village has indicated that dispatch-related processes do not pertain to it. The record also does not include documentation of interpreter requests, interpreter usage, or communication accommodations in field encounters, nor does it include training materials or records demonstrating implementation of the policy.
The department identified a professional services agreement with an ASL-fluent provider; however, that agreement is defined in psychological terms, and the materials provided do not indicate whether it remained in effect during the period under review. The agreement further designates Village administrative personnel—not the Chief of Police—as authorized agents for communications, despite the policy assigning operational responsibility for its use to the Chief.
No records were produced identifying an ADA Coordinator or a formal administrative structure responsible for communication access. Employee roster records produced by the Village indicate staffing levels above the threshold at which federal regulations call for designation of an ADA Coordinator. The materials provided do not identify such a designation or an equivalent administrative role.
This is the governance and operational posture reflected in the FOIL record.
II. Risk Implications
The presence of a written policy addressing communication with Deaf and hard-of-hearing individuals, combined with the absence of documented implementation systems, creates risk that is structural rather than incident-specific—meaning it affects any encounter with a Deaf or hard-of-hearing individual regardless of the individual officer involved.
At the operational level, the policy contemplates interpreter use and identifies pathways for obtaining communication support, but the materials provided do not show how those pathways function in practice. Communication accommodations may depend on individual officer judgment and situational availability, and there is no record-based method to verify whether interpreter services are requested, provided, or declined.
At the system design level, interpreter access is dependent on externalized components—dispatch coordination and a single contracted provider—without corresponding documentation describing how those components are managed or integrated into field operations. The lack of visibility into dispatch functions, combined with the limited scope and uncertain status of the external agreement, prevents evaluation of whether these pathways are consistently available.
At the governance level, no ADA Coordinator or administrative structure has been identified, and the record does not describe who has authority to make or review decisions regarding communication accommodations. Without defined responsibility, there is no identified mechanism for managing compliance, receiving complaints, or addressing failures.
These conditions also limit auditability. The materials provided do not include interpreter usage logs, training records, procedural documentation, or other administrative records that would typically allow a department to demonstrate how communication access is implemented in practice.
III. Notice Function
This notice is not a demand for action. Its function is to create a documented record that the conditions described above have been identified and communicated to municipal and departmental leadership.
This correspondence documents that the absence of ADA governance and implementation systems has been identified through the FOIL process, and that the associated risks have been articulated in writing to municipal and departmental leadership.
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.