Notice of Population-Level ADA Communication Risk – Webster

Transparent Law Enforcement has issued a formal notice to the Town of Webster regarding conditions identified through a records-based review of the Webster Police Department’s communication access framework for individuals who are Deaf or hard of hearing.

This notice follows the publication of the Webster 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.

Cadhla McBride admin@transparentlawenforcement.com
Mar 23, 2026, 5:26 PM
to Supervisor@ci.webster.ny.us,
kdoyle@ci.webster.ny.us
cc:
Deaf Equity DeafEquity@monroecounty.gov,
mail@drny.org

Supervisor Scialdone,

This correspondence serves as formal notice of population-level ADA Title II communication risk within the Town of Webster and the Webster Police Department.

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.

This notice is not incident-based. It concerns structural governance and operational risk.

I. FOIL-Confirmed Governance Posture

The Webster Police Department maintains written policies governing communication with individuals with disabilities, including those who are Deaf or hard of hearing.

Policy 332 (Communications with Persons with Disabilities), dated February 12, 2026, requires the Chief of Police to delegate ADA-related responsibilities to an ADA Coordinator and assigns that role responsibility for interpreter access procedures, complaint process coordination, and program administration.

Based on written FOIL responses:

• The Town of Webster reported that no ADA Coordinator designation is on file and no ADA grievance procedure records exist;

• The Webster Police Department reported that it is not in possession of records identifying ADA-related designation or program administration, or records demonstrating implementation of ADA-related functions;

• With respect to field encounters, the department reported that it is not in possession of records documenting Deaf or hard-of-hearing encounters, interpreter usage, or communication accommodations for calendar year 2024.

In correspondence accompanying the FOIL response, the department stated that an ADA Compliance Policy was issued on October 14, 2025 to replace the Communications with Persons with Disabilities policy, but that the earlier policy had not yet been removed.

The record therefore reflects overlapping policy documents rather than a single clearly superseded standard.

These responses establish the Town’s and department’s documented governance posture as of this date.

II. Population-Level Risk Implications

The presence of written policies establishing ADA communication obligations, combined with the absence of records demonstrating governance and implementation, creates structural risk across law enforcement interactions involving Deaf and hard-of-hearing residents and visitors.

1. Effective Communication Risk (Operational Level)

Policy 332 requires effective communication and the use of auxiliary aids and services, including qualified interpreters, where necessary.

The policy assigns responsibility for interpreter access procedures and communication access oversight to the ADA Coordinator role.

No records were produced identifying an ADA Coordinator or the procedures and systems assigned to that role.

Without documented procedures, training records, or records of communication accommodations:

• Officers may rely on individual discretion in situations where effective communication is legally required;

• There is no record-based method to verify whether communication accommodations are consistently provided in field encounters;

• The department cannot demonstrate, based on the available record, how communication access is operationalized in practice.

2. Governance and Compliance Risk (Administrative Level)

Policy 332 contemplates coordination between a departmental ADA Coordinator and a Town ADA Coordinator.

The Town reported that no ADA Coordinator designation or grievance procedure is on file, and the Police Department reported no records identifying ADA program administration.

As a result, the governance structure described in policy is not reflected in the records produced.

3. Auditability and Defensibility Risk

Policy 332 requires documentation of communication methods and retention of training records, and assigns responsibility for ADA program administration and complaint processes to the ADA Coordinator role.

Structured ADA communication programs typically generate administrative records, including:

• ADA coordinator designation records
• grievance procedures
• interpreter access procedures
• training materials and attendance records
• documentation of interpreter deployment

No such records were produced in response to FOIL requests.

The absence of these records limits the ability to demonstrate compliance in response to complaints, administrative review, or legal proceedings.

III. Risk Category Summary

Based on FOIL-confirmed representations, the Town of Webster and the Webster Police Department currently reflect:

• A written ADA policy framework with overlapping policy documents
• No documented ADA Coordinator designation at the Town or department level
• No documented ADA grievance procedure
• No records of interpreter usage or communication accommodations in field encounters
• No records demonstrating completion of ADA-related training
• No records demonstrating implementation of ADA program administration functions

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 ADA governance and implementation has been identified through the FOIL process;

• The associated operational and compliance risks have been articulated in writing to municipal and departmental leadership; and

• The Town of Webster and the Webster Police Department are now on notice of the structural exposure reflected in the current record.

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

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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.