Portland Copwatch Analyzes Compliance Officer Report on US DOJ Agreement October 2019

COMPLIANCE OFFICER'S FAULTY ANALYSIS GIVES EARLY FINISH TO POLICE IMPROVEMENTS

New Report is Short on Outcomes and Other Key Data
an analysis by Portland Copwatch, October 29 2019

In its latest draft report analyzing the progress toward eliminating excessive force by Portland Police, especially against people in mental health crisis, the Compliance Officer/Community Liaison (COCL) COCL claims the City and the Bureau are now in full compliance with the US Department of Justice Settlement Agreement. The consultant group's finding confirms what Portland Copwatch (PCW) has been expressing over the past year of COCL reports, that the question of compliance is more about "did the City check the box" than it is about "did it produce the desired outcomes in a sustainable way." For example, the COCL is giving full compliance to misconduct investigations happening within 180 days (paragraph 121) even though compliance is somewhere around 94%, adding together cases handled by the "Independent" Police Review (IPR) and the Bureau's Internal Affairs (IA).*-1 Nowhere do they examine that the caseload for both IPR and IA have dropped by at least half with the invention of a new "Supervisory Investigation" which derails many cases from being fully examined by uninvolved parties. Furthermore, the existence of a Community Engagement Plan (paragraph 146) is not the same as one that lends to community trust. Indicating the Bureau's lack of interest in truly engaging the community, the Behavioral Health Unit Advisory Committee (BHUAC) has never held any of its meetings in public-- because the letter of the Agreement doesn't require it and the COCL "greenlighted" their meeting behind closed doors (paragraph 94). The Bureau's retooled force (and deadly force) policies (paragraph 67) have actually led to an increase in people in mental health crisis being shot or killed since the Department of Justice (DOJ) arrived.*- 2 And, PPB's annual report presentations (paragraph 150) blithely ignored requirements listed in the Agreement.

Alarmingly, at the October 22 Portland Committee for Community Engaged Policing (PCCEP) meeting, the COCL explicitly stated that the purpose of the DOJ Agreement is not to provide better outcomes, but rather to create systems for the police to monitor its own behavior. It boggles the mind that the City has spent millions of dollars and countless hours, filed two appeals to block the case from moving forward in court, and claims that the stringent requirements of the Agreement are one reason they're having trouble recruiting new officers when the people monitoring the changes say it doesn't really matter if the officers' behavior is any different as a result.

There are bits and pieces of data scattered throughout the COCL report, with just two charts in the Use of Force section, four charts and one table in the IPR section, and overall no real attention to the quality rather than the quantity of what the PPB has purportedly done. Considering these quarterly assessments are supposed to focus on outcomes, it's not credible to say the City is in full compliance with the DOJ Settlement Agreement.

The COCL gushes over the fact that the Bureau finally (after 5 years under COCL scrutiny) released an Annual Report and held meetings in each precinct and at City Hall as required by paragraph 150. The Compliance Officer notes that the Central Precinct presentation was "lightly attended" and that "community members asked questions about policing tactics and made observations about policing in their communities." The COCL team-- which is paid per year roughly enough money to fund Portland Copwatch for 100 years-- failed to analyze their compliance with the actual Agreement. As noted in their summary of paragraph 150, the PPB is supposed to use the presentation of Annual Reports to "educate the community about its efforts in community policing in regard to the use of force, and about PPB's policies and laws governing pedestrian stops, stops and detentions, and biased-free policing, including a civilian's responsibilities and freedoms in such encounters." While the Annual Report commendably notes the impact of deadly force incidents on the community (while leaving out the death in custody of Richard Barry), there are few other mentions of PPB use of force, one mention of implicit bias training, and one mention of the collection of stop data. There was no mention of the required items at the City Council hearing on October 2. Even though the COCL team does not reside in Portland, they could easily have observed this by watching the Council hearing on video.*-3

The Council heard the Annual Report in conjunction with the Community Engagement Plan. Mayor Wheeler attempted to direct public input to only talk about the Plan because he "in his great and infinite wisdom" does not like to take testimony on Reports. Portland Copwatch testified on both matters anyway. The fact that only 5-6 people in the community testified about the Plan and the Report shows that the Bureau's efforts to engage the community are inadequate. Compare this to the over 70 people who attended an Albina Ministerial Alliance Coalition for Justice and Police Reform forum on the Police Association Contract on August 26, or even the dozen or so people who attend PCCEP meetings. PCW warned of the irony if the Mayor failed to take community input on the Community Engagement plan, but wasn't expecting the hearing to be so embarrassingly miniscule. PCW and other community groups could have had more time to turn people out had the October 2 date been announced prior to the Sept. 24 PCCEP meeting, just 8 days before the hearing. Maybe the COCL, the police and City Council don't need to plan their schedules more than a week in advance-- especially something taking place in the middle of a Wednesday afternoon-- but many of us in the community do need to do so.

The COCL also says the PCCEP itself is in compliance and claims they have plenty of alternate members to fill vacancies, even though there have been eight resignations and one seat reserved for youth which has been open for five months in just the first year of the group's existence. PCCEP also was unable to pass a recommendation at its August meeting due to one member who was unable to vote, two members abstaining and that empty youth seat.

The COCL explains that their findings of Substantial Compliance are based on asking whether violations are minor or systemic (citing paragraph 178a on compliance). The Bureau's inability to communicate important document release or meeting to the public is definitely systemic. Luckily (or, maybe not since they were more generous than the COCL in their last report), the DOJ still has the final word in whether the City is found in full compliance. The court, as the COCL notes, has jurisdiction for one full year after that time to make sure the City is not falling down in its responsibilities. COCL claims they will be "rigorous" about ensuring that compliance, which given their eagerness to give passing grades despite ongoing violence against people in mental health crisis, is not reassuring.

This leads to one of the main questions raised by the report (which PCW has raised before): Once the COCL's job is finished, who will be given access to all the PPB's trainings, documents, and data to be sure they are following the supposed systems of self examination the report claims are in place? Repeatedly, the COCL mentions how they step in to make suggestions on how the Bureau can improve what it is doing. It is not clear that the PCCEP will be able to fulfill this function in the future, even though they are envisioned to do so.

One sticking point since the outset of the implementation of the Agreement has been that the Behavioral Health Unit's Advisory Committee (BHUAC) does not hold public meetings. The City Attorney ruled that those meetings do not have to conform to Oregon Public Meetings Laws. The COCL has continually deferred to the BHUAC's own decisions, repeatedly turning down the suggestion to hold open meetings. The new Report encourages the BHUAC to consider ways to include the community-- posting their agendas ahead of time (even though people can't attend the meetings), posting their minutes afterward, and seeking "avenues" to involve the public. Not long after the COCL report was released-- once again giving full credit to the City for following the letter of the agreement for creating the BHUAC (paragraph 94), the Committee finally responded to a request from the Mental Health Alliance made in March, once again rejecting the notion that they should hold public meetings. The seven months to come up with a response which seems to violate the spirit of the Agreement is, in itself, a violation of that spirit.

In the previous several quarterly reports, the COCL was only focusing on areas they thought the Bureau needed to focus on to complete compliance. This time, they began revisiting some sections they claim were already in compliance: Force, Mental Health, Crisis Intervention, and the Employee Information System (EIS). However, there is no clear explanation why some paragraphs (for example, 99, 105 and 115 in the Crisis Intervention section, 116-117 in the Employee Information section) are not covered. PCW surmises that the COCL is skipping over these as they were found in compliance as of the Q2 or Q3 quarterly reports, and this report is only looking at paragraphs which were in compliance prior to that time. Below PCW examines what the COCL had to say about these and other areas of the Agreement. Paragraph numbers are listed in (parentheses) and page numbers in [brackets].

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USE OF FORCE: Wasn't This About People with Mental Illness?

The level of force used against persons with mental illness is not mentioned in the COCL report, only the overall "force to custody" ratio (about 3% of the time people are arrested, taken on civil holds, or given a citation, the police use force) and the actual rate of use of force (which is roughly 200 times per quarter, or more than twice per day). The ratio went up from 3% of custodies to nearly 5% when the PPB re-defined what has to be reported as force in 2017, then went back down. It's not clear if this means officers are (a) using less force from the new categories, (b) not reporting those uses of force in order to avoid the paperwork (after all, some handcuffed civilians might not realize their rough cuffing was a Use of Force), or (c) engaging less frequently in more serious uses of force. These questions persist (1) because of the lack of data in this report and (2) because the COCL claims they cannot assess whether those more serious uses of force went down after 2017 [p. 11], which would seem to be fairly simple to do by subtracting the new categories.

Part of this section looking at force reporting requirements perpetuates the problematic compromise that was made to allow officers in deadly force incidents to avoid writing their own Force reports because of the automatic investigations into these incidents (69c). If the concern is that an officer might self-incriminate regarding criminal conduct, isn't that also a possibility in the report for any other police action? The idea is that officers are entrusted to follow the law and Bureau policy, and if they violate those they can be charged or disciplined. Why is deadly force continually walled off from other common procedures?

According to the COCL, no witness or involved officers have refused to participate in compelled interviews for force other that deadly force (69b).

The COCL also states the PPB has an adequate number of Sergeants to supervise line officers (69 total, each supervising an average of 5 officers) but doesn't, as usual, raise the question of whether the Sergeants' initial investigations into Use of Force incidents (70) makes sense in the long term. PCW had pointed out that Sergeants and Officers are in the same collective bargaining unit, which came as a surprise to the COCL some three years into their tenure, and which lends itself toward minimizing problems rather than rigorous scrutiny.

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TRAINING: Procedural Justice Has Potential

The report examines the one item the COCL previously said was not yet in compliance, which the lack of adequate role plays for officers to practice "procedural justice" and de-escalation (84a). According to the new report, this was done in the 2019 fall "in-service" training. The tenets of procedural justice are certainly noble: giving voice to the community member, being respectful, maintaining neutrality and showing concern, empathy and helpfulness [p. 14]. The Bureau has hired someone, the report notes, to integrate procedural justice into all Training. The COCL once again refuses to describe the "realistic" scenario that was used for fear officers who haven't been trained will read it. We have a hint for the Compliance Officer: Other than the Oregonian's reporters, we're pretty much the only people in Portland who read these reports any more.

In any case, the COCL describes how some officers struggled with the scenario but all were debriefed to learn ways to improve. The COCL says they had some concerns but didn't ask the Training Division to re-do the training [p. 15].

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MENTAL HEALTH: Letting the City and Bureau Off the Hook (Again)

The COCL briefly mentions that there are changes being made to the Unity Center, the facility whose existence was used to claim the City was in compliance with paragraph 89. However the Unity Center is not the drop-off / walk-in facility envisioned in that paragraph, and the "correction plan" is being implemented due to serious mismanagement issues raised by whistleblowers at Unity. Because the Bureau participates in the "transportation subcommittee" at Unity, they are given full compliance on this paragraph.

(For paragraph 88, there's a description in this section about Portland State University doing an analysis in 2018 which found discrepancies between law enforcement and provider policies and made recommendations. Was this in a previous report? Did the changes get made? -- page 17 this year).

With regard to paragraph 90 which requires the Bureau to sit in on Community Care Organizations' subcommittees, the report says there is "no sustained opportunity" to do so since no such meetings are happening. But because the Behavior Health Unit's Advisory Committee and the Behavioral Health Coordinating Team include people listed in this paragraph the City again gets a "Substantial" rating.

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CRISIS INTERVENTION: Is Collecting Info on Non-Criminal Behavior Even Legal?

Months after their introduction, the COCL finally reveals that the Bureau's recently-added two Behavioral Health Response Teams are not assigned to any of the three precincts, where the original three Teams reside. Rather, one is used for follow up on clients prior to the usual 60-day check-up, and the other is assigned solely to engage with houseless persons (106). It is not clear whether and how this BHRT connects to the houseless liaison the Bureau hired a few months ago. The COCL continues to praise the Service Coordination Team even though previous data showed that only about 20% of the people attending rehab finished the program.

PCW has come upon a curious issue we hadn't pondered before. The BHCT meets biweekly to discuss people who have repeat contacts with officers or who "represent an escalating concern" [p. 19], to comply with the use of data to decrease use of force outlined in paragraph 92. Oregon state law prohibits the collection or maintenance of data on people's social, religious or political affiliations unless there is reasonable suspicion of criminal conduct. So unless the contacts with officers specifically relate to criminal behavior, is the entire program monitoring people with alleged Behavioral Health issues in violation of this statute? A related question is, once you are put on a list of people with suspected mental health issues, if the PPB's auditors find no mental health indicators in reviewing police reports [p. 20], are you taken off that list? The flags are triggered not just for people who have three Mental Health Templates (filled out when officers believe there is a mental health issue) in a month, but also those who have two or more Enhanced Crisis Intervention Team (ECIT) calls with general offense reports; the latter criterion indicates criminal conduct, the former does not.

A total of 66 people were referred to the BHRT in three months for having three mental health template reports in a period of 30 days. Information bulletins are put out to street cops to help locate these people. Could this be another potential area of over-policing rather than actually getting help to people?

The BHU's newsletters are used to highlight which officers do a good job; however it is not clear whether the Bureau is following paragraph 93's other requirement to identify officers who need correction in their performance.

Also it's not clear if earlier reports noted that the Behavioral Health Unit contacts the Multnomah County Crisis Line to decide whether to disengage with a person or at least to delay engagement/custody [p. 19], which seems like a good practice.

Getting back to the BHU Advisory Committee, the COCL notes that they voted on improvements to the mental health system throughout the year. There is no indication of whether their recommendations were adopted or produced meaningful outcomes, though previous reports show the Bureau responding more quickly to the BHUAC than they ever did to the Community Oversight Advisory Board (COAB-- the predecessor to the PCCEP). The analysis of paragraph 95 notes that the group's minutes were provided to the COCL for the report but hadn't been posted to the website. The BHUAC nonetheless is given Substantial compliance, based on those privately shared documents. Side note: The BHUAC's work on policies about custody of people in mental health crisis is not mentioned even though it is part of the criteria for compliance with paragraph 111.

Again raising the question of "who will do this once the Agreement is dropped," the COCL notes that they go over reports about BHU and Emergency Communications triage with the BHU Lieutenant "as needed" (96).

As for the Crisis Intervention Team model, there was no follow up on the previously disputed paragraph 99, which required a "Memphis Model" to be used in Portland. The last report noted that the DOJ and COCL are satisfied that Portland training all its officers in Crisis Intervention and then adding an "Enhanced Crisis Intervention Team" is satisfactory, which PCW agrees with conceptually. The original Memphis Model only gives CIT training to the elite volunteer group of cops who get called to situations determined to involve mental health.

The 130 ECIT officers-- impressively twice as many as the Agreement's recommended 60-80-- apparently only show up 75% of the time to ECIT calls. The COCL says this is similar to how things work in other cities, which is too bad for those cities where not all officers get at least basic CIT training. They attribute just 6% of the no-show cases to officers not being available when called, but don't explain the other 19% (100).*-4

An interesting question is raised in a survey of cops showing there is confusion about whether an ECIT officer is to take primary responsibility when responding to a call. The COCL says this led to a clarification of the role of ECIT-- but doesn't say what that clarification was [p. 24]. So despite praising the Bureau's review of the surveys as reading "like a scientific journal" (peer reviewed? hard for a layperson to understand? who knows), the COCL's report doesn't answer questions it raises.

Side note: Apparently the PPB identified an officer who missed part of ECIT training and stopped them from being listed as qualified to take calls [p. 25]. In addition to attending required training (102), there are very strict criteria to stop cops from continuing to be on ECIT: being found out of policy for using force or mistreating people with mental health issues (101). Since such allegations are rarely sustained (Force allegations are only found out of policy 1% of the time) there should be more ways to determine whether officers are appropriate to be part of ECIT. This is also true for removal from the Behavioral Health Response Team, which only involves five officers (108).

The COCL also finds Substantial compliance for highlighting the work of the ECIT (104), including their quarterly newsletters, presenting to subcommittees of the PCCEP, and taking part in "Coffee with a cop" and "Shop with a cop" activities. It is not clear what these last two feel-good events have to do with promoting ECIT's work with people in crisis. Missing is a fairly key question: If you talk to the average person on the street, do they know that the Enhanced Crisis Intervention Team exists or what it does? If not, these "highlights" are not effective.

Paragraph 110, requiring that the BHU hook people up with services, gets a Substantial finding too, even though only 26% of people contacted were coordinated with such services. The report does not say what the outcomes are for the other 74% of people, only saying the 26% is the "most prevalent" outcome.*-5

The section on the Service Coordination Team (112) introduces a project called "Supportive Transitions and Stabilization" which provides housing before people enter the SCT program. It is not clear how or whether (or why) this program is related to the Bureau; PCW cannot find any reference to it in earlier reports.*-6 Housing is important for people seeking recovery, but as we have noted repeatedly, should be available to all, not just those who are arrested over and over by the police.

The Bureau of Emergency Communications (BOEC) staff apparently have shown increased empathy and other positive attitudes about people with mental illness after receiving the training outlined for them in paragraph 114. Only 5 of 138 (Q1 2019) and 9 of 109 (Q2 2019) people who were identified as needing ECIT officers required regular cops to respond after ECIT officers, indicating BOEC's training is doing some good. The data on how many calls overall were treated as ECIT calls-- up from 3% to 19%-- is a bit confusing. The COCL talks about looking at "non- seasonal decreases" being used by BOEC to remind the dispatchers to send ECIT cops out, perhaps this means that some months normally include more (or fewer) such calls.

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EMPLOYEE INFORMATION SYSTEM: Don't Raise the Bridge, Lower the River

The Agreement requires supervisors to talk to officers if they meet certain thresholds, for instance, officers who use force three times in one month (119). The COCL again refers to the Bureau enacting additional analyses to the thresholds required by the Agreement (118-119) as "Risk Management." PCW has cautioned against the use of this term since Risk Management is the City's office which processes lawsuits for police misconduct [p. 32].

The Bureau dealt with the low referral rate for officers who cross the thresholds around Use of Force, which were between 21 and 45%, rather than refer more cops to their supervisors, instead they now treat "low-level" force as half-incidents. This level of force (Category IV) includes pointing a firearm at a person, which is very serious. The COCL agrees with the DOJ's calling the inclusion of the lower uses "white noise." The referral rate went up to 39%... less than it was in Q4 2018. The COCL blames the new rate on yet another new supervisor taking charge at the EIS-- at least the fourth since 2016.*-7 We understand that people in the Bureau want to have varying assignments to help advance their careers, but some jobs like those involved in accountability mechanisms should be looked at for longer tenures.

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ACCOUNTABILITY: Is Timeliness More Important than Just Outcomes?

The DOJ and COCL agreed that the Bureau's Internal Affairs and the Independent Police Review were not meeting the mandated 180 day timeline to complete investigations (121). As noted above, this report says there has been much improvement. However, it ignores one of the main reasons for the change: many cases that used to be handled as full misconduct investigations are instead being shuffled off to Supervisors. The "Supervisory Investigations" began toward the end of 2018. Since that time the overall number of full investigations dropped by 50%-- from 56 to 28. In other words, of course they are getting more cases investigated faster as they only have half the caseload they once did. The fact that the IPR's managerial reviews of cases shows a steady decline from January to the present is very surprising, considering the entire management resigned in April and May. This could be seen as a testament to Interim Director Amanda Lamb, who helmed IPR from April to early August, or more likely the even more dramatic drop in IPR's caseload from 11 in Q2 2018 to 4 in Q3 2019, a 64% drop.

The COCL over-enthusiastically cheers on IPR for opening three cases in Q2 which should all be done in 180 days... except for one [p. 34].

Since, as PCW pointed out in our previous analyses, the COCL does not take a serious look at the outcomes of the investigations-- including whether the complainants were satisfied with either the process or the findings-- this does not mean that the Accountability System is improved in the way the Agreement promises.

One given reason for the improvement at IPR and IA is a new set of Standard Operating Procedures (SOPs). It has never been mentioned anywhere that the Citizen Review Committee, whose City Code-enshrined duties include advising IPR on its operations, had input in to the original guidelines for investigations. At least as far as we can tell from public meetings, CRC was not asked to weigh in on any of these changes.

The SOP changes include some kind of electronic case file that can show up in a shared mailbox for IPR and IA. The findings from investigations are then shared on thumb drives [p. 37]. For anyone whose ever had a thumb drive (/flash drive/USB drive) go bad, this is not necessarily reassuring.

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COMMUNITY ENGAGEMENT/PCCEP: Oh, Really?

Though the PCCEP's recommendations have been few and of minimum impact, the COCL continues to find they have the "potential" to fulfill the Settlement Agreement's vision of a serious oversight body [p. 5]. It will be interesting to see whether Judge Michael Simon, who made a point of not wanting to approve of PCCEP's structure until he saw them actually working, agrees that they do not have to accomplish all their tasks to be found in full compliance, as the COCL asserts.

As noted above, the PCCEP's meetings usually only have about a dozen community members in attendance, and the COCL admits that their subcommittee meetings are "sparsely attended" [p. 40]. Yet the PCCEP's outreach and participation in formulating the Bureau's Community Engagement Plan over the course of a mere one month are praised here (145). The COCL notes the PCCEP was invited to the Bureau's "Steering Committee" but doesn't clarify that body is only specific to the five year plan [p. 41]. That said, PCW received notification of the five year plan Steering Committee meetings when they began, but hasn't heard of any for months. Neither of the two PCCEP members who attended the meeting PCW observed have reported back to the full body about the progress of the plan. The COCL claims that PCCEP "questioned whether the PPB needed a full year to 'establish an Hispanic/Latinx Advisory Council.'" But that comment was made by one or two members of PCCEP, it was not done in the form of a formal recommendation. Moreover, our public comment about this issue was that PCCEP and the PPB need to examine the harm done when two officers involved in shooting Jose Mejia Poot in 2001 were given medals, which led to the self- imposed dissolution of the Latinx Round Table as it existed at the time.

Examples given of the PCCEP's recommendations (142) show they have been focused on Settlement Agreement metrics, the PPB Annual Report, and the Community Engagement Plan. There has been very little input (though this may change at the October 22 meeting) into assessing the implementation of the Agreement,*-8 or about Directives "touching the DOJ Settlement Agreement "involving "constitutional policing, use of force, interactions with people experiencing mental illnesses, complaint investigations and racial justice" as outlined in the City's plan creating the PCCEP.

The community survey which was conducted in February (paragraph 146) wasn't presented to PCCEP until July. The COCL claims the outcome of the survey was used to inform PCCEP's recommendations on the Community Engagement Plan, but doesn't include a single example to prove this statement [p. 42].

Perhaps one of the biggest indicators that the COCL is not adequately researching their assessment report is the assertion that there are enough PCCEP alternates waiting in the wings to address future resignations of members [p. 40]. In the first year of its meetings (Nov 2018-Oct 2019) there have been at least 8 resignations (most recently, Sam Sachs resigned at the end of the October meeting) and one seat for a youth representative remains open due to a term that ended in June. A few alternates have declared they are unable or unwilling to serve. This turnover rate is alarmingly similar to the resignation rate at the COAB. Moreover, the staff overseeing the PCCEP appears to think alternate members should serve full terms from the time they are called in to fill a vacancy, which will result in disorderly staggering of terms, making recruitment and training new members extremely complicated.

And while it is somewhat true that members of the PCCEP are "not afraid" to express their concerns about police practices [also p. 40], one major recommendation from the People with Mental Illness Subcommittee was derailed when two members abstained. They wanted to run the idea of expressing condolences after a police shooting by the police, when the Committee's job is to make recommendations to the Bureau reflecting community concerns. The fact that the PMI Subcommittee went around the process and handed the recommendation directly to the Mayor and Chief is not mentioned anywhere in the report.

This area also includes paragraph 150 on the PPB's annual reports, which as we noted above is a true test for whether the Bureau is capable of engaging the community. In a city with over 600,000 residents, it is telling that there were fewer than 10 community members present for at least two of the four presentations (East Precinct and City Council). The COCL assigning full compliance to this item epitomizes the "checking the box" analysis and ignores the deeper goals of the Agreement.

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CONCLUSION

There are many reasons Portland Copwatch was dubious about the Department of Justice conducting a pattern and practice investigation of the Portland Police. One concern was that the recommended fixes would run counter to community demands. Ultimately the Settlement Agreement fell short on many fronts.*-9 That said, if implemented fully, there was at least some potential to improve the police by lowering the amount of force used, improving the accountability system, and creating a more transparent and honest police force which was not afraid to engage the public in discussions about difficult issues (rather than continually bombarding us with public relations). The COCL's many years of going too easy on the PPB have now culminated in a document claiming complete transformation while people are still racially profiled, harmed by violent responses to protest actions, and killed with no accountability or sense of remorse from those responsible.

The adopted Community Engagement plan does not mention the word "accountability." The Bureau did a terrible job letting people know about the DOJ-mandated meetings to present their annual report. Additionally, they continue to put out Police Review Board (131) reports without alerting community members. It is almost as if the Bureau is not truly interested in Community Engagement. This may explain the lackluster community response to PCCEP's meetings and the reason the PPB's own community survey continues to show a lack of trust in the Bureau.

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Footnotes:

Footnotes:

*1-The Report refers twice to the Internal Affairs and IPR "Joint rates" being at 85.4% and 94.4% "respectively"; it took several reads to realize the "respectively" was referring to Q4 2018 and Q1 2019, not to IA and IPR.

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*2- See PCW's comments on the 2019 OR Group report which show 55% of cases before 2012 and 65% afterward involved people in mental health crisis.
http://www.portlandcopwatch.org/shootings_analysis_0219.html

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*3- The COCL's report was supposed to cover the quarter ending September 30 but extended its reach to include the October 2 hearing.

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*4- The officers may have been called off by a sergeant, the situation was resolved, or the subject could not be located.
< a href="https://www.oregonlive.com/crime/2019/10/city-hired-overseers-find-portland-police-in- substantial-compliance-with-doj-settlement-community-activists-scoff-at-findings.html"> https://www.oregonlive.com/crime/2019/10/city-hired-overseers-find-portland-police-in-substantial- compliance-with-doj-settlement-community-activists-scoff-at-findings.html

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*5- Previous reports listed other outcomes as: (Dan needs to research this part)

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*6- An internet search turned up a reference in a PPB document presented to the COAB in 2015 about the STS being created, and indications that it is a program of Central City Concern.

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*7- This was Frank Gorgone in 2016, Mike Fort in 2017, Jay Bates in 2018 and Nathan Sheppard in 2019.

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*8-The PCCEP plan, under "Goals" begins with this sentence: "PCCEP members will independently assess the Settlement Agreement using the tools outlined in this plan." Mayor Wheeler went on record when the plan was adopted saying this meant the implementation of the Agreement.

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*9- "Bringing a Plastic Mallet to Hammer in a Problem Nail: US DOJ/City of Portland Agreement Doesn't Go Far Enough (10/31/12)
http://www.portlandcopwatch.org/copwatch_analysis_doj_1012.html

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Posted December 15, 2019