Portland Copwatch Analyzes Compliance Officer Report on
Employee Information and Training
Table of contents
So Much Questionable Conduct, So Little Concern
Questions About Training Remain Despite Rosy Picture
PPB Still Resistant to Change
Other Items of Concern
Some Positive Notes
Confusion, Wrong Words, Errors and Oddities
Final Item of Interest: PPB Getting National Help
Appendix: The maze of PPB databases (partial list)
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Compliance Officer Reports Officers Repeatedly Using Force Not Counseled, PPB's Reluctance to
In early October, the Compliance Officer/Community Liaison (COCL)*-
1 put out its first Report since 2017 on whether the Bureau's training and officer tracking
systems meet the terms of the US Department of Justice (DOJ) Settlement Agreement. The
Agreement came about because the DOJ found a pattern of the Portland Police Bureau (PPB) using
excessive force, especially against people with mental illness. The draft Report ( https://www.portlandcocl.com/reports/2018/10/1/draft-compliance-and-outcome-
assessment-training-eis ) continues a pattern noted by Portland Copwatch (PCW) in past
analyses: the COCL makes some important observations and recommendations, reveals some facts
that are of great concern, and sometimes (though less frequently now than in the past) overlooks the
impact of police actions on community members. As has been happening since the last full analysis
of the Agreement, which was released in October 2017, the Compliance Officer pushed a number of
ratings to "Substantial Compliance," including several using the made-up rating "Substantial
an analysis by Portland Copwatch, October 31, 2018
The key issues revealed by the Report include that most officers flagged in the Employee
Information System (EIS) for repeated use of force are not being counseled, not all officers' use of
force is used to find patterns in police units, an astonishing 57 officers were subjected to either
criminal charges or complaints that could contain such charges in the past year, that the
"Independent" Police Review (IPR) and Internal Affairs had to undergo a second training when
outside experts didn't do a sufficient job, and that the various computerized databases used by the
Bureau still require manual printouts to track training of officers. Some positive trends include a
few mentions that community members were involved in training police, that the PPB should
remember to ask the community for input, and that the COCL and the Bureau are considering
adding "Communication" to the list of basic skills for officers. This last item was something
Portland Copwatch recommended many years ago but was told communication ran throughout the
other disciplines; it is a welcome goal to see. What is missing includes: detailed data on how many
officers crossed various thresholds of force use and complaints-- the Report only lets us know that
officers were flagged at least 426 times for force and 111 times for complaints; the specific content
of training scenarios and videos, and an analysis of how the PPB's re-defining what constitutes
force last year may have affected the EIS alerts.*-2
Out of 15 items under review, six are "still" labeled Substantial, four went from Partial Compliance
to Substantial-Conditional, three went from Partial to Substantial, and one went from Not Assessed
to Substantial. Only one paragraph, number 81 regarding tracking training records, is still listed as
Partial. The COCL's scorecards showing compliance, therefore, have nearly every aspect
highlighted in green, which PCW has noted before gives the Bureau the idea that they are finished,
even when the "Conditional" term means they have work to do-- or when the Substantial rating
involves activity which has not been ongoing long enough to prove systemic change has occurred.
The scorecards also continue to only list the paragraph number and the rating, despite PCW asking
for a summary of the paragraphs to be included for clarity. Copwatch has posted a sample
scorecard with four columns (with one showing the previous rating) at (
In the below analysis, PCW uses page numbers in [brackets] and Settlement Agreement paragraph
numbers in (parentheses).
SO MUCH QUESTIONABLE CONDUCT, SO LITTLE CONCERN
The EIS flags officers who use force for one of three reasons: if the officer uses force for 20% or
more of their arrests in six months, if their ratio of force use is three times higher than others on
their shift, or if they use force three times within 30 days. Of the 426 officers flagged,*-3 only 79 (19%) ended up with an "intervention" [pp. 53-55].
"Intervention" is defined very late on in the 60 page document as monitoring, debriefing, and/or
discussion [p. 54]. The COCL speculates based on dialogue with the PPB that many of the cops
are being talked to, but the Supervisors do not want to document it because they are afraid it will
reflect negatively on the officers. Moreover, the COCL's survey of officers in 2017 showed that
only 16% think the EIS is an effective tool, and most think it is for discipline-- even though the
Portland Police Association contract forbids EIS being used as such.
While the COCL urges the Bureau to engage in more "interventions," they also note that the EIS is
used for commendations to support the officers, and that being counseled can include being told
they are doing something correctly.
Because the COCL combines all force alerts into one category, it is unknown how many were for
using force multiple times in a month and which officers were outliers in how often they use force.
The COCL seems satisfied with the fact that some senior officers' force ratios were high because
they don't make as many arrests [p. 50]; this still does not mean it was ok for them to use force.
The Report correctly suggests writing down criteria so that all officers are assessed equally.
It is surprising-- especially given that the COCL receives hundreds of thousands of dollars a year to
generate these Reports (and, it should be noted, PCW is given diddly squat to do these analyses)--
that the Report does not examine whether the high number of force alerts is related to the Bureau's
changing its definition of force in August 2017. This change lumped in some lower level uses of
force (such as force against resisted handcuffing, and "control against resistance") in the lowest
level (category IV). The only hint about this being an issue appears on p. 48 where the COCL notes
that category II force (which includes extreme violence short of deadly force) and category IV
(which includes pointing firearms at people) are treated the same way. It seems a logical
recommendation would be to set up different alert thresholds based on the seriousness of force.
Reported incidents of force went up from 260 in Q2 to 789 in Q4 2017 after the change. PCW
would say that the old category IV items should still be included in the existing thresholds, but the
lower level force should have slightly higher tipping points (perhaps five in a month).
This raises the question of whether Category I Deadly Force incidents are included in the EIS
counts, since the Bureau adamantly treats those cases differently by conducting "reviews" instead of
misconduct investigations, which blocks community members from filing appeals or complaints
about the most serious use of force.
The Report states that a total of 911 alerts were forwarded to commanders ("RU Managers") in the
year, claiming this meant each RU Manager received 2.5 per day [p. 47]. This is just bad math; it
means there were 2.5 per day across the entire Bureau.*-4 This
allegedly leaves officers feeling overwhelmed and questioning the utility of the EIS. To lower the
number of alerts, the COCL suggests that the Bureau extend the time frame to up to a year rather
than a month or six months. While this is a good idea in terms of finding more officers who use
force, it will likely lead to more alerts, rather than fewer. They also suggest moving away
from flagging individual officers and just looking at clusters, though both are supposed to be done
under the Agreement (116-119).
One suggestion that was not made: reduce the alerts by getting officers to stop using so much force
and prompting so many complaints.
On that note, officers are flagged if they receive three complaints total or two complaints in
the same category within a six month period. Again the COCL does not break out how many of the
111 alerts generated by complaints fell into either category [p. 53]; they do, however, let the public
know that only three of those alerts led to interventions. Yes, that is correct-- less than three percent
of officers who received multiple complaints got talked to by their Supervisors despite generating
enough complaints to flag them as potential problems. The reason for this injustice is that the Police
Association believes the intervention can be seen as "Command Counseling" and thus could subject
the officer to double jeopardy, or really double "correctional action"-- a term for soft discipline after
investigations end [p. 56]. The COCL wisely suggests that counseling could come after the
misconduct investigation ends, though that could be more than six months after the alert is sent to
the Supervisor. PCW suggests that if the first complaint is resolved when the second one surfaces,
the Supervisor can say "Hey, I heard there was another complaint against you, is there something
going on?" rather than get into the details of what happened. The Report also sensibly notes that
interventions are supposed to be based on trends, not individual incidents.
However, the COCL also minimizes the enormity of this problem-- the 111 alerts applied to 86
officers, which they say is a "relatively small proportion." This is nearly 10% of the Bureau's 920
sworn members, meaning almost one in ten officers civilians encounter may have 2-3 complaints
against them. (It also means that as many as 25 officers triggered the complaint alerts twice.) A side
note here before looking at issues about training: Lt. Leo Besner, known in the community as the
"million dollar man" for the amount of money his actions have cost the city in lawsuits, was briefly
assigned to the Training Division in early 2018. Besner was the subject of two nearly identical
complaints by community members who were observing police behavior and say he grabbed them
roughly by the arm to move them to a different location. Both cases were appealed to the Citizen
Review Committee (CRC). The complaints were filed almost two years apart,*-5 so they would not have led to an EIS alert. Moreover, complaint alerts
are not part of the criteria used to disqualify officers from being assigned to Training (83).
However, it would be great if the Bureau is looking at those alerts and complaint histories as
reasons to keep people like Besner from teaching other officers right from wrong.
Alerts also go out automatically if there is an allegation of criminal conduct. As noted above, 57
officers were flagged for this reason, but not a single one was counseled as a result. The COCL
does not examine whether this was because they were cleared of charges, found guilty and let go, or
if the commanders feel the "justice" system will take care of the allegations without their
intervention. The COCL should make just as strong a case for follow up after criminal allegations
as is made for after misconduct complaints have cleared.
It should be pointed out that in 2017, the COCL reported that the PPB "rejected" the idea of
expanding the thresholds. It is not clear what happened to the COCL's suggestion from the 2017
Report to look at whether officers repeatedly charge someone subjected to force with resisting
arrest, which PCW supported.
Fortunately, one suggestion we are glad disappeared was to look only at officers who are at the top
15% of using force in any unit and comparing them only to other officers in that unit rather than
across the board, which PCW pointed out could have let off other officers in that unit (such as the
Gang Enforcement Team, say) if the unit's use of force were already higher than the rest of the
PPB. Now PPB is saying they will institute a "multivariate" set of conditions to trigger alerts which
include force, overtime, sick time and the existing EIS alerts [p. 5]. For following the thresholds
(118-119), the COCL gives Substantial Compliance while finishing the subsection saying "we look
forward to seeing results" with regard to the new approach that will use multiple criteria.
In summary, the COCL gave Conditional Substantial Compliance to the Bureau for its use of the
EIS to identify officers, units and Supervisors with outlying behavioral issues (117) even though it
seems as if the Bureau is far away from using the EIS properly in its current configuration. The
COCL blames the DOJ Agreement for being too strict, saying it is not the PPB's fault for trying to
stay in compliance. This is utter nonsense, as the Bureau has done many things which are not
strictly within the word of the Agreement and have not been warned by the COCL or the DOJ for
doing so, but rather are often reported in Substantial Compliance.
QUESTIONS ABOUT TRAINING REMAIN DESPITE ROSY PICTURE
To their credit, the PPB began training officers on implicit bias and procedural justice in the spring
of 2018, with four hours of follow-up in the fall. As noted briefly above, some of the training even
included community members, which has been the suggestion of the Albina Ministerial Alliance
(AMA) Coalition for Justice and Police Reform for a long time.*-6 A
consulting firm called the Police Executive Research Forum (PERF) came to "train the trainers" on
de-escalation in May, which led to what the COCL said was an "effective and engaging" In-Service
class for officers [p. 23]. The Bureau made its own videos with community members role playing.
crime scenes and in "houseless settings," and also three African American teens presented in-
person on profiling and excessive force, requiring officers to listen and not respond or ask
questions [p. 27].
However, a lot of the information about PPB training left lingering concerns. Another consulting
firm, the OIR Group, which usually reviews Portland Police shootings for quasi-annual reports, was
hired to conduct a joint training between the Bureau's Internal Affairs unit (IA) and the IPR in
February. PCW expressed concern about this since the "I" in IPR is supposed to stand for
"Independent." The Report indicates the training was important because IPR can now "reach"
findings due to changes in the Agreement and City Code-- even though they really just recommend
such findings. Anyway, the Captain of IA and the IPR Director apparently did a follow up training
in April, the implication being that OIR, which is from California, gave a generalized training which
wasn't specific to "local rules" [pp. 30-31].*-7
The lead paragraph in the Agreement's section on training (78) calls for officers to be trained on
Constitutional rights. The COCL had not assessed this paragraph in the past because it relies on the
other sections being acted upon. Even though there are 10 paragraphs in the section-- including the
one outlining what kinds of training have to be done (84)-- the COCL reports that because the PPB
is "communicating expectations to officers," they are in Substantial Compliance with Constitutional
One main component of the Agreement's requirements for Training is that there be a Needs
Assessment to set priorities each year (85). The Training Advisory Council (TAC) is explicitly
required to give input on this Assessment. While it is true, as the Report notes, that the TAC gave
informal input to the Bureau in 2018, what's not highlighted is how little of the Council's June 2017
Needs report made it to the Bureau's November 2017 audit. From what PCW can tell, only two of
TAC's recommendations out of nine made it in, focusing on learning systems [Appendix COCL-B,
p. 36]. They made four recommendations regarding use of Tasers, which are not referenced by the
Bureau or the COCL.*-8 The COCL reminds the Bureau to check with
the community for input [p. 34], but it is in the context of responding to the Bureau complaining
that the COCL and DOJ ("third parties") came in with "last minute changes" [p. 33]. Perhaps the
COCL now knows how PCW feels when our recommendations are ignored, even when they have
The only area in which the COCL found the Bureau to still be in Partial Compliance was tracking
training records (paragraph 81). One main reason for this is that the Learning Management System
(LMS) program which tracks officers' classes is not accessible to all Supervisors for officer
performance reviews, so manual printouts are being used [pp. 17-19]. This is in part because
357,000 rows of old data had not been entered into the new system yet. In a random audit, the
COCL found that only 1/4 of classes were recorded for 10 officers they reviewed. Of greater
concern: the PPB did not include information on scenario trainings because they claim that is a
performance issue, not a training issue. The COCL seems ok that those data were entered into a
different database ("Questionpro"), and that the results of officers' surveys after trainings are in yet
another program referred to as Voxco [p. 20]. Allegedly, there is no way to ensure the officers
remain anonymous using the LMS. This atomization of data is partly what the DOJ was supposed
to help fix, instead it seems it is being further institutionalized. PCW has drawn up a short list of
known databases and what they do at the end of this document, but recommends the COCL should
create an official such list as an appendix to the Report.
In the late 2017 Report, the COCL initially held out on describing the details of scenarios the
officers were asked to use for role playing exercises. That draft Report promised to fill in the
blanks after the training was done, but ultimately the COCL said some officers might be put
through those roles in 2018 training. The same excuse is given for not fully describing the only
scenario used in 2018, which included someone in mental health crisis with a weapon. The Report
also lists "drills" involving use of firearms and Tasers, control tactics, procedural justice, implicit
bias, communication, decision making [p. 22], using "PPB's dummy" to simulate wound packing,
and a "cover drill" of rescuing a person on the ground under fire [p. 24]. It would be helpful to
know more about what the PPB is claiming are likely "realistic" situations. To their credit, the
COCL does note that most scenarios revolve around gunshots and the threat of death, with one
specifically around an ambush [p. 28], pointing out that not only is that not necessarily the best
place to practice de-escalation communication, but it is also something that happens extremely
rarely. The Report says officers find it hard to show respect to civilians once they try to kill you; it
would be great for the COCL to note that same instinct goes both ways. In other words, officers
often crank up their use of force when they feel suspects are being disrespectful, but that could
easily be the community member's natural reaction to someone tweaking their arm, pointing a gun at
them or zapping them with a 50,000 volt Taser.
The COCL continues to find PPB in Substantial Compliance with paragraph 83 because the PPB
has a system to screen out officers who use excessive force or otherwise mistreat people with
mental health issues, but there is no indication that screening has done anything. These criteria were
not the reason for the unexplained, but welcome, removal of Lt. Besner from Training as noted
above. There is no mention of the comment made in the 2017 Report where the COCL said it would
be acceptable for the Bureau to use a "common sense" standard to make exceptions to the existing
criteria, nor an indication that the PPB adopted guidelines for making any exceptions as PCW
suggested last year.
Overall the COCL says that the content of training (84) is Conditionally Substantial because while
officers get some time to flex their communications skills, they need more practice to get it right.
PPB STILL RESISTANT TO CHANGE
While there are a few instances where it seems the Bureau is making the needed changes, as noted
above the COCL's rating for their following thresholds to find possible problem officers is based
on the PPB adhering to the letter of the Agreement. The DOJ has said from the beginning that the
City would not be found out of compliance if they go beyond what is required in the Agreement. In
addition to (essentially) stubbornly sticking to the EIS guidelines, the Bureau also refused to look at
the content of classes during their audit of the Training Division, saying it was "beyond the scope
of their mission" [p. 7].
In evaluating the training, in addition to the "audit team" griping about the input from third parties
(described by the COCL as "lamentation"), they told the COCL they did not want to use the
surveys conducted in classes to determine future training needs. Rather, they want to do a specific
survey of officers to ask what to include, once again leaving the COCL realizing what it feels like to
have ideas rejected [p. 34].
In the summary of the training section, the COCL reasserts that using input from outside sources
can be in the best interest of the Bureau and for Portland as a whole. They concede that they can't
force the Training Division to document class content in their audit, but hope the PPB will do so
voluntarily [p. 38]. They also note that the audit did not explain what criteria were used to assess the
training. PCW wonders why the DOJ can't arbitrate these disputes, since they ultimately are the
ones who will report to the Court whether the Bureau is complying.
OTHER ITEMS OF CONCERN
--14 Alerts on Performance, No Action Taken
One major issue of concern relating to the Employee Information System alerts relates to a table on
page 57 showing how many officers had how many alerts, and whether action was taken. The
COCL claims that if there are more alerts, more interventions are done-- which seems logical.
However, of 21 officers who had six alerts, only eight of them were counseled, or 38%, which is
less than the percentage of officers with any other number between two and 12 alerts. Perhaps more
disturbing is that two officers racked up 13 and 14 alerts respectively, but neither was subjected to
an intervention at all.
In addition, on p. 54 it says that 10% of EIS alert outcomes are "declined." It is not clear what that
means or how it is acceptable under policies and the Agreement.
--Least Favorite Trainings Most Meaningful to Community
Line officers were given four classes in spring 2018: De-escalation, legal, pathogens and implicit
bias. The class they rated highest was about pathogens, the lowest was about bias [p. 13]. To be
fair, it was only by a few percentage points, but it is still telling.
Supervisors were trained on After Action Reports, EIS, "policy 330" (which is about Internal
Affairs Investigations), Directive 1010 (which is about use of force), the Mental Health Template
and case management. The Supervisors liked the training on EIS the best, and the one about Use of
Force the least [p. 14].
--No Real Life Examples from Portland?
On p. 22, the Report notes that an interactive online test was given including YouTube videos
showing "problematic officer behavior prior to or during the use of force."*-
9 They also report about local videos produced with the help of community members, "from
crime scenes to houseless settings." However, the City Auditor's report on training from June 2018
says the PPB does not want to use actual scenarios based on real incidents in Portland because they
are afraid of "embarrassing" the officers who were involved. Isn't this one point of training-- to
learn from one's own mistakes? It is not clear why the COCL did not weigh in on this ridiculous
--You Make Decisions with the Training You Have, Not the Training You Don't Believe Works
In feedback about training on critical decision making, the Report quotes one officer saying that
applying those principles is not how things work when cops are under pressure [p. 29]. The COCL
does not explicitly state that it should be. Perhaps the COCL is implying that if officers get more
scenario training, making quick decisions which includes "treating all community members with
respect [to gain compliance], and de-escalating intense situations... reducing the need for force" [p.
21] will be second nature.
--Four to Five Officer Involved Shootings Per Year, 300 Traumatic Events
When PCW first learned that "traumatic incidents" was one category in the Employee Information
System that could lead to alerts, we thought it would be rare for officers to trigger such an alert as
there are only four to five officer involved shootings per year. However, the Report shows that 292
officers were flagged for having three such incidents in 30 days, making up 20% of the alerts [p.
53]. Traumatic incidents are not defined anywhere in the Report, nor in Directive 345.00 on the
EIS. However that Directive defines "Critical Incident" as "an atypically traumatic event that may
cause physical, emotional, and/or psychological injury or harm" which is very vague. We hope the
COCL will give more details on what these officers are doing that leads to so much trauma. Side
note: While only 19% of cops using too much force get interventions, a whopping 73% of those
with traumatic incidents get such counseling [p. 9].
--Everyone Reviewing Police Misconduct Needs Training on Discipline
A training given to commanders about the discipline guide covered important issues, such as what
happens if a complaint falls into more than one category, what deviations from the guide are
acceptable, and what factors to consider when adding or subtracting to discipline. Those factors
include intent, history, harm/injury, negative effects to the public, and training [p. 30]. This is a great
idea in terms of being consistent with discipline. PCW strongly recommends, though, that this same
class should be given to the civilian (and officer) pool of members for the Police Review Board,
since they have to grapple with the same questions.
--Too Generous a Grade to PPB Interactions with Training Advisory Council
As has happened in the past, the COCL glosses over the superficial way in which the Bureau
presents quarterly Use of Force Data to the Training Advisory Council (86). PCW has attended
nearly every TAC meeting and in general, the Bureau spends more time explaining how they collect
and categorize data than the numbers themselves. Moreover, the COCL says they are "satisfied"
that the TAC asks for analysis and the Bureau is responsive "where appropriate" [pp. 38-39]. At the
September TAC meeting, it was revealed that the Bureau rejected the TAC's reasonable request to
put demographic data about the City's population in the reports to compare to force data. It would
not be surprising if the COCL was part of making that decision, which the PPB is now re-
--Force Per Arrest Ratio Means Something, Or It Doesn't
On page 49, a table shows that most precincts/divisions had a force-to-arrest ration of .1, meaning
most officers use force in one out of 10 arrests. Two shifts-- one in Central Precinct and one in
North-- had ratios of about .17, almost twice as high as the others. The Bureau said because the
numbers are based on officers who use force four times or more, the pool is too small for that
number to make a difference. (Interestingly, whatever PPI stands for, that division has only a .05
ratio, meaning only one use of force per 20 arrests.) The COCL opines that putting in too many
officers will dilute the meaning of the ratio, but that is ridiculous. The idea is to find which
precincts/divisions use the most force, and by eliminating officers who use force three times or
fewer this exercise is not giving the DOJ-- or the community-- the information promised in the
--Did the Bureau Not Do These Things, Or Simply Not Report Them?
The COCL notes that the Needs Assessment bibliography does not include any research done on
Procedural Justice and Implicit Bias [p. 12]. Hopefully this means the research was done but not
listed, rather than the PPB made up its own materials.
Also, 7.6% of Supervisors and 5.6% of officers either missed their trainings, or their presence was
not recorded properly [p. 35].
Similarly, paragraph 85e requires training reports to be "accessible" to the DOJ and two Assistant
Chiefs*-10, but the COCL's analysis of the outcomes does not make it
clear this is happening [pp. 35-36].
Seven officers failed to sign off on seven or more Directives in 30 days as required. The training
audit suggested that since there was no way to notify officers or hold them accountable, notification
should come up when 60 days pass, and the officer's computers should pop up with reminders until
the signatures are given [pp. 37-38].
The Inspector apparently found trends showing officers need more training in box-ins, force on
fleeing subjects, handcuffing leading to force, takedowns, waiting for cover, pursuits, pursuit After
Action review and Taser use by "tenured officers" [pp. 38-39]. It is not clear how these issues were
reported or how they were addressed in "In Service" training.
SOME POSITIVE NOTES
--Training for kindness?
(a) On p. 27, the Report notes that the police are being trained in "the value of human life."
However, it is not elaborated on or explained elsewhere.
(b) The PPB is teaching that officers using commands to control the suspect are not a form of de-
escalation, something both the COCL and PCW have noted repeatedly [p. 23].
(c) Similarly, they are teaching that just because an officer is allowed to use force under the
law and PPB policy does not mean they should do so [p. 29].
(d) They are also teaching de-escalation to calm an agitated subject, promote rational decision
making and lessen the likelihood force is used to "gain compliance" [p. 5].
(e) In an ethics class in spring 2018, police were taught to listen to a subject, show concern for their
welfare, and treat them fairly, with respect, within the law and without bias [p. 22].
(f) Part of de-escalation training is to slow down to make better decisions [p. 23].
PCW notes here that the above advances will be welcome when they are seen on the streets,
including in crowd situations.
(g) Peer intervention was given two hours in spring training, though it is not clear if "peer" here
means persons with mental health issues who can help with someone in crisis or officers
intervening when they see another officer doing something wrong [p. 22].
--In addition to mentioning the value of the community in training classes and videos, the COCL
reminds the Bureau to ask the community for input into the training Needs Assessment [p. 11],
including "maybe" prioritizing the issue of crowd control.
--The Bureau started putting notices in Supervisors' files when they fail to review the EIS for
officers under their command. This non-disciplinary threat, along with reminder emails, helped
push compliance up to 97% in Q3, though it bounced up and down when the emails were not sent.
--The Training Division took care of the problem the COCL found last year where officers were
talking to each other when they were supposed to be writing up evaluations of training [p. 41].
--Following feedback from Portland Copwatch last year, the City Attorney included information
about how injuries caused by force could have constitutional, civil and criminal consequences [p.
24]. The description is vague but seems to be heading in the right direction; the City Attorney also
told officers they need "individualized reasonable suspicion" to make arrests, presumably in the
context of crowd situations where they have been detaining entire groups of people.
--The Training Division has three new people heading up the areas of leadership, ethics and
Procedural Justice [p. 31].
--An audit of training records recommended that the Bureau create manuals for "specialty trainings"
and keep track when officers get certified on items that are not part of the regular academy-- both
good ideas [p. 35].
--After last year's Report urging more attention to EIS alerts, the amount of alerts forwarded from
Professional Standards to Supervisors went from 6% in Q4 2015 to 65% in Q2 2018 [p. 53].
CONFUSION, WRONG WORDS, ERRORS AND ODDITIES
There are a number of typographical errors in the Report, many of which PCW has sent to the
COCL in a separate document. As noted above, the COCL made a mathematical error in calculating
the number of EIS alerts sent to the Bureau in one day-- 911 alerts in a year divided by 365 days is
2.5 alerts per day overall, not per managing Supervisor.
Other confusion came from these apparent errors:
--On page 15, the Report refers to the "CSCSC model" around ambush training. On page 28, it is
again referred to as CSCSC but explained in a footnote as CRCRC, Cover / record / command /
radio / check injury.
--Page 16 talks about "Customer satisfaction," a term PCW has repeatedly noted does not apply to
police work. Even though arguably people who call 911 could be considered "customers," as they
are sometimes targeted for arrest by police, but in many other cases people are approached by
police without that person asking them to do so, thus this term should not be used. The term is
repeated on p. 27.
--Also on page 16, the COCL suggests that the community surveys about the PPB should look at
"persons experiencing mental health crises and other subgroups within the Portland community."
This is at best teetering on the edge of insensitivity.
--The COCL seems fascinated by the fact that the PPB used a laminated sheet in training; it is
mentioned both on p. 15 and p. 28.
--The Training Advisory Council is incorrectly called a "Committee" on pp. 11 and 21.
--While the Report is not a copy-and-paste of old Reports, as was the problem in the past, the
COCL repeats some phrases over and over to where it almost seems humorous (or meaningless).
The term "significant strides" describing Bureau progress is used at least eight times [pp. 5, 6
(twice), 21, 27, 28, and 31 (twice)]. The variation "significant steps" is on pp. 4, 8, and 12.
--The reference to a bibliography of studies in the Needs Assessment lists it as being in "Appendix
D" which is true, but confusing because the Needs Assessment is Appendix B of the COCL's
Report. Numbering the COCL's appendices or calling them COCL-A and COCL-B might help.
--On pp. 45-46 and 49 there are a number of references to divisions within the Bureau that PCW is
not familiar with despite our years of work on this issue. Many of them are not clarified in the text
or the appendix, including: PPI, NRT, SCU, YSD, PED, FED, SSD or CIU.
--Although the COAB has been defunct for over a year and a half, its various subcommittees are
still listed in the Abbreviations section, while the new Portland Committee on Community Engaged
Policing (PCCEP) is not mentioned in the entire Report.
--In the troubling table on how many officers received their evaluations [pp. 45-46], which shows
most units at or under 64% compliant, the total number of employees reviewed is 1051 out of 1788
(59%). This is very confusing because even with non-sworn personnel, the Bureau only employes
--As noted in earlier feedback on COCL Reports, this Report uses many scientific terms like
"multivariate" and "dyad," making it difficult for ordinary civilians (and, probably, most officers) to
FINAL ITEM OF INTEREST: PPB GETTING NATIONAL HELP
On pages 16 and 17, the COCL reveals two national agencies helping the Bureau; it is not clear if
these are good or bad developments. The Police Foundation from Washington DC is helping
develop the contact survey to be given to civilians after encounters with officers. Moreover, Portland
is a "pilot site" for a National Law Enforcement Applied Research and Data Platform administered
by the National Institute for Justice.
PCW has been concerned from day one that the DOJ Agreement would take away from other
needed reforms at the Portland Police Bureau, and that the changes required in the Agreement do
not go far enough. The COCL's Reports, including this one, confirm that suspicion and add to the
problem by deferring to the police when they are not going far enough. The COCL is no longer a
community liaison, only connecting to the public once every three months at town halls to present
these Reports, and either quietly slipping in and out of Portland in-between or hiding back in
academia in Chicago while shootings, attacks on protestors, and mistreatment of people in mental
health crisis continue.
To their credit, the COCL team seems open to comments from the community, including from
PCW, in a way that was not happening back when they started in 2014. However, for instance, a
response to community input on the last Quarterly Report was not published (despite a claim
otherwise at the October 17 COCL forum) until after PCW asked where it was.
While on the one hand it will be a good thing if the PPB is declared in compliance with the
Agreement and Portlanders can regain local control of the police, in reality there will be little
holding them to account for continuing the positive trends which are slowly surfacing after six
years under the DOJ's watch. Unless the PCCEP picks up the important task of examining the
COCL's Reports and then makes plans of how to keep auditing the police for compliance, there will
be no oversight at all, uneven as the COCL's analyses are. The COCL seems to want to declare the
City in full compliance and move on, at which point the DOJ can ask the judge to sign off on the
reforms. Someone has to stop them from backsliding, instead building more accountability and less
racial bias and force.
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*1- Portland Copwatch has noted that since the COCL's role no longer involves managing the
community board set up to oversee implementation of the agreement, they should be called the
Compliance Officer/CO not the COCL.
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*2- At the COCL's town hall on October 17, it was apparent that the COCL team did not realize the
new rules were in effect for 10.5 out of the 12 months they were reviewing.
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*3- Actually, there were 944 flags but 423 of 518 were not forwarded because the officers' force-to-
arrest ratio went up when older arrests fell off the calendar even though no new force was involved
or similar technical reasons. It is not clear why the other 95 were not forwarded.
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*4- PCW raised this concern with the COCL on October 17 and they did not argue the point.
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*5- One was filed in March 2016, the other in January 2018.
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*6- However, so far as we know the PPB did not reach out to the Coalition itself to participate or
request persons who might participate in the trainings.
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*7- COCL promises more details in the Q4 Accountability Report which is due out in January.
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*8- TAC also made 11 recommendations about the Bureau's Use of Force reports which don't
relate to the annual Needs Assessment.
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*9- Actually it says "the use force," which is a typo that needs to be fixed.
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*10- The Agreement actually refers to the "Director of Services," which is what the Assistant Chief
of Services was called when civilian Mike Kuykendall had the job until February of 2013; perhaps
the COCL should add [Assistant Chief of Services] in brackets to cut down the confusion from
using this term.
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APPENDIX: The maze of PPB databases (partial list)
EIS: Employee Information System. Includes complaints, commendations, sick leave and other data
to help find officers doing well or who may be exhibiting problematic behavior. It is not used for
Performance Discussion Tracker (PDT): Entries in this part of the EIS can affect promotions and
LMS: Learning Management System, contains records of what training officers received, lesson
plans, and other training related data not in the following two other databases.
Questionpro: Holds data on PPB scenario training.
Voxco: Holds data on PPB training evaluations.
ADORE: Automated Observation Reports and Evaluations. Includes data on Field Training for
probationary officers. (Note: this was added to the abbreviations appendix in Q1-Q3 2017 in
response to a PCW comment.)
Directive acknowledgment system: Database showing if officers signed new policies within 30
"Skills manager" and "Snapshot": Old databases used to track training information.
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Posted October 31, 2018