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)

Portland Copwatch
  a project of Peace and Justice Works
  PO Box 42456
  Portland, OR 97242
  (503) 236-3065/ Incident Report Line (503) 321-5120
  e-mail: copwatch@portlandcopwatch.org

Compliance Officer Reports Officers Repeatedly Using Force Not Counseled, PPB's Reluctance to Change
an analysis by Portland Copwatch, October 31, 2018

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 Compliance-Conditional."

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 ( http://www.portlandcopwatch.org/sampleDOJscorecard.pdf ).

In the below analysis, PCW uses page numbers in [brackets] and Settlement Agreement paragraph numbers in (parentheses).


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.


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 policing.

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 meaningful content.

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.


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.


--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 policy.

--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- considering.

--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 Agreement.

--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.


--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].


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 1175 people.

--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 read.


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.

Back to top


*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.
back to text

*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.
back to text

*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.
back to text

*4- PCW raised this concern with the COCL on October 17 and they did not argue the point.
back to text

*5- One was filed in March 2016, the other in January 2018.
back to text

*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.
back to text

*7- COCL promises more details in the Q4 Accountability Report which is due out in January.
back to text

*8- TAC also made 11 recommendations about the Bureau's Use of Force reports which don't relate to the annual Needs Assessment.
back to text

*9- Actually it says "the use force," which is a typo that needs to be fixed.
back to text

*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.
back to text

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 discipline.

Performance Discussion Tracker (PDT): Entries in this part of the EIS can affect promotions and pay.

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 days.

"Skills manager" and "Snapshot": Old databases used to track training information.

back to table of contents back to top

back to table of contents back to top
Portland Copwatch home page
Peace and Justice Works home page

Posted October 31, 2018