HomeMy WebLinkAbout4/19/2022 Item 6e, Scott - Staff Agenda Correspondence
Council Agenda Correspondence
City of San Luis Obispo, Council Memorandum
DATE: April 19, 2022
TO: Mayor and Council
FROM: Rick Scott, Police Chief
VIA: Derek Johnson, City Manager
SUBJECT: Item # 6e. - Council Correspondence regarding the Ordinance approving
the Military Use policy in accordance with AB 481
This correspondence is regarding the item at the April 18, 2022, City Council meeting
related to the new legislation governing the use of military equipment by the Police
Department titled AB 481. To date no public questions have been received for follow up.
The information and materials were circulated with both the Police Advisory Committee
(formerly PACT) and the Police Roundtable. A few questions for clarification on the
department’s (AB 481) policy. Below is a summary of the questions posed to the
department and our response to date which are indicated in italics. There will be a few
minor changes to our proposed policy based on good feedback received thus far.
1. Q: Who (which position in the department, not necessarily a named individual) will
be deemed the Equipment Coordinator?
a. The “Police Administrative Captain” will be the Chief’s designee and named
in the proposed policy.
2. Q: What will the process be for acquisition and funding of each piece of equipment?
a. Acquisition: See next question referencing approval below.
b. Funding: There is no change for funding. All equipment we currently have
is essentially funded until replacement is needed. We work through our
existing budgetary process for this and request funding when items are
expended or worn and become non-serviceable.
3. Q: What will be the approval process for new equipment?
a. Yes, any NEW (not previously approved) equipment must go back to
Council for approval via the ordinance process. We cannot buy anything
Council has not reviewed and approved via this process. Ideally, this would
happen once a year along with the annual military equipment report. If the
need should arise for additional equipment, we did not previously seek
approval for, then we will come back to Council.
City of San Luis Obispo
Item 6e – Staff Agenda Correspondence Page 2
4. Q: What will the public process be for filing a complaint and what will be the
documentation and follow-up processes for those complaints? Who will manage
that process?
a. A specific section will be added to the proposed policy covering the process
outlining and referring community members to our existing and robust
complaint process which meets the elements of the law. Ideally it is not good
practice to restate an existing policy within a policy as this will create
opportunities for inconsistencies and significant version control issues and
confusion for the public and staff.
5. Q: AFSC California Healing Justice reviewed policies from other cities. Could you
please let us know if any of the concerns below are applicable to our policy?
a. The San Luis Obispo Police Department and its policies are in alignment
with AB 481. We reviewed numerous model policies including Sacramento
PD. The AFSC document mostly parallels AB 481, but we are strictly
following the mandates in the law which is best practice and required.
b. The first line of AFSC letter states, “Policies complying with AB 481 should
describe uses that are not authorized.” This is not a direct quote from the
law and to better address the question is to have the actual verbiage from
AB 481. AB 481 in Chapter 12.8 7070 (d)(2) states “Military equipment use
policy means a publicly released, written document governing the use of
military equipment by a law enforcement agency or a state agency that
addresses, at minimum, all of the following. (2) The purposes and
authorized uses for which the law enforcement agency or the state agency
proposes to use each type of military equipment.” Attachment A of SLOPD’s
Policy 709 does this as it lists the proposed and authorized use for each
item of equipment.
c. The next section highlighted is from the AFSC document and not AB 481,
“Policies should clearly state to whom deployments will be reported and how
records will be kept.” AB 481 Chapter 12.8 7072 specifically outlines what
is required by law. …The annual military equipment report shall, at a
minimum, include the following information for the immediately preceding
calendar year for each type of military equipment:
1. A summary of how the military equipment was used and the
purpose of its use.
2. A summary of any complaints or concerns received concerning the
military equipment.
3. The results of any internal audits, any information about violations
of the military equipment use policy, and any actions taken in
response.
Item 6e – Staff Agenda Correspondence Page 3
4. The total annual cost for each type of military equipment, including
acquisition, personnel, training, transportation, maintenance,
storage, upgrade, and other ongoing costs, and from what source
funds will be provided for the military equipment in the calendar
year following submission of the annual military equipment report.
5. The quantity possessed for each type of military equipment.
6. If the law enforcement agency intends to acquire additional military
equipment in the next year, the quantity sought for each type of
military equipment.
7. SLOPD Policy 709.8 closely follows AB 481 Chapter 12.8 7072
processes for reporting the use of this equipment as required by
this law providing this information to Council annually.
d. The last highlighted section from AFSC’s letter states, “Adequate
enforcement of military equipment policies requires ordinances with a
private right of action.” SLOPD Policy 709.3 (e) and 709.9 both outline our
policy which ensures community engagement. Additionally, Policy 709.3 (g)
ensures that the community can register a complaint or question regarding
the use of military equipment. A complaint would follow our established
complaint process Policy 1019. This will be better specified in our proposed
policy for tomorrow.
6. Q: On page 1 of the policy, the listing of “military equipment” seems to include all
items listed in AB 481. Are there specific items which we would not want for our
City and should exclude within the policy? Perhaps specific assault weapons or
LRAD’s?
a. Yes, all items listed in the law that are not being requested are by default
not authorized already. Page 1 of our policy does list all items from AB 481.
The reason is Policy 709.1.1 is the “Definitions” section of the policy and we
are adhering to the law outlined in AB 481. Our policy recognizes and
adopts AB 481 in its entirety.
b. The Department thoughtfully determined what minimum equipment is
necessary to carry out our duties and responsibilities as a department. The
Department have been discerning in determining what equipment is needed
and are not requesting at this time any new equipment that the department
does not already possess and for which the department has governing
policies.
c. The use of equipment and tools outlined in this report is very rare. In these
rare and extreme circumstances, it would only be used to protect the welfare
of community members and peace officers. For example, we do not have
an LRAD and this is something that we found is not appropriate for our
community along with many other items we are not requesting. If we
continue with the policy as written, an LRAD and many other pieces of
military equipment (not requested) will not be allowed for use by the
department as intended.
Item 6e – Staff Agenda Correspondence Page 4
7. Our comprehensive Use of Force policies were developed over years of robust
research and input and most recently in partnership with a nationally well know
Jewish activism group Bend the Arc and model policies from the ALCU to ensure
we are not using force or any weapons disproportionately against any members of
our community to include black, brown, or any marginalized members. The
equipment in this law (481) and others are merely tools only, their use is governed
exclusively in our stringent and Use of Force policy.
8. The following is an excerpt from the Council Agenda Report that addresses the
statement from AB 481: “It is important to note that the use of equipment and tools
as outlined in this report is very rare. The Police Department has policies in place
to deescalate situations and only uses force as needed to protect public
safety. Nevertheless, many of these tools have been tested in the field and are
used in very rare and life-threatening situations to protect public health and safety
by LEAs to enhance resident and officer safety. The ability to use these items
during rare and extreme circumstances are to protect the welfare of residents and
peace officers within the City of San Luis Obispo.”
Attachment A - Military Equipment Policy 04/18/2022
San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Copyright Lexipol, LLC 2022/01/03, All Rights Reserved. Military Equipment - 1
Published with permission by San Luis Obispo Police
Department
Policy
709
Military Equipment
709.1 PURPOSE AND SCOPE
The purpose of this policy is to provide guidelines for the approval, acquisition, funding, and
reporting requirements regarding military equipment as defined in Government Code § 7070
(Government Code § 7070; Government Code § 7071; Government Code § 7072).
709.1.1 DEFINITIONS
Definitions related to this policy include (Government Code § 7070):
Governing body – The San Luis Obispo City Council (“City Council”).
Military equipment – Includes, but is not limited to, the following as defined in Government Code
§ 7070(c):
• Unmanned, remotely piloted, powered aerial or ground vehicles.
• Mine-resistant ambush-protected (MRAP) vehicles or armored personnel carriers.
• High mobility multipurpose wheeled vehicles (HMMWV), two -and-one-half-ton trucks,
five-ton trucks, or wheeled vehicles that have a breaching or entry apparatus attached.
• Tracked armored vehicles that provide ballistic protection to their occupants.
• Command and control vehicles that are either built or modified to facilitate the
operational control and direction of public safety units.
• Weaponized aircraft, vessels, or vehicles of any kind.
• Battering rams, slugs, and breaching apparatuses that are explosive in nature. This
does not include a handheld, one-person ram.
• Firearms and ammunition of_.50 caliber or greater, excluding standard -issue
shotguns and standard-issue shotgun ammunition.
• Specialized firearms and ammunitio n of less than_.50 caliber, including firearms and
accessories identified as assault weapons in Penal Code § 30510 and Penal Code §
30515, with the exception of standard -issue handguns.
• Any firearm or firearm accessory that is designed to launch explosive projectiles.
• Noise-flash diversionary devices and explosive breaching tools.
• Munitions containing tear gas or OC, excluding standard, service -issued handheld
pepper spray.
• TASER® Shockwave, microwave weapons, water cannons, and long -range acoustic
devices (LRADs).
• Kinetic energy weapons and munitions.
• Any other equipment as determined by City Council to require additional oversight.
Pursuant to Government Code § 7070(c), the following are not military equipment:
• Police versions of standard consumer vehicle s
• Unarmored all-terrain vehicles (ATVs) and motorized dirt bikes
• Items designed to remove a lock, such as bolt cutters, or a handheld ram designed
to be operated by one person
San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Military Equipment
Copyright Lexipol, LLC 2022/01/03, All Rights Reserved. Military Equipment - 2
Published with permission by San Luis Obispo Police
Department
• Standard issue shotguns
• Standard issue shotgun ammunition
• Standard issue service weapons and ammunition of less than .50 caliber
• Standard service-issued handheld pepper spray
• General equipment not designated as prohibited or controlled by the federal Defense
Logistics Agency
709.2 POLICY
It is the policy of the San Luis Obispo Police Department that members of this department comply
with the provisions of Government Code sections 7070 through 7075 with respect to the approval
for, acquisition, funding, and use of, and reporting regarding military equipment.
709.3 MILITARY EQUIPMENT COORDINATOR
The Police Administrative Captain is designated as the Military Equipment Coordinator by the
Chief of Police and shall have all duties and responsibilities herein to include, but are not limited
to:
(a) Acting as liaison to City Council for matters related to the requirements of this policy.
(b) Identifying department equipment that qualifies as military equipment in the current
possession of the department, or the equipment the department intends to acquire
that requires approval by City Council.
(c) Conducting an inventory of all department military equipment at least annually.
(d) Collaborating with any allied agency that may use military equipment within the
jurisdiction of San Luis Obispo Police Department (Government Code § 7071).
(e) Preparing for, scheduling, and coordinating the annual community engagement
meeting, as outlined in section 709.8 of this policy, to include:
1. Publicizing the details of the meeting.
2. Preparing for public questions regarding the departmen t’s funding, acquisition,
and use of military equipment.
(f) Preparing the annual military equipment report for submission to the Chief of Police
and ensuring that the report is made available on the department website
(Government Code § 7072).
(g) Establishing the procedure for a person to register a complaint or concern, or how that
person may submit a question about the use of a type of military equipment by the
department, and how the department will respond in a timely manner.
709.4 MILITARY EQUIPMENT INVENTORY
The qualifying equipment for the department is listed in Attachment A to this policy.
San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Military Equipment
Copyright Lexipol, LLC 2022/01/03, All Rights Reserved. Military Equipment - 3
Published with permission by San Luis Obispo Police
Department
709.5 APPROVAL
The Chief of Police or the authorized designee shall obtain approval from the City Council by way
of an ordinance adopting the military equipment policy. As part of the approval process, the Chief
of Police or the authorized designee shall ensure the propo sed military equipment policy is
submitted to City Council and is available on the department website at least 30 days prior to any
public hearing concerning the military equipment at issue (Government Code § 7071). The military
equipment policy must be approved by City Council prior to engaging in any of the following
(Government Code § 7071):
(a) Requesting military equipment made available pursuant to 10 USC § 2576a.
(b) Seeking funds for military equipment, including but not limited to applying for a grant,
soliciting or accepting private, local, state, or federal funds, in -kind donations, or other
donations or transfers.
(c) Acquiring military equipment either permanently or temporarily, including by borrowing
or leasing.
(d) Collaborating with another law enforcement agency in the deployment or other use of
military equipment within the jurisdiction of this department.
(e) Using any new or existing military equipment for a purpose, in a manner, or by a
person not previously approved by City Council.
(f) Soliciting or responding to a proposal for, or entering into an agreement with, any other
person or entity to seek funds for, apply to receive, acquire, use, or collaborate in the
use of military equipment.
(g) Acquiring military equipment through any means not provided above.
709.6 COORDINATION WITH OTHER JURISDICTIONS
Military equipment in the possession of the department shall not be used by any other law
enforcement agency or member in this jurisdiction unless the military equipment is approved for
use in accordance with this policy.
This policy recognizes the need for agencies to provide assistance to each other, whether in
ongoing, combined, or regional operations, occasional planned operations, or in exigent
circumstances. Where applicable to the provisions of Government Code § 7070 through § 7075,
such assisting agencies shall comply with their respective military equipment use policies whe n
rendering assistance and with any directions for use of department military equipment given by
department command.
San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Military Equipment
Copyright Lexipol, LLC 2022/01/03, All Rights Reserved. Military Equipment - 4
Published with permission by San Luis Obispo Police
Department
709.7 EXTRAORDINARY CIRCUMSTANCES
This policy also recognizes that there may be very limited or extreme instances where incidents
of extraordinary nature could demand the need for incident commanders to authorize Department
personnel to use equipment not specified in this policy. This decision must be made depending
on the totality of the circumstances, including due regard for the public ’s safety, officer safety,
respecting civil rights, the seriousness of the situation, and other information available at that time.
Should such extreme instances occur that call for members of this Department to use equipment
not specified in this policy, the incident commander shall, if practical, notify the Chief of Police via
the chain of command prior to deploying such equipment and the use of such equipment shall be
documented in an appropriate report. Should such circumstances occur, the Chief of Po lice, or
his/her designee, shall notify the City Council as soon as practical, and document any such uses
in the required annual report.
709.8 ANNUAL REPORT
Upon approval of a military equipment policy, the Chief of Police or the authorized designee shall
submit a military equipment report to City Council for each type of military equipment approved
within one year of approval, and annually thereafter for as long as the military equipment is
available for use (Government Code § 7072).
The Chief of Police or the authorized designee shall also make each annual military equipment
report publicly available on the department website for as long as the military equipment is
available for use. The report shall include all information required by Government Code § 7072
for the preceding calendar year for each type of military equipment in department inventory.
The annual military equipment report shall, at a minimum, include the following information for the
immediately preceding calendar year for each type of military equipment:
(a) A summary of how the military equipment was used and the purpose of its use.
(b) A summary of any complaints or concerns received concerning the military
equipment.
(c) The results of any internal audits, any infor mation about violations of the military
equipment use policy, and any actions taken in response.
(d) The total annual cost for each type of military equipment, including acquisition,
personnel, training, transportation, maintenance, storage, upgrade, and o ther
ongoing costs, and from what source funds will be provided for the military
equipment in the calendar year following submission of the annual military
equipment report.
(e) The quantity possessed for each type of military equipment.
(f) If the department intends to acquire additional military equipment in the next year,
the quantity sought for each type of military equipment.
San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Military Equipment
Copyright Lexipol, LLC 2022/01/03, All Rights Reserved. Military Equipment - 5
Published with permission by San Luis Obispo Police
Department
709.9 COMMUNITY ENGAGEMENT
Within 30 days of submitting and publicly releasing the annual report, the Department shall hold
at least one well-publicized and conveniently located community engagement meeting, at which
the general public may discuss and ask questions regarding the ann ual military equipment report
and the Department’s funding, acquisition, or use of military equipment. At the meeting, the
Department shall discuss the report and respond to questions regarding the Department’s
funding, acquisition, or use of military equipment (Government Code §7072).
709.10 MILITARY EQUIPMENT COMPLAINT PROCESS
Trust and transparency to the community we serve is paramount to our community -oriented
policing philosophy. Maintaining an active exchange of ideas and feedback is integral to the
harmonization of this collaborative initiative. The most effective way to partner with our community
on these important topics is to provide a safe and transparent means by which we listen to
feedback and engage concerns on the necessary tools we are entru sted with to serve our
community. Building and maintaining trust is predicated on first listening to concerns, giving a
voice through dialogue, and swiftly acting on areas where we can improve.
Pursuant to 709.3 (g) of this policy, all formal complaints, q uestions, or inquiries received by the
department, regardless of manner, pertaining to the use or misuse, possession, or acquisition of
any item defined by this policy and/or AB 481 as Military Equipment shall be referred to Lexipol
policy 1019 Personnel Complaints. Any complaint related to the misuse of Military Equipment is
deemed serious in nature and will be investigated thoroughly and as expeditiously as possible
and in accordance with the stringent procedures and processes as directed by Lexipol polic y
1019.
Complaints received under 709.10 will be thoroughly documented and dispositions recorded per
Lexipol policy 1019. All complaints, regardless of findings and/or disposition, shall be aggregated
annually and reported to the Chief of Police for inclus ion into the department’s annual Military
Equipment Report presented to Council.