Common use of Substantial Compliance Clause in Contracts

Substantial Compliance. Paragraph 115 requires the City to ensure that Crisis Triage is fully operational, including the implementation of policies and procedures developed by the Bureau of Emergency Communications (BOEC) and the Portland Police Bureau (PPB). The policies and procedures developed by BOEC and PPB triage calls related to mental health issues and assign them for handling by PPB, the Multnomah County Crisis Line (MCCL), or the City’s Portland Street Response (PSR). To assess compliance with this paragraph, the Monitoring Team: 1) reviewed relevant BOEC policies for the Crisis Triage System; 2) reviewed the results of BOEC's internal audit of dispatch calls; and 3) performed additional review of a random sample of 20 calls dispatched to each of four sets of responders: PSR, Enhanced Crisis Intervention Team (ECIT), MCCL, and non-ECIT PPB. The Monitoring Team's review confirmed that BOEC is dispatching incoming calls in accordance with its policies regarding the appropriate use of the City's Crisis Triage System. BOEC’s internal audit assesses the subset of 9-1-1 emergency calls for which responding officers documented in the Computer-Aided Dispatch (CAD) system that there was a mental health component, and a PPB ECIT was not dispatched. The purpose of BOEC’s audit is to determine whether any of these calls should have been dispatched to ECIT. There were 9,180 calls received by BOEC during the Reporting Period meeting these review criteria. BOEC audited a random sample of 689 of those calls, finding that 36 of them (5.2 percent of the sample) met the criteria for dispatching ECIT but did not reflect a change in the call type to indicate ECIT response. BOEC also reported transferring 411 calls to MCCL, with 13 calls (3.2 percent) returned to BOEC for ECIT dispatch. This finding does not indicate fault with the BOEC call-takers, as MCCL staff may learn new information after the transfer requiring an ECIT response. Additionally, BOEC reports transferring 7,463 calls to PSR during the Reporting Period. The Monitoring Team talked with BOEC staff about the lessons learned during their audits of dispatch calls. BOEC reported that any results suggesting systematic issues in call-taker or dispatcher performance were fed back into their training system for remediation. Additionally, BOEC reported that in the coming months staff members will receive direct feedback on their individual performances from call audits. BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a stratified random sample of 20 audited calls. The sample was stratified to include both calls that BOEC indicated did not meet ECIT criteria (12 calls), and those that did (eight calls, or 40 percent of the sample). We reviewed the call audio and documentation to determine whether these calls should have been dispatched to ECIT. Of the 20 calls reviewed, we found one call that was dispatched to ECIT and should not have been included in the sample. Of the remaining 19 calls, we identified seven (36.8 percent) meeting the criteria for ECIT dispatch, which is close to the 40 percent anticipated by the sample. The audit results from BOEC agreed with the Monitoring Team’s results in 18 of the 19 calls, or 94.7 percent agreement. Finally, BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a random sample of 20 calls dispatched to each of three key Crisis Triage Responders: PSR, ECIT, and MCCL. As with the audited calls reviewed, the Monitoring Team reviewed the call audio and documentation to determine whether these calls were dispatched to the correct responder in the Crisis Triage System based on BOEC policy. Of the 60 calls reviewed, one PSR call did not have call audio because the PSR team self-dispatched. Among the remaining 59 calls reviewed, 58 (98.3 percent) were dispatched to the correct responders as required by BOEC policy. The agreement between our results and BOEC’s internal audit results suggests that BOEC call- takers and dispatchers are largely successful in identifying calls that do not warrant an ECIT or PSR response. However, BOEC’s internal audit is limited to assessing only those calls that were identified as not requiring an ECIT or PSR response. A review of calls dispatched to PSR, ECIT, and ▇▇▇▇ further demonstrated a high degree of integrity by BOEC call takers and dispatchers in triaging calls to the appropriate responders in the City’s Crisis Triage system. We therefore conclude that PPB is in Substantial Compliance with Paragraph 115 of the Settlement Agreement. To assess compliance with paragraphs 116, 117, and 118, the Monitor met with PPB on three separate occasions in July 2024, December 2024, and March 2025 to discuss and review the use and functionality of the EIS system in order to confirm the application of the principles required by this portion of the Settlement Agreement. The Monitor also reviewed PPB Directives related to the application of the EIS system, including, primarily, Directive 345.00, to evaluate PPB’s implementation of the principles and processes required by this portion of the Settlement Agreement. The Monitor also reviewed relevant Standard Operating Procedures (SOPs) and the results of analyses conducted by PPB. The Monitoring Team’s review of PPB’s Employee Information System (EIS) confirmed that PPB has developed policies and procedures intended to support the early identification of potentially problematic trends among officers, supervisors, and teams. In accordance with the Settlement Agreement, PPB has implemented mechanisms requiring supervisors and commanders to conduct regular performance reviews of officers, including upon transfer, and to document those reviews in the Performance Data Tracker (PDT). The system is structured to support analyses of force activity at both the individual and unit levels, and to trigger case management reviews when an officer uses force in 20 percent of their arrests over a six-month period, or when their use of force exceeds three times the average of their peers on the same shift. The Monitoring Team’s review confirmed that these structural components are in place, and that the majority of required reviews have been completed in a timely manner. At the same time, concerns remain as to whether the system is being used to its full potential, particularly with respect to identifying patterns that warrant intervention, ensuring transparency in decision- making, and applying threshold criteria in a consistent and meaningful way. Paragraph 116 of the Settlement Agreement requires supervisors and commanders to conduct reviews of EIS records of employees and new transfers, and to document these reviews in the PDT. It also requires PPB staff to regularly analyze unit and supervisor data to identify and compare activity patterns. Similar to Paragraph 116(c), Paragraph 117 requires PPB to use force audit data to conduct analyses at supervisor and team levels. Finally, Paragraph 118 requires PPB to use two thresholds to trigger case management reviews:

Substantial Compliance. Paragraph 115 requires The Monitoring Team reviewed City Council Ordinance 190606, passed on November 17, 2021, which included the provision of funding for a qualified outside entity to critically assess the City’s response to crowd control events in 2020 in a public-facing report and prepare a follow-on review of the City’s response to the report.22 We reviewed the contract entered into between the City and Independent Monitor LLC to ensure that Crisis Triage is fully operationalconduct the required assessment, including the implementation Scope of policies Work contained therein, and procedures developed by we also reviewed the Bureau completed report itself as well as the completed follow- on review. We reviewed the training needs assessment that the City was required to prepare using the report, and, finally, we reviewed the DOJ’s Seventh Periodic Compliance Assessment Report with regard to the Settlement Agreement, which indicated the DOJ’s agreement with the Scope of Emergency Communications (BOEC) and Work for the Portland Police Bureau (PPB)assessment project. The policies and procedures developed by BOEC and PPB triage calls related to mental health issues and assign them for handling by PPBBased on all of these materials, the Multnomah County Crisis Line (MCCL), or Monitoring Team confirmed that the City met all of the requirements in Paragraph 189 in a comprehensive fashion and with a high level of integrity. We therefore conclude that the City is in Substantial Compliance with Paragraph 189 of the Settlement Agreement. Substantial Compliance To assess the City’s Portland Street Response (PSR). To assess compliance with this paragraph, the Monitoring Team: 1) reviewed relevant BOEC policies for the Crisis Triage System; 2) Team reviewed the results of BOEC's internal audit of dispatch calls; and 3) performed additional review of a random sample of 20 calls dispatched to each of four sets of responders: PSRCity’s Adopted Budgets from FY2022-23, Enhanced Crisis Intervention Team (ECIT), MCCLFY2023-24, and nonFY2024-ECIT 25. We also received spreadsheets showing PPB. The Monitoring Team's review confirmed that BOEC is dispatching incoming calls in accordance with its policies regarding the appropriate use ’s budgets for FY2023-24 and FY2024-25, which were identified as part of the City's Crisis Triage System’s “technical budget”. BOECThe City’s internal audit assesses the subset of 9FY2022-1-1 emergency calls 23 Adopted Budget includes a line item for which responding officers documented in the Computer-Aided Dispatch (CAD) system that there was a mental health component“Train & Dev”, and the City pointed us to a supplementary email communication about that budget indicating that this line item was specifically designated for overtime for the training of PPB ECIT was not dispatchedofficers. The purpose of BOECCity’s audit is to determine whether any of these calls should have been dispatched to ECITFY2023-24 and 22 The ordinance provided $300,000 for this purpose. There were 9,180 calls received by BOEC during the Reporting Period meeting these review criteria. BOEC audited a random sample of 689 FY2024-25 Adopted Budgets each included line items for “Training”, though no specific designation of those calls, finding that 36 items for overtime training of them (5.2 percent of the sample) met the criteria for dispatching ECIT but did not reflect a change in the call type to indicate ECIT response. BOEC also reported transferring 411 calls to MCCL, with 13 calls (3.2 percent) returned to BOEC for ECIT dispatch. This finding does not indicate fault with the BOEC call-takers, as MCCL staff may learn new information after the transfer requiring an ECIT response. Additionally, BOEC reports transferring 7,463 calls to PSR during the Reporting Periodofficers is evident. The Monitoring Team talked with BOEC staff about the lessons learned during their audits spreadsheets from PPB’s portion of dispatch calls. BOEC reported that any results suggesting systematic issues in call-taker or dispatcher performance were fed back into their training system for remediation. Additionally, BOEC reported that in the coming months staff members will receive direct feedback on their individual performances from call audits. BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a stratified random sample of 20 audited calls. The sample was stratified to include both calls that BOEC indicated did not meet ECIT criteria (12 calls), and those that did (eight calls, or 40 percent of the sample). We reviewed the call audio and documentation to determine whether these calls should have been dispatched to ECIT. Of the 20 calls reviewed, we found one call that was dispatched to ECIT and should not have been included in the sample. Of the remaining 19 calls, we identified seven (36.8 percent) meeting the criteria for ECIT dispatch, which is close to the 40 percent anticipated by the sample. The audit results from BOEC agreed with the Monitoring Team’s results in 18 of the 19 calls, or 94.7 percent agreement. Finally, BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a random sample of 20 calls dispatched to each of three key Crisis Triage Responders: PSR, ECIT, and MCCL. As with the audited calls reviewed, the Monitoring Team reviewed the call audio and documentation to determine whether these calls were dispatched to the correct responder in the Crisis Triage System based on BOEC policy. Of the 60 calls reviewed, one PSR call did not have call audio because the PSR team self-dispatched. Among the remaining 59 calls reviewed, 58 (98.3 percent) were dispatched to the correct responders as required by BOEC policy. The agreement between our results and BOEC’s internal audit results suggests that BOEC call- takers and dispatchers are largely successful in identifying calls that do not warrant an ECIT or PSR response. However, BOEC’s internal audit is limited to assessing only those calls that were identified as not requiring an ECIT or PSR response. A review of calls dispatched to PSR, ECIT, and ▇▇▇▇ further demonstrated a high degree of integrity by BOEC call takers and dispatchers in triaging calls to the appropriate responders in the City’s Crisis Triage systemtechnical budgets for each of those years, however, break down the total amount listed for training into additional categories, including “Overtime”. Paragraph 190 specifically requires “the City to provide in the budget a separate line item for overtime costs to conduct necessary training for PPB officers.” Although the City’s publicly posted Adopted Budgets do not include the separate line item for this purpose, the additional materials provided to us by the City illustrated that PPB's sections of the City’s technical budgets do. The observation that the City’s Adopted Budgets do not explicitly list the item is of minor concern and does not take away from the City’s compliance with this paragraph. We therefore conclude that PPB the City is in Substantial Compliance with Paragraph 115 190 of the Settlement Agreement. To assess compliance with paragraphs 116, 117, and 118, the Monitor met with PPB on three separate occasions in July 2024, December 2024, and March 2025 to discuss and review the use and functionality of the EIS system in order to confirm the application of the principles required by this portion of the Settlement Agreement. The Monitor also reviewed PPB Directives related to the application of the EIS system, including, primarily, Directive 345.00, to evaluate PPB’s implementation of the principles and processes required by this portion of the Settlement Agreement. The Monitor also reviewed relevant Standard Operating Procedures (SOPs) and the results of analyses conducted by PPB. The Monitoring Team’s review of PPB’s Employee Information System (EIS) confirmed that PPB has developed policies and procedures intended to support the early identification of potentially problematic trends among officers, supervisors, and teams. In accordance with the Settlement Agreement, PPB has implemented mechanisms requiring supervisors and commanders to conduct regular performance reviews of officers, including upon transfer, and to document those reviews in the Performance Data Tracker (PDT). The system is structured to support analyses of force activity at both the individual and unit levels, and to trigger case management reviews when an officer uses force in 20 percent of their arrests over a six-month period, or when their use of force exceeds three times the average of their peers on the same shift. The Monitoring Team’s review confirmed that these structural components are in place, and that the majority of required reviews have been completed in a timely manner. At the same time, concerns remain as to whether the system is being used to its full potential, particularly with respect to identifying patterns that warrant intervention, ensuring transparency in decision- making, and applying threshold criteria in a consistent and meaningful way. Paragraph 116 of the Settlement Agreement requires supervisors and commanders to conduct reviews of EIS records of employees and new transfers, and to document these reviews in the PDT. It also requires PPB staff to regularly analyze unit and supervisor data to identify and compare activity patterns. Similar to Paragraph 116(c), Paragraph 117 requires PPB to use force audit data to conduct analyses at supervisor and team levels. Finally, Paragraph 118 requires PPB to use two thresholds to trigger case management reviews:.

Substantial Compliance. Paragraph 115 requires The Monitoring Team reviewed the City to ensure that Crisis Triage is fully operational, including the implementation of policies and procedures developed December 2022 Training Division Assessment conducted by the Bureau PPB Office of Emergency Communications the Inspector General (BOEC) OIG)17 and used a series of 10 questions during our review to verify whether all of the Portland Police Bureau (PPB). The policies and procedures developed by BOEC and PPB triage calls related to mental health issues and assign them requirements included in the Settlement Agreement for handling by PPB, the Multnomah County Crisis Line (MCCL), or the City’s Portland Street Response (PSR). To assess compliance with this paragraph, the Monitoring Team: 1) reviewed relevant BOEC policies for the Crisis Triage System; 2) reviewed the results of BOEC's internal that audit of dispatch calls; and 3) performed additional review of a random sample of 20 calls dispatched to each of four sets of responders: PSR, Enhanced Crisis Intervention Team (ECIT), MCCL, and non-ECIT PPBwere fulfilled. The Monitoring Team's ’s review confirmed verified that BOEC is dispatching incoming calls the Training Division Assessment consistently satisfied the essential requirements included in accordance with its policies regarding the appropriate use Paragraph 85 of the City's Crisis Triage SystemSettlement Agreement. BOEC’s internal Settlement Agreement Paragraph 85 requires PPB to audit assesses its training program using the subset following performance standards to ensure PPB does the following: 1) conducts a comprehensive needs assessment annually; 2) creates a Training Strategic Plan annually; 3) develops and implements a process for evaluation of 9-1-1 emergency calls for which responding officers documented in the Computer-Aided Dispatch effectiveness of training (CADwithin 180 days of the Effective Date of the Settlement Agreement); 4) system that there was a mental health componentmaintains accurate records of training delivered, including substance and attendance; 5) makes training records accessible to the Director of Services, Assistant Chief of Operations, and DOJ; 6) trains officers, supervisors, and commanders on areas specific to their responsibilities; and 7) ensures sworn PPB members are provided a copy of all PPB ECIT was not dispatched. The purpose of BOEC’s audit is to determine whether any of these calls should have been dispatched to ECIT. There were 9,180 calls received by BOEC during the Reporting Period meeting these review criteria. BOEC audited a random sample of 689 of those calls, finding that 36 of them (5.2 percent of the sample) met the criteria for dispatching ECIT but did not reflect a change in the call type to indicate ECIT response. BOEC also reported transferring 411 calls to MCCL, with 13 calls (3.2 percent) returned to BOEC for ECIT dispatch. This finding does not indicate fault with the BOEC call-takers, as MCCL staff may learn new information after the transfer requiring an ECIT response. Additionally, BOEC reports transferring 7,463 calls to PSR during the Reporting Period. The Monitoring Team talked with BOEC staff about the lessons learned during their audits of dispatch calls. BOEC reported that any results suggesting systematic issues in call-taker or dispatcher performance were fed back into their training system for remediation. Additionally, BOEC reported that in the coming months staff members will receive direct feedback on their individual performances from call audits. BOEC provided directives and 17 PPB informed the Monitoring Team with the dispatch call audio and summary documents for a stratified random sample of 20 audited calls. The sample was stratified that it had completed multiple previous assessments pursuant to include both calls that BOEC indicated did not meet ECIT criteria (12 calls)Paragraph 85, and those it provided us with materials from them, including the initial assessment conducted in 2015 (slightly after the 180-day deadline referenced in this paragraph). Given that did (eight callsParagraph 85 does not include any specific requirement for PPB to conduct recurring assessments, or 40 percent including during the present Reporting Period, we limited our review to the most recently completed one. policies issued pursuant to the Settlement Agreement and that they sign a statement acknowledging that they have received, read, and had an opportunity to ask questions about the directives and/or policies, within 30 days of the sample). We reviewed the call audio and documentation to determine whether these calls should have been dispatched to ECIT. Of the 20 calls reviewed, we found one call that was dispatched to ECIT and should not have been included in the sample. Of the remaining 19 calls, we identified seven (36.8 percent) meeting the criteria for ECIT dispatch, which is close to the 40 percent anticipated by the sample. The audit results from BOEC agreed with the Monitoring Team’s results in 18 release of the 19 calls, or 94.7 percent agreementdirectives and/or policies. Finally, BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a random sample of 20 calls dispatched to each of three key Crisis Triage Responders: PSR, ECIT, and MCCL. As with the audited calls reviewed, the Monitoring Team reviewed the call audio and documentation to determine whether these calls were dispatched to the correct responder in the Crisis Triage System based on BOEC policy. Of the 60 calls reviewed, one PSR call did not have call audio because the PSR team self-dispatched. Among the remaining 59 calls reviewed, 58 (98.3 percent) were dispatched to the correct responders as required by BOEC policy. The agreement between our results and BOEC’s internal audit results suggests that BOEC call- takers and dispatchers are largely successful in identifying calls that do not warrant an ECIT or PSR response. However, BOEC’s internal audit is limited to assessing only those calls that were identified as not requiring an ECIT or PSR response. A Our review of calls dispatched to PSR, ECIT, the 2022 Training Division Assessment found that it satisfied the essential requirements of this paragraph in a comprehensive fashion and ▇▇▇▇ further demonstrated with a high degree level of integrity by BOEC call takers and dispatchers in triaging calls to the appropriate responders in the City’s Crisis Triage systemintegrity. We therefore conclude that PPB is in Substantial Compliance with Paragraph 115 85 of the Settlement Agreement. To assess compliance with paragraphs 116, 117, and 118, the Monitor met with PPB on three separate occasions in July 2024, December 2024, and March 2025 to discuss and review the use and functionality of the EIS system in order to confirm the application of the principles required by this portion of the Settlement Agreement. The Monitor also reviewed PPB Directives related to the application of the EIS system, including, primarily, Directive 345.00, to evaluate PPB’s implementation of the principles and processes required by this portion of the Settlement Agreement. The Monitor also reviewed relevant Standard Operating Procedures (SOPs) and the results of analyses conducted by PPB. The Monitoring Team’s review of PPB’s Employee Information System (EIS) confirmed that PPB has developed policies and procedures intended to support the early identification of potentially problematic trends among officers, supervisors, and teams. In accordance with the Settlement Agreement, PPB has implemented mechanisms requiring supervisors and commanders to conduct regular performance reviews of officers, including upon transfer, and to document those reviews in the Performance Data Tracker (PDT). The system is structured to support analyses of force activity at both the individual and unit levels, and to trigger case management reviews when an officer uses force in 20 percent of their arrests over a six-month period, or when their use of force exceeds three times the average of their peers on the same shift. The Monitoring Team’s review confirmed that these structural components are in place, and that the majority of required reviews have been completed in a timely manner. At the same time, concerns remain as to whether the system is being used to its full potential, particularly with respect to identifying patterns that warrant intervention, ensuring transparency in decision- making, and applying threshold criteria in a consistent and meaningful way. Paragraph 116 of the Settlement Agreement requires supervisors and commanders to conduct reviews of EIS records of employees and new transfers, and to document these reviews in the PDT. It also requires PPB staff to regularly analyze unit and supervisor data to identify and compare activity patterns. Similar to Paragraph 116(c), Paragraph 117 requires PPB to use force audit data to conduct analyses at supervisor and team levels. Finally, Paragraph 118 requires PPB to use two thresholds to trigger case management reviews:.

Substantial Compliance. Paragraph 115 requires the City to ensure that Crisis Triage is fully operationalDuring this Reporting Period, including the implementation multiple members of policies and procedures developed by the Bureau of Emergency Communications (BOEC) and the Portland Police Bureau (PPB). The policies and procedures developed by BOEC and PPB triage calls related to mental health issues and assign them for handling by PPB, the Multnomah County Crisis Line (MCCL), or the City’s Portland Street Response (PSR). To assess compliance with this paragraph, the Monitoring Team: 1) Team reviewed relevant BOEC policies for the Crisis Triage System; 2) reviewed the results and provided comments on approximately 20 of BOEC's internal audit PPB’s In-Service Training curricula covering a wide variety of dispatch calls; law enforcement practices and 3) performed additional review procedures, as well as approximately 12 of a random sample of 20 calls dispatched to each of four sets of responders: PSR, Enhanced Crisis Intervention PPB’s Rapid Response Team (ECIT), MCCL, and non-ECIT PPB. RRT) training curricula covering multiple responsibilities of that specialized unit within PPB.16 The Monitoring Team's ’s review confirmed that BOEC is dispatching incoming calls in accordance verified the consistent conformity of these training courses with its policies regarding the appropriate use language of the City's Crisis Triage System. BOEC’s internal audit assesses applicable Directives and the subset of 9-1-1 emergency calls for which responding officers documented in the Computer-Aided Dispatch (CAD) system that there was a mental health componentSettlement Agreement, and a our observations of PPB ECIT was not dispatched. The purpose of BOEC’s audit is to determine whether any of these calls should have been dispatched to ECIT. There were 9,180 calls received by BOEC training during the Reporting Period meeting these review criteria. BOEC audited a random sample of 689 of those calls, finding that 36 of them (5.2 percent of the sample) met the criteria for dispatching ECIT but did not reflect a change in the call type to indicate ECIT response. BOEC also reported transferring 411 calls to MCCL, with 13 calls (3.2 percent) returned to BOEC for ECIT dispatch. This finding does not indicate fault with the BOEC call-takers, as MCCL staff may learn new information after the transfer requiring an ECIT response. Additionally, BOEC reports transferring 7,463 calls to PSR during the Reporting Period. The Monitoring Team talked with BOEC staff about the lessons learned during their audits of dispatch calls. BOEC reported that any results suggesting systematic issues in call-taker or dispatcher performance were fed back into their training system for remediation. Additionally, BOEC reported that in the coming months staff members will receive direct feedback on their individual performances from call audits. BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a stratified random sample of 20 audited calls. The sample was stratified to include both calls that BOEC indicated did not meet ECIT criteria (12 calls), and those that did (eight calls, or 40 percent of the sample). We reviewed the call audio and documentation to determine whether these calls should have been dispatched to ECIT. Of the 20 calls reviewed, we found one call that was dispatched to ECIT and should not have been included in the sample. Of the remaining 19 calls, we identified seven (36.8 percent) meeting the criteria for ECIT dispatch, which is close to the 40 percent anticipated by the sample. The audit results from BOEC agreed with the Monitoring Team’s results in 18 of the 19 calls, or 94.7 percent agreement. Finally, BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a random sample of 20 calls dispatched to each of three key Crisis Triage Responders: PSR, ECIT, and MCCL. As with the audited calls reviewed, the Monitoring Team reviewed the call audio and documentation to determine whether these calls were dispatched to the correct responder in the Crisis Triage System based on BOEC policy. Of the 60 calls reviewed, one PSR call did not have call audio because the PSR team self-dispatched. Among the remaining 59 calls reviewed, 58 (98.3 percent) were dispatched to the correct responders as required by BOEC policy. The agreement between our results and BOEC’s internal audit results suggests that BOEC call- takers and dispatchers are largely successful in identifying calls that do not warrant an ECIT or PSR response. However, BOEC’s internal audit is limited to assessing only those calls that were identified as not requiring an ECIT or PSR response. A review of calls dispatched to PSR, ECIT, and ▇▇▇▇ further demonstrated a high degree of integrity by BOEC call takers and dispatchers in triaging calls to the appropriate responders in the City’s Crisis Triage system. We therefore conclude confirmed that PPB is fulfilling the requirements of this paragraph in Substantial Compliance with actual practice. 16 These reviews were conducted pursuant to requirements contained in Settlement Agreement Paragraph 115 246. Our review generally included evaluations of both Lesson Plans and Materials for each course (unless one of those elements of the Settlement Agreement. To assess compliance with paragraphs 116curriculum was not in use for that course), 117as well as relevant PPB Directives, and 118, the Monitor met with PPB on three separate occasions in July 2024, December 2024, and March 2025 to discuss and review the use and functionality of the EIS system in order to confirm the application of the principles required by this portion of the Settlement Agreement. The Monitor also reviewed PPB Directives related to the application of the EIS system, including, primarily, Directive 345.00, to evaluate PPB’s implementation of the principles and processes required by this portion of the Settlement Agreement. The Monitor also reviewed relevant Standard Operating Procedures (SOPs) ), and other associated records, as appropriate. We aimed to be thoughtful, thorough, and comprehensive in each review we conducted and in each comment for PPB’s consideration we provided. In addition to these detailed reviews of training curricula, multiple members of the results Monitoring Team conducted in-person observations of analyses conducted by PPB. The Monitoring Team’s review some of PPB’s Employee Information System training courses, including the following ones: • 2024 2-day In-Service Training • 2024 Supervisory In-Service Training • 2024 Crisis Negotiation Team Demonstration Liaison Officer (EISvideo-recorded) confirmed that • 2024 August Monthly RRT Training • 2024 October Monthly RRT Training • 2024 October Joint Training with RRT and Oregon State Police Mobile Response Team • 2024 December Monthly RRT Training Having multiple members of the Monitoring Team engaged in these reviews and in-person observations related to PPB has developed policies and procedures intended training allowed us to support the early identification rely on a collective set of potentially problematic trends among officersskills including civilian oversight of law enforcement, supervisorspolice operations, and teamsconsent decree compliance. In accordance with Crucially, having more than one Monitoring Team member involved in these activities also helped us to ensure that we infused different perspectives into the Settlement Agreementassessments we made, PPB has implemented mechanisms requiring supervisors and commanders as opposed to conduct regular performance reviews relying solely on a single person’s experiences or point of officers, including upon transfer, and to document those reviews in the Performance Data Tracker (PDT)view. The system is structured to support analyses of force activity at both the individual and unit levels, and to trigger case management reviews when an officer uses force in 20 percent of their arrests over a six-month period, or when their use of force exceeds three times the average of their peers on the same shift. The Monitoring Team’s review confirmed that these structural components are in place, and that the majority of required reviews have been completed in a timely manner. At the same time, concerns remain as to whether the system is being used to its full potential, particularly with respect to identifying patterns that warrant intervention, ensuring transparency in decision- making, and applying threshold criteria in a consistent and meaningful way. Paragraph 116 of the Settlement Agreement Paragraph 84 requires supervisors and commanders all PPB training to conduct reviews conform to PPB’s current policies at the time of EIS records of employees and new transfers, and to document these reviews in the PDTtraining. It also requires PPB staff the training of patrol officers to regularly analyze unit and supervisor data to identify and compare activity patterns. Similar to Paragraph 116(c), Paragraph 117 requires PPB to use force audit data to conduct analyses at supervisor and team levels. Finally, Paragraph 118 requires PPB to use two thresholds to trigger case management reviewsinclude the following six elements:

Substantial Compliance. Paragraph 115 requires the City to ensure that Crisis Triage is fully operational, including the implementation of policies and procedures developed by the Bureau of Emergency Communications (BOEC) and the Portland Police Bureau (PPB). The policies and procedures developed by BOEC and PPB triage calls related to mental health issues and assign them for handling by PPB, the Multnomah County Crisis Line (MCCL), or the City’s Portland Street Response (PSR). To assess compliance with this paragraph, the Monitoring Team: 1) reviewed relevant BOEC policies for the Crisis Triage System; 2) reviewed the results of BOEC's internal audit of dispatch calls; and 3) performed additional review of a random sample of 20 calls dispatched to each of four sets of responders: PSR, Enhanced Crisis Intervention Team (ECIT), MCCL, and non-ECIT PPB. The Monitoring Team's review confirmed that BOEC is dispatching incoming calls in accordance with its policies regarding the appropriate use of the City's Crisis Triage System. BOEC’s internal audit assesses the subset of 9-1-1 emergency calls for which responding officers documented in the Computer-Aided Dispatch (CAD) system that there was a mental health component, and a PPB ECIT was not dispatched. The purpose of BOEC’s audit is to determine whether any of these calls should have been dispatched to ECIT. There were 9,180 calls received by BOEC during the Reporting Period meeting these review criteria. BOEC audited a random sample of 689 of those calls, finding that 36 of them (5.2 percent of the sample) met the criteria for dispatching ECIT but did not reflect a change in the call type to indicate ECIT response. BOEC also reported transferring 411 calls to MCCL, with 13 calls (3.2 percent) returned to BOEC for ECIT dispatch. This finding does not indicate fault with the BOEC call-takers, as MCCL staff may learn new information after the transfer requiring an ECIT response. Additionally, BOEC reports transferring 7,463 calls to PSR during the Reporting Period. The Monitoring Team talked with BOEC staff about the lessons learned during their audits of dispatch calls. BOEC reported that any results suggesting systematic issues in call-taker or dispatcher performance were fed back into their training system for remediation. Additionally, BOEC reported that in the coming months staff members will receive direct feedback on their individual performances from call audits. BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a stratified random sample of 20 audited calls. The sample was stratified to include both calls that BOEC indicated did not meet ECIT criteria (12 calls), and those that did (eight calls, or 40 percent of the sample). We reviewed the call audio and documentation to determine whether these calls should have been dispatched to ECIT. Of the 20 calls reviewed, we found one call that was dispatched to ECIT and should not have been included in the sample. Of the remaining 19 calls, we identified seven (36.8 percent) meeting the criteria for ECIT dispatch, which is close to the 40 percent anticipated by the sample. The audit results from BOEC agreed with the Monitoring Team’s results in 18 of the 19 calls, or 94.7 percent agreement. Finally, BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a random sample of 20 calls dispatched to each of three key Crisis Triage Responders: PSR, ECIT, and MCCL. As with the audited calls reviewed, the Monitoring Team reviewed the call audio and documentation to determine whether these calls were dispatched to the correct responder in the Crisis Triage System based on BOEC policy. Of the 60 calls reviewed, one PSR call did not have call audio because the PSR team self-dispatched. Among the remaining 59 calls reviewed, 58 (98.3 percent) were dispatched to the correct responders as required by BOEC policy. The agreement between our results and BOEC’s internal audit results suggests that BOEC call- takers and dispatchers are largely successful in identifying calls that do not warrant an ECIT or PSR response. However, BOEC’s internal audit is limited to assessing only those calls that were identified as not requiring an ECIT or PSR response. A review of calls dispatched to PSR, ECIT, and ▇▇▇▇ further demonstrated a high degree of integrity by BOEC call takers and dispatchers in triaging calls to the appropriate responders in the City’s Crisis Triage system. We therefore conclude that PPB is in Substantial Compliance with Paragraph 115 of the Settlement Agreement. To assess compliance with paragraphs 116, 117, and 118, the Monitor met with PPB on three separate occasions in July 2024, December 2024, and March 2025 to discuss and review the use and functionality of the EIS system in order to confirm the application of the principles required by this portion of the Settlement Agreement. The Monitor also reviewed PPB Directives related to the application of the EIS system, including, primarily, Directive 345.00, to evaluate PPB’s implementation of the principles and processes required by this portion of the Settlement Agreement. The Monitor also reviewed relevant Standard Operating Procedures (SOPs) and the results of analyses conducted by PPB. The Monitoring Team’s review of PPB’s use of force reporting directives confirmed their inclusion of the requirements listed in Paragraph 73 of the Settlement Agreement. These include: 1) the Employee Information System (EIS) confirmed that PPB has developed policies and procedures intended to support the early identification of potentially problematic trends among officers, supervisors, and teams. In accordance with the Settlement Agreement, PPB has implemented mechanisms requiring supervisors and commanders to conduct regular performance reviews of officers, including upon transfer, and to document those reviews in the Performance Data Tracker (PDT). The system is structured to support analyses of force activity at both the individual and unit levels, and to trigger case management reviews when an officer uses force in 20 percent of their arrests over a six-month period, or when their tracks all use of force exceeds three times investigation findings and corrections; 2) all supervisors in the average chain of command are subject to and receive corrective action or discipline for the accuracy and completeness of AARs completed by supervisors under their peers on command; 3) all supervisors in the same shift. chain of command are accountable for inadequate reports and analysis; 4) supervisors receive the appropriate corrective action when they repeatedly conduct deficient investigations, and shift or precinct commanders receive the appropriate corrective action when they repeatedly permit deficient investigations; 5) PPB takes appropriate corrective action consistent with the Accountability provisions of the Settlement Agreement when a use of force is found to be out of policy; 6) where a use of force indicates policy, training, tactical, or equipment concerns, the immediate supervisor shall notify the Inspector and the Chief, who shall ensure PPB timely addresses all such concerns; and 7) the Chief (or their designee) and Professional Standards The Monitoring Team’s review of a sample of use of force events and investigations confirmed the consistent and verified performance of these requirements by PPB officers in actual practice. Our review found appropriate tracking of use of force investigation findings in the Employee Information System. Our sample did not uncover any cases where discipline for chain of command supervisors was warranted, where a supervisor repeatedly conducted deficient investigations or a shift/precinct commander repeatedly permitted them, or where a use of force investigation gave rise to policy, tactical, training, or equipment concerns. In the one case from our sample that these structural components are included an inadequate AAR which deemed a particular use of force to be in placepolicy, the chain of command supervisors identified the issues with the report and that rectified them, including by appropriately determining the majority use of required reviews have been completed in a timely mannerforce to be out of policy. At the same timeFinally, concerns remain as to whether the system is being used to its full potential, particularly with respect to identifying patterns that warrant interventionsame case, ensuring transparency its ultimate adjudication via an administrative investigation remains pending; no other cases in decision- making, and applying threshold criteria in a consistent and meaningful way. Paragraph 116 our sample involved an out of the Settlement Agreement requires supervisors and commanders to conduct reviews policy use of EIS records of employees and new transfers, and to document these reviews in the PDT. It also requires PPB staff to regularly analyze unit and supervisor data to identify and compare activity patterns. Similar to Paragraph 116(c), Paragraph 117 requires PPB to use force audit data to conduct analyses at supervisor and team levels. Finally, Paragraph 118 requires PPB to use two thresholds to trigger case management reviews:force.

Substantial Compliance. Paragraph 115 requires the City to ensure that Crisis Triage is fully operational, including the implementation For its assessment of policies and procedures developed by the Bureau of Emergency Communications (BOEC) and the Portland Police Bureau (PPB). The policies and procedures developed by BOEC and PPB triage calls related to mental health issues and assign them for handling by PPB, the Multnomah County Crisis Line (MCCL), or the City’s Portland Street Response (PSR). To assess compliance with this paragraph, the Monitoring TeamTeam reviewed the following reports completed by PPB related to officer training: • 2024 Annual Training Needs Assessment • FY2025 Annual Training Plan • 2024 Training Needs Assessment: Law Enforcement Response to Mass Demonstrations As we reviewed them, we answered a series of 13 questions about them (collectively), which we developed based on the requirements laid out for the training plan and the needs assessment in Paragraph 79. Our review confirmed that the updates PPB made to its Annual Training Plan during this Reporting Period, as well as the Training Needs Assessment PPB conducted to inform those updates, met the requirements of Settlement Agreement Paragraph 79. PPB’s Training Division is required to review and update PPB’s training plan annually. The updates it makes must be informed by a training needs assessment, to be modified annually, which takes into consideration the following elements: 1) reviewed relevant BOEC policies for the Crisis Triage Systemtrends in hazards officers are encountering in performing their duties; 2) reviewed analysis of officer safety issues; 3) misconduct complaints; 4) problematic uses of force; 5) input from members at all levels of PPB; 6) input from the results of BOEC's internal audit of dispatch callscommunity; 7) concerns reflected in court decisions; 8) research reflecting best practices; 9) the latest in law enforcement trends; 10) individual precinct needs; and 311) performed additional any changes to Oregon or federal law or PPB policy. Our review of a random sample of 20 calls dispatched the 2024 Annual Training Needs Assessment found it to each of four sets of responders: PSRbe thorough, Enhanced Crisis Intervention Team (ECIT), MCCLcomprehensive, and non-ECIT PPBeffective in its utilization of data, findings, and recommendations related to the various elements listed in Paragraph 79. The Monitoring Team's review confirmed that BOEC is dispatching incoming calls in accordance with its policies regarding Furthermore, the appropriate use of the City's Crisis Triage System. BOEC’s internal audit assesses the subset of 9-1-1 emergency calls for which responding officers documented conclusions in the Computer-Aided Dispatch (CAD) system that there was assessment were appropriately relied on to inform PPB’s FY2025 Annual Training Plan and revisions made to it from prior iterations. PPB satisfied the requirements of this paragraph in a mental health component, comprehensive fashion and a PPB ECIT was not dispatched. The purpose of BOEC’s audit is to determine whether any of these calls should have been dispatched to ECIT. There were 9,180 calls received by BOEC during the Reporting Period meeting these review criteria. BOEC audited a random sample of 689 of those calls, finding that 36 of them (5.2 percent of the sample) met the criteria for dispatching ECIT but did not reflect a change in the call type to indicate ECIT response. BOEC also reported transferring 411 calls to MCCL, with 13 calls (3.2 percent) returned to BOEC for ECIT dispatch. This finding does not indicate fault with the BOEC call-takers, as MCCL staff may learn new information after the transfer requiring an ECIT response. Additionally, BOEC reports transferring 7,463 calls to PSR during the Reporting Period. The Monitoring Team talked with BOEC staff about the lessons learned during their audits of dispatch calls. BOEC reported that any results suggesting systematic issues in call-taker or dispatcher performance were fed back into their training system for remediation. Additionally, BOEC reported that in the coming months staff members will receive direct feedback on their individual performances from call audits. BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a stratified random sample of 20 audited calls. The sample was stratified to include both calls that BOEC indicated did not meet ECIT criteria (12 calls), and those that did (eight calls, or 40 percent of the sample). We reviewed the call audio and documentation to determine whether these calls should have been dispatched to ECIT. Of the 20 calls reviewed, we found one call that was dispatched to ECIT and should not have been included in the sample. Of the remaining 19 calls, we identified seven (36.8 percent) meeting the criteria for ECIT dispatch, which is close to the 40 percent anticipated by the sample. The audit results from BOEC agreed with the Monitoring Team’s results in 18 of the 19 calls, or 94.7 percent agreement. Finally, BOEC provided the Monitoring Team with the dispatch call audio and summary documents for a random sample of 20 calls dispatched to each of three key Crisis Triage Responders: PSR, ECIT, and MCCL. As with the audited calls reviewed, the Monitoring Team reviewed the call audio and documentation to determine whether these calls were dispatched to the correct responder in the Crisis Triage System based on BOEC policy. Of the 60 calls reviewed, one PSR call did not have call audio because the PSR team self-dispatched. Among the remaining 59 calls reviewed, 58 (98.3 percent) were dispatched to the correct responders as required by BOEC policy. The agreement between our results and BOEC’s internal audit results suggests that BOEC call- takers and dispatchers are largely successful in identifying calls that do not warrant an ECIT or PSR response. However, BOEC’s internal audit is limited to assessing only those calls that were identified as not requiring an ECIT or PSR response. A review of calls dispatched to PSR, ECIT, and ▇▇▇▇ further demonstrated a high degree level of integrity by BOEC call takers and dispatchers in triaging calls to the appropriate responders in the City’s Crisis Triage systemintegrity. We therefore conclude that PPB is in Substantial Compliance with Paragraph 115 79 of the Settlement Agreement. To assess compliance with paragraphs 116, 117, and 118, the Monitor met with PPB on three separate occasions in July 2024, December 2024, and March 2025 to discuss and review the use and functionality of the EIS system in order to confirm the application of the principles required by this portion of the Settlement Agreement. The Monitor also reviewed PPB Directives related to the application of the EIS system, including, primarily, Directive 345.00, to evaluate PPB’s implementation of the principles and processes required by this portion of the Settlement Agreement. The Monitor also reviewed relevant Standard Operating Procedures (SOPs) and the results of analyses conducted by PPB. The Monitoring Team’s review of PPB’s Employee Information System (EIS) confirmed that PPB has developed policies and procedures intended to support the early identification of potentially problematic trends among officers, supervisors, and teams. In accordance with the Settlement Agreement, PPB has implemented mechanisms requiring supervisors and commanders to conduct regular performance reviews of officers, including upon transfer, and to document those reviews in the Performance Data Tracker (PDT). The system is structured to support analyses of force activity at both the individual and unit levels, and to trigger case management reviews when an officer uses force in 20 percent of their arrests over a six-month period, or when their use of force exceeds three times the average of their peers on the same shift. The Monitoring Team’s review confirmed that these structural components are in place, and that the majority of required reviews have been completed in a timely manner. At the same time, concerns remain as to whether the system is being used to its full potential, particularly with respect to identifying patterns that warrant intervention, ensuring transparency in decision- making, and applying threshold criteria in a consistent and meaningful way. Paragraph 116 of the Settlement Agreement requires supervisors and commanders to conduct reviews of EIS records of employees and new transfers, and to document these reviews in the PDT. It also requires PPB staff to regularly analyze unit and supervisor data to identify and compare activity patterns. Similar to Paragraph 116(c), Paragraph 117 requires PPB to use force audit data to conduct analyses at supervisor and team levels. Finally, Paragraph 118 requires PPB to use two thresholds to trigger case management reviews:.