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October 28, 2022 <br /> TO: e-comments <br /> BCC: Santa Ana City Council <br /> SUBJECT: Comments to the First Draft Ordinance for the Police Oversight Commission <br /> What follows are my comments to the subject document. <br /> My comments are intended to strengthen the independent structure of the proposed Commission, <br /> clarify roles of all key participants and mitigate against unintended consequences and internal conflicts. <br /> My comments are premised on the Constitution of the City of Santa Ana (aka the City Charter) and its <br /> relevant Sections. <br /> Section 2-665(a) <br /> • Define"practices"to include financial,management,and operational practices. <br /> • Remove the process for City Manager response and allow the Commission to submit their final <br /> report to the City Manager and the City Council where it then becomes a matter of public <br /> record. <br /> This speeds the distribution of information to the public and builds trust within the Community. <br /> It also enables independence of the Commission. <br /> The final disposition of findings and recommendations is an issue between the City Manger and <br /> the City Council. <br /> Section 2-665 (f)(1)(ii) <br /> • The Commission findings of the concerning the complaint should concurrently be presented to <br /> the City Manager and City Council <br /> Section 2-665(G) <br /> • Following this,the responsibilities of the Independent Director should include developing loss <br /> trend reports, root cause/post loss analysis,claim reviews,and identification of <br /> recommended improvements for reducing the incidence of loss and lowering the cost of all <br /> civil lawsuits. <br /> Section 2-666—Add F <br /> • The termination of the Independent Oversight Director must require the vote of 3/5th of the <br /> Commission. Such vote shall be considered advisory in nature and may at the Commissions <br /> discretion be done in executive session. <br />