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COMMENTS ON REVISED DIRECTIVE 635.10, CROWD MANAGEMENT/CROWD CONTROL

To Chief Marshman, Acting Chief Davis, Capt. Bell, Captain Krantz, PPB Policy Analysts, Compliance Officer/Community Liaison Team, Community Oversight Advisory Board staff, US Dept. of Justice, Citizen Review Committee and the Portland Police Bureau:

While we are thankful that the Bureau has asked for more input into Crowd Management/Crowd Control Directive 635.10, as we predicted, the sheer volume of changes made to the last draft posted in January is far too large for a 15-day comment period. We've repeatedly requested "red-line" versions of proposed Directives, and noted that when you began this new process, a list of general concepts about changes being made would make public input more meaningful. Now we find ourselves in the position of sorting through the revised draft almost from scratch.

While all references to pepper spray have been removed from the Directive, it's not clear if that substance (whether in canisters or projectiles) is covered by the generic term "riot control agents," which still appears in a few places in the new draft (including Procedure 5.1.6). We remain opposed to the use of impact munitions, tear gas, flash-bangs and other weapons at protests, as well as bicycles used as weapons and the Mounted Patrol Unit in crowds.
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