Chapter 8.01 — INDEPENDENT POLICE AUDITOR

The purpose of this chapter is to establish the role of an independent police auditor (IPA) to enhance

accountability and transparency, to provide training, and promote adherence to the law and best practices within

the Petaluma police department (PPD). The IPA will provide independent review of police activities, policies, and

practices as speciNed in the agreement prescribing the IPA’s scope of services to ensure compliance with legal and

ethical standards and city policy. By fostering a culture of accountability, codiNcation of the IPA role pursuant to

this chapter is intended to:

The Petaluma Municipal Code is current through Ordinance 2916 NCS, passed December 1, 2025.

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A. Promote community trust in law enforcement through impartial review and public reporting regarding PPD

activity.

B. Ensure fairness, thoroughness, and impartiality in the investigation and resolution of complaints against PPD

personnel.

C. Evaluate and recommend improvements to PPD policies, procedures, and practices to reduce misconduct

and improve community relations.

D. Serve as a liaison between the community and the PPD, ensuring that the public’s concerns are heard and

addressed.

Through these measures, the IPA will work to ensure that the PPD upholds the principles and laws promoting

justice, equity, and public safety while respecting the rights of all community members.

Nothing in this chapter is intended to modify the agreement prescribing the IPA’s scope of services. This chapter is

intended to guide the preparation of the IPA’s contractual scope of services, which may be amended from time to

time, and to generally describe the role of the IPA in the city’s civilian public safety oversight policies. The IPA’s

contractual duties shall be as speciNed in the agreement prescribing the IPA’s scope of services.

(Ord. 2910 NCS §3, 2025.)

A. The city shall contract with an IPA to review the actions and policies of the PPD. The IPA shall conduct

independent reviews and evaluations of PPD practices and procedures and submit quarterly reports to the city

manager detailing the IPA’s activities in accordance with Section 8.01.030.

B. The IPA shall provide bi-annual reports to the public safety advisory committee (PSAC), established pursuant

to Chapter 2.50.

C. The IPA shall provide an annual report to the city council, which shall supplement the annual military

equipment report required by Section 8.03.020.

(Ord. 2910 NCS §3, 2025.)

The scope of work of the IPA pursuant to the contract by which the IPA is retained shall generally include the

following tasks:

A. Review of Community Complaints and Internal A5airs Investigations.

The Petaluma Municipal Code is current through Ordinance 2916 NCS, passed December 1, 2025.

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1. Independent Complaint Intake.

a. The IPA may receive complaints directly from citizens, and shall forward a summary, along with

complainant contact information, to the PPD professional standards division (PSD) through the chief of

police.

b. If the PPD receives a complaint or initiates an internal investigation, it shall notify the IPA within

three working days, providing the nature of the allegations.

c. Both the IPA and PPD shall independently review complaints and investigations to assess whether a

criminal referral is warranted.

2. Review of PPD Investigations.

a. The IPA shall review the disposition of PPD’s citizen complaints and internal aQairs investigations

within ten working days, or as soon thereafter as reasonably possible, to evaluate their thoroughness

and appropriateness.

b. The IPA shall have unrestricted access to all relevant information, evidence, and materials necessary

to discharge its duties.

c. The IPA shall assess whether investigations were complete, thorough, and objective, and may

recommend further inquiry or modiNcations to Nndings.

3. Disposition and Follow-Up.

a. Upon completion of an investigation and any disciplinary action, if applicable, the IPA shall confer

with the chief of police to address any concerns related to process, Nndings, or disciplinary

recommendations.

b. The IPA shall document any policy, procedural, or training recommendations arising from complaint

investigations.

c. Investigation outcomes shall be categorized as sustained, not sustained, unfounded, or exonerated.

4. Tracking and Reporting. The IPA shall review all complaint investigations to ensure timely and fair

resolution by:

a. Tracking each case through completion.

b. Documenting complaint classiNcations and nature.

c. Reviewing compliance with investigation timelines.

d. Evaluating the fairness and appropriateness of disciplinary actions.

e. As part of the semi-annual report, pursuant to Section 8.01.020, the IPA shall provide a detailed

analysis of complaint statistics, trends, initial allegations, investigation Nndings, and recommendations.

The Petaluma Municipal Code is current through Ordinance 2916 NCS, passed December 1, 2025.

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B. Independent Investigations and Additional Audits.

1. If the IPA determines that an internal investigation was insuPcient, or if PPD declines to investigate a

complaint, the IPA may, with approval from the city manager and city attorney, initiate an independent

investigation.

2. The IPA shall have full, unrestricted access to all necessary information, evidence, and records necessary

to discharge its duties.

3. The IPA shall provide an annual report to the city manager assessing the eQectiveness of the PSD.

C. Review of Policies, Procedures, and Training.

1. Policy and Procedure Evaluation.

a. The IPA shall review and assess both existing and new PPD policies and procedures, as speciNed in

the IPA contract.

b. The IPA shall evaluate training programs related to professional standards, accountability, and

discipline.

2. Priority Policy and Practice Audits. The IPA shall focus on auditing PPD policies and practices, including:

a. Body-worn camera usage and supervisory review.

b. Early warning systems for identifying use-of-force trends.

c. PSD disciplinary processes.

d. Identifying policy or training deNciencies and recommending corrective actions.

3. Recommendations for Policy, Procedure, and Training Improvements.

a. The IPA shall submit written recommendations for improvements in PPD policies, procedures, and

training.

b. Recommendations shall be shared with the chief of police and made publicly available when

appropriate.

c. The IPA shall include a summary of all policy recommendations and their implementation status in

the semi-annual report.

D. Review of Critical Incidents.

1. The PPD shall notify the IPA within twenty-four hours of any critical incident, including:

a. All oPcer-involved shootings.

The Petaluma Municipal Code is current through Ordinance 2916 NCS, passed December 1, 2025.

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b. Police-involved traPc collisions resulting in death or serious bodily injury.

c. Use of force incidents leading to death or serious bodily injury.

d. In-custody deaths of detainees.

2. The IPA shall review PPD’s investigation, Nndings, and disciplinary recommendations related to critical

incidents.

3. Based on its review, the IPA may recommend policy changes, training improvements, or disciplinary

actions.

E. Monitoring of Police Conduct and Performance Trends.

1. The IPA shall audit background investigations of police personnel to ensure compliance with the law and

best practices regarding oPcer qualiNcations and character standards.

2. The IPA shall identify and report on trends in arrests, citations, and oPcer use-of-force incidents,

including demographic data.

3. The IPA shall monitor the PPD’s early warning system(s) for tracking oPcer misconduct, vehicle pursuits,

   and other high-risk behaviors.

F. Community Engagement and Public Safety Advisory Committee Participation.

1. The IPA shall work collaboratively with city staQ, the PSAC, and community stakeholders to enhance

police-community relations.

2. The IPA shall provide the PSAC with all reports and audits submitted to the city council, pursuant to

3. The IPA shall consider community feedback when reviewing police policies and making

   recommendations.

(Ord. 2910 NCS §3, 2025.)