Performance Audit City of Oaklands Homeless Encampment Management Interventions and Activities

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Oakland's Homeless

Encampments

PERFORMANCE AUDIT OF THE CITY OF


OAKLAND’S HOMELESS ENCAMPMENT
MANAGEMENT INTERVENTIONS & ACTIVITIES
FISCAL YEARS 2018-19 AND 2019-20

CITY AUDITOR
Courtney Ruby, CPA, CFE

AUDIT TEAM
Assistant City Auditor, Mike Edmonds, CIA
Performance Auditor, Jennifer Lim, CIA
Senior Performance Auditor, Orshi Kovesdi, MBA
Senior Performance Auditor, Mark Carnes, CFP
Performance Auditor, Daniel Williams

APRIL 14, 2021


OAKLAND

Source: Understanding Homelessness/Sasaki: https://www.bloomberg.com/news/articles/2017-04-07/where-america-s-homeless-live.

Acknowledgments
Homelessness is a serious problem, not just in Oakland, but across the United States. Solving the root causes of
homelessness and housing affordability will require an unprecedented amount of intergovernmental, business, and
nonprofit coordination and cooperation – it will require a model similar to the COVID response where we all come together
with a sense of urgency, respect, commitment, and shared purpose. Therefore, I'd like to thank all those who contributed to
this important audit.

Thank you to the City’s Encampment Management Team and all the City departments and offices that assisted us in
completing this audit.

I also want to thank Oakland’s homeless advocates and members of the homeless population for meeting with us at the
start of this audit. Both your lived experiences and knowledge of homelessness helped us better understand the problems
our unsheltered community are facing.

I want to commend Pauline Miller, Juliet Flores Wilson, and Alexandra Marzolf, from the Goldman School of Public Policy at
the University of California, Berkeley, for their outstanding work and contributions to this report.

I especially want to thank my entire team for their tireless work, dedication, and energy they put into this audit. Your
expertise and professionalism shine through in this report.

Last, but certainly not least, I want to thank my Assistant City Auditor, Mike Edmonds, for his partnership and auditing
expertise. This report is one of many exceptional audits we have produced together since 2007 when he first served as my
Assistant City Auditor. He is a gifted professional, a dear friend, and a trusted confidant. As Mike ventures into retirement,
we thank him for making all of us in the City Auditor’s office better auditors and for his dedicated service to the City of
Oakland.
Courtney A. Ruby, CPA, CFE (510) 238-3378
City Auditor FAX (510) 238-7640
TDD (510) 238-3254
www.oaklandauditor.com

April 14, 2021

HONORABLE MAYOR
HONORABLE CITY COUNCIL
HONORABLE CITY ATTORNEY
HONORABLE COMMISSIONERS
CITY ADMINISTRATOR
OAKLAND RESIDENTS

RE: PERFORMANCE AUDIT OF THE CITY OF OAKLAND’S HOMELESS ENCAMPMENT


MANAGEMENT INTERVENTIONS AND ACTIVITIES

Dear Mayor Schaaf, City Council President Bas, Members of the City Council, City Attorney
Parker, Members of the Commission on Homelessness, City Administrator Reiskin, and
Oakland Residents:

For several years, the residents of Oakland have identified homelessness as the most
pressing issue facing our City. As such, this audit was a priority for both the City Auditor’s
Office and the City Council. I want to acknowledge City Council President Bas for her
leadership on this issue, and her collaboration in defining the audit objectives with my
office. This audit report is the first of two audit reports on homelessness.

The audit found the City’s efforts to address homelessness are akin to those of other local
governments dealing with the growing number of unsheltered residents in their
communities, which has only worsened by the severe economic impact of the COVID
pandemic. In July 2019, Alameda County released its Homeless Point-in-Time count,
indicating the number of homeless residents living in Oakland between 2015 and 2019 had
increased from 2,191 to 4,071, an increase of 86 percent. Nearly 79 percent of these
individuals were unsheltered due to the lack of permanent affordable housing options,
coupled with limited emergency and temporary housing options. The count also identified
that 70 percent of Oakland’s homeless population are African American, compared to 24
Honorable Mayor, Honorable City Council, Honorable City Attorney, Honorable Commissioners, City
Administrator, and Oakland Residents
Performance Audit of the City of Oakland’s Homeless Encampment Management Interventions and Activities
April 14, 2021
Page 2

percent in the general population. Moreover, the vast majority of known homeless
encampments are within communities of concern.
The impacts of homeless encampments are far-reaching, affecting the City’s housed and
unhoused residents, City workers, City services, businesses, and the community. The
purpose of the audit was to examine the City’s practices for managing the numerous
encampments throughout the City. Specifically, the audit objectives were to determine the
cost of encampment interventions and activities, determine how many encampments exist
in the City of Oakland, assess the quality of conditions at encampments, assess whether the
City is achieving its goals and objectives, and determine response times for 911 and 311
calls. Also, we assessed the closure notification process, the bag-and-tag process, and the
quality of data around encampment management services and activities and identified
best practices employed by other local governments as well.

The increase in homeless residents resulted in a significant rise in the number of


encampments. The City estimates that at least 140 encampments are scattered throughout
the City, and this estimate may be conservative. In response to the rise in encampments,
the City established the Encampment Management Team (EMT) in 2017, a multi-
departmental team to coordinate the City’s encampment response. The EMT developed an
Encampment Management Policy (EMP), designed to address the physical management of
homeless encampments and establish criteria for determining the types of interventions to
undertake at encampments.

The audit found the City was not adequately prepared to shoulder such a massive project
and the EMT was overwhelmed by the undertaking of closing and cleaning encampments
throughout Oakland. Specifically, the audit found the City lacked an effective strategy for
dealing with the growth in encampments and did not provide sufficient policy direction or
adequate funding at the onset of this crisis. Additionally, the EMT lacked sufficient
resources, including a budget. The audit also identified the City needs more complete data
on encampment activities, increased outreach, improved notification before encampment
interventions occur, improved collection of encampment residents’ belongings during
interventions, and a formal transportation policy to assist encampment residents in
relocating. Overall, the audit found the City needs to establish and fund a formal
encampment management program to address the findings in the audit and to put in place
effective management systems to implement, evaluate, and monitor the new encampment
policy passed in October 2020.

Every day our unhoused residents are exposed to unsanitary and dangerous conditions and
are vulnerable to serious health risks and significant safety hazards that threaten their lives.
As leaders and policymakers across the country seek timely affordable housing solutions
and come up with creative policies to help our unsheltered, we on the West Coast, and the
Honorable Mayor, Honorable City Council, Honorable City Attorney, Honorable Commissioners, City
Administrator, and Oakland Residents
Performance Audit of the City of Oakland’s Homeless Encampment Management Interventions and Activities
April 14, 2021
Page 3

Bay Area specifically, are called to work at a faster pace than most. Our housed and
unhoused residents are counting on us to make this right. It is both a humanitarian duty and
a civic expectation that our homeless become housed, and our City streets and parks are
returned to their intended public uses.

This is a very complex problem requiring every level of government to participate through
policy, funding, leadership, and cooperation. COVID has required an unprecedented amount
of intergovernmental, business, and nonprofit coordination. Addressing the root causes of
homelessness and affordability will require a similar commitment in which we all come
together with a sense of urgency, respect, commitment, and shared purpose.

Sincerely,

COURTNEY A. RUBY, CPA, CFE


City Auditor
Oakland’s City Auditor is an elected official and works for, and reports to, the residents of Oakland. The
Auditor’s job is to provide oversight to the City’s activities. The Auditor has the authority to access and
audit City financial and administrative records, plus the policies and procedures of all City agencies and
departments.
To make sure this work is done objectively and without bias, the City Auditor is not connected to any
other City departments and has no day-to-day financial or accounting duties for the City of Oakland.
This autonomy allows for independent analyses, ensuring tax dollars and other resources serve the
public interest.

Copies of audit reports are available at: www.OaklandAuditor.com


Alternate formats available upon request.
--
Copias de nuestros informes de auditoría están disponibles en: www.OaklandAuditor.com
Formatos alternativos de los informes se harán disponibles a pedido.
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審查報告可以在此網頁下載﹕www.OaklandAuditor.com
可根據要求提供其它格式版本。

Phone: (510) 238-3378


Email: [email protected]

@OaklandAuditor

@OaklandAuditor

www.OaklandAuditor.com or Text AUDITOR to 22828

Independent City Auditor. Serving Oakland With Integrity.


Executive Summary........................................................................................................................... 1
Introduction and Background ........................................................................................................... 7
Audit Results ................................................................................................................................... 22
Section 1. Impacts of Encampments and the City’s Efforts to Mitigate Them ......................... 22
Conclusion and Recommendations: ......................................................................... 38
Section 2. Police, Fire, and 311 Response Times ...................................................................... 40
Conclusion and Recommendations: ......................................................................... 44
Section 3. City's Costs Associated with Encampment Activities ...................................................... 46
Conclusion and Recommendation:........................................................................... 51
Section 4. Management Systems Needed to Effectively Implement the New Encampment
Management Policy .................................................................................................................. 52
Conclusion and Recommendations: ......................................................................... 60
Objectives, Scope, and Methodology ............................................................................................. 63
Statement of Compliance .............................................................................................................. 65
Appendix: Detailed Cost Analysis and Description of Departments and Offices Encampment
Activities .......................................................................................................................................... 66
City Administration’s Response ...................................................................................................... 83
City Administration’s Response Letter...................................................................................... 83
Recommendation Implementation Matrix ............................................................................... 84
This report examines the City of Oakland’s encampment management services and activities and has
four sections. Section 1 discusses the impacts of encampments on Oakland residents, both housed and
unhoused, City staff, City services, businesses, and the community, as well as the City’s efforts to
mitigate the impacts of encampments. Section 2 addresses the Police Department’s and the Fire
Department’s response times to 911 emergency calls at encampments and the City’s response to the
311 Call Center service requests at encampments. Section 3 includes estimates of the City’s costs
associated with encampment activities. Specific cost details and the roles and responsibilities of staff
working on encampment activities, and the audit methodology to estimate such costs, are shown in the
Appendix. Finally, Section 4 provides guidance for the City Administration to more effectively implement
the City’s new encampment policy.

Cities across the country, especially the West Coast, are facing a homelessness crisis. The federal
Department of Housing and Urban Development released a study in late 2019, which stated, “While the
rest of the country experienced a combined decrease in homelessness in 2019, significant increases in
unsheltered and chronic homelessness on the West Coast, particularly California and Oregon, offset
those national decreases, causing an overall increase in homelessness of 2.7 percent in 2019.” The study
found 567,715 persons experienced homelessness on a single night in 2019, an increase of 14,885
homeless individuals since 2018.

Oakland has been significantly impacted by the homelessness crisis. In July 2019, Alameda County
released its Homeless Point-in-Time count, indicating the number of homeless residents living in
Oakland between 2015 and 2019, increased from 2,191 to 4,071, an increase of 86 percent. Nearly 79
percent of these individuals were unsheltered due to a lack of permanent affordable housing options
coupled with limited emergency and temporary housing options.

Oakland, like other jurisdictions, has experienced a significant increase in the number of encampments.
However, the number of encampments and the number of residents occupying encampments changes
frequently and is difficult to quantify. A 2018 report identified 329 encampments in the City of Oakland.
In comparison, the City’s May 2019 master list of encampments identified 87 specific encampments and
the City’s master list of encampments in October 2020 included 140 encampments.

Like other cities, the City of Oakland established a multi-departmental team, the Encampment
Management Team (EMT), in 2017, to coordinate its response to the numerous encampments
throughout the City. The goal of the team is to address issues arising from the increase in encampments
and coordinate the City’s response to managing encampments. The EMT was initially comprised of staff
from the following departments and outside agencies: City Administrator’s Office, Public Works, Human

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Services, Transportation, Police, Fire, Parks, Recreation and Youth Development, the Mayor’s Office and
Alameda County Vector Control. On occasion, representatives from Bay Area Rapid Transit (BART),
Caltrans, Alameda County’s Homeless Response Team, and other agencies and City departments also
participate.

A City survey of Oakland residents reported that homelessness and affordability of housing were the
two biggest issues that Oakland residents wanted addressed in the City’s upcoming two-year budget
cycle. Conducting an audit addressing homelessness was a high priority for the City Auditor since taking
office in January 2019; it was also a high priority for the Oakland City Council (City Council). Accordingly,
the City Auditor and City Council identified the following points for the audit to consider:

1. Determine the cost of the encampment management services.


2. Determine how many encampments exist in the City of Oakland.
3. Assess the quality of conditions at encampments.
4. Assess whether the City is achieving its goals and objectives.
5. Determine response times for 911, 311, and 211 calls.
6. Determine how many homeless are served in encampments, including the number receiving
permanent housing and retention rates on permanent housing.
7. Assess the closure notification process.
8. Assess the bag-and-tag process.
9. Identify best practices.
10. Assess the quality of data around the encampment management services.
11. Assess the coordination, partnerships, and performance of City departments, other
governmental agencies, and contractors.

This audit is not intended to address all aspects of homelessness. For instance, this audit will not assess
shelter options such as Community Cabins, recreational vehicles (RV) sites, transitional housing, and
other shelters. The audit also does not address the causes or solutions to homelessness. Rather, this
report focuses on the City’s encampment management services and activities. It also includes
information related to encampment conditions, but due to the COVID-19 (COVID) pandemic, the City
Auditor was unable to perform a formal assessment of the quality and conditions of encampments. In
addition, we did not assess 211 response times given this is a county system that connects residents
with a broad scope of services.

Additionally, the City Auditor will issue a separate audit report at a later date to address the following
issues: 1) assessing the coordination, partnerships, and performance of City departments, other
governmental agencies, and contractors, and 2) determining the number of encampment residents
receiving permanent housing and corresponding retention rates.

This audit report provides critical information to City policymakers and City staff to assist them in
overseeing and managing the City’s encampment activities. For instance, the report highlights the

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significant impacts encampments have on encampment residents, the community, business, and City
staff, as well as the City’s efforts to mitigate these impacts. Moreover, the report identifies
opportunities to enhance the City’s intervention efforts. The report also includes information on the
Police Department and the Fire Department’s response to emergencies at encampments. This
information is valuable for policymakers to ensure encampment residents are receiving appropriate and
equitable service. To manage the City’s encampments, the report estimates the City has incurred
approximately $12.6 million in costs, most of it unbudgeted, over the last two fiscal years. Reliable cost
information is critical for City policymakers to have in order to develop informed encampment
management policy decisions and appropriately budget for encampment services and activities. The
report ends by providing a roadmap for the City Administration to more effectively implement the City’s
new encampment policy, scheduled to take effect in January 2021.

Section 1: The impacts of encampments are far-reaching—affecting the City’s housed and unhoused
residents, City workers, City services, businesses, and the community.

• Encampments:
➢ are unhealthy for its residents due to unsanitary (i.e., vermin, lack of clean water, garbage,
needles, etc.) and dangerous living conditions (i.e., murders, drug use, etc.), fires, and health
risks to vulnerable individuals.
➢ have significantly impacted City staff through traumatic experiences, dangerous working
conditions, and other safety risks. As a result, multiple City staff have filed workers’
compensation claims, one of which resulted in an employee receiving $19,000 in
compensation.
➢ have impacted City services through an increased demand for public safety and service
requests. Additionally, multiple legal actions have been filed against the City.
➢ have had significant impacts on Oakland businesses and their clients/customers and staff.
Additionally, businesses have reported damage to property and safety concerns.
➢ have significantly impacted the community through destroyed or compromised City parks,
illegal dumping, environmental issues, damaged or blocked public rights-of-way and traffic
signals, and damage to other public infrastructure.
• The EMT coordinates and schedules the City’s encampment interventions, which include
closures, cleanings, and garbage and hygiene services, based on the initial Encampment
Management Policy.
• The City conducted nearly 2,100 interventions in FY 2018-19 and FY2019-20. These interventions
included a total of approximately 500 closures, re-closures, and cleanings. Additionally, the City
provided nearly 1,600 garbage pickups and other hygiene services such as installing and
maintaining showers and portable toilets.
• The City faced numerous challenges in addressing the growing number of encampments
including, but not limited to, the lack of affordable housing, the lack of shelter options, shelter
options that did not meet the personal needs of homeless individuals, and legal actions that
delayed the City’s intervention efforts.

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• The EMT and the City were overwhelmed by the undertaking of closing and cleaning
encampments because the City was not adequately prepared to undertake such a massive
project. Specifically, the City lacked an effective strategy for dealing with the growth in
encampments and did not provide sufficient policy direction or adequate funding at the onset of
this crisis, and the EMT lacked sufficient resources, including a budget.
• Opportunities exist to enhance the City’s encampment interventions by:
➢ improving the information on the schedule of interventions,
➢ documenting the criteria for determining which encampments receive garbage and hygiene
services.
➢ enhancing outreach efforts and re-assessing the notification process for interventions,
improving the bag-and-tag process, and
➢ developing a clear policy on transportation provided to residents at closures.

This section includes 10 recommendations to: improve the organizational structure of the EMT; ensure
adequate recordkeeping for interventions; better define when services are provided to encampments;
improve outreach, the intervention notification process, and the bag-and-tag process; and develop a
comprehensive policy for providing transportation assistance when encampments are closed. A more
detailed and comprehensive list of these 10 recommendations are listed on page 39 of the report and
the City Administration has agreed to implement these 10 recommendations.

Section 2: The Police Department’s response times to 911 emergency calls at encampments were not
timely, but the Fire Department’s responses to fire emergencies at encampments were timely, and
the response time to 311 service requests need further examination.

• Police Department
➢ In FY 2018-19, the Police Department received 823 calls to encampments. We were unable
to analyze all these calls because response data was incomplete. Accordingly, we analyzed
572 calls in which the data was complete. Most of these calls to encampments were Priority
2, which ideally should be responded to in 10 to 15 minutes. The Police Department,
however, responded to these calls in an average of 4 hours. The range of response times
was 0 to 54 hours and the median response time was 2 hours.
➢ In FY 2019-20, the Police Department received 636 calls to encampments. We analyzed 416
of these calls. Again, most of these calls to encampments were Priority 2 calls. The Police
Department’s response to these calls averaged 6 hours, the median response time was
approximately 3 hours, and response times ranged from 0 to 153 hours. For the one Priority
3 call, the Police Department responded in approximately 7 hours.
• Fire Department
➢ The Fire Department responded to 988 encampment related fires in fiscal years 2018-19
and 2019-20.
➢ The Fire Department responded to 90 percent of these calls in less than 8 minutes in fiscal
years 2018-19 and 2019-20.

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➢ We were unable to assess the response time for medical emergencies because the Fire
Department currently does not track data for calls for medical emergencies at
encampments.
• 311 Call Center
➢ In calendar years 2018 and 2019, the Call Center received a total of 1,152 calls related to
encampments.
➢ 311 Call Center response times are based on closed service requests. In calendar year 2018,
there were 299 closed cases and the average response time was 22 days. In calendar year
2019, there were 152 closed cases and the average response time was 39 days.
➢ Given the gravity of the homeless crisis, the response times are concerning, and the
Administration should evaluate both the integrity of the data and the resolution of calls
regarding encampments.

This section includes three recommendations to better identify all police and fire emergencies at
encampments and improve tracking of 311 calls concerning encampments. A more detailed and
comprehensive list of these three recommendations are listed on pages 44-45 of the report and the City
Administration has agreed to implement these three recommendations.

Section 3: The City incurred approximately $12.6 million in direct costs associated with encampment
activities in fiscal years 2018-19 and 2019-20. Most of these costs were unbudgeted and resulted in
the City forgoing other services to redirect staff and resources to encampment activities

• The City did not budget and track costs for encampment management activities
• The audit estimates that the City incurred approximately $12.6 million in direct costs associated
with encampment activities in FY 2018-19 and FY 2019-20.
• The audit estimates the hourly cost of closures and cleanings to be $1,464 per hour.
• The audit could not quantify the cost of a second crew, which is used on larger interventions, or
days with multiple interventions.
• In addition to incurring costs, encampment activities are diverting time and resources from
other City services like illegal dumping and fire inspections.

This section includes one recommendation to improve recordkeeping for tracking and monitoring costs
on encampment activities. A more detailed recommendation is listed on page 51 of the report and the
City Administration has agreed to implement this recommendation.

Section 4: The City needs to develop and implement formal management systems to effectively
administer the new encampment policy

• The City Council adopted a new Encampment Management Policy in 2020 designating high and
low sensitivity areas, determining findings that will prompt EMT interventions, and providing

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guidance on addressing unreasonable health and safety risks, promoting voluntary compliance,
and strategies to address non-compliance.
• The 2020 Encampment Management Policy also includes an equity provision in recognition that
70 percent of Oakland’s homeless population are African American, and the vast majority of
known encampments are within communities of concern.
• To be more proactive, programmatic, and strategic, the City will need to create a more formal
program to manage the encampment services and activities. The program should include
➢ establishing measurable goals and objectives,
➢ developing written strategic plans for achieving goals and objectives,
➢ establishing formal systems for assessing progress in implementing strategies,
➢ developing annual work plans to implement strategies and achieve goals and objectives,
➢ developing annual budgets and tracking costs for encampment management activities,
➢ determining the appropriate staffing levels, the appropriate composition of staff, and
defining the roles, responsibilities, and authority of staff,
➢ developing written policies and procedures to guide the implementation of the new policy,
➢ developing data collection systems to manage encampment activities, and
➢ ensuring staff are adequately trained.

This section includes 12 recommendations to establish a formal encampment management program


with appropriate controls in place to effectively manage the City’s new encampment management
policy. These controls include goals and objectives, developing a strategic plan and annual work plans,
establishing formal systems for tracking progress in implementing strategies, developing a budget and
comprehensive system for tracking costs of encampment activities, assessing staffing requirements,
defining the roles and responsibilities of staff, developing written policies and procedures, developing
data collection systems, assigning responsibility for maintaining an up-to-date list of all encampments in
the City, and developing training programs for staff working on encampment activities. A more detailed
and comprehensive list of these 12 recommendations is listed on pages 60-62 of the report and the City
Administration has agreed to implement all 12 of these recommendations.

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Homelessness, homeless encampments, and housing affordability are among the biggest issues facing
the City of Oakland (City). Accordingly, the City Auditor placed a high priority on performing an audit of
homeless services and put it at the top of her annual workplan, soon after taking office in January 2019.
In June 2019, the Oakland City Council (City Council) also requested the Office of the City Auditor (City
Auditor) examine the City’s practices for managing the numerous encampments1 throughout the City.
The City Auditor and City Council identified the following points for the audit to address:

1. Determine the cost of the encampment management services.


2. Determine how many encampments exist in the City of Oakland.
3. Assess the quality of conditions at encampments.
4. Assess whether the City is achieving its goals and objectives.
5. Determine response times for 911, 311,2 and 2113 calls.
6. Determine how many homeless are served in encampments, including the number receiving
permanent housing and retention rates on permanent housing.
7. Assess the closure notification process.
8. Assess the bag-and-tag4 process.
9. Identify best practices.
10. Assess the quality of data around the encampment management services.
11. Assess the coordination, partnerships, and performance of City departments, other
governmental agencies, and contractors.

This audit is not intended to address all aspects of homelessness. For example, this audit will not assess
shelter options such as Community Cabins, recreational vehicles (RV) sites, transitional housing, and
other shelters. Rather, this report is focused on the City’s encampment management services and
activities. Due to the COVID-19 (COVID) pandemic, the City Auditor was unable to perform a formal
assessment of the quality and conditions of encampments, however, the report does include
information related to encampment conditions. Additionally, the following issues will be addressed in a
separate audit report at a later date: 1) assessing the coordination, partnerships, and performance of
City departments, other governmental agencies, and contractors, and 2) determining the number of
encampment residents receiving permanent housing and corresponding retention rates.

This report has four sections. Section 1 discusses the impacts of encampments on Oakland residents,
both housed and unhoused, City staff, City services, and the community, as well as the City’s efforts to
mitigate the impacts of encampments. Section 2 addresses the Police Department’s and Fire

1 The term encampment is widely used to describe homeless individuals choosing to live together in groups, which may also be
referred to as tent cities, homeless settlements, and homeless camps. The nature of encampments, as well as the definition of
and what constitutes an encampment, is further discussed later in the Background section and throughout the report.
2 OAK 311 is a service to make it easier for Oaklanders to report problems and request infrastructure maintenance. For more

information on OAK 311, click here.


3 We did not assess 211 response times because it is an Alameda County program that connects residents with a broad scope of

health and human services in their community. For more information on 211, click here.
4 The City of Oakland’s bag-and-tag process is a system to bag up, tag, and store the belongings of encampment residents

during an encampment closure, so encampment residents can later retrieve their belongings.

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Department’s response times to 911 emergency calls at encampments and the City’s response to the
311 Call Center service requests at encampments. Section 3 includes estimates of the City’s costs
associated with encampment activities. Specific cost details and the roles and responsibilities of staff
working on encampment activities, and the audit methodology to estimate such costs, are shown in the
Appendix. Finally, Section 4 provides guidance for the City Administration to more effectively implement
the City’s new encampment policy.

What is homelessness?
According to the Oxford Encyclopedia of Social Work, homelessness is formally defined by the United
States government as a condition in which a person “lacks a fixed, regular, and adequate nighttime
residence, and if they sleep in a shelter designated for temporary living accommodations or in places not
designated for human habitation.”

Who are the homeless?


To address the diversity within the population experiencing homelessness, the federal Department of
Housing and Urban Development (HUD) defines four subpopulations. These subpopulations are:

• Chronically homeless – defined by HUD as an unaccompanied individual or head of a family


household with a disabling condition, who has either continuously experienced homelessness
for more than a year or has experienced at least four episodes of homelessness totaling 12
months, in the past three years,
• Unaccompanied children – children under the age of 18 who are not accompanied by a parent
or guardian,
• Persons in families with children – at least one adult and one child under the age of 18, and
• Veterans – persons who have served in the military.

Counting the homeless


Although it may not be possible to know the exact number of people experiencing homelessness, the
primary data for measuring homelessness trends is the Point-in-Time count, a nationwide count of the
number of people that meet the HUD definition of homelessness on a single night in January.

The Point-in-Time counts are considered conservative for several reasons. HUD acknowledges that
factors such as a distrust of public services, mental health issues, and a desire to not be found make it
difficult to count the homeless population. Also, the definition of homeless differs amongst other
federal agencies. For example, HUD guidelines specify that only institutions with space dedicated to
people experiencing homelessness are included in the Point-in-Time count. As a result, the count does
not include individuals experiencing homelessness who are in jail, hospitals, or substance abuse
treatment facilities on the night of the count. Also, HUD does not consider children living in motels or
hotels or living with relatives as homeless, with several exceptions. However, the Department of

8
Education and the Department of Health and Human Services consider children living in hotels and
motels or staying with others that are not relatives as homeless.

National trends in homelessness


Cities across the country, like Oakland, are facing a homelessness crisis. A HUD study released in late
2019, reported that “While the rest of the country experienced a combined decrease in homelessness in
2019, significant increases in unsheltered and chronic homelessness on the West Coast, particularly
California and Oregon, offset those national decreases, causing an overall increase in homelessness of
2.7 percent in 2019.” The study found 567,715 persons experienced homelessness on a single night in
2019, an increase of 14,885 homeless individuals since 2018.

Oakland and Alameda County trends in homelessness


In July 2019, Alameda County released its Homeless Point-in-Time count, indicating the number of
homeless residents living in Oakland between 2015 and 2019, increased from 2,191 to 4,071, an
increase of 86 percent. Nearly 79 percent of these individuals were unsheltered due to a lack of
permanent affordable housing options coupled with limited emergency and temporary housing options.

As shown in Exhibit 1 below, homelessness in Alameda County and Oakland is at its highest level in the
last five years. Between 2015 and 2019, the number of homeless in Oakland and Alameda County nearly
doubled.

Exhibit 1: Total number of individuals experiencing homelessness in the City of Oakland and Alameda
County between calendar years 2015 – 2019

8,022

5,629

4,040 4,071

2,761
2,191

2015 2017 2019

City of Oakland County of Alameda

Source: Alameda County Point-in-Time Count and Survey from 2015, 2017, and 2019

Exhibit 2 below shows the subpopulations in Oakland and Alameda County as of the 2019 Point-in-Time
count.

9
Exhibit 2: Total number of federally reported subpopulations experiencing homelessness in the City of
Oakland and Alameda County in 2019
Subpopulation Category City of Oakland Alameda County
# % # %
Unaccompanied Youth and Young Adults 468 11% 731 9%
Persons in Families with Children 198 5% 524 7%
Chronically Homeless 865 21% 2,236 28%
Veterans 361 9% 692 9%
Homeless Individuals not categorized in the above
2,179 54% 3,839 48%
subpopulations
Total Homeless Population 4,071 100% 8,022 100%
Source: Alameda County Point-in-Time count and survey 2019

As Exhibit 2 shows, in January 2019, the Point-in-Time count identified 8,022 homeless individuals in
Alameda County, of which, 4,071 were located in Oakland. Unaccompanied youth and young adults
represented 468 individuals, or 11 percent of the homeless population in Oakland. Persons in families
with at least one adult and one child under the age of 18 represented 198 individuals, or 5 percent of
the overall homeless population. This was a decrease from 2017, when families represented 9 percent
of the population (262 individuals). Veterans represented 361 individuals, or 9 percent of the homeless
population. HUD does not categorize all homeless into one of these subgroups. In 2019, more than half
or 2,179 homeless individuals were not categorized into any of the four subpopulations.

As noted above, the Homeless Point-in-Time count is considered a conservative count of persons
experiencing homelessness. Various agencies have different methodologies for determining the
numbers of homeless individuals and families. For example, a January 2021 report issued by the
Oakland-Berkeley-Alameda County Continuum of Care found that, in Oakland, 6,087 households,
without children were experiencing homelessness and 499 families with children were experiencing
homelessness.

According to the Point-in-Time count, Black/African Americans are disproportionally affected by


homelessness. In Alameda County, Black/African Americans represent 11 percent of the County’s
general population but make up 47 percent of the homeless population. In Oakland, Black/African
Americans represent 24 percent of the City’s general population but make up 70 percent of the City’s
homeless population.

The next Point-in-Time count was scheduled for January 2021 but was delayed due to of the COVID
pandemic.

10
All levels of government, the private sector, and nonprofits are working to
address homelessness
Agencies from all levels of government and within the private and nonprofit sectors have dedicated
resources to address homelessness through various programs and services. We have listed several
agencies and their programs and services below.

Federal agencies
U.S. Department of Housing and Urban Development (HUD)

• Provides funding to states and local governments and nonprofit providers to serve individuals
and families across the country who are affected by homelessness.
• Serves over one million people through emergency, transitional, and permanent housing
programs each year.

U.S. Interagency Council on Homelessness (USICH):

• Comprises 19 federal member agencies and is charged with coordinating the federal response to
homelessness by fostering partnerships at every level of government and the private sector.
• Provides expert guidance to communities and leads interagency working groups to design and
implement strategies to end homelessness. USICH develops tools and guidance to support all
communities in implementing best practices and it leads the interagency implementation of the
federal strategic plan, Home Together, to prevent and end homelessness.

State of California
Multiple state entities in California administer a variety of homeless service programs:

• The Business, Consumer Services, and Housing Agency (BCSH) administers the Homeless
Emergency Aid Program (HEAP), which provides a total of $500 million in one-time funding to
localities. This funding is meant to assist localities in addressing their immediate homelessness
challenges.
• The Department of Housing and Community Development, the California Department of Social
Services, the California Housing Finance Agency, California Tax Credit Allocation Committee, and
the Homeless Coordinating and Financing Council (HCFC) administer some of the state’s longest
standing and/or largest housing and homelessness programs.
• Other state departments administer programs that address homelessness indirectly. Those
departments include the Department of Health Care Services, the Department of Veterans
Affairs, the Office of Emergency Services, and the Department of Corrections and Rehabilitation.

Alameda County
Multiple county agencies and departments administer a variety of homeless programs:

11
• County Encampment Response Team (ERT) has been established to coordinate responses to
encampments, with an initial focus on unincorporated county areas and prioritizing other
County-managed properties.
• Alameda County Homeless Council developed an ‘Encampment Toolkit’ that includes a
framework and policies to be piloted within unincorporated areas to assist unsheltered persons.
The toolkit will also be modified so that it can be utilized in City-County partnership agreements.
• Alameda County’s Public Health Department has partnered with Oakland to implement vector
and rodent control, as well as a Hepatitis A vaccine program for residents in encampments.
• The City and County have been working together to provide a variety of interventions to address
COVID among unsheltered individuals. This includes moving homeless individuals into hotels and
RV’s and providing COVID tests.
• Other County agencies and departments address homelessness, including the Health Care
Services Agency, the Housing and Community Development Department, and the Social Services
Agency.

Organizations and service providers around the Bay Area


Numerous organizations provide a variety of services to the homeless including, but not limited to

• Bay Area Community Services,


• Building Futures with Women and Children,
• East Oakland Community Project,
• Health Care for the Homeless,
• Lifelong Medical,
• Operation Dignity, and
• Roots Community Health Center.

Many informal groups, faith-based organizations, and private individuals visit encampments regularly to
provide food and personal items.

What is the City of Oakland doing in response to homelessness?


The City has initiated numerous actions to address homelessness in Oakland. In 2006, the City
developed the Permanent Access to Housing (PATH) framework as a roadmap for ending homelessness.
In 2019, the City updated the PATH framework to align the City’s efforts with national best practices and
to focus on homelessness within the City. The PATH framework aims to reduce the number of people
experiencing homelessness. Specifically, the framework

• Provides an outline for addressing homelessness across the full spectrum of services from
prevention, intervention, and solutions to end homelessness.
• Identifies the scale and scope of the investments needed to make substantial change in the
current crisis.
• Seeks to align all stakeholders on the importance of investing across the spectrum of services
and in setting ambitious measurable goals.
• Points to the absolute need to increase revenues.
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• Informs policy makers about what to advocate for from federal, state, county, and private
funding partners.

Additionally, the PATH framework outlines strategies to reach its goals and commits to measuring the
effectiveness of these strategies annually for the life of the plan. The framework outlines specific
strategies5 to reduce homelessness in Oakland by

• Reducing the number of people who become homeless each year.


• Increasing the number of people returning to housing as quickly as possible.
• Expanding, improving and maintaining crisis response beds.
• Assisting people in securing the incomes and support they need to avoid returning to
homelessness.
• Expanding the supply of deeply affordable and supportive housing for Oakland’s most
vulnerable residents.
• Addressing impacts of unsheltered homelessness on sheltered and unsheltered neighbors.

The City’s Crisis Response and Long-term/Permanent Housing Options


The City offers two types of housing options: crisis response and long-term/permanent housing. Crisis
response beds provide temporary night-by-night shelter or lodging for those experiencing
homelessness. These include transitional housing, shelters, RV Safe Parking, Operation HomeBase, and
Community Cabins. Since 2017, the City has significantly reduced its capacity to house the homeless in
shelters, transitional housing, community cabins, and RV sites. According to Human Services, the City
has more than doubled its capacity over the last three years. Additionally, the City offers long-
term/permanent housing options including: rapid re-housing, Project HomeKey, and long-term re-
housing services. The City’s crisis response and long-term/permanent housing options are described
below.

Crisis response options


Transitional housing
The City and its contractors oversee five transitional housing programs: 1) Families in Transition, 2) the
Matilda Cleveland, 3) the Oakland Homeless Youth Housing Collaborative, 4) the Holland, and 5) the
Henry Robinson Center. Each program is intended to provide transitional housing services to stabilize
unhoused residents and provide resources to prepare them to transition to permanent housing.

Shelters
The City funds or partially funds nonprofits to operate four low-barrier emergency shelters for single
adults and for families: 1) Crossroads Shelter, 2) Family Matters, 3) St. Vincent de Paul, and 4) Building
Futures with Women and Children shelters. The shelters do not provide transitional or long-term
housing. Each shelter provides slightly different services to its clients. Services include two to three

5
The PATH framework outlines more specific goals, which can be found here.

13
meals per day, drinking water, clean bathrooms and showers, and varying levels of case management
services and aftercare support.

Operation HomeBase
In response to the COVID pandemic, the City received 67 RVs donated by the State of California. The City
uses these vehicles to provide medically vulnerable unsheltered residents a safe space to maintain social
distancing. Operation HomeBase can serve a maximum of 128 people at any given time. Participants
must either be 65 years of age or older or have an underlying medical condition that makes them more
vulnerable to complications from COVID. The program was funded by a combination of funds from the
State of California’s Emergency COVID Response Fund, and a $500,000 donation from a private donor.
The City also anticipates receiving some reimbursement for its expenses related to the COVID pandemic
from the Federal Emergency Management Agency (FEMA).

Recreational Vehicle (RV) Safe Parking


The City has three RV Safe Parking sites: 1) High Street, 2) 71st Avenue, and 3) Beach Street. The City
contracts with nonprofit partners to manage the sites. Each site consists of a parcel of publicly or
privately-owned land, where residents can legally park their RV (regardless of whether it is operable).
The sites are intended to provide a safe and healthy option for residents who reside in RVs. Currently,
the RV Safe Parking program has the capacity to host 108 RVs, depending on the size and available
spaces at the sites.

Community Cabins
The Community Cabin sites are a coordinated grouping of small shelters that sleep two people per unit.
The City has six Community Cabin sites: 1) Lake Merritt, 2) Mandela North, 3) Mandela South, 4)
Northgate, 5) Miller, and 6) Oak Street. Like the RV Safe Parking sites, day-to-day operations at each site
are managed by different nonprofit organizations contracted by the City to provide site maintenance,
housing navigation services, and site security. Residents have access to support services provided by the
contracted nonprofit organizations. Community Cabins are available to adults over the age of 18 and are
not intended to be a long-term housing solution, but rather a stepping stone to help residents gather
the resources needed to secure permanent housing. Currently, the Community Cabin program has a
capacity to house 232 individuals at any given time.
Exhibit 3 below summarizes the City’s crisis response bed capacity, which provides temporary shelter or
lodging for those experiencing homelessness.

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Exhibit 3: Summary of crisis response bed options and capacity
Crisis Response Bed Accommodates
Name Number of Beds
Options Families6
Families in Transition 28 X
Matilda Cleveland 43 X
Transitional Housing Oakland Homeless Youth
22
Housing Collaborative
Holland 85
Henry Robinson 137
Crossroads Shelter 142* X
Family Matters 62 X
Shelters St. Vincent de Paul 100
Building Futures with
Women and Children 20 X
Shelters
Operation HomeBase Operation HomeBase 128
High Street 90
RV Safe Parking 71st Avenue 92
Beach Street 34
Lake Merritt 40
Mandela North 38
Community Cabins Mandela South 38
Northgate 40
Miller 38
Oak Street 38

Total Number of Beds 1,215


* This includes 10 beds only available in the winter

As Exhibit 3 above shows, for crisis response housing options, the City has a total of 1,215 beds
available.

6
The number of available beds for housing options accommodating families are based on the average size of
homeless families, which is 3.1 family members. Additionally, the number of available beds for RV sites are based
on 2 people per RV.

15
Long-term/permanent housing options
Rapid re-housing
The City and its contractors oversee three rapid re-housing options: 1) North County Family, 2) North
County Youth, and 3) St. Mary’s. These options provide move-in assistance, short-term rental subsidies,
and connection to support services to quickly transition homeless households to a permanent housing
solution. Currently, these three sites provide a total of 169 beds.

Project Homekey Initiative


Project Homekey is a statewide grant initiative, where local jurisdictions and their development partners
acquire and rehabilitate a variety of housing types, including (but not limited to) hotels, motels, vacant
apartment buildings, and residential care facilities to serve people experiencing and/or at risk of
experiencing homelessness or who are also at risk of serious illness from COVID.
As part of its Project Homekey Initiative, the State of California awarded the City of Oakland $21.3
million for three housing projects: 1) Clifton Hall, 2) Inn at Temescal, and 3) scattered sites throughout
the City. These three projects provide a total of 171 units for people experiencing or at risk-of
homelessness. Clifton Hall, a dormitory building previously owned by the California College of the Arts,
has 61 units and is located in the Rockridge neighborhood. The Inn at Temescal is an existing hotel
located in the Temescal neighborhood and has 21 units for veterans experiencing homelessness and at
severe risk of contracting COVID. The City, in partnership with the Bay Area Community Services (BACS),
acquired funds through Project Homekey to provide 89 units of housing in locations scattered
throughout Oakland.

Long-term re-housing services


The two providers, Abode Services and First Place for Youth, are social service and housing providers
that aim to re-house people in need. Currently, in Oakland these providers have 125 units for adults and
youth aged 18 to 24, including families. Beginning in FY 2020-21, the providers may be able to serve up
to an additional 40 families.

Exhibit 4 below summarizes the City’s long-term/permanent housing options for those experiencing
homelessness. These include rapid re-housing, Project Home Key, and long-term re-housing services.

16
Exhibit 4: Summary of long-term/permanent housing options
Long-term/Permanent Number of Number of Accommodates
Name
Housing Option Beds Units7 Families8

North County Family Rapid


118 X
Re-Housing
Rapid Re-Housing North County Youth Rapid
40
Re-Housing
St. Mary’s Rapid Re-Housing 11
Clifton Hall Dorm 61
Project Homekey Temescal Inn 21
Scattered sites 89
Long-Term Re-Housing Adobe 100 X
Services First Place for Youth 25 X
Total Number of Beds and
169 296
Units

Between rapid-rehousing, Project Homekey, and long-term subsidies and services, the City has a total of
169 beds and an additional 296 units available.

The City established an Encampment Management Team to coordinate the City’s


response to the increase in encampments
What is an encampment?
Cities, suburban communities, and rural areas across the United States have seen, in recent years, a rise
in the number of people experiencing unsheltered homelessness and choosing to live together. The
term encampment is widely used to describe these groups, but other terms include tent cities, homeless
settlements, and homeless camps. Federal, state, and local governments, including Oakland, do not
have a single definition of what constitutes an encampment. This issue will be discussed further in
Section 4.

The term encampment has connotations of both impermanence and continuity. People are staying in
temporary structures or enclosed places that are not intended for long-term continuous occupancy.
Inhabitants may be a core group of people who are known to one another and who move together to
different locations when necessary, or they may be a changing group of people who cycle in and out of a
single location. The physical structures that make up encampments can take many forms, including tents
on pallets and shanties, or lean-to shacks built with scavenged materials. Structures may be simple or
complex multi-room compounds. People experiencing homelessness in encampments may also stay in

7
HUD defines a unit as a house, apartment, group of rooms, or single room occupied, or intended as occupancy, as
separate living quarters.
8
As noted in footnote 6, the number of available beds for housing options accommodating families are based on
the average size of homeless families, which is 3.1 family members.

17
groups of cars or vans or in man-made tunnels and naturally occurring caves. According to a HUD report,
several related factors seem to influence whether people experiencing homelessness prefer to stay in
encampments, instead of shelters or other unsheltered locations. These factors include: 1) shortcomings
in the shelter system, 2) a sense of safety and community within encampments, and 3) a desire for
autonomy and privacy.

Specific shortcomings in the shelter system contribute to increased numbers of people congregating in
encampments such as

• an insufficient supply of shelter beds to meet the demand,


• restrictions in shelters that would result in separation from a partner, family member, or pet,
• shelter entry/exit times and locations that are inconvenient or incompatible with people’s daily
routines,
• concerns about the security of personal belongings and difficulty moving belongings in and out
of shelters daily,
• concerns about personal safety and exposure to germs and disease within shelters,
• specific barriers to entry, such as sobriety requirements and entry fees, and
• general perceptions of shelters as “inhospitable,” “alienating,” “demeaning,” and offering little
or no support or case management to find permanent housing.

Oakland, like other jurisdictions, experienced a significant increase in the number of encampments. The
number of encampments and the number of residents occupying encampments changes frequently and
is difficult to quantify. The Just Cities October 2018 Report9 identified 329 encampments in the City of
Oakland. In comparison, the City’s May 2019 master list of encampments identified 87 specific
encampments and the City’s master list of encampments in October 2020 included 140 encampments.

The City established a multi-department team in 2017


Like other cities, the City of Oakland established a multi-departmental team to coordinate its response
to the numerous encampments throughout the City. The City’s Encampment Management Team (EMT)
was created in late spring of 2017. The goal of the team is to address issues arising from the increase in
encampments and coordinate the City’s response to managing encampments. The EMT was initially
comprised of staff from the following departments and outside agencies: City Administrator’s Office,
Public Works, Human Services, Transportation, Police, Fire, Parks, Recreation and Youth Development,
Alameda County Vector Control, and the Mayor’s Office. On occasion, representatives from Bay Area
Rapid Transit (BART), Caltrans, Alameda County’s Homeless Response Team, and other agencies and City
departments also participate.

Exhibit 5 below outlines City departments’ and offices’ encampment-related responsibilities and
services. Information on the estimated costs for each of the departments and offices incurred on

9
Led by The Village, the East Oakland Collective, the Dellums Institute for Social Justice/Just Cities, the Goldman School of
Public Policy’s Rawan Elhalaby and Dr. Dan Lindheim, and the Housing and Dignity Project worked for almost a year to develop
a community-based plan to house all of Oakland's unhoused residents. The report, Housing Oakland's Unhoused, can be found
here.

18
encampment activities is provided in Section 3 and in the Appendix, which provides detailed cost
information, descriptions of each of the department’s and office’s responsibilities on encampment
activities, and the methodology used to estimate the cost incurred.

Exhibit 5: Departments’ and offices’ roles related to encampment activities


Departments and Offices Encampment-Related Activities
Human Services • Attends EMT meetings
Department (Human • Manages contracts for street outreach, including advance
Services) notification process of encampment interventions
• Provides supplemental outreach at encampments
• Manages contracts for health and hygiene interventions such as
portable toilets, handwashing stations, water stations, and mobile
showers at encampments
• Provides direct and on-going outreach specifically to support
encampments in managing hygiene interventions
• Coordinates with the County on public health issues such as COVID
impacts on encampment residents
• Attends EMT meetings
• Performs cleaning and clearing operations associated with various
Oakland Public Works
encampment interventions to protect the public right of way,
(Public Works) remove debris, and store materials if needed
• Performs garbage services at encampments
• Manages hazardous waste removal contract
Oakland Police • Attends EMT meetings
Department (Police • Participates in all interventions to create a safe working zone for City
Department) staff
• Dispatches and responds to emergency calls at encampments
• Traffic control
• Tagging and towing abandoned vehicles
Oakland Fire • Attends EMT meetings
Department (Fire • Performs inspections for fire hazards at encampments
Department) • Provides education on fire prevention
• Provides staff during some interventions
• Manages hazardous waste removal contract
• Responds to fires at encampments
• Responds to calls for medical emergencies at encampments
Department of • Attends EMT meetings
Transportation • Assesses and repairs electrical issues that occur at encampments
(Transportation) such as illegal wire splices and wire thefts and resulting impairment
of traffic signals and street lighting
Parks, Recreation and • Attends EMT meetings
Youth Development • Identifies and reports encampment-related issues at parks

19
Departments and Offices Encampment-Related Activities
City Attorney’s Office • Attends EMT meetings
• Advises all departments on matters related to homeless
encampments, policies, services, and interventions
• Defends City in lawsuits challenging encampment policies and
practices
• Represents City in state regulatory enforcement actions and
interagency disputes (CalTrans/BART)
• Advises on grant applications for state and federal funding
• Drafts legislation, including Planning Code Amendments to authorize
emergency shelters and RV parking; resolutions approving leases,
grants, and appropriations
• Reviews grants and Professional Services Agreements with homeless
service providers
• Negotiates and drafts contracts for the purchase, sale, and lease of
real property for shelter operations
• Advises Commission on Homelessness and City Council
• Drafts legal opinions
City Administrator • Sets agenda and leads EMT meetings
• Coordinates the City’s cross-departmental and inter-agency
homelessness response
Mayor’s Office • Attends EMT meetings
• Participates in other key local, regional, and statewide efforts
• Participates in policy discussions related to encampment activities
• Assists in building public-private partnerships to fund and evaluate
efficacy of innovative homelessness interventions

The City established the Commission on Homelessness


The Commission on Homelessness (Commission), a citizen oversight body, was established in 2018 and
seated in November 2020. This Commission oversees the revenue collected from the 2018 Measure W
vacant parcel tax and the 2020 Measure Q parcel tax received by the City for homeless services.
Measure W raises revenue for 1) homeless services, 2) preserves existing funding, 3) provides new
funding for new affordable housing options, and 4) illegal dumping remediation. Measure Q provides
funding for 1) the maintenance and improvement of City parks, landscape maintenance, and
recreational facilities and services, 2) homeless services, and 3) the maintenance and cleaning of
stormwater trash collection systems and reducing trash and litter in our parks, creeks, and waterways.

In addition, the Commission will make recommendations to the City Council for strategies to remedy
homelessness, make budget recommendations on homelessness priorities to the Mayor and the City
Council each biennial budget cycle, and review and respond annually to the City’s Encampment
Management Policy and the PATH framework. They will also hear reports on the available housing,
programs, and services for persons experiencing homelessness in the City including, but not limited to,
street outreach, homeless shelters, transitional housing, housing exits, and permanent supportive

20
housing as needed. The Commission is staffed by the Homeless Administrator and will meet at least four
times a year. City Council appointed the Commissioners in November 2020 and their first meeting took
place the following month.

21
Summary
Encampments in Oakland have grown significantly, creating health and safety issues for the City’s
housed and unhoused residents. Encampments have also significantly impacted City staff, City services,
businesses, and the community. In fiscal years 2018-19 and 2019-20, the City undertook approximately
500 closures, re-closures, and cleanings to manage the impacts of encampments. Additionally, the City
provided nearly 1,600 garbage services and other hygiene services such as installing and maintaining
showers and portable toilets. The EMT and the City were overwhelmed by the undertaking of closing
and cleaning encampments because the City was not adequately prepared to undertake such a massive
project. Specifically, the City lacked an effective strategy for dealing with the growth in encampments
and did not provide sufficient policy direction or adequate funding at the onset of this crisis, and the
EMT lacked sufficient resources, including a budget. The need to establish management systems to
address these shortcomings is detailed in Section 4 of this report. We also identified several other areas
for the City to enhance its intervention activities. These areas include the need for more complete data
on encampment activities, increased outreach, improved notification and bag-and-tag processes, and
the need for a clear and comprehensive policy on transporting encampment residents, in the event of a
closure.

Encampments are unhealthy for the unsheltered and have significantly


impacted City staff, City services, businesses, and the community
As noted in the introduction, the number of encampments in Oakland has grown significantly over the
last several years. The encampments have had significant impacts on the residents of encampments,
City staff, City services, businesses, and the community.

Encampments are unhealthy for its residents


In a 2018 report on adequate housing as a component of the right to an adequate standard of living, the
United Nations General Assembly described treatment of encampments in Oakland and San Francisco as
“cruel and inhumane.” It reported that by discouraging informal encampments in the City, residents
were denied access to water, sanitation, and health services.

22
The unsheltered have endured significant impacts due to living in encampments. Moreover, many of the
unsheltered are already more vulnerable to health and safety risks. These impacts are described below.

• Unsanitary conditions - Encampments lack clean water, accumulate large amounts of garbage,
needles, human feces, rodents, and other vermin. Additionally, poor hygiene at encampments
contribute to dental, skin, and other health problems, as well as diseases and illnesses. For
example, in 2017, former Governor Brown declared a State of Emergency when a Hepatitis A
outbreak in San Diego killed 20 homeless individuals and left hundreds sick. The City responded
to the Hepatitis A outbreak in Southern California by increasing hygiene services, such as
providing and keeping portable toilets clean, to avoid a similar outbreak in Oakland.

• Dangerous living conditions - Crimes including murders, sex trafficking, and drug use have
become a significant problem in encampments. The City began tracking murders in
encampments in 2020, and in calendar year 2020, 19 murders occurred at encampments, which
represents 18 percent of all Oakland murders in 2020. Sex trafficking and forced labor is another
significant problem at encampments. According to the National Alliance to End Homelessness,
“Human trafficking exploits a person through force, fraud, or coercion for forced labor or
commercial sex. Traffickers prey on the vulnerabilities of individuals in poverty, experiencing
homelessness, or who are part of marginalized populations.” People are more susceptible to
engaging in dangerous employment when they lack housing. It should be noted that individuals
from outside of the unsheltered communities also contributed to the violence and illegal
activities in and around the encampments.

• Fires - Fires are common and pose


significant safety hazards.
Encampment residents turn to
wood stoves and camp fires for
heat and cooking. These fires have
the potential to become out of
control and burn down camp
structures and injure people, as
shown by the photo on the right.
Larger fires can spread to more
populated areas and damage
buildings and infrastructure, as
demonstrated by the recent loss of the Vietnamese American Community Center. In fiscal years
2018-19 and 2019-20, the Fire Department responded to 988 fire emergencies at encampments.
In 2019, several homeless individuals moved into a boarded up vacant building that was
previously damaged by a fire and started another fire. In 2020, an encampment resident died
from a fire at an encampment.

23
• Vulnerable to health risks - The homeless face barriers to accessing healthcare—leading to
further health challenges. Strong evidence links homelessness with health issues such as mental
illness, substance abuse, poor nutrition, skin conditions, diabetes, and higher exposure to
weather-related incidents. Studies have shown high mortality rates among homeless people in
general. For example, a 2019 report by the National Health Care for the Homeless Council stated
that people who are homeless have higher rates of illness and die on average 12 years sooner
than the general U.S. population. The COVID pandemic has only exacerbated the health risks to
the homeless. People who are experiencing homelessness often have compromised immune
systems and may be at elevated risk for viruses like COVID. They may be also at a higher risk of
developing complications due to COVID, as they are more likely to have underlying chronic
conditions compared to the general population.

Working at encampments has significantly impacted City staff


Not only do the conditions and risks at encampments affect encampment residents, but they also affect
the work and well-being of City staff. City staff have encountered dangerous, stressful, and intense
working environments within the encampments, leading to injuries and workers’ compensation claims.
Encampment activities have led to increased demand on public safety responses and legal actions
against the City. Finally, City staff have had to forego their primary duties to work on encampment
activities. The impacts of encampments on City staff are outlined below.

• Traumatic experiences - City staff reported trauma and obtained counseling services to help
cope with the intense working environments at encampments. Verbal and physical
confrontations are common when carrying out their duties.

• Dangerous working conditions - City staff were threatened on multiple occasions with weapons,
such as guns, bottles, axes, and aggressive dogs when working at encampments. Further, staff
have stepped on needles, handled human waste, and were exposed to COVID.

• Other safety risks - The Fire Department also reported that firefighters have been exposed to
serious safety risks while fighting
fires along railroad lines, where
encampments are often located.
The Fire Department has needed
to contact the railroad companies
to close the railroad lines during
these fires. Delays in the railroad
companies’ responses to these
requests have caused dangerously
close calls for firefighters with
approaching trains. Even though
no injuries to firefighters have occurred, the Fire Department has lost firehoses, nozzles, and

24
other equipment during these incidents. The above photo shows an encampment fire on East
12th Street, located along the BART tracks.

Because of these traumatic and dangerous working conditions, City staff have filed multiple workers’
compensation claims due to mental stress or physical injury. In FY 2018-19, City staff filed four workers’
compensation claims and another 22 claims in FY 2019-20. These claims were related to City staff
working with the homeless population. For example, in 2019, a City employee filed a workers’
compensation claim and received approximately $19,000 to compensate the employee for mental stress
while working with encampment residents, picking up human waste and needles, and experiencing
harassment from City management. Most of the claims in 2020 were related to COVID exposures.

Encampments have impacted City services


Encampments have also impacted City services as described below.

• Increased demand for public safety responses - In fiscal years 2018-19 and 2019-20, the Police
Department responded to 1,459 calls at encampments. As noted above, homicides at
encampments represented 18 percent of all homicides occurring citywide in 2020. Additionally,
the Fire Department responded to 988 fire emergencies at encampments in the same period. In
some instances, the fires were significant and required responses with multiple fire engines and
trucks. In some instances, the Fire Department has been challenged to extinguish fires due to
the lack of fire hydrants near encampment locations. As a result, the Fire Department has
needed additional engines to provide water to extinguish the fires.

• Increased demand for service requests - In calendar years 2018 and 2019, the 311 Call Center
received a total of 1,152 complaints about encampments.

• Legal actions filed against the City - In 2018, the Ninth Circuit Court of Appeals issued a
landmark ruling in Martin v. Boise, finding that Boise’s enforcement of a “no camping”
ordinance against homeless individuals violated the Eighth Amendment’s prohibition against
cruel and unusual punishment. Since the Martin ruling, seven lawsuits have been filed against
the City challenging its homeless encampment management policies, practices, and procedures
as unconstitutional. Each of the seven lawsuits alleges, among other claims, that the City has
violated the constitutional civil rights of homeless individuals in violation of the Fourth, Eighth,
and Fourteenth Amendments.10

In addition, in October 2020, the San Francisco Bay Conservation and Development Commission (BCDC)
issued a cease and desist order demanding that the City remove all encampments at Union Point Park

10
The Fourth Amendment prohibits unreasonable searches and seizures and requires a search warrant supported
by probable cause. The Eighth Amendment is a prohibition of cruel and unusual punishment that directly forbids
communities from criminalizing certain aspects of homelessness. The Fourteenth Amendment guarantees all
citizens equal protection under the laws.

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due to deteriorating conditions at several park sites located along the shoreline as a result of destructive
encampment activities, or face penalties in the amount up to $6,000 per day.

Homeless encampments have had significant impacts on Oakland businesses


As described below, homeless encampments have had significant impact on businesses in Oakland.

• Impacts on clients/customers and staff - Kaiser Permanente (Kaiser) reported their patients, as
well as staff, were affected by the nearby encampment at Mosswood Park. For example, the
smoke from open fires at the encampment permeated the hospital buildings, affecting patients
and staff. This was especially concerning as vulnerable patients sought medical attention in
these buildings. In fact, Kaiser Pediatrics is directly adjacent to the encampment. In a
collaborative effort with Operation Dignity and the City of Oakland, Kaiser donated $1 million to
provide housing and support services for 50 people living at the encampment and relocated
encampment residents to nearby hotels and other supportive housing.

A large encampment located at the Home Depot store near the Fruitvale neighborhood also
experienced significant impacts to its customers and employees. During a cleaning of this
encampment in November 2019, the City removed more than 250 tons (75 truckloads) of debris
and garbage. In another incident, a man living in his RV brandished a pistol threatening two
employees. In response to this and other incidents, Home Depot hired additional security and
lobbied City officials to clean up and relocate the encampment. The encampment was closed in
January 2020 and some residents were relocated to a Safe RV site that opened across the street.

The Oakland Marina tenants near Union Point Park are also impacted by encampments. Given
the break-ins of the bathroom facilities, which tenants use to access showers, and threats of
physical violence, it is difficult to rent boat slips at this marina.

Other businesses have reported stolen and abandoned vehicles left on the street for several
months. In some cases, there are individuals residing in the vehicles. Further, this takes up
needed parking spaces and blocks entrances.

• Damage to property - Business have reported being broken into. For example, at an Oakland
marina, private bathrooms have been broken into, resulting in significant repair costs.

• Safety concerns - This includes harassment, blocked entryways, drug use, discarded hypodermic
needles, prostitution, and more.

Encampments have significantly impacted the community


Encampments have also had significant impacts on the community. Some of these impacts include
destroying or compromising City assets, environmental damage, and affecting public right-of-way and
traffic, resulting in significant repair costs.

• Destroyed or compromised City parks - Residents in an encampment near Lake Merritt caused
damage to the restored tidal marsh along the Lake Merritt channel in Peralta Park. This park

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renovation was part of the 10th Street Lake Merritt Channel widening project completed in 2018,
at a cost of $21 million. State and federal permits required the restoration as part of the overall
project and required the City to maintain the parks in compliance with the permit criteria. The
park now has extensive damage and the water quality of the channel has been compromised
due to an encampment near the park. These damages include damaged park vegetation, broken
irrigation lines, and ruined fencing. Encampment residents also urinated and defecated in the
marsh. To repair the damage, the City will need to fence off the area, replace the soil, put in
trees and plants, and repair the irrigation system. The City projects these repairs will cost an
estimated $550,000.

Another park, Union Point Park, is one of the most heavily impacted parks by homeless
encampments. The San Francisco Bay Conservation and Development Commission (BCDC) has
received numerous complaints from residents about conditions at the park that rendered the
park unusable. In November 2019, BCDC staff observed numerous tents, vehicles, and other
evidence of people living in the area and throughout the park. BCDC staff observed substantial
amounts of dead or overgrown vegetation, numerous piles of debris, substantial graffiti, and
poorly maintained restrooms, barbecues, and benches. BCDC staff also reported that numerous
benches had been burned to the ground, and other instances of poor maintenance.
Furthermore, BCDC staff found numerous public access amenities were missing, including a
bicycle rack, public and Bay Trail signs, and several picnic tables. Staff were unable to access
missing amenities and improvements, due to the presence of encampments, which prevented
access to many portions of the park. Finally, BCDC staff reported that the park was unusable by
the public for safe walking, picnicking, or other uses. The City performed a preliminary
assessment of damage and estimated the repair cost for the lighting alone to be $500,000. This
does not include additional costs to repair bathrooms, landscaping, benches, and other
damaged amenities. Due to the extent of the damage, the scope of the repairs exceeds existing
contract capacities and vendor capabilities. These repairs will need to be addressed through the
Capital Improvement Program, with corresponding procurement timelines and City Council
approval of capital expenditures.

• Illegal dumping - Illegal dumping in and around encampments poses significant health and
safety hazards to the encampment residents and the community. Illegal dumping refers to the
willful, intentional, or negligent depositing, dropping, dumping, placing or throwing of any waste
matter onto public property that is not expressly designated for disposal of waste matter. The
City has received multiple complaints from residents, businesses, and City staff related to
excessive garbage and litter associated with encampments. The complaints cited inaccessible
roads and parks, overflowing garbage cans and garbage in waterways, needles on the ground,
vermin, and more. One complaint of the illegal dumping of debris and appliances noted a person
was “shooting up” drugs, while rats crawled around his feet. Additionally, the City re-allocated
its Keep Oakland Clean and Beautiful (KOCB) Public Works’ staff and resources, which are
normally dedicated to removing illegal dumping throughout the city, to spend 80 percent of
their time performing interventions at encampments. Below are examples of illegal dumping in
two City parks—Union Point Park and Mosswood Park.

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• Water quality - Encampments have caused environmental issues for the community. For
instance, some encampments or RV’s parked on City streets disposed of hazardous and human
waste into the storm drain system, which flows to San Francisco Bay, potentially contaminating
the Bay. Moreover, the Regional Water Quality Board, which regulates discharges to the Bay, is
including a new provision in its latest administrative draft of Oakland’s discharge permit to
address such problems associated with homelessness. Additionally, as mentioned above, human
waste was also found in the Lake Merritt channel, compromising water quality.

• Public rights-of-way and traffic signals have been affected - Encampments that spill out onto
sidewalks and streets block public rights of way and violate the Americans with Disabilities Act.
The blockages hinder school walking routes and neighborhood access to grocery stores and
other commercial areas. The encampments may also
hinder the ability of children to walk to school safely. For
instance, encampments on 29th and 30th Streets in West
Oakland were blocking both sides of the sidewalk under
the freeway in a residential neighborhood.

Encampment residents have also illegally tapped into the


Pacific Gas and Electric Company (PG&E) power
connections through the City’s utility boxes, electrical
cabinets, and/or street light and traffic signal poles. This
illegal tapping results in safety issues for drivers,
pedestrians, and others by turning off traffic signals and
street lighting. In addition, the City could risk liability if
such events cause vehicular accidents and increased street crime due to the lack of adequate
street lighting. The picture to the right is an example of electrical damage caused by
encampment residents.

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• Other public infrastructure has been damaged or compromised - Encampment residents have
also damaged other infrastructure. For example, in January 2019 and again in August 2020,
encampment fires occurred in the same area under the BART tracks in East Oakland. Train
service was halted in both directions due to these fires as transit officials surveyed the tracks for
damage. Thick smoke from the 2019 fire caused visibility issues and a track support pillar was
damaged. In addition, the Fire Department reported that one individual living under the BART
tracks had one tent, around 80 bikes, tarps, lumber, and rubber tires at their encampment. The
Fire Department reported that if the rubber tires had caught on fire, the BART tracks would have
been destroyed.

Several encampment residents have resorted to opening fire hydrants, as a result of not having
access to a clean water supply. Without specialized tools to open the hydrants, the fasteners on
the hydrants can become stripped. Stripping the fasteners can make the hydrants difficult or
impossible for firefighters to operate when needed. The improper use of hydrants can
potentially cause other issues such as backflow contamination in the water system. In response,
the East Bay Municipal Utility District has placed security locks on some hydrants, but some of
the security locks have been removed. Additionally, nearby water lines have been tapped.

The Encampment Management Team was established to coordinate the City’s


response to the growing number of encampments
The EMT was created as an ad hoc multi-departmental team to coordinate the City’s response to the
growing number of encampments throughout the City. Accordingly, the City Administrator assigned an
Assistant to the City Administrator to lead the team in developing and implementing the City’s
Encampment Policy. In 2020, the City Administrator appointed a Homeless Administrator to lead the
Encampment Management Team. As noted earlier, the team included staff from the City Administrator’s
Office, Public Works, Human Services, the Police Department, the Fire Department, Transportation,
Parks, Recreation and Youth Development, Mayor’s Office, and City Attorney’s Office on an as needed
basis.

In 2017, the EMT developed the Encampment Management Policy (Policy) as one part of the City’s
strategy to address homelessness in Oakland. The Policy addressed the physical management of
homeless encampments and established criteria for determining the various types of interventions to
undertake at encampments. The criteria determining the level of intervention includes: health, safety,
location, and size. Within each of the criteria are several factors that the EMT weighs in its decision-
making process. The interventions include

• Closure – removing the encampment,


• Enforcement of closure – when homeless individuals return to a previously closed encampment,
the City performs an intervention to prevent re-encampment. The 2017 Policy refers to this
intervention as an enforcement of closure; however, this report will use the term “re-closure” to
refer to this type of intervention,
• Cleaning – temporarily moving an encampment so that health and hygiene issues can be
addressed and allowing the encampment to return, and

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• Hygiene and garbage services – providing portable toilets, hand-washing stations, regular
garbage service, and/or traffic barriers to protect the health and safety of those in an
encampment.

Prior to COVID, the EMT met every other week to make decisions related to encampment interventions.
The EMT identified encampments for interventions primarily based on complaints received through the
Oakland Call Center (Oak 311) and from complaints or observations from City staff.

The City conducted nearly 2,100 interventions in FY 2018-19 and 2019-20


In fiscal years 2018-19 and 2019-20, the City conducted nearly 2,100 interventions at encampments.
These interventions included a total of approximately 500 closures, re-closures, and cleanings.
Additionally, the City provided nearly 1,600 garbage services and other hygiene services such as
installing and maintaining showers and portable toilets. The totals for FY 2019-20 are only for the first
eight months of the fiscal year because the City suspended most closures, re-closures, and cleanings
interventions at the beginning of the COVID pandemic as recommended by the federal Center for
Disease Control and Prevention, state, and local guidelines.

Exhibit 6 below breaks down the number of interventions by type for fiscal years 2018-19 and 2019-20.
Each intervention type such as a closure, re-closure, cleaning, and hygiene/garbage services counts as
one intervention per encampment. For example, some encampments receive weekly garbage services
and each pick-up is counted as one intervention.

Exhibit 6: Encampment interventions by type in fiscal years 2018-19 and 2019-20


Encampment Encampment
Type of Intervention Interventions Interventions Total Interventions
FY 2018-19 FY 2019-20
(reflects 8 months)

Closure 38 20 58

Re-Closure 56 67 123

Cleaning 224 74 298


Subtotal of Closures, Re-
318 161 479
Closures, and Cleanings
Hygiene and Garbage Services* 797 802 1,599

Total Number of Encampment


1,115 963 2,088
Interventions
Source: Chart created by auditors based on data provided by Oakland Public Works
*Not all encampments that receive portable toilets and hand-washing stations receive garbage service.

As Exhibit 6 above shows, the City reduced the number of closures and cleanings in FY 2019-20
compared to the previous fiscal year and increased the number of re-closures. On the other hand, the

30
City provided more hygiene and garbage services in the first eight months of FY 2019-20 than in the
prior 12 months.

In March 2020, the City suspended its encampment policy and enacted a temporary policy in response
to the COVID pandemic, which accounts for some of the changes in the number of interventions. The
City stopped closing encampments, significantly reduced the number of cleanings, and increased the
number of encampments receiving hygiene and garbage services. The number of encampment sites
receiving hygiene interventions was increased from 20 to 40.

The City’s temporary policy included


• immediate suspension of the Encampment Management Policy and the Standard Operating
Procedure and the implementation of a Temporary Encampment Management Policy effective
March 2020,
• suspension of ordinary closures and ordinary cleaning interventions,
• suspension of towing, including oversized vehicles, and
• immediate intensive outreach to identify vulnerable unsheltered residents to relocate them to
hotels and trailers.

The City’s approach was consistent with relevant federal, state, and local legal and policy mandates or
guidelines issued in response to COVID.

The challenges of addressing the growing number of encampments


The challenges of addressing the growing number of encampments and the City’s efforts to address the
conditions at encampments overwhelmed the EMT and the City. The following factors severely
hampered the City’s efforts to address the conditions at encampments throughout the City:

• The City lacks sufficient housing alternatives to house the unsheltered population.
• Offers of shelter beds are often declined because the shelters may not meet personal needs,
such as restrictions for allowing pets.
• Closed encampments are often re-populated because many residents do not want to be
displaced or relocated.
• Encampment residents complained, and even threatened City staff, about being displaced from
encampments.
• Legal actions were filed against the City to stop its intervention efforts. As noted earlier, the City
had seven lawsuits filed against it related to encampments and interventions.
• Encampment residents and their advocates protested at City Hall and at scheduled encampment
closures to stop the City’s intervention efforts.
• Residents and businesses complained about the growing number of encampments springing up
in their neighborhoods and business districts.
• City staff were traumatized and burned-out because of the intense environment in which they
worked.

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The City’s efforts were also hampered by the lack of adequate resources and planning to carry out this
massive undertaking. Specifically, we noted

• The City lacked an effective strategy for dealing with the growth in encampments.
• The City did not provide sufficient policy direction early on, including adequate funding.
• The EMT lacked sufficient resources to address the growing number of encampments and the
City did not budget for the City’s intervention activities.
• The EMT’s collective decision-making was hampered because it lacked clear authority to make
decisions on interventions. EMT members assigned to the team could not always attend the
meetings or did not have the authority to commit resources to planned interventions. For
instance, if department directors did not attend the meetings, they needed to be consulted at a
later date to commit their departments’ resources. Other members of the team, such as the
Police Department’s staff, did not have the authority to commit resources to conduct additional
same day interventions. As a result, scheduling of interventions was more difficult, and delays
were encountered.
• City staff were not adequately trained on crisis management and dealing with traumatized
encampment residents.

These management issues and other management systems needed to improve the City’s encampment
management activities are addressed in Section 4.

The City’s intervention efforts are constrained by recent legal decisions


The City’s encampment-related actions are constrained by the ruling in the 2018 Ninth Circuit Court of
Appeals case of Martin v. Boise. In Martin, the Court found that Boise’s enforcement of a “no camping”
ordinance against homeless individuals violated the Eighth Amendment’s prohibition against cruel and
unusual punishment. Since that ruling, seven lawsuits have been filed against the City challenging its
homeless encampment management policies, practices, and procedures. Each of the seven lawsuits
alleges, among other claims, that the City violated the constitutional civil rights of homeless individuals
in violation of the Fourth, Eighth, and Fourteenth Amendments.

The Fourth and Fourteenth Amendment claims allege that the City improperly seized and destroyed
property, and that other due process violations occurred during encampment cleaning and closure
operations. However, the property collection and storage procedures in the City’s Standard Operating
Procedure (SOP) have been reviewed in the course of the litigation and, based on the preliminary
proceedings, the SOP does not violate the Fourth or Fourteenth Amendments. The SOP requires legally
sufficient notice before property is collected and allows property to be retrieved after storage.

The Eighth Amendment claims allege that the City is “criminalizing” the “status” of being homeless. In
Martin, the Ninth Circuit explained that, “as long as there is no option of sleeping indoors, the
government cannot criminalize indigent, homeless people for sleeping outdoors, on public property, on
the false premise they had a choice in the matter.” Martin prohibits punishing or criminalizing an
involuntary act or condition if it is an “unavoidable consequence” of the status of being homeless.

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Significantly, however, the ruling in Martin is narrow. The decision distinguishes individuals who have
access to adequate shelter and recognizes a city’s ability to regulate public conduct and that which takes
place on its property, stating:

Naturally our holding does not cover individuals who do have access to adequate shelter,
whether because they have the means to pay for it or because it is realistically available
to them for free, but who choose not to use it. Nor do we suggest that a jurisdiction with
insufficient shelter can never criminalize the act of sleeping outside at particular times or
in particular locations might well be constitutionally permissible. So, too, might an
ordinance barring the obstruction of public rights of way or the erection of certain
structures.

The City does not issue citations or arrest individuals for violating local or state laws aimed at prohibiting
sitting, lying, or sleeping in public. Instead, the Police Department is tasked with ensuring and
maintaining a safe work zone for staff from Public Works who perform cleaning and clearing operations
at encampments.

The City may have the authority to determine the “time and place” of certain activities or the use of its
public property. Nonetheless, it is legally obligated to follow established due process legal precedent,
the ruling in Martin, as well as its own homeless encampment management policies, procedures, and
legislation.

Opportunities exist to enhance the City’s encampment interventions


We also identified other opportunities to enhance the City’s intervention efforts. These enhancements
include

• improving the information on the schedule of interventions,


• documenting the criteria for determining which encampments receive garbage and hygiene
services,
• enhancing outreach efforts and re-assessing the notification process for interventions,
improving the bag-and-tag process, and
• developing a clear policy on transportation provided to residents at closures.

Encampment Management schedule of interventions needs improvement


The Encampment Management schedule, the City’s main record of interventions, tracks encampment
interventions including the location of encampments, date(s) of intervention, number of crews used,
and the types and conditions of encampments. However, this schedule does not adequately capture the
types of interventions, the rationale for the intervention, the date of the intervention, the number of
staff needed for the intervention, and the number of hours needed to complete the intervention. This
information should provide a more accurate and comprehensive record of the City’s encampment
intervention activities. It could also provide a basis for planning future interventions.

The City’s information on the schedule was incomplete. For instance, the schedule did not include the
following information:

33
• Not all interventions were recorded on the schedule. The EMT schedule was missing days/weeks
of scheduled interventions that had occurred. This makes it difficult for the City to accurately
track the number and location of encampment interventions.
• The City did not adequately document the reason for applying an intervention at a specific
encampment. The policy requires encampment interventions consider safety, health, location,
and size when determining which intervention to apply, but the actual justifications for the
interventions were not recorded.
• The description of the type of intervention was not consistent. One column identifies the type of
intervention, but because there is no standard for inputting data, it showed numerous variations
of the same intervention. Having uniform naming conventions of interventions would improve
documentation on the number and types of interventions.
• The schedule did not reflect when an intervention was postponed or cancelled, nor did the
schedule accurately reflect when the intervention occurred. The schedule should indicate when
an intervention was scheduled and whether the intervention took place on that day.
• The number of staff and hours spent at an intervention were not documented. The resources
spent on interventions was not documented on the schedule.

The City needs to improve controls for data collection activities associated with encampment activities.
The EMT meets regularly to share information and coordinate activities, however, regular
communication did not necessarily translate to quality record-keeping as described in the section above.

Much of what is known about encampments takes the form of institutional knowledge, which could
present challenges when organizational changes such as staff turnover occur.
Establishing controls around collected data provides assurance that the data is comprehensive,
accurate, consistent, and ultimately reliable, so that the City can make data-driven decisions regarding
encampment management.

The City needs to develop formal criteria for determining which encampments receive
garbage and hygiene services
The EMT determines which encampments receive various services such as garbage services, portable
toilets, handwashing stations, and other hygiene services. The City currently provides garbage services
and hygiene services to approximately 40 encampments.

The City, however, does not provide these services to all encampments. Although the City increased
these services to encampments, the criteria on which encampments receive these services is not written
and the decisions reached are not documented. To ensure equitable service, the City should develop
written criteria to determine which encampments should receive these services and then document
which encampments receive these services based on these criteria.

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The City should enhance its outreach efforts and should reassess how it notifies
encampment residents of impending interventions
A critical piece of carrying out an encampment intervention is the outreach to homeless individuals prior
to the intervention. The City contracts with a nonprofit, Operation Dignity, to provide homeless
outreach services at encampments. Human Services staff provide supplemental outreach services as
needed. Outreach is a process designed to seek out and offer basic services to homeless individuals who
might otherwise be overlooked or underserved. Effective outreach requires building trust and rapport,
ensuring that people’s basic needs are met, and supporting them along pathways toward housing
stability.

Currently, outreach services include, but are not limited to, providing hygiene services to encampments,
notifying residents prior to interventions, offering alternative shelter, providing harm reduction
supplies,11 facilitating reunification with family and friends, and more. Due to COVID, the audit was
unable to make a comprehensive assessment of outreach services at encampments, but did identify the
following observations:

• In several instances, the City extensively documented outreach at specific encampment closures
such as identifying the number of encampment residents and the conditions at the
encampment. The City, however, did not consistently document this information. Collecting
data around the outreach provided, including the level of acceptance of services and alternative
shelter offered, allows the City to analyze this information and adapt outreach strategies if
needed.
• Encampment outreach is not sufficiently addressed in the 2017 or the 2020 EMT policy, other
than to address the outreach related to the notification process. Specific outreach strategies
should be established, and the results should be periodically reported to relevant stakeholders.
• The outreach strategy should include
▪ establishing specific outreach goals,
▪ defining and expanding roles and responsibilities for all stakeholders involved, including
City staff and contracted outreach service providers,
▪ ensuring adequate funding, and
▪ implementing monitoring and reporting protocols, to ensure internal and external
stakeholders can track the effectiveness of outreach strategies.
Prior to closures and cleaning interventions, the EMT policy requires the City to notify encampment
residents no less than 72 hours ahead of interventions. For closures, the City is also required to post
signage in multiple languages. Human Services manages the notification and outreach process through a
third-party contractor, Operation Dignity, that notifies encampment residents no less than 72 hours in
advance of closures and cleanings.

11
These include food, hygiene kits, and blankets.

35
Operation Dignity provides Human Services staff with
photos of the posted notifications to document the
notifications were posted (see example to the left). The
audit selected a random sample of 11 encampment
interventions to verify Operation Dignity posted the
proper notification no less than 72 hours in advance of the
intervention, as required by the City’s policy. City staff
provided documentation from Operation Dignity that the
notifications were posted for all 11 interventions tested.

Encampment residents, however, have voiced concerns


that notifications are not regularly posted or viewed
before an intervention, and some residents were
unprepared on the day of an intervention.

As the picture to the right indicates, the audit team


witnessed notifications ripped off and discarded,
potentially before encampment residents had seen them.
Further, Operation Dignity staff may conduct an encampment
visit at a time when few residents are present, and in these
cases, some unsheltered residents may first encounter
Operation Dignity staff on the day of an intervention.

These observations suggest that the notification process, even


when followed, is not effective because the City cannot provide
adequate assurance that encampment residents were properly
notified of impending interventions.

Based on a limited sample of interventions, it appears the City


complied with its notification process, however, the City should
re-assess this process. Requiring encampment residents to
relocate, even for a short period of time, can be very traumatic, especially for those residents with
special needs. Thus, the City should evaluate its method for notifying residents of pending interventions.
In doing so, the City should reassess whether there should be multiple in-person notifications that
include documenting contact with the residents. Such an approach, if implemented, should be evaluated
for its cost effectiveness, given increased in-person notifications and documentation will require more
staff resources.

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The bag-and-tag process could be improved
During encampment closures and re-closures, the City’s Standard Operating Procedure (SOP) requires
Public Works staff to dispose of items that are clearly garbage or unsafe for storage. All other personal
belongings left at a site are to be collected, labeled, and stored (a process called bag-and-tag) in the
Public Works warehouse for at least 90 days. Public Works staff are required to fill out an itemization
form detailing the belongings collected with the location, date, and time of collection. A ‘Notice of
Collected Property’ is posted at the site, which includes the Public Works Call Center phone number so
that the encampment resident can reclaim their property.

According to City staff, encampment residents are encouraged to keep their belongings with them. Thus,
the bag-and-tag process is not often used. When the process is used, however, the City’s procedures
were not strictly followed as the audit found the following discrepancies:

• Perishable items - The SOP states that Public Works staff should dispose of belongings that are
clearly garbage or are unsafe for storage, such as food or food wrappers, soiled items, or used
personal hygiene items. Auditors observed perishable items, including string cheese, being
stored.

• Controlled substances - The SOP states that all


medications and controlled substances will be
turned over to the Police Department.
However, auditors observed a container of
anti-psychotic medication being stored, as
shown to the right.

• Lack of labels/itemization - The SOP states that


Public Works staff will collect, bag, and label
personal belongings left at the site and itemize
belongings collected. The labeling should include the location, date, and time of collection on
the itemization form. Auditors observed that all items collected were not labeled as required. As
a result, it is difficult to ensure belongings are returned
to their owner.

• Unorganized storage - Auditors observed roughly 30


unlabeled bicycles (including parts and tires) stacked on
top of each other, as shown to the right. The
department would benefit from a system of
organization and documentation of items.

• 90-day storage - The SOP states that collected


belongings will be stored at a Public Works Department
facility for at least ninety (90) days. We observed a lack
of organization and labeling of items, suggesting that
following guidelines for storage time is likely difficult to

37
follow. Without an organizational structure, the City may also expose itself to additional risk
associated with the potential for items to be misplaced or stolen.

Other jurisdictions have articulated a similar need to improve the storage options of personal belongings
for unsheltered individuals. For instance, the City of Los Angeles recommends offering subsidized
transportation to storage facilities. While this option would certainly remove existing barriers that may
currently discourage encampment residents from utilizing storage options, Public Works currently stores
possessions in a single shipping container, unfit to accommodate many additional items. Los Angeles
also recommends increasing access to neighborhood-based storage facilities in close proximity to
encampments by operating on City-owned property or offering vouchers to private storage facilities and
establishing storage limits. A similar approach could allow the City of Oakland to reduce barriers to
encampment residents accessing their property.

The City needs to develop a clear, comprehensive policy for transportation assistance

The City should develop a clear, comprehensive policy for transportation assistance following a closure
or a re-closure. Currently, Operation Dignity is contracted to provide unsheltered individuals with
transportation assistance in the form of bus tickets, cab vouchers, agency vehicles with staff, and/or
companion public transportation, but only when the individual is being connected with benefits or
services with a designated destination prior to closure. Encampment residents, who have not been
offered shelter, denied shelter options, are waiting to enter Community Cabins or Safe RV sites, or want
to relocate to another encampment rely on volunteers unaffiliated with the City to help coordinate their
transportation. Occasionally, City staff offer stranded encampment residents transportation assistance
to shelter options or other locations. Informal transportation agreements between encampment
residents and City staff or volunteers demonstrate a gap in policy. The City should reassess its
contractual agreement with Operation Dignity or otherwise ensure that transportation needs are met
when City actions result in the displacement of encampment residents.

Conclusion
Encampments in Oakland have grown significantly creating health and safety issues for the City’s housed
and unhoused residents. Encampments have also significantly impacted City staff, City services,
businesses, and the community. In fiscal years 2018-19 and 2019-20, the City undertook nearly 2,100
interventions to manage the impacts of encampments. These interventions at encampments included
approximately 500 closures, re-closures, and cleanings, and approximately 1,600 garbage services, and
other hygiene services. The EMT and the City were overwhelmed by the undertaking of closing and
cleaning encampments because the City was not adequately prepared to undertake such a massive
project. Specifically, the City lacked an effective strategy for dealing with the growth in encampments
and did not provide sufficient policy direction or adequate funding at the onset of this crisis, and the
EMT did not have resources, including a budget. The need to establish management systems to address
these shortcomings is in Section 4 of this report. We also identified several other areas for the City to
address, in order to enhance its intervention activities. These areas include the need for more complete

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data on encampment activities, increased outreach, improved notification and bag-and-tag processes,
and a clear, comprehensive policy on transporting residents, in the event of a closure.

Recommendations
To enhance its encampment intervention activities, the City Administration should

1. Implement an organizational structure for the EMT that includes defined roles, responsibilities
and authority, including a clearly defined decision-making process.
2. Modify its encampment schedules to better document the types of interventions, the rationale
for the intervention, the date of the intervention, the number of staff needed for the
intervention, and the number of hours needed to complete the intervention.
3. Work with the EMT to develop a more user-friendly system for tracking encampment activities.
This system should include drop-down menus to provide uniform naming conventions, as well as
stronger controls to ensure that information on encampment activities are complete and
consistently documented.
4. Establish written criteria for determining which encampments should receive garbage services,
portable toilets, and other hygiene services, and document which encampments are to receive
these services based on these criteria.
5. Modify the Encampment Management Policy to address outreach strategies prior to
interventions. The outreach strategies should include
• establishing specific outreach goals,
• defining and expanding roles and responsibilities for all stakeholders involved, including
City staff and contracted service providers,
• ensuring adequate funding, and
• implementing monitoring and reporting protocols to ensure internal and external
stakeholders can track the effectiveness of outreach strategies.
6. Develop policies and procedures to document the City’s outreach efforts at encampments,
including the outreach provided, the acceptance of services, and the alternative shelter offered.
7. Evaluate other cities’ methods for informing encampment residents of impending interventions
so that encampment residents are adequately notified of scheduled interventions.
8. Take appropriate actions to ensure City staff comply with the Standard Operating Procedure for
the bag-and-tag process.
9. Evaluate other cities’ use of storage facilities to provide alternatives to the bag-and-tag process.
10. Develop a clear, comprehensive policy for transportation assistance following an encampment
closure or re-closure. The City contracts should align with any policy changes.

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Summary
In addition to providing interventions, the City also responds to emergency and service requests related
to encampments. The Police Department responds to 911 emergency calls for services at encampments
and the Fire Department responds to fire and medical emergencies at encampments. The 311 Call
Center receives and responds to service requests at encampments.

The Police Department’s response time to emergency calls at encampments averaged four to six hours
in fiscal years 2018-19 and 2019-20. The Police Department also needs more information to fully capture
all police emergencies at encampments. The Fire Department responded to fire emergency calls at
encampments in less than eight minutes in fiscal years 2018-19 and 2019-20. The Fire Department’s
response times to medical emergencies could not be calculated because the Fire Dispatch Center does
not distinguish these calls from other medical emergencies. The 311 Call Center’s average response time
to service requests was 22 days in 2018 and 39 days in 2019.

The Police Department’s response to 911 emergency calls at encampments were


not timely
The Police and Fire Communications Divisions are charged with handling police, fire, and medical-related
calls. The Communications Divisions answer the calls and dispatches them to either the Police
Department’s Patrol Divisions and/or the Fire Department.

Response time goals for police emergency calls


Calls for service that require a physical police response are categorized and dispatched by the 911 Call
Center as Priorities 1, 2, and 3. The priorities are described below.

• Priority 1 calls are the highest priority and include situations where life or property is in
imminent danger. These include crimes in progress such as robberies, rapes, assaults, or
burglaries. These calls also include violent disturbances, reports of individuals with guns, or
shots fired.

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• Priority 2 calls include situations that require an immediate response, with no immediate threat
to life or property. These include family disputes, disturbance of the peace, and suspicious
activities.
• Priority 3 calls include calls where there is no substantial threat to life or property, but a police
response is needed. These include reports of crimes where a significant amount of time has
elapsed since the occurrence of the crime. For example, someone comes home from work to
find their home had been broken into several hours earlier.

According to a 2010 Oakland Police Department report, a reasonable standard for a priority 1 call is for
no more than five minutes from the time the call is received at the 911 Call Center until a police officer
is on scene. The report also noted that Priority 2 calls should be responded to within 10 to 15 minutes
and Priority 3 calls should be responded to within 30 minutes.

To achieve these response times, the 2010 report stated that the Police Department would need at least
420 to 517 officers on patrol to achieve the response time goals. In 2009, the Police Department had
334 officers on patrol, or 86 to 183 fewer patrol officers than the report stated would be needed to
achieve the response time goals. As of December 31, 2020, the Police Department had 248 officers
actually working on patrol. Although the Police Department has not achieved staffing levels required to
achieve the response time goals specified in the 2010 report, these ideal response times provide context
for the Police Department’s response times at encampments.

The Police Department’s response to emergency calls at encampments were not


timely
In FY 2018-19, the Police Communications Division dispatched 823 emergency calls to encampments.
We were unable to analyze all these calls because response data was incomplete. Accordingly, we
analyzed 572 calls in which the information was complete. Exhibit 7 below shows the priority of the
calls, the range of response times, the average response time, and median response time for the 572
calls.

Exhibit 7: FY 2018-19 Police Department response time to 911 calls at encampments


Call Number
Response Time Range Average Response Time Median Response Time
Priority of Calls
1 1 25 minutes 25 minutes 25 minutes

2 568 0 - 54 hours 4 hours 2 hours

3 3 1– 13 hours 7 hours 7 hours


TOTAL
572
CALLS
Source: Dispatch data provided by the Police Department

As Exhibit 7 above shows, the Police Department’s response times to calls to encampments in FY 2018-
19 were not timely. The overwhelming majority of the calls to encampments were Priority 2, which
ideally should be responded to in 10 to 15 minutes. The Police Department, however, responded to

41
these calls in an average of 4 hours. The range of response times was 0 to 54 hours and the median
response time was 2 hours.

Our review of the FY 2019-20 calls to encampments showed similar results. In FY 2019-20, the
Communications Division dispatched 636 emergency calls to encampments. We analyzed 416 calls, of
which, 415 calls were Priority 2, and 1 call was a Priority 3. Exhibit 8 below summarizes the Police
Department’s response times to the 416 calls.

Exhibit 8: FY 2019-20 Police Department’s response times to 911 calls at encampments


Call Number
Response Time Range Average Response Time Median Response Time
Priority of Calls
1 0 N/A N/A N/A

2 415 0 – 153 hours 6 hours 3 hours

3 1 7 hours 7 hours 7 hours


TOTAL
416
CALLS
Source: Dispatch data provided by the Police Department

As Exhibit 8 above shows, the Police Department’s response time to the 415 Priority 2 calls at
encampments was slower than the previous year. The Police Department’s response time for the
Priority 2 calls averaged 6 hours, the median response time was approximately 3 hours, and response
times ranged from 0 to 153 hours. For the one Priority 3 call, the Police Department responded in
approximately 7 hours.

According to Police Department staff, the 911 emergency calls identified as encampment calls do not
capture all encampment-related calls. In some instances, the Police Department’s Patrol staff respond to
emergencies near encampments that involve encampment residents. The Communications Division
would be unable to classify these calls as encampment-related when the calls come in.

The Fire Department’s response time to encampment fires were timelier than the
Police Department’s, but information is needed on medical emergencies
The Fire Department responds to fire incidents such as structure fires, fires at encampments, and other
fires such as vehicle fires, vegetation fires, or other outside fires. The Fire Department’s goal is to
respond to 90 percent of fire calls within seven minutes. Exhibit 9 below shows the fire incident types
and numbers for each incident type for fiscal years 2018-19 and 2019-20.

Exhibit 9: Fire Department’s incident types and numbers for fiscal years 2018-19 and 2019-20
Fire Incident Types FY 2018-19 FY 2019-20
Structures 901 907
Encampments 447 541
Other (Vehicle, Vegetation, Outside Fires) 2,192 2,896
Total 3,540 4,344
Source: Dispatch data provided by the Fire Department

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As Exhibit 9 above shows, the Fire Department responded to 447 fire calls at encampments, or 12.6
percent of all Fire Department calls, during FY 2018-19 and 541, or 12.5 percent of all Fire Department
calls in FY 2019-20.

Exhibit 10 below shows the Fire Department’s response times to encampment fires in fiscal years 2018-
19 and 2019-20.

Exhibit 10: Fire Department’s response time to encampment fires in fiscal years 2018-19 and 2019-20
FY 2018-19 FY 2019-20
Total Response Time 7 minutes 53 seconds 7 minutes 54 seconds
Source: Response time data provided by Oakland Fire Department

As Exhibit 10 above shows, the Fire Department responded to 90 percent of its calls to encampments in
7 minutes and 53 seconds in FY 2018-19. In FY 2019-20, the Fire Department responded to 90 percent of
calls to encampments in 7 minutes and 54 seconds. The Fire Department’s response times to
encampment fires were consistent over the two years. In addition, the Fire Department’s responses to
encampment fires were slightly better than its responses to all other fires in which the Fire Department
responded to in both fiscal years. Specifically, in FY 2018-19, the Fire Department responded to 90
percent of all fires in 8 minutes and 6 seconds. Similarly, in FY 2019-20, the Fire Department responded
to 90 percent of all fires in 8 minutes and 12 seconds.

We were unable to assess the response time for medical emergencies because the Fire Department
currently does not track data for calls for medical emergencies at encampments.

311 Call Center response time data needs further examination


We also analyzed response times for 311 calls associated with encampment complaints. Residents
contact the 311 Call Center to register complaints about various City activities, including complaints
about encampments. As mentioned earlier, the Encampment Management Team uses the complaints
received through the 311 system to assist in determining which encampments to perform interventions.
Unlike the Police Department’s and Fire Department’s response times, the 311 response times are
calculated from the time the complaint was received to when it was resolved or closed.

In calendar years 2018 and 2019, the Call Center received a total of 1,152 calls related to encampments,
627 calls in 2018 and another 525 calls in 2019. Exhibit 11 below shows the average response range, the
average response time, and median response time. Our analysis included only calls that were closed. As
noted above, the Call Center received 627 calls in 2018, but only 299 calls were formally closed. In 2019,
525 were received, but only 152 calls were closed. Additionally, the 311 calls we analyzed specifically
identified encampments, but there likely were other calls for illegal dumping at or near encampments
that may not have been identified as an encampment complaint.

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Exhibit 11: Response times to close 311 encampment service requests in calendar years 2018 and 2019
Category Calendar Year 2018 Calendar Year 2019

Response Time Range 0 – 212 days 0 – 202 days

Average Response Time 22 days 39 days

Median Response Time 12 days 23 days

# of Closed Cases 299 152


Source: Analysis created by auditors based on Oak 311 service request data

As Exhibit 11 above shows, the response times ranged from less than 1 day to 212 days in 2018 and less
than 1 day to 202 days in 2019. The average response time was 22 days in 2018 and 39 days in 2019. The
median response time was 12 days in 2018 and 23 days in 2019.

Given the gravity of the homeless crisis, the response times are concerning, and the Administration
should evaluate both the integrity of the data and the resolution of calls regarding encampments.

Conclusion
The Police Department responds to 911 emergency calls for services at encampments and the Fire
Department responds to fire and medical emergencies at encampments. The Police Department’s
response time averaged four to six hours in fiscal years 2018-19 and 2019-20. The Police Department
needs more information reported to fully capture all police emergencies at encampments. The Fire
Department responded to fire emergency calls at encampments in less than eight minutes in fiscal years
2018-19 and 2019-20. The Fire Department’s response times to medical emergencies cannot be
calculated because the Fire Dispatch Center does not distinguish these calls from other medical
emergencies. The response time for 311 calls related to encampments ranged from less than 1 day to
212 days in 2018 and 2019. These response times could be improved, and the corresponding data
should be reviewed to ensure the integrity of the data and to determine if calls are being properly
resolved and closed.

Recommendations
To capture all emergency calls to encampments, the Police Department should
11. Modify its call reports to identify when staff respond to encampment calls.

To more comprehensively identify emergency calls associated with encampments, the Fire Department
should
12. Work with the records management software vendor and Fire Dispatch Center to establish a
unique Incident Type that will allow the department to distinguish medical emergency calls at
encampments from all other medical emergencies. Further, the Fire Department should ensure
staff use the appropriate disposition code upon clearing the location.

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To address the concerning 311 Call Center response times, the City Administration should
13. Evaluate both the integrity of the 311 Call Center data and the resolution of calls regarding
encampments.

45
Summary
In fiscal years 2018-19 and 2019-20, we estimate multiple City departments and offices incurred
approximately $12.6 million in direct costs associated with encampment activities. The City currently
does not have a comprehensive budget and formal systems in place to account for the costs associated
with activities at encampments, including the time spent on interventions. Further, the City has not
established a dedicated budget for encampment management activities, so departments are left to use
their existing budgets and resources to address encampment activities.

The City does not budget and track costs for encampment management
activities
The City does not possess a specific, programmatic budget that covers the full scope of the encampment
management activities it performs. Some departments have limited dollars allocated for encampment-
related services, while most do not, and fund encampment activities through their department budgets,
thus prioritizing encampment management activities over other department obligations. As a result, the
true cost of encampment management activities can become obscured within larger operational
budgets, leaving the extent of these expenditures unknown.
The City currently does not have formal systems in place to account for the costs associated with
activities at encampments. Therefore, we estimated the costs based on interviews with various
department staff and obtained documentation, whenever possible, to estimate the City’s costs
associated with activities at encampments. Our estimate is not intended to be an exact accounting for
all costs the City is currently incurring. Instead, it is an estimate based upon known costs and activities
associated with encampments.

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Multiple City departments and offices incurred approximately $12.6 million in direct
costs associated with encampment activities in fiscal years 2018-19 and 2019-20
Multiple City departments and offices perform a variety of activities associated with encampments
located throughout the City. We estimate that the City incurred approximately $12.6 million in direct
costs associated with encampment activities in fiscal years 2018-19 and FY 2019-20. In FY 2018-19, we
estimate the City incurred approximately $5.5 million in direct costs and $7.1 million in direct costs in FY
2019-20, an increase of 30 percent between the two fiscal years. The methodologies used to estimate
these costs are shown in the Appendix. Exhibit 12 below provides an overview of the City’s estimated
costs on encampment-related activities in fiscal years 2018-19 and 2019-20.
Exhibit 12: Estimate of the direct costs the City incurred on encampment activities by departments
and offices for fiscal years 2018-19 and 2019-20
Departments and Offices FY 2018-19 FY 2019-20 2-Year Total % Change
Public Works $ 1,569,000 $ 1,652,000 $ 3,221,000 5%
Police Department $ 1,469,000 $ 1,628,000 $ 3,097,000 11%
Human Services $ 811,000 $ 1,333,000 $ 2,144,000 64%
Fire Department $ 733,000 $ 1,032,000 $ 1,765,000 41%
City Attorney $ 415,000 $ 822,000 $ 1,237,000 98%
City Administrator $ 191,000 $ 296,000 $ 487,000 55%
Transportation $ 168,000 $ 145,000 $ 313,000 -14%
Parks, Recreation & Youth Development $ 88,000 $ 116,000 $ 204,000 32%
Mayor $ 12,000 $ 74,000 $ 86,000 517%
Total $ 5,456,000 $ 7,098,000 $ 12,554,000 30%

As Exhibit 12 above shows, the direct costs the City incurred increased from $5.5 to $7.1 million
between fiscal years 2018-19 and 2019-20. This represents an increase of 30 percent from FY 2018-19 to
FY 2019-20 for all departments and offices.

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Exhibit 13 shows the percentage of combined total costs incurred for encampments activities by
departments and by offices for fiscal years 2018-19 and 2019-20.
Exhibit 13: Estimated percentage of combined total costs incurred by departments and offices for
fiscal years 2018-19 and 2019-20

Parks, Recreation & Youth Transportation


Mayor 1% Development 2%
1%
City Administrator
4%

Public Works City Attorney


26% 10%

Fire Department
14%

Police Department
25%
Human Services
17%

Exhibit 13 represents each department’s and office’s percentage of the combined total costs for both
fiscal years 2018-19 and 2019-20. Public Works and the Police Department accounted for approximately
50 percent of the costs the City incurred on activities associated with encampments between fiscal years
2018-19 and 2019-20. Human Services and the Fire Department accounted for the next largest
percentage of the costs with 31 percent of the total cost. The remaining 19 percent of the costs were
split between Department of Transportation, Parks, Recreation and Youth Development, the City
Administrator’s Office, the City Attorney’s Office, and the Mayor’s Office.
This analysis focuses on the City’s significant costs directly associated with encampment activities. As
such, not all departments that provide services to the homeless population are included in this cost
analysis. We did not include cost analyses for other departments that have been indirectly impacted by
homelessness. For example, this analysis does not include the Oakland Public Library, which serves the
unsheltered population with computers and literacy services.
Also, we did not include overhead costs in this analysis. Overhead costs refer to all indirect expenses of
running a department or function in the City. For example, certain administrative functions like
accounting, cash management, telephone expenses, and information technology. These costs can be
difficult to allocate because the City uses predetermined overhead rates to recover costs from each
department’s budget.

48
We estimated the hourly cost of closures and cleanings to be $1,464 per hour
We also calculated the hourly rate of a typical encampment intervention such as a closure or a cleaning.
As shown on Exhibit 14, a typical encampment intervention deploys 12 staff and a total of 8 vehicles and
pieces of equipment. We calculated the average hourly cost to be $1,464 per hour. As Exhibit 14 shows,
our estimate includes Public Works staff (one supervisor, four Maintenance Workers, three Street
Maintenance Leaders, and one Heavy Equipment Operator), and Police Department staff (one Sergeant
and two Officers). The estimate also includes the vehicles and equipment needed for a typical
intervention. The estimate does not include the cost of the EMT to plan the interventions.

Exhibit 14: Hourly cost of intervention activities in FY 2019-20 and the list of staff, vehicles, and
equipment used on interventions
Number of Staff Number of Vehicles/Equipment12
Public Works (9) Public Works

• Public Works Maintenance Workers (4) • 25-Cubic Yard Packers (2)


• Street Maintenance Leaders (3) • Pickup Trucks (2)
• Heavy Equipment Operator (1) • Lightning Loader (1)
• Public Works Supervisor (1) • Front End Loader (1)
• Dingo (1)
Police Department (3) • Trailer (1)
• Police Officers (2)
• Police Sergeant (1)

Total number of staff: 12 Total number of vehicles/equipment: 8


Hourly Cost of Interventions: $1,464
Source: Prepared by auditors based on data from the City’s financial reporting system and information from Public Works

According to City staff, the interventions can vary in time from several hours to several days. We were
unable to estimate the cost of each intervention because the departments and offices involved with the
interventions do not track the amount of time spent. To provide some perspective, however, an
encampment intervention taking two hours would cost approximately $3,000 and an intervention taking
three days would cost approximately $35,000.

We could not quantify the cost of a second crew, which is used on larger
interventions, or days with multiple interventions
Sometimes, the City needs a second crew at encampment interventions due to the size or number of
interventions planned for that day. The additional crew is typically made up of one Street Maintenance

12
A 25-Cubic Yard Packer carries and compresses debris. Once the load is full, City staff dump the debris at the
David Street Transfer Station (DSTS). This piece of equipment requires a commercial license to drive. The Lightning
Loader and the Front-End Loader are used either to load debris on the vehicle itself or on other vehicles. City staff
later dispose of the debris at the DSTS. Both loaders require a commercial license to drive. The Dingo is used to
load debris onto the 25-cubic yard Packer.

49
Leader, two Public Works Maintenance workers, and two Police Officers, as well as two additional pieces
of equipment, which likely incurs significant costs.

However, we were unable to estimate costs associated with the additional crew for several reasons.
First, prior to May 2019, Public Works neither tracked the instances when an additional crew was
needed, nor the number of hours the additional staff spent at the operations. Second, the Police
Department did not start tracking the same information until February 2020.
Until the City comprehensively tracks the hours associated with the second crew (i.e., Public Works staff
and Police officers), the costs cannot be accurately calculated nor estimated.

In addition to incurring costs, encampment activities are diverting time and


resources from primary City services
As Oakland’s homelessness crisis grows, so does the cost for managing the encampments. City
departments and offices had to prioritize encampment management at the expense of other City
services.
City services that have been affected by the City’s increased focus on encampments include
• Illegal dumping – the Keep Oakland Clean and Beautiful Division of Public Works used funding
and staffing dedicated to illegal dumping services to carry out encampment interventions,
leaving fewer staff to respond to illegal dumping complaints.
• Residential and commercial fire inspections – the Fire Prevention Bureau of the Fire
Department inspects encampments for fire hazards and investigates causes of fires at
encampments. Inspectors have less time to dedicate to residential and commercial fire
inspections, thereby reducing the number of fire safety inspections conducted and revenue
generated from these inspections.
• Abandoned autos – the Abandoned Auto Unit of the Police Department participates in some
encampment interventions to tag and facilitate the towing of cars. As such, the Police
Department faces a growing backlog of abandoned auto cases that are not encampment-related
and are impacting neighborhoods.
• Hazardous material disposal – the volume of hazardous waste generated by encampments has
imposed a burden on the Fire Department. Collecting, handling, recycling, treating, storing and
disposing hazardous waste from encampments has significantly increased the department’s
costs dedicated to hazardous materials.
• Street light and traffic signal maintenance – the Department of Transportation is responsible
for repairing illegal wire taps into the City’s utility boxes, electrical cabinets, and street light and
traffic signal poles at encampments. Additionally, when conducting repairs, they require support
from the Police Department, the Fire Department, and Public Works for safety and assistance
removing debris. These repairs pull staff from their primary responsibility of maintaining street
lights and traffic signals.

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Conclusion
In fiscal years 2018-19 and 2019-20, we estimate multiple City departments and offices incurred
approximately $12.6 million in direct costs associated with encampment activities. The City currently
does not have a comprehensive budget or formal systems in place to account for the costs associated
with activities at encampments, including the time spent on interventions. Further, the City has not
established a dedicated budget for encampment management activities, so departments are left to use
their existing budgets and resources to address encampment activities. Recommendations for the need
for a budget and cost tracking system have been incorporated into Section 4.

Recommendation
To provide the City with systems for tracking and monitoring costs associated with encampment
activities, the City should
14. Document the amount of time spent, and staff needed, on encampment interventions such as
closures, re-closures, cleanings, and hygiene services.

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Summary
The City Council adopted a new encampment policy in October 2020, which was scheduled to take
effect in January 2021. The new policy will significantly change how the City manages homeless
encampments throughout the City. To effectively implement the policy, the City will need to take a more
proactive, programmatic, and strategic approach in managing encampments throughout the City. Such
an approach includes establishing a more formal structure more akin to how other programs are
managed. This includes establishing goals, objectives, strategies, and annual workplans for achieving the
City’s vision, a budget for encampment management activities, assessing staffing roles and
requirements, implementing written policies and procedures, better management information, and staff
training.

The City Council adopted a new Encampment Management Policy in 2020


The City Council adopted a new encampment management policy in October 2020, which was scheduled
to become effective in January 2021. The purpose of the policy is to protect and serve all Oaklanders –
sheltered and unsheltered, by balancing the interests of residents. Key elements of the policy include

1. Designating high-sensitivity areas, where unmanaged encampments are presumed to cause


unreasonable health and safety impacts due to the nature of the location. These areas are
formally designated by the City Council and can include parks, protected waterways, and other
public lands. In these locations, the City would prioritize maintaining the areas free of
encampments. The City Council reserves the right to allow encampments in high-sensitivity
areas; however, it is recommended that the operation and management of encampments in
these areas be in collaboration with a managing agency such as a nonprofit organization,
advocacy group, faith-based organizations, other public agency, or a grassroots collective. The
managing agency would work in collaboration with encampment residents and the City to
mitigate safety and health hazards. Encampments located within a high-sensitivity area that are

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not approved by the City Council will be subject to a closure intervention. Except when urgent
health and safety concerns require shorter notice, encampment residents will be given no less
than 72 hours to accept an offer of shelter or alternative housing, if such referrals are available.
Individuals are also free to voluntarily relocate to a low-sensitivity area if shelter provisions are
declined. All declinations will be documented.

2. Designating low-sensitivity areas, where enforcement will not be prioritized. These areas are to
be monitored and managed by the EMT. These areas will have a set of standards that need to be
followed and encampments that do not comply with the standards and with applicable and
generally enforced state codes and local ordinances are subject to EMT intervention.

3. Determining findings that will prompt EMT intervention. The policy allows the EMT to consider
public health findings and public safety findings to justify interventions at encampments.
Potential public health findings include but are not limited to: confirmed cases of infectious
diseases, confirmed exposures to infectious diseases, and excessive animal or vector hazards,
such as rats and other vermin. The public safety findings include but are not limited to: the
location of the encampment impedes traffic or the right-of-way, excessive fire hazards, and
excessive amounts of waste, debris, and garbage. The interventions to address these findings of
public health or safety include: hygiene and garbage services, deep cleaning, partial closures,
and closures. Additionally, the policy provides guidance on proper noticing prior to any
encampment intervention. The policy also addresses the storage of individuals’ property, in the
event of an intervention.

4. Providing guidance on addressing unreasonable health and safety risks, promoting voluntary
compliance, and strategies to address non-compliance. For instance, the policy provides
guidance on proper noticing prior to any encampment intervention. The policy also addresses
the storage of individuals’ property, in the event of an intervention. It also provides guidance on
compliance to balance the rights of encamped individuals against the City’s fundamental duty to
maintain public safety and public health.

The policy also includes an equity provision in recognition that 70 percent of Oakland’s homeless
population are African American, and the vast majority of known encampments are within communities
of concern.13 Accordingly, the policy was developed with an intentional focus on achieving the following
equity outcomes:

• Health and safety standards are achieved and maintained for encampment residents who are
disproportionately Black, Indigenous, and Persons of Color (BIPOC).
• BIPOC neighborhoods and businesses are not disproportionately impacted by vehicle and street
encampments.
• Service provisions close disparities in BIPOC groups’ representation in homelessness.

13
Communities of concern are determined by eight factors: minority, low-income, level of English proficiency,
elderly (over 65), zero-vehicle households, single parent households, disabled, and rent-burdened households.

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The policy requires that an equity analysis be conducted in coordination with the City’s Department of
Race and Equity after the adoption and implementation of the policy to ensure the stated outcomes are
achieved and maintained. Furthermore, the policy will undergo a semi-annual equity review to
determine its effectiveness in relation to the equity indicators and outcomes consistent with guidelines
and best practices promoted by the City’s Department of Race and Equity.

The policy also requires the City launch at least one co-governed encampment pilot on public land in
2021. The policy requires the pilot be developed in collaboration with the unhoused community,
advocates, housed and business neighbors, and the councilmember of the district.

To be more proactive, programmatic, and strategic, the City will need to


formalize its encampment management activities into a more formal program

To be more proactive, programmatic, and strategic, the City will need to formalize its encampment
management activities into a more formal program. The City needs to establish a more formal structure
more akin to how other programs are managed. This formal management structure should include

• establishing measurable goals and objectives,


• developing written strategic plans for achieving goals and objectives,
• developing annual work plans to implement strategies and achieve goals and objectives,
• establishing formal systems for tracking progress in implementing strategies,
• developing annual budgets and tracking costs for encampment management activities,
• determining the appropriate staffing levels, the appropriate composition of staff, and defining
the roles, responsibilities, and authority of staff,
• developing written policies and procedures to guide the implementation of the new policy,
• developing data collection systems to manage encampment activities, and
• ensuring staff are adequately trained.

The City needs to develop formal goals, objectives, strategies, and annual workplans
to effectively implement the City’s new Encampment Management Policy
The City needs to establish measurable and achievable goals and objectives for its encampment
activities. These goals and measurable objectives should formally communicate what the City hopes to
achieve with its encampment management activities. Measurable goals and objectives would also assist
the City in determining to what degree its efforts are succeeding in achieving intended results and
whether its activities are having a positive effect (health, safety, equity) on sheltered and unsheltered
Oaklanders.
A study from Arizona State University identified some potential measures of effectiveness for managing
homeless encampments. These include but are not limited to
• reduced numbers of encampments and the homeless living in them,
• less crime in areas around the encampments,
• fewer resident complaints about the homeless’ behavior and encampments,
• fewer health and safety hazards associated with encampments,

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• reduced number of conflicts between the homeless and others over use of public space,
• fewer or less serious crimes committed against the homeless living in encampments,
• fewer calls for police service to the encampment area,
• fewer calls for police service for nuisance problems caused by the homeless,
• fewer calls for police service by businesses and residents concerning the homeless, and
• lower costs of police response dealing with homeless encampments.

In addition to these measures, the City needs to establish formal goals and objectives for addressing the
equity outcomes specified in the new policy.
The City also needs to establish a strategic plan for achieving its goals and objectives, specifically related
to encampment management. A strategic plan assists a formal program in providing a sense of direction
and defining the activities to achieve stated goals and objectives.
Additionally, the City needs to establish annual workplans. These workplans should identify goals and
deadlines for the next year, the strategies for achieving them, and provide transparency around the
work to be accomplished. To ensure its efforts are achieving the desired outcomes, the City should also
establish formal systems for tracking progress in implementing strategies.

The City needs to budget and account for encampment activities


Budgets are statements of value that reflect organizational priorities. The budget process requires
organizations to consider actual and estimated expenditures in light of available revenues; defines
spending limitations; and essentially serves as a roadmap for how public funds will be used. The budget
process can help hold government agencies accountable, as each budget cycle provides an opportunity
to evaluate whether funds have been used for their intended purposes and whether those purposes
have produced desired results.
As stated in Section 3, the City does not possess a specific, programmatic budget that covers the full
scope of the encampment management activities it performs. Because encampment activities are not
budgeted for in full, the City lacks a formal fiscal plan for encampment activities. The lack of a budget for
encampment management inhibits the City’s ability to understand, monitor, and evaluate the role of
encampment management as part of its larger strategy for addressing homelessness. It also limits the
City’s ability to consider how scarce resources might be allocated between encampment management
and other programs, reduces opportunities for public oversight and input on funding decisions about
encampment management, and prevents the City from determining whether funds are being expended
efficiently or allocated toward the most effective actions for serving the homeless population. These
concerns were echoed by City staff in interviews.
As noted in Section 3, the City incurred approximately $12.6 million in direct costs related to
encampments and does not have formal systems in place to account for the costs associated with
encampment activities. Our estimate above does not include overhead costs. When establishing a
budget for the encampment management program, all these costs should be considered and included to
fully account for the true cost of encampment interventions.

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Other cities have experienced similar financial reporting challenges and have recommended the use of
budgeting and improved citywide cost tracking systems as solutions to financial data quality issues and
capturing comprehensive financial information. The City of San Diego recently recommended the
development of a “funding strategy and long-term financial plan” to accurately identify the full cost of
the homeless services it provides (including encampment abatement) and monitor whether
departmental spending is achieving the City’s homelessness goals. The City of Seattle is currently
developing a tracking system for encampment abatement costs across City departments, and the City of
San José has recommended changes to its expenditure tracking system to more precisely monitor
spending that occurs at the programmatic or service level.

The City needs to determine appropriate staffing levels, roles, and the composition of
staff for future encampment management activities

Based on the City’s experience with encampment activities over the last several years, the City should be
better able to assess its staffing needs and the mix of staffing necessary to manage encampments in the
future. The City should re-assess its staffing to determine whether additional resources are needed to
carry out the new policy. The City should also re-assess whether the current mix of staff is appropriate
as the City moves forward in managing encampments. For instance, the City should re-assess whether
the current levels of law enforcement staff are needed. Currently, the Police Department participates in
all interventions to create a safe working zone for City staff. However, certain homeless individuals,
especially immigrants and refugees, might be reluctant to speak with police officers. Research has found
that immigrants are less likely to report crimes to the police for reasons including: negative experience
with law enforcement in country of origin, fear of the police due to immigration status, and cultural and
language barriers. Other jurisdictions are using different staffing models to address homeless
encampments. The City of Austin Homeless Outreach Team (HOST) operates in sections of the City to
address the needs of people living on the streets. The HOST includes two police officers, two behavioral
health specialists, one paramedic, and one outreach social worker.

Additionally, the City will need to determine whether other skill sets are needed to implement the new
policy. For instance, the City will need to monitor encampments on an on-going basis to ensure that
encampments are complying with the new policy. This type of monitoring may require a skill set like
Code Enforcement inspectors to monitor encampments to ensure they are complying with the new
policy. The City may also need administrative staff to manage the data collection around encampments.
As mentioned in other sections of this report, the City needs better data collection methods and
documentation requirements to provide appropriate, consistent, and reliable information on its
encampment activities.

The City also needs to clearly define and document the roles, responsibilities, and authority of staff
working on encampment activities. Teams function more effectively and efficiently when members
share a common understanding of their respective roles, responsibilities, authority, and the
expectations they hold for one another when working together to accomplish their vision, mission,
goals, and objectives.

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The City should develop policies and procedures for guiding the effective
implementation of the new Encampment Management Policy

Policies and procedures are an essential part of any organization. Together, policies and
procedures provide a roadmap for day-to-day operations. They ensure compliance with laws
and regulations, give guidance for decision-making, and streamline internal processes. Written policies
and procedures are particularly important for managing the City’s encampment activities because of the
interdepartmental nature of the City’s encampments.

Some of the areas in need of clear policies and procedures include but are not limited to

• establishing a definition and criteria for what constitutes an encampment,


• establishing thresholds for responding to and providing encampment interventions and services,
• monitoring the conditions of encampments for compliance with the Encampment Management
Policy,
• enforcing the Encampment Management Policy, and
• assigning responsibility for conducting the racial equity analysis and the semi-annual review, as
well as defining how these requirements will be met.

As mentioned in the background section of this report, federal, state, and local governments, including
Oakland, have not established a single definition of encampments. A HUD report from January 2019
states, “Researchers and other experts have not yet developed a single, standard set of criteria defining
a group of people experiencing unsheltered homelessness as an ‘encampment.’” Defining the term
‘encampment’ would allow the City to establish thresholds for responding and providing encampment
interventions and services. It would also allow the City to maintain consistent data on encampment
activities and to monitor implementation based upon established guidelines and encampment
management policies. The definition of encampments should consider, but not be limited to, the size,
type of structure, and length of stay.
The City’s new Encampment Management Policy establishes areas where unmanaged encampments are
presumed to cause unreasonable health and safety impacts due to the nature of the location. In
addition, the new policy designates where enforcement will not be prioritized. These areas are to be
monitored and managed by the EMT. These areas have a set of standards that need to be followed and
encampments that do not comply with the standards and with applicable and generally enforced state
codes and local ordinances, are subject to EMT intervention.

The City will need to develop a written policy and procedure defining how it will monitor compliance
with the new encampment policy. It will also need a policy and a procedure defining how it will enforce
the policy when encampments are out of compliance. These policies and procedures will define parties
responsible for carrying out these policies, as well as procedures.

As noted above, the City’s new Encampment Management Policy requires the City to conduct a racial
equity analysis to assess whether the stated equity outcomes are achieved and maintained.
Furthermore, the policy requires a semi-annual equity review to determine its effectiveness in relation

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to the equity indicators and outcomes consistent with guidelines and best practices promoted by the
City’s Department of Race and Equity. The City needs to develop a policy assigning responsibility for
conducting the racial equity analysis and the semi-annual review, as well as procedures defining how
these requirements will be met.

The City needs more data to effectively measure the desired outcomes
Strong performance management rests on the simple principle that “what gets measured gets done.” In
an ideal performance measurement system, metrics flow from the top-level strategic objectives down to
the daily activities of its frontline employees. Managers continually monitor those metrics and regularly
engage with their teams to discuss progress in meeting the targets.

The City needs to improve its data collection systems to manage the City’s
encampment activities
The City needs to improve its data collection systems related to encampment activities, including

• data to assess whether the City is achieving its goals and objectives,
• activity information, and
• master list of encampments.

The City should determine the data needed to assess whether it is meeting its established encampment
management goals and objectives. Further, the City will need to develop metrics for key encampment
management activities, including but not limited to

• interventions conducted by type,


• encampments provided various hygiene services,
• garbage services,
• garbage tonnage removed from homeless encampments,
• inspections conducted at encampments,
• condition reports on encampments,
• complaints received from residents and businesses
• fires and medical emergencies at encampments,
• crime statistics at encampments,
• response times to emergencies at encampments, and
• enforcement actions conducted.

The City also needs to track the number of residents in encampments, as well as demographic
information to provide a basis for assessing whether the City is achieving equity outcomes specified in
the Encampment Management Policy.

A master list of encampments will be an important tool in assisting the City to monitor encampments to
ensure that encampments are following the new policy. The City currently lacks an accurate,
comprehensive list of encampments. The latest encampment list was updated in October 2020. Prior to
this update, the City had not updated the list since May 2019. We tested the accuracy and completeness

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of the City’s current list of 140 encampments updated in October 2020. Based on our sample of 41
encampments, 12 encampments were no longer in existence and we also identified 5 encampments
that were not on the list. Thus, we concluded that the City’s current list is not complete and accurate.
This suggests that the City needs to continually update its master encampment list to ensure it has a
complete and accurate inventory of encampments that need to be managed.

Although encampments are difficult to track due to the frequent changes in size and location, the City
must develop and maintain an accurate, comprehensive master list of encampments to monitor
compliance with the new policy.

The City needs to maintain data to comply with federal, state, and regional permits
Besides monitoring the encampments for compliance with the new policy, the City needs to develop and
maintain a master list of encampments to comply with new permit requirements established by the Bay
Area Regional Water Quality Control Board (Control Board). The Federal Clean Water Act (Act) addresses
urban stormwater runoff pollution of the nation’s waters. In response to the Act, the US Environmental
Protection Agency (EPA) promulgated rules establishing the National Pollution Discharge Elimination
System (NPDES) stormwater program. The rules require municipal operators that serve populations of
100,000 or greater to implement a stormwater management program to control polluted discharges.
The Control Board regulates the City’s discharges to the storm drains, which flow to San Francisco Bay.

The Control Board issues county-wide permits to the municipal operators approximately every five years
that address the conditions the municipalities and local agencies in the county must comply with to
regulate the discharge of pollutants into the storm drains. In November 2015, the Control Board re-
issued the county-wide municipal stormwater permits on the Municipal Regional Stormwater NPDES
Permit to regulate stormwater discharges from municipalities and local agencies in Alameda, Contra
Costa, San Mateo, and Santa Clara counties, and the cities of Fairfield, Suisun City, and Vallejo.

The Control Board is developing a new NPDES permit and has developed and released an administrative
draft permit for public comment. The draft permit contains provisions to address the management,
tracking, and reporting of non-stormwater discharges from homeless encampments. The draft permit
will require municipalities such as Oakland to create a map identifying the location of encampments,
both formal and informal, including but not limited to, informal tent or small cabin encampments,
formal encampments, areas where residents are living in parked vehicles, and safe parking areas. The
map should identify the locations of these encampments in relation to storm drain inlets and existing
streams, rivers, and flood control channels, as well as other surface water bodies within the permittee’s
jurisdictions.

City staff need training on crisis management and interacting with traumatized
encampment residents
As noted in Section 1, City staff working on encampment activities reported difficulties in working in a
stressful, intense environment. As a result, staff reported trauma and have needed to obtain counseling

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services to help deal with the stress of the work. City staff reported being threatened on multiple
occasions with weapons such as guns, an axe, a dog, and endured multiple verbal confrontations.

Most of the City staff working on encampment activities have not received training on how to interact
with encampment residents that are dealing with trauma and/or mental health issues and how to use
crisis intervention practices in situations with homeless residents. Staff in the Police Department’s
Abandoned Auto Unit specifically cited the need for training on how to deal with encampment residents
that live in abandoned autos or encampments.

The City of Seattle’s former Navigation Team, which is comparable to the City’s Encampment
Management Team, received a four-hour training on trauma informed care from the King County Health
Department. The U.S. Substance Abuse and Mental Health Services has commissioned a Trauma-
Informed Toolkit for Homeless Services, in recognition that homeless individuals have significant
histories of trauma that impact their current functioning and needs. This toolkit is designed to be used
by homeless-serving programs to evaluate how well trauma-informed practices are incorporated,
identify areas for organizational growth, and make practical changes using their self-assessment
evaluation as a guide.

Conclusion
In October 2020, the City Council adopted a new encampment policy that was scheduled to take effect
in January 2021. The new policy will significantly change how the City manages homeless encampments
throughout the City. To effectively implement the policy, the City will need to take a more proactive,
programmatic, and strategic approach in managing encampments throughout the City. Such an
approach includes establishing a more formal structure modeled on how other programs are managed.
This includes establishing goals, objectives, strategies, and annual workplans for achieving the City’s
vision, a budget for encampment management activities, assessing staffing roles and requirements,
implementing written policies and procedures, better management information, and staff training.

Recommendations
To implement more formal systems to manage encampment activities, the City should

15. Develop written goals and objectives for its encampment management activities. These goals
and objectives should formally communicate what the City hopes to achieve with its
encampment management activities.
16. Develop a strategic plan that includes written strategies for achieving its encampment
management goals and objectives and establish formal systems for assessing the City’s progress
in implementing these strategies.
17. Develop annual work plans identifying goals and deadlines for the next year and the strategies
for achieving them.
18. Develop a formal comprehensive budget for encampment management activities including all
direct and indirect costs.

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19. Establish funding/project codes to track expenditures for encampment-related activities across
City departments.
20. Perform a staffing analysis to assess the City’s staffing requirements for encampment
management activities. The staffing analysis should not only address the number of staff needed
to carry out encampment management activities but should also address the appropriate mix
and composition of staff needed to effectively administer the new encampment policy. This
staffing analysis, at minimum, should assess the need for
• police officers providing the current level of security at encampment interventions,
• staff resources needed to monitor and enforce the encampment policy, and
• administrative staff needed to improve recordkeeping
21. Clearly define and document roles, responsibilities, and authority of all staff working on
encampment activities, to ensure all staff have a shared understanding of their respective roles,
responsibilities, authority, and the expectations they hold for one another.
22. Develop and implement written policies and procedures for carrying out all its encampment
management activities. These policies and procedures should
• Establish a definition, including criteria, for the term ‘encampment’ and thresholds for
responding to and providing services to the various encampments.
• Determine how the City will monitor encampments to ensure compliance with the new
Encampment Management Policy.
• Determine how the City will enforce the new encampment policy when encampments
are not complying with the Encampment Management Policy.
• Determine how the City conducts its racial equity analysis and the semi-annual review to
ensure the desired outcomes are achieved.
23. Develop data collection systems that includes
• information needed to measure the City’s progress in achieving its encampment
management goals and objectives,
• activity reports that provide information to management such as the number of
interventions conducted by types, the number of encampments provided various
hygiene services, the number of garbage services, the amount of garbage removed from
encampments, the number of inspections conducted of encampments, condition
reports on encampments, the number of complaints received from residents and
businesses, the number of fire and medical emergencies at encampments, crime
statistics, emergency response times to encampments, and the number of enforcement
actions conducted, and
• demographic information on encampments to facilitate the racial equity review and the
semi-annual review to ensure the desired equity outcomes are achieved.
24. Assign responsibility for developing and maintaining a comprehensive master list of
encampments, which maps the locations of encampments, both formal and informal, including
but not limited to, informal tent or small cabin encampments, formal encampments, areas
where residents are living in parked vehicles, and safe parking areas. This master list should
include the population and demographics of the encampments. The maps should also identify
the locations of these encampments in relation to storm drain inlets and existing streams, rivers,

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and flood control channels, as well as other surface water bodies within the City to ensure
compliance with federal, state, and regional permits.
25. Develop formal training programs for City staff working on encampment activities. This training
should include training on crisis interventions and understanding, recognizing, and interacting
with encampment residents suffering from trauma.
26. Use the ‘U.S. Substance Abuse and Mental Health Services’ Trauma-Informed Toolkit for
Homeless Services to evaluate how well trauma-informed practices are incorporated into the
City’s encampment practices to identify areas for organizational growth, and make practical
changes using their self-assessment tool-kit.

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Objectives
The audit had the following objectives:

1. Determine the cost of the encampment management services.


2. Determine how many encampments exist in the City of Oakland.
3. Assess the quality of conditions at encampments.
4. Assess whether the City is achieving its goals and objectives.
5. Determine response times for 911 and 311 calls.
6. Assess the closure notification process.
7. Assess the bag-and-tag process.
8. Identify best practices.
9. Assess the quality of data around the encampment management services.

Scope
The scope of the audit includes fiscal years 2018-19 through 2019-20 and includes the current policy the
City Council approved in October 2020.

Methodology
To achieve the audit objectives, we

• Reviewed policies relevant to encampment management including, the Encampment


Management Policy 2017, the Temporary Encampment Management Policy March 2020, the
Encampment Management Policy January 2021 and Public Works’ Standard Operating
Procedures.
• Reviewed City Council meetings related to encampment management and related staff reports.
• Interviewed City management and staff from the Departments of Human Services, Public Works,
Police, Fire, Parks, Recreation and Youth Development, Transportation, Office of the Mayor, City
Administrator, and City Attorney to gain an understanding of their roles related to encampment
management activities.
• Interviewed homeless individuals and advocates.
• Reviewed City of Oakland’s PATH framework.
• Reviewed Alameda County’s Point-in-Time Homeless Survey and a United States Department of
Housing and Urban Development study released in late 2019.
• Reviewed the current and draft Water Board permits.
• Reviewed relevant City, state, and federal guidelines.
• Reviewed audits and related best practices of homeless services in other jurisdictions.
• Performed a site visit of Public Works’ storage facility to assess whether the bag-and-tag
procedures were followed.
• Obtained a list of City-funded shelter options including emergency shelters, Community Cabins,
RV sites, and transitional housing.
• Reviewed relevant legal proceedings.

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• Surveyed departments to identify the impact of homelessness on their work/services.
• Observed a sample of encampment closures.
• Reviewed the Encampment Management Team schedule to assess the quality of data and
identify the number of closures, cleanings, garbage services, and hygiene services.
• Obtained and reviewed Police and Fire emergency call data and 311 service requests to analyze
response times.
• Selected a sample of encampments from the City’s October 2020 master list of encampments to
verify its completeness and accuracy.
• Selected a sample of encampment closures/cleanings to verify that required notifications were
posted.
• Reviewed Police Department’s homicide report and identified those specifically related to
encampments.
• Estimated costs incurred by departments on encampment management activities by calculating
costs of staff time, equipment, materials, and third-party contracts.
• Reviewed workers’ compensation claims related to homelessness.
• Reviewed and summarized actual homeless related expenditures and approved budgets.
• Obtained and reviewed research and other documents on the impact of homeless
encampments on encampment residents, City staff, businesses, and the community.

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We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.

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Exhibit 15: Cost analysis summary for all City departments and offices fiscal years 2018-19 and 2019-20
Departments and Offices FY 2018-19 FY 2019-20 2-Year Total % Change
Public Works $ 1,569,000 $ 1,652,000 $ 3,221,000 5%
Police Department $ 1,469,000 $ 1,628,000 $ 3,097,000 11%
Human Services $ 811,000 $ 1,333,000 $ 2,144,000 64%
Fire Department $ 733,000 $ 1,032,000 $ 1,765,000 41%
City Attorney $ 415,000 $ 822,000 $ 1,237,000 98%
City Administrator $ 191,000 $ 296,000 $ 487,000 55%
Transportation $ 168,000 $ 145,000 $ 313,000 -14%
Parks, Recreation & Youth Development $ 88,000 $ 116,000 $ 204,000 32%
Mayor $ 12,000 $ 74,000 $ 86,000 517%
Total $ 5,456,000 $ 7,098,000 $ 12,554,000 30%

Below are the departments’ and offices’ detailed cost information associated with encampment
activities, as well as their respective responsibilities for encampment activities.

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Department of Public Works
As Exhibit 16 shows, we estimate Public Works incurred costs of approximately $3.2 million on
encampment activities in fiscal years 2018-19 and 2019-20.

Exhibit 16: Oakland Public Works’ cost of encampment activities in fiscal years 2018-19 and 2019-20
Oakland Public Works FY 2018-19 FY 2019-20 % Change
KOCB Labor $1,233,000 $1,314,000 7%
KOCB Equipment $180,000 $246,000 37%
Parks Maintenance Labor, Materials, and
$135,000 $82,000 -39%
Equipment
Hazardous Waste Removal Contracts $21,000 $10,000 -52%
Total $1,569,000 $1,652,000 5%
Combined Total $3,221,000

As Exhibit 16 shows, Public Works incurred a total of $3.2 million in the two fiscal years, of which $1.6
million was incurred in FY 2018-19 and $1.7 million in FY 2019-20, an increase of 5 percent between the
two fiscal years. These labor costs were for staff of Keep Oakland Clean and Beautiful (KOCB) and Parks
Maintenance staff. In addition, Public Works incurred additional costs for materials, equipment, and
contracts.

KOCB Labor: In fiscal years 2018-19 and 2019-20, KOCB staff in Public Works incurred approximately
$2.5 million in labor costs14 associated with encampment activities. The KOCB Division is responsible for
cleaning and clearing activities at encampment interventions throughout the City. Typically, the KOCB
encampment crew has nine employees from KOCB’s Illegal Dumping Section. These positions include
Street Maintenance Leaders, Public Works Maintenance Leaders, a Heavy Equipment Operator, and a
Public Works Supervisor. While 9 employees are typical, the number of employees on the crew can
range from 4 to 12, depending on the size of an encampment. When assigned to an encampment crew,
employees spend approximately 80 percent of their time (32 hours per week) on encampment-related
activities.

KOCB also performs garbage services for approximately 40 encampments on a weekly basis and two
encampments twice a week due to the large amount of garbage generated. Before COVID, KOCB
performed garbage services to encampments twice a week, but they have doubled to four times a week
since the pandemic began.

KOCB Equipment: In fiscal years 2018-19 and 2019-20, Public Works incurred approximately $426,000
in equipment costs associated with the various interventions at encampments. The KOCB Division of
Public Works rents equipment from its Equipment Services Division at a fixed monthly rate. Equipment

14
KOCB staff working on encampment interventions receive premium pay, which is included in the labor costs.

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used for encampment interventions include: 25 cubic yard packers, pick-up trucks, lightning and front-
end loaders, a dingo, and a trailer.

Parks Maintenance Labor, Materials, and Equipment: In fiscal years 2018-19 and 2019-20, the
Parks Maintenance Division of Public Works incurred $217,000 in labor, material and equipment costs
associated with illegal dumping at City Parks. The Parks Maintenance Division’s role is to remove illegal
dumping at parks, much of which is attributed to encampment residents. In the past, this division
assisted in encampment operations, however, this is no longer the City’s practice.

Hazardous Waste Removal Contracts: In fiscal years 2018-19 and 2019-20, Public Works incurred
approximately $31,000 in contract costs. Public Works uses a third-party contractor for hazardous waste
removal and clean-up services at encampments. Hazardous waste includes waste such as hypodermic
needles, feces, and sewage.

Cost Analysis Methodology


Calculating Labor Costs
1. Identified staff by position and the percentage of their total time spent on encampment-related
work in fiscal years 2018-19 and 2019-20.
2. Identified one individual per position and obtained the corresponding Oracle report that shows
actual and fully burdened labor costs and removed overtime costs as most overtime
assignments were unrelated to work at encampments.
3. Applied the number of positions per classification to the labor cost identified in step two.
4. Added each employee’s annual labor cost to arrive at the department’s total encampment-
related labor cost for each fiscal year.

Calculating Equipment Costs


1. Obtained the Public Works’ rental report for equipment which shows monthly rental rates for
each piece of equipment.
2. Obtained the list of equipment used for operating closures, cleanings, and garbage services and
identified the monthly rental cost for each piece of equipment.
3. Multiplied the monthly rental cost for each piece of equipment by 12 months then added the
cost of all items to arrive at the annual equipment rental cost.
4. Multiplied the annual equipment rental cost by 80 percent because KOCB works on EMT
operations 80 percent of the week.

Calculating Hazardous Waste Contract Costs


1. Identified annual payments to Public Work’s hazardous waste contractors for fiscal years 2018-
19 and 2019-20.
2. Public Works estimated that 15 percent of hazardous waste payments are related to
encampments. Applied 15 percent to all payments made to the hazardous waste contractor in
FY 2018-19 to estimate encampment-related hazardous waste payments.

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3. For the first half of FY 2019-20, the same methodology as the step above was used to calculate
encampment-related hazardous waste payments. Starting the second half of the fiscal year, the
City started using specific codes to track encampment-related costs, so these codes were used
to identify encampment-related costs in the second half of FY 2019-20.

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Police Department
As Exhibit 17 shows, we estimate that the Police Department incurred approximately $3.1 million in
costs associated with encampment activities in fiscal years 2018-19 and 2019-20.
Exhibit 17: Police Department’s cost of encampment activities for fiscal years 2018-19 and 2019-20
Oakland Police Department FY 2018-19 FY 2019-20 % Change
Homeless Outreach Team Labor $829,000 $875,000 6%
Abandoned Auto Unit Labor $372,000 $432,000 16%
Patrol Labor $268,000 $321,000 20%
Total $1,469,000 $1,628,000 11%
Combined Total $3,097,000

As Exhibit 17 shows, the Police Department incurred an estimated $1.5 million in encampment-related
costs in FY 2018-19 and another $1.6 million in FY 2019-20. The Police Department’s costs are for labor
costs associated with the Homeless Outreach Team, the Abandoned Auto Unit, and Patrol costs
associated with responding to 911 emergencies at encampments.

Homeless Outreach Labor: In fiscal years 2018-19 and 2019-20, we estimate the Police Department’s
staff incurred approximately $1.7 million in costs associated with encampment activities to provide
support at closures, cleanings, and garbage services. The Police Department’s Homeless Outreach Team
has three employees, a Police Sergeant and two Police Officers, who dedicated 100 percent of their time
to encampment-related work. In some instances, additional officer support is needed during larger
operations to provide safety to the Public Works’ crews. When additional officers are needed, the Police
Department pays the officer’s overtime to work at the encampment interventions. We could not
estimate the cost of the additional officers for all of FY 2018-19 and the first seven months of FY 2019-20
because the Police Department did not start tracking the overtime costs associated with encampment
activities until February 2020. Based on overtime data provided by the Police Department, the overtime
costs for additional officers between February and June 2020 totaled $7,000. During this period, the City
was conducting fewer interventions due to COVID. Therefore, we could not develop an accurate
estimate of these costs for the two fiscal years and excluded it from our analysis.

Abandoned Auto Unit Labor: In fiscal years 2018-19 and 2019-20, we estimate that the Police
Department incurred over $800,000 in labor costs in both fiscal years to provide support at moderate to
large encampment closures. The Abandoned Auto Unit is responsible for traffic control and tagging and
towing vehicles at encampments when necessary. On average, 6 to 10 civilian technicians from the
Abandoned Auto Unit spend between 10 to 35 percent of their time on encampment-related work.

Patrol Labor: In fiscal years 2018-19 and 2019-20, we estimate that the Patrol staff incurred nearly
$600,000 in labor costs associated with responding to 911 emergency calls at encampments. Patrol staff
responded to a total of 1,459 calls at encampments in both fiscal years.

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Additionally, the Police Department responded to 19 homicides at encampments in calendar year 2020.
According to Police Department staff, homicides require much more intensive labor than other crimes
therefore, its encampment-related costs may be higher than reported in this analysis.

Cost Analysis Methodology


Calculating Abandoned Auto Unit/Homeless Outreach Team Labor Costs
1. Identified staff by position and the percentage of their total time spent on encampment-related
work in fiscal years 2018-19 and 2019-20.
2. Obtained an Oracle report that shows actual and fully burdened labor costs for the employees
identified in step one.
3. Applied the percent of time worked on encampments to the average labor costs identified in
step two for each position.
4. Added each employee’s annual labor cost to arrive at the department’s total encampment-
related labor cost for each fiscal year.

Calculating Patrol Labor Costs


1. Obtained the Police Department’s dispatch data for fiscal years 2018-19 and 2019-20 and
isolated calls related to encampments.
2. Calculated the percent of encampment-related calls to all calls received by the Police
Department’s Dispatch Center for both fiscal years.
3. Applied the percent of encampment-related calls to the Police Department’s Patrol costs for the
respective fiscal year to arrive at estimated Patrol labor costs for each fiscal year.

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Human Services Department
As Exhibit 18 shows, we estimate Human Services incurred approximately $2.1 million in costs in fiscal
years 2018-19 and 2019-20.

Exhibit 18: Human Services’ cost of encampment activities for fiscal years 2018-19 and 2019-20
Human Services Department FY 2018-19 FY 2019-20 % Change
Labor $232,000 $230,000 -1%
Health and Hygiene Services $226,000 $750,000 232%
Street Outreach Services $353,000 $353,000 0%
Total $811,000 $1,333,000 64%
Combined Total $2,144,000

As Exhibit 18 shows, Human Service incurred a combined total of $2.1 million in costs in the two fiscal
years, of which $811,000 was incurred in FY 2018-19 and $1.3 million in FY 2019-20. Total expenditures
increased 64 percent between fiscal years 2018-19 and 2019-20. As shown above, the expenditures
were for: Labor, Health and Hygiene Services, and Street Outreach Services. These items are described
below.

Labor: In fiscal years 2018-19 and 2019-20, Human Services incurred approximately $462,000 in labor
costs associated with encampment activities. These costs include a portion of the salaries and benefits
of four Human Services staff who are responsible for attending EMT meetings, managing contracts for
encampment services, providing outreach services, managing hygiene interventions, and other
encampment-related activities.

Health and Hygiene Services: In fiscal years 2018 and 2019, Human Services incurred costs of nearly
$1 million on health and hygiene services at encampments. Human Services provides health and hygiene
interventions at encampments by providing portable toilets, wash stations, and mobile showers. Human
Services has managed these interventions since 2017. A more formal program was developed in late
2018; and, in early 2019, Human Services created a full-time direct services position within the
department to provide outreach specifically to support encampments in managing hygiene
interventions. Starting in the spring of 2020, due to the COVID pandemic, the number of encampment
sites receiving hygiene interventions was increased from 20 to 40.

Street Outreach Services: In fiscal years 2018-19 and 2019-20, Human Services incurred over
$700,000 in costs associated with contracted street outreach at encampments. Current street outreach
services include general outreach to unsheltered individuals at encampments to build relationships,
ensure basic needs are met, connect people to needed shelter and services, assist with connections to

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housing through the Coordinated Entry System,15 and assist people to obtain documents such as
identification and social security cards. In addition, Human Services’ outreach teams provide site profiles
of encampments that may be scheduled for an intervention.

Human Services’ work extends well beyond services provided to informal, unsanctioned encampments.
In FY 2019-20, Community Housing Service’s16 adopted budget was $19.4 million. In FY 2020-21, the
adopted budget increased to approximately $48.5 million, reflecting the State of California HEAP and
HHAP funds of approximately $19 million (approved by City Council in May 2020 for expenditure in FY
2020-21 and beyond) and other funds allocated to address the rising cost of the homelessness crisis.
Recent funds received from the state and federal governments can be spent over multiple years and
have very specific funding requirements that limit their use. Most of these funds are used for homeless
services outside the scope of encampment management. Human Services oversees the City’s full array
of services in response to addressing and ending homelessness for Oakland residents. These services
include

• crisis response interventions such as street outreach, street based intensive case management
(housing navigation), the Community Cabins program, and the Safe RV Parking Program,
• permanent shelter facilities for singles and families,
• transitional housing programs for unsheltered residents,
• permanent housing interventions (short-term and long-term subsidies, services to support
people in housing),
• coordinated Entry – Human Services is the regional lead for implementing the Coordinated Entry
system in Oakland,
• employment services for people who are unsheltered,
• homeless Prevention services to keep those most at risk of homelessness off the streets,
• hunger relief including the annual Thanksgiving dinner and brown bag distribution,
• coordination with County Health Care Services, Oakland Housing Authority, state agencies, and
others to leverage and strengthen the system of support, and
• capacity building and investments in growing local, black-led agencies to support their work.

Cost Analysis Methodology


Calculating Labor Costs
1. Identified staff by position and the percentage of their total time spent on encampment-
related work in fiscal years 2018-19 and 2019-20.

15
The Coordinated Entry system is a process developed to ensure all people experiencing a housing crisis have fair
and equal access and are quickly identified, assessed for, referred, and connected to housing and assistance based
on their strengths and needs
16
Community Housing Services is a service area within the Human Services Department that administers contracts
and partners with nonprofits to assist the homeless and near-homeless community with temporary shelter,
hotel/motel vouchers, rental assistance, eviction prevention, transitional, and supportive and special needs
housing.

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2. Obtained Oracle report that shows actual and fully burdened labor costs for each employee
identified in step one for the two fiscal years.
3. Applied the percent of time worked on encampments to each employee’s annual labor costs
identified in step two.
4. Added each employee’s annual labor cost to arrive at the total labor cost for each fiscal year.

Calculating Health, Hygiene, and Street Outreach Costs


1. Obtained and reviewed documentation from Human Services to identify health and hygiene and
street outreach costs.

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Fire Department
As Exhibit 19 shows, we estimate the Fire Department incurred costs of approximately $1.8 million on
encampment activities in fiscal years 2018-19 and 2019-20.

Exhibit 19: Oakland Fire Department’s cost of encampment activities in fiscal years 2018-19 and 2019-20
Fire Department FY 2018-19 FY 2019-20 % Change
Fire Prevention Labor $279,000 $397,000 42%
Fire Suppression $438,000 $599,000 37%
Hazardous Waste Removal Contract $16,000 $36,000 125%
Total $733,000 $1,032,000 41%
Combined Total $1,765,000

As Exhibit 19 shows, the Fire Department incurred $733,000 in costs on encampment activities in FY
2018-19 and $1 million in FY 2019-20. These costs include labor costs for Fire Prevention staff, the cost
of fire suppression, and contracts associated with hazardous material clean up.

Fire Prevention Labor: In fiscal years 2018-19 and 2019-20, the Fire Prevention Bureau (Fire
Prevention) incurred an estimated $676,000 in labor costs for encampment activities. Fire Prevention
staff inspects encampments for fire hazards, investigate causes of fires at encampments, and approve
removal of hazardous waste at encampments. Four Fire Prevention staff are assigned to work on
encampment-related work, including an Assistant Fire Marshal, a Fire Investigator, a Fire Inspector, and
a Hazardous Materials Inspector. Although these positions are assigned to work on encampments, they
do not spend all their time on encampment-related work. Between the four positions, the time spent on
encampments work ranged from an estimated 15 percent to 80 percent of their time.

Fire Suppression: The Field Operations Bureau is responsible for emergency medical response, fire
suppression, mitigation of disasters, and rescue activities. In fiscal years 2018-19 and 2019-20, we
estimate that fire suppression incurred over $1 million in labor and equipment costs associated with
responding to fires at encampments. In fiscal years 2018-19 and 2019-20, the Field Operations staff
responded to nearly 1,000 calls at encampments. The Fire Department also responds to medical
emergencies at encampment; however, the department was unable to determine the number of calls
received for medical emergencies at encampments. Thus, our estimate of the Fire Department’s costs
does not include the cost of responding to medical emergencies at encampments.

Hazardous Waste Removal Contract: In fiscal years 2018-19 and 2019-20, the Fire Department spent
$52,000 for payments to contractors for hazardous material clean-up at encampments.

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Cost Analysis Methodology
Calculating Fire Prevention Labor Costs
1. Identified staff by position and the percentage of their total time spent on encampment-related
work in fiscal years 2018-19 and 2019-20.
2. Obtained an Oracle report that shows actual and fully burdened labor costs for each employee
identified in step one for the two fiscal years.
3. Applied the percent of time worked on encampments to each employee’s annual labor costs
identified in step two.
4. Added each employee’s annual labor cost to arrive at the department’s total encampment-
related labor cost for each fiscal year.

Calculating Fire Suppression Costs


1. Obtained the number of calls, by fiscal year, for incidents at homeless encampments.
2. Obtained the cost of a single response by fiscal year.
3. Assumed 75 percent of calls for service for incidents at homeless encampments required a
single engine or single response.
4. Multiplied 75 percent of the total calls by the cost of a single engine cost to calculate the annual
cost of using a single engine.
5. Assumed the remaining 25 percent of calls for service at homeless encampments required a
larger engine response.
6. Calculated a larger engine response cost by adding the cost for a Battalion Chief, three engine
companies, and one truck company to calculate the cost per incident.
7. Multiplied 25 percent of the total calls for incidents at homeless encampments to the cost
calculated in step 6.
8. Finalized annual cost by adding the annual single response call cost with the annual larger
engine response call cost.

Calculating Hazardous Waste Removal Contract


1. Identified annual payments to the Fire Department’s hazardous waste contractor for fiscal years
2018-19 and 2019-20.
2. Identified total annual payments for both fiscal years. For FY 2019-20, we divided encampment-
related costs ($36,406) by the total annual payments to the third-party contractor, to determine
that encampment-related payments represented 25 percent of OFD's total hazardous waste
payment.
3. For FY 2018-19, because OFD did not track costs specific to encampments, we used the
previously identified 25 percent in step 2 above and applied this percentage to the FY 2018-19
annual costs to arrive at encampment-related costs.

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City Attorney’s Office
As Exhibit 20 below shows, we estimate the City Attorney incurred over $1.2 million in costs associated
with encampment activities in fiscal years 2018-19 and 2019-20.

Exhibit 20: City Attorney’s cost of encampment activities in fiscal years 2018-19 and 2019-20
City Attorney’s Office FY 2018-19 FY 2019-20 % Change
Labor $413,000 $792,000 92%
Expenses $2,000 $30,000 1400%
Total $415,000 $822,000 98%
Combined Total $1,237,000

As Exhibit 20 shows above, the City Attorney incurred a combined total of over $1.2 million in costs in
the two fiscal years, of which $415,000 was incurred in FY 2018-19 and $822,000 in FY 2019-20, an
increase of 98 percent between the two fiscal years. The City Attorney’s costs associated with
encampments increased by 98 percent between fiscal years 2018-19 and 2019-20, primarily due to the
number of lawsuits filed against the City following the Martin v. Boise decision issued by the 9th Circuit
Court of Appeals in September 2018.

Labor: The City Attorney’s labor costs associated with encampment activities amounted to $413,000 in
FY 2018-19, and $792,000 in FY 2019-20. Much of these costs were incurred defending the City in
lawsuits and state agency enforcement actions. In addition, substantial costs were incurred providing
legal services and advice to multiple departments and offices including: Human Services, Fire, Public
Works, Housing and Community Development, Transportation, Police, City Administrator, and the
Mayor’s Office, on a broad range of encampment-related policies, legislation, reports, services and grant
contracts, leases and other real property transactions, and other matters related to encampments.

Expenses: The City Attorney incurred expenses associated with encampment activities of
approximately $2,000 in FY 2018-19, and approximately $30,000 in FY 2019-20. These expenses include
support staff and litigation expenses such as depositions, mediation, and court transcripts.

Cost Analysis Methodology


1. Obtained and reviewed the documentation from City Attorney’s office to identify the cost of
labor and expenses.

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City Administrator’s Office
As the Exhibit 21 below shows, we estimated the City Administrator’s Office incurred costs of $487,000
on encampment activities for fiscal years 2018-19 and fiscal years 2019-20.

Exhibit 21: City Administrator’s cost of encampment activities for fiscal years 2018-19 and 2019-20
City Administrator FY 2018-19 FY 2019-20 % Change
Labor $191,000 $296,000 55%
Total $191,000 $296,000 55%
Combined Total $487,000

As Exhibit 21 above shows, the City Administrator’s office incurred a combined total of $487,000 in labor
costs in the two fiscal years. Of this amount $191,000 was incurred in FY 2018-19 and $296,000 in FY
2019-20, an increase of 55 percent between the two fiscal years.

Labor: The City Administrator’s office coordinates the City’s cross-departmental and inter-agency
responses related to homelessness. The City approved the creation of the Homeless Administrator
position in June 2019 during the FY 2019-21 budget deliberations, to serve as the central coordinator of
homelessness.

The City Administrator’s encampment-related labor costs include one Assistant to the City Administrator
in both fiscal years and one Homeless Administrator in FY 2019-20. These positions spent between 25 to
75 percent of their time on encampment-related work, and as the Homeless Administrator was brought
online, the Assistant to the City Administrator’s time was decreased accordingly.

Cost Analysis Methodology


1. Identified staff by position and the percentage of their total time spent on encampment-related
work in fiscal years 2018-19 and 2019-20.
2. Obtained Oracle reports that show actual and fully burdened labor costs for the employees
identified in step one.
3. Applied the percent of time worked on encampments to the average labor costs identified in
step two for each position.
4. Added each employee’s annual labor cost to arrive at the department’s total encampment-
related labor cost for each fiscal year.

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Department of Transportation
As Exhibit 22 below shows, we estimate that Transportation incurred over $300,000 in costs associated
with encampment activities in fiscal years 2018-19 and 2019-20.

Exhibit 22: Transportation’s cost of encampment activities for fiscal years 2018-19 and 2019-20
Department of Transportation FY 2018-19 FY 2019-20 % Change
Labor $79,000 $77,000 -3%
Materials and Equipment $89,000 $68,000 -24%
Total $168,000 $145,000 -14%
Combined Total $313,000

As Exhibit 22 above shows, Transportation incurred $313,000 in encampment-related costs in fiscal


years 2018-19 and 2019-20. These costs were for labor, materials, and equipment.

Labor: In fiscal years 2018-19 and 2019-20, we estimate Transportation incurred approximately
$156,000 in labor costs. Transportation staff works on electrical issues that occur at encampments such
as illegal wire splices and wire thefts. Specifically, they perform an analysis of the impact to the electrical
system and perform repairs. Additionally, Transportation provided KOCB with a heavy equipment
operator to assist with encampment interventions. In FY 2019-20, however, this position was
transferred to Public Works.

Materials and Equipment: In fiscal years 2018-19 and 2019-20, we estimate that Transportation
incurred approximately $157,000 for cost of materials and equipment. Materials used to fix the
compromised electrical infrastructure included electrical wiring, traffic signal wiring, electrical street
light fixtures, pull box covers, electrical cabinets, locks, concrete, and other necessary electrical
components.

Cost Analysis Methodology


DOT uses work orders to document work performed at encampments. Work orders specify labor,
material, and equipment costs.

Calculating Labor, Materials and Equipment Costs


1. Obtained and reviewed encampment-related work order data.
2. Identified the cost of labor, materials, and equipment for fiscal years 2018-19 and 2019-20.

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Department of Parks, Recreation and Youth Development
As Exhibit 23 below shows, we estimate that Parks, Recreation and Youth Development incurred costs of
over $200,000 related to encampment activities in fiscal years 2018-19 and 2019-20.

Exhibit 23: Parks, Recreation and Youth Development cost of encampment activities for fiscal years
2018-19 and 2019-20
Parks, Recreation and Youth Development FY 2018-19 FY 2019-20 % Change
Labor $88,000 $116,000 32%
Total $88,000 $116,000 32%

Combined Total $204,000

As Exhibit 23 shows, we estimate that Parks, Recreation and Youth Development incurred $88,000 in
costs related to encampment activities in FY 2018-19 and another $116,000 in FY 2019-20.

Labor: Parks, Recreation and Youth Development’s (PRYD) role related to encampment activities is to
refer encampment issues to the EMT and to regularly attend the EMT meetings. PRYD is heavily
impacted by homeless encampments located on City parks and recreation centers, but it does not play a
role on the day of an intervention. We estimate that PRYD incurred over $200,000 in labor costs. This
includes two Recreation General Supervisors, six to seven Recreation Supervisors, one Facilities
Manager, and one Recreation Center Director. These positions spent between 5 to 8 percent of their
time on encampment-related work.

Cost Analysis Methodology


1. Identified staff by position and the percentage of their total time spent on encampment-related
work in fiscal years 2018-19 and 2019-20.
2. Obtained an Oracle report that shows actual and fully burdened labor costs for the employees
identified in step one.
3. Applied the percent of time worked on encampments to the average labor costs identified in
step two for each position.
4. Added each employee’s annual labor cost to arrive at the department’s total encampment-
related labor cost for each fiscal year.

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Mayor’s Office
As the Exhibit 24 shows, we estimate the Mayor’s Office incurred $86,000 in costs related to
encampment activities in fiscal years 2018-19 and 2019-20.

Exhibit 24: Mayor’s Office cost of encampment activities for fiscal years 2018-19 and 2019-20
Mayor’s Office FY 2018-19 FY 2019-20 % Change
Labor $12,000 $74,000 517%
Total $12,000 $74,000
Combined Total $86,000

As Exhibit 24 shows, the Mayor’s Office incurred a combined total of $86,000 in costs in the two fiscal
years, of which $12,000 was incurred in FY 2018-19 and $74,000 in FY 2019-20.

Labor: The Mayor’s Office’s role is to attend EMT meetings and engage in policy discussions related to
encampment activities. However, they do not play a role on the day of an intervention. In FY 2018-19,
the labor cost includes one staff who participated in EMT and policy meetings. In FY 2019-20 the labor
cost included a Homeless Policy Director17 whose role is to serve as the Mayor’s chief policy advisor to
address Oakland’s homeless crisis, represent the Mayor in key local, regional, and statewide efforts, and
to help build public-private partnerships to test and evaluate innovative homelessness interventions.
These positions spent between 5 and 50 percent of their time on encampment-related work in the two
fiscal years.

Cost Analysis Methodology


1. Identified staff by position and the percentage of their total time spent on encampment-related
work in fiscal years 2018-19 and 2019-20.
2. Obtained Oracle report that shows actual and fully burdened labor costs for the employees
identified in step one.
3. Applied the percent of time worked on encampments to the average labor costs identified in
step two for each position.
4. Added each employee’s annual labor cost to arrive at the department’s total encampment-
related labor cost for each fiscal year.

17
This position is funded by a private grant.

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CITY OF OAKLAND

CITY HALL • 1 FRANK H. OGAWA PLAZA • OAKLAND, CALIFORNIA 94612


Office of the City Administrator (510) 238-3301
Edward D. Reiskin FAX (510) 238-2223
City Administrator TDD (510) 238-3254

April 7, 2021

The Honorable Courtney Ruby


Oakland City Auditor
1 Frank Ogawa Plaza, 4th Floor
Oakland, CA 94612

RE: City Administrator’s Response to the Homelessness Intervention Performance Audit

Dear City Auditor Ruby:

The City Administrator’s Office appreciates the performance audit of the City of Oakland’s homeless
encampment management interventions and activities. Attached is management’s response to the
following recommendations:

• Enhance encampment intervention activities;


• Capture and identify emergency calls to encampments, including 311 Call Center responses;
• Develop systems for tracking and monitoring costs associated with encampment activities; and
• Implement more formal systems to manage encampment activities.

I want to thank you and your staff for the open communication during this audit. Management was kept
up to date on all progress.

Sincerely,

Jason Mitchell, Assistant City Administrator on behalf of Edward


D. Reiskin, City Administrator

cc: LaTonda Simmons, Assistant City Administrator

Attachments: City Administration’s Recommendation Implementation Plan Matrix

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Office of the City Auditor

1 To enhance its encampment intervention activities, the City Administration should:

1. Implement an organizational structure for the • Create EMT org chart CAO 6/2021
EMT that includes defined roles, responsibilities • Draft Operations Command statements for
and authority, including a clearly defined each department
decision-making process.
• Document workflow for complaints and
interventions
• Prepare decision matrix per workflow

2. Modify its encampment schedules to better • Create Intervention Schedule CAO 9/2021
document the types of interventions, the • Create an Intervention Project Scope Template
rationale for the intervention, the date of the
intervention, the number of staff needed for the
intervention, and the number of hours needed
to complete the intervention.

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Office of the City Auditor

3. Work with the EMT to develop a more user- • Engage IT for Needs Assessment/ Business CAO 5/2021- 1/2022
friendly system for tracking encampment Analysis
activities. This system should include drop-down • Assess/determine system needs
menus to provide uniform naming conventions,
• Identify systems/product/costs
as well as stronger controls to ensure that
information on encampment activities are
complete and consistently documented.

4. Establish written criteria for determining which • Identify criteria per the EMP, Fire Safety Codes, CAO/HSD 7/1/2021
encampments should receive garbage services, and other guiding documents
portable toilets, and other hygiene services, and 9/30/2021
• Draft intervention models using criteria
document which encampments are to receive
• Formalize/Adopt intervention models per 10/1/2021
these services based on these criteria. criteria options

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Office of the City Auditor

5. Modify the Encampment Management Policy to • Establish client outreach intervention plan CAO/HSD 5/25/2021
address outreach strategies prior to template that delineates staff and provider
interventions. The outreach strategies should roles
7/1/2021
include: • Incorporate template within provider protocols
• Establishing specific outreach goals • Identify electronic systems for documenting 7/15/2021
• Defining and expanding roles and the work and sharing metrics
responsibilities for all stakeholders involved, 8/1/2021
• Identify funding and support for systems
including City staff and contracted service
providers
• Ensuring adequate funding
• Implementing monitoring and reporting
protocols to ensure internal and external
stakeholders can track the effectiveness of
outreach strategies

6. Develop policies and procedures to document • Staff will create SOP to track service offer CAO/HSD Draft reqs
the City’s outreach efforts at encampments, details and outreach regularity 5/1/2021
including the outreach provided, the acceptance • Staff will establish digital and manual intake Pilot (Scope
of services, and the alternative shelter offered. methods and reporting to track outreach TBD subject to
dev of APP)
• Staff will prepare reports and audit client 6/1/2021
interaction periodically to evaluate,
performance, consistency, and other trends Finalize
9/1/2021

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Office of the City Auditor

7. Evaluate other cities’ methods for informing • Staff will contact comparable cities to review CAO/HSD 9/15/2021
encampment residents of impending notification methods for interventions
interventions so that encampment residents are • Staff will modify procedures to align with best
adequately notified of scheduled interventions. practices

8. Take appropriate actions to ensure City staff • Staff instituted an inventory form to verify CAO/OPW 3/2021
comply with the Standard Operating Procedure allowable items for storage and disposal of
for the bag-and-tag process. non- storable items consistent with SOP
• Staff now requires 2nd level validation and sign
off for bag and tag inventories

9. Evaluate other cities’ use of storage facilities to • Staff will follow up w/Los Angeles, San Jose and CAO/HSD/ OPW 7/2021
provide alternatives to the bag-and-tag process. other comparable cities to assess practice on
bag and tag procedures
• Staff will modify City procedures to adhere to
best practices.

10. Develop a clear, comprehensive policy for • Research/analyze policy on transportation HSD/CAO 5/2021
transportation assistance following an models, determine costs
encampment closure or re-closure. The City 8/2021
• Draft recommendations, including funding
contracts should align with any policy changes. options
• Implement recommendation adopted, revise
agreements; Pending funding approval

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Office of the City Auditor

2 To capture all emergency calls to encampments, the Police Department should:

11. Modify its call reports to identify when staff • The Communications Division uses incident OPD 11/2021
respond to encampment calls. type “encmp” for complaints regarding
encampments and officer coding when clearing
encampment related calls. Due to systems
limitations, only one incident code can be
applied with a limit of 5 disposition codes
which can further describe the incident. If the
call is crime related, the incident type re: the
crime is applied in CAD and the department
also applies the disposition code “encmp”
when possible.
• Implementation of the new CAD system
(Premier One CAD) will allow unlimited
disposition codes.
• Until then, staff has asked Motorola, the
current CAD vendor, to help identify more
efficient tracking methods.
• Staff will receive instruction to apply
encampment codes consistent with the
forthcoming definition created by these
recommendations.

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Office of the City Auditor

To more comprehensively identify emergency calls associated with encampments, the Fire Department should:

12. Work with the records management software • March 2021 Oakland Fire Dispatch Center The Fire Dispatch 5/2021
vendor and Fire Dispatch Center to establish a created an Incident Type and a Disposition Center
unique Incident Type that will allow the code for all medical calls at encampments. Fire
officers shall use the disposition code upon
department to distinguish medical emergency
clearing the location to accurately track such
calls at encampments from all other medical
calls. Fire Dispatch will manage the data
emergencies. Further, the Fire Department collection for these incidents, and will add
should ensure staff use the appropriate incident type figures to monthly and annual
disposition code upon clearing the location. reports.

To address the concerning 311 Call Center response times, the City Administration should:

13. Evaluate both the integrity of the 311 Call • Explore possible implementation and CAO/EMT 3/2023
Center data and the resolution of calls regarding integration of complaint systems
encampments. • Determine resources
• Establish an accountability management plan
• Ensure resolution and reporting of request

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Office of the City Auditor

3 To provide the City with systems for tracking and monitoring costs associated with encampment activities, the City should:

14. Document the amount of time spent, and staff • Staff will create and utilize logs for the CAO/HSD 7/2021
needed, on encampment interventions such as providers and staff planning and execution of
closures, re-closures, cleanings, and hygiene field activities
services.

4 To implement more formal systems to manage encampment activities, the City should:

15. Develop written goals and objectives for its • Draft operational goals/objectives/ mission CAO 6/2021
encampment management activities. These
goals and objectives should formally
communicate what the City hopes to achieve
with its encampment management activities.

16. Develop a strategic plan that includes written • Using policy documents, establish goals for CAO/All 1/2022
strategies for achieving its encampment department functions, standards, methods of Departments
management goals and objectives and establish evaluation
formal systems for assessing the City’s progress
in implementing these strategies.

17. Develop annual work plans identifying goals and • Analyze operations trends CAO/All 7/2021
deadlines for the next year and the strategies Departments
• Establish full cycle goals
for achieving them.

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Office of the City Auditor

18. Develop a formal comprehensive budget for • From tasks, document all supported funding CAO 7/2021
encampment management activities including
all direct and indirect costs.

19. Establish funding/project codes to track • Meet with Finance/Budget to assign CAO/All 9/2021
expenditures for encampment-related activities funds/project codes for use by all departments Departments
across City departments. supporting encampment management
activities subject to fund use restrictions

20. Perform a staffing analysis to assess the City’s • Assess EMT activity completion by intervention CAO/All 9/2021
staffing requirements for encampment type Departments
management activities. The staffing analysis • Assess budgeted support
should not only address the number of staff
• Establish annual goals by intervention
needed to carry out encampment management
activities, but should also address the • Cost staffing support to # of proposed
interventions
appropriate mix and composition of staff
needed to effectively administer the new
encampment policy. This staffing analysis, at
minimum, should assess the need for:
• Police officers providing the current level of
security at encampment interventions
• Staff resources needed to monitor and
enforce the encampment policy
• Administrative staff needed to improve
recordkeeping

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Office of the City Auditor

21. Clearly define and document roles, • Using draft Operations Command document, CAO/All 9/2021
responsibilities and authority of all staff working create member authority/role for each Departments
on encampment activities, to ensure all staff department
have a shared understanding of their respective
roles, responsibilities, authority, and the
expectations they hold for one another.

22. Develop and implement written policies and • Establish descriptions for the execution of tasks CAO/All 1/2022
procedures for carrying out all its encampment Departments
• Establish definition of “Encampment”
management activities. These policies and
procedures should include the following: • Establish Encampment Oversight standards
• Establish a definition, including criteria, for the • Establish Encampment Enforcement standards
term “encampment” and thresholds for
• Establish Racial Equity Analysis Scope with
responding to and providing services to the semi-annual review deadlines
various encampments
• How the City will monitor encampments to
ensure compliance with the new encampment
management policy
• How the City will enforce the new encampment
policy when encampments are not complying
with the new encampment management policy
• How the City conduct racial equity analysis and
the semi-annual review to ensure the desired
outcomes are achieved

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Office of the City Auditor

23. Develop data collection systems that includes • Engage IT for Assessment/Analysis CAO 5/2021- 3/2022
the following: • Assess/determine system needs
• Information needed to measure the City’s
• Identify systems/ product/costs
progress in achieving its encampment
management goals and objectives
• Activity reports that provide information to
management such as the number of
interventions conducted by types, the
number of encampments provided various
hygiene services, the number of trash pick-
ups, the amount of garbage removed from
homeless encampments, the number of
inspections conducted of encampments,
condition reports on encampments, the
number of complaints received from
residents and businesses, the number of fire
and medical emergencies at encampments,
crime statistics, emergency response times to
encampments, and the number of
enforcement actions conducted
• Demographic information on encampments
to facilitate the racial equity review and the
semi-annual review to ensure the desired
equity outcomes are achieved

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Office of the City Auditor

24. Assign responsibility for developing and • Engage IT for Assessment/Analysis CAO 5/2021- 3/2022
maintaining a comprehensive master list of • Assess/determine system needs
encampments, which maps the locations of
• Identify systems/ product/costs
encampments, both formal and informal
encampments, including but not limited to,
informal tent or small cabin encampments,
formal encampments, areas where residents are
living in parked vehicles, and safe parking areas.
This master list should include the population
and demographics of the encampments. The
maps should also identify the locations of these
encampments in relation to storm drain inlets
and existing streams, rivers, and flood control
channels, as well as other surface water bodies
within the City to ensure compliance with
federal, state, and regional permits.

25. Develop formal training programs for City staff • Develop and institute Homeless Engagement CAO/HSD 9/2021
working on encampment activities. This training Strategy Guidelines
should include training on crisis interventions • Staff will schedule trainings with partners and staff
and understanding, recognizing, and interacting alike
with encampment residents suffering from
trauma.

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Office of the City Auditor

26. Use the ‘U.S. Substance Abuse and Mental • The City will obtain and review the Toolkit to CAO/All 12/2021
Health Services’ Trauma-Informed Toolkit for incorporate practices into the Encampment Departments
Homeless Services to evaluate how well trauma- Management practices
informed practices are incorporated into the
City’s encampment practices to identify areas
for organizational growth, and make practical
changes using their self-assessment tool-kit.

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