HomeMy WebLinkAbout2023/06/12 - ADMIN - Agenda Packets - City Council - Study Session
AGENDA
JUNE 12, 2023
The St. Louis Park City Council meets in person at St. Louis Park City Hall, 5005 Minnetonka
Blvd. Members of the public can attend the meeting in person, watch by webstream at
bit.ly/watchslpcouncil, or watch on local cable (Comcast SD channel 17/HD channel 859).
Recordings are available to watch on the city’s YouTube channel at
https://www.youtube.com/user/slpcable, usually within 24 hours of the end of the council
meeting or study session.
6:30 p.m. City council study session – council chambers
Discussion items
1. 90 min. Advisory boards and commissions program analysis
2. 30 min. Body worn camera annual update
Written reports
3. Annual stormwater pollution prevention program report
4. Connected infrastructure system wrap-up
The agenda is posted on Fridays on the official city bulletin board in the lobby of city hall and on the text display on
civic TV cable channel 17. The agenda and full packet are available after noon on Friday on the city’s website.
If you need special accommodations or have questions about the meeting, please call 952 .924.2505.
Meeting: Study session
Meeting date: June 12, 2023
Discussion item: 1
Executive summary
Title: Advisory boards and commissions program analysis
Recommended action: None at this time. The purpose of this report is to inform council on the
results of the program analysis by an outside consultant.
Policy consideration: None at this time. Future policy considerations will be presented in
subsequent discussions.
Summary: In 2022, the council directed staff to solicit consultant services to review the current
structure, function and role of the advisory boards and commissions program to ensure
alignment with the city’s strategic priorities. Transformational Solutions and Wiesner Consulting
were selected to complete the analysis and they began work in January of 2023. At this
meeting, the consultant will review the findings of their analysis and recommendations on next
steps.
The review was completed through a public engagement process that worked directly with
commission members, community leaders, council members and city staff. The analysis
includes themes that cut across many existing boards and commissions and an overview of
opportunities to update the program, including redefining, or recommitting the program’s
purpose.
The overall conclusions from the analysis recommend setting a clear and renewed purpose for
the program. Once that initial phase is complete, elements of the program such as recruitment,
method of work, purpose of meetings and the relationship to the city council should be further
clarified. The recommendations point to a need to set the scope of potential programming
based on the available resources of staff and funding that could be supported. A high-level
comparative city analysis is included in the report which indicates that the challenges
encountered with the program are not unique to the City of St. Louis Park.
Financial or budget considerations: N/a
Strategic priority consideration: St. Louis Park is committed to creating opportunities to build
social capital through community engagement.
Supporting documents: Consultant program analysis
Prepared by: Michael Sund, civic engagement coordinator
Reviewed by: Cheyenne Brodeen, administrative services director
Melissa Kennedy, city clerk
Approved by: Kim Keller, city manager
Study session meeting of June 12, 2023 (Item No. 1) Page 2
Title: Advisory boards and commissions program analysis
Discussion
Background: Boards and commissions provide opportunities for the city to engage people in
the democratic process and hear different perspectives that help plan and shape the future of
the community. Ideally, boards and commissions bring people together and create space for
the expression of viewpoints that might not otherwise be heard.
The history of boards and commissions in St. Louis Park aligns with other programs locally and
nationally. When created in the 1960s, boards and commissions represented best practices in
civic and community engagement strategies. As engagement needs and methods have evolved,
many communities are finding a misalignment between the goals of boards and commissions
and the implementation of associated programming. Boards and commissions can be an
effective engagement strategy when they are used to collaborate with the public.
The city currently has ten boards and commissions made up of volunteers with wide -ranging
interests and expertise who care about the community and want to participate in public
service. The charter authorizes the city council to create commissions with advisory powers to
investigate any subject of interest to the city. The city code contains the enacting ordinances for
those bodies, created with the express purpose of acting in an advisory capacity to the city
council. Other boards and commissions derive their authority to conduct specific business from
state statute. Membership requirements, composition, scope of work and authority are varied.
The city council appoints most, but not all, board and commission members.
The city council reviewed the boards and commissions program during two sessions in 2022 on
March 28 and April 22. At that time staff presented reports on the state of the program and
took direction from the council on potential next steps. Staff recommended engaging an
outside consultant to receive and review feedback from various st akeholders in the existing
program and to analyze the program potential in comparison to other board and commission
programs.
The city council supported engaging a consultant to evaluate and provide a recommendation
related to the structure, role, functi on and authority of the city’s boards and commissions
program. Staff recommended the consultant’s evaluation include an analysis of certain topics to
determine:
• Internal and external needs.
• Capacity and resources needed to ensure both staff and council can effectively support
and manage programming going forward.
• Desired objectives and outcomes of programming.
Including this in the broader evaluation of the boards and commission program provide d an
opportunity to assess if the creation of new advisory bodies was the appropriate strategy to
address needs or if opportunities existed to modify or leverage existing programs to achieve
desired outcomes.
Present considerations: The review was completed over the winter and early spring of 2023.
During that time the consultant engaged residents who serve on commissions as well as
community leaders such as cultural liaisons that work in the St. Louis Park Public school district.
Study session meeting of June 12, 2023 (Item No. 1) Page 3
Title: Advisory boards and commissions program analysis
The resulting themes collected during those conversations and the related recommendat ions
are attached to this report.
Next steps: At the June 12 study session, the consultants and s taff will present the report’s
findings and recommendations. No policy direction is requested at that meeting. Staff
anticipates bringing back the item at the June 26 study session for conversation and to ask for
direction to follow the approach outlined below:
1) Building for the future:
a) Phase one: Staff will work with council to set the overall purpose and scope of the
program and to set the policy for commissions going forward based on feedback from
stakeholders included in the report.
b) Phase two: Staff will operationalize the policy set by council in the recruitment and
retention of commission members and set up a process to establish the relationship
between council and the commissions following the direction of the work in phase one .
c) Phase three: Staff will implement the programming and engage in a regular process of
review and alignment with other community and civic engagement programming. Staff
will report to council regularly on the status of the program during the community and
civic engagement system in subsequent years.
2) Valuing the current state:
a) While the goals and purpose of the program are being updated to be in better
alignment, current members will be asked to continue to serve in their current capacity.
During this interim period staff will work to address gaps in the program that can be
resolved through programmatic changes. An abbreviated appointment process will
occur in the event of a vacancy.
Throughout this process stakeholders will continue being informed as the process develops,
including direct feedback on how the information they provided to the consultant will be used.
City of St. Louis Park
Boards and Commissions Assessment
June, 2023
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 4
.
Why does the program have limited participation from certain demographic
and community groups?
How might the application process be limiting participation?
How can time spent serving through this program feel meaningful to
participants?
How can program support staff be most effective in their role?
Overall, better align with the city's vision and strategic priorities.
Overview
Learning Questions
Approach
Survey (30)
Listening sessions and One-on-One Interviews (45)
Review of charter, commission bylaws, city organizational structure
Peer city review (3)
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 5
Topline Messages
There are great building blocks in place. St. Louis Park has the potential
to stand out as a leader in this kind of engagement.
Many cities are taking a look at their Boards and Commissions for
much the same reasons as St. Louis Park--wanting to update, ensure
relevance, be responsive to new demographics and community trends.
The program has evolved over many years, as have community needs.
As things have changed, gaps have emerged. This is normal and to be
expected.
Adjustments to the program can realign goals and practices to more
accurately reflect current strategic priorities.
The themes, implications, and recommendations are things to be
worked through over time, not decided on today or all at once.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 6
What We'll Cover Today
.
Themes gleaned from community and staff input
Themes are things that came up consistently across
respondents. While outliers can be interesting and
important, themes are those things around which there
appears to be substantial concensus.
Implications
Recommendations
Questions/Discussion
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 7
Themes & Implications
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 8
Respondents see serving as a fruitful way to advance their careers, develop
new skills and job prospects, or get involved in local public office.
Respondents are enthusiastic about the opportunity to learn the inner
workings of governing and city functions.
People want to help and have been hanging on and hoping for things to
gel.
People have stuck with it even through the pandemic.
There’s a strong sense of community identity and community service.
Theme # 1: We want to help, and we see value...
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 9
Theme #2: We don’t know what we’re supposed to
be doing.
Respondents report that the way the program is run shifts
depending on city leadership (Council and staff).
Respondents wonder what their role is in relation to the
Council, City Manager, City Staff, and community. They
wonder if they are supposed to be giving input, and if so to
whom and how.
This uncertainty sometimes results in preventing or slowing
momentum.
Lack of clarity hinders the ability of community partners to
promote the program and help recruit new commissioners
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 10
Theme #2: We don’t know what we’re supposed to
be doing (continued).
Respondents (staff, commissioners) connected to
Planning/BOZA and the Housing Authority are very clear on
their purpose and scope, as a result of clear parameters and
statutory requirements. The rest of the respondents are less
clear.
There is lack of clarity about Council expectations, needs, and
motivations for engaging community through this program.
While many respondents said it was nice to have latitude, the
lack of guidance or structure from Council also makes people
feel rudderless or without focus.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 11
...It's frustrating that we simply don't have a purpose. We
have no power or responsibility.
...The most challenging thing is understanding what’s
expected of the commission and how we could better
help the city.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 12
Theme #3: We get mixed messages.
Respondents describe confusion about what they view as
mixed messages. For example:
"You're here to advise council" but they rarely interact with
Council, aren't consistently asked for advice, and there is
no reliable mechanism for interaction or workflow--staff is
the conduit.
"You're an ambassador for the city" but they don't have
authority or mechanisms to communicate with the
community on the City's behalf.
"Commissions are for community input, commissioners
represent community perspective" but there are no
resources or mechanisms for getting input from
community
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 13
Commissioners only interact with Council once a
year (if that), and for a very limited time and
purpose.
For the most part Commissioners don't interact
with other Boards/Commissions, even though
some of the issues overlap.
Commissioners feel discouraged from
communicating with each other due to perceived
limitations of Open Meeting Law
Theme #4: We feel disconnected.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 14
What's frustrating is the poor communication flows between
the three players (the commission, [city staff], and the City
Council). We could get a lot more done if there was more
transparency.
...I think that commissions are a great way to get people
involved, they provide opportunities for Council to be able to
delegate things to commissions...But to be effective they
need to be tended to by City Council. They need to give us
direction. While we are independent, we are desperate to
hear what we can do for them. Without their authority, we
are less impactful.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 15
There is no standardized onboarding/training
The workplan process doesn’t support the charge of
advising city council
There is not a reliable system in place for being
proactive and supporting Council's required needs
Nor is there a reliable system for being reactive in a
timely way as community issues emerge
Regular evaluation and updating the purpose and
relevance of commissions does not occur in a
systematic way
Theme #5: There aren’t systems in place to
support us sufficiently.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 16
...Our committee serves no actual purpose. Without any
actual guidance from the city, we literally make things up
as we go along. Every time someone leaves, there is a
brain drain as there is no centralized location to save
documents, contact, resources, etc. Worse, we have no
way to communicate our work with fellow commissions,
nonprofits, like minded groups, potential partners, or
curious residents.
..I am in a room full of capable people who have no official
structure to serve this city in a meaningful way.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 17
Theme # 6: We don’t see our impact.
Respondents believe they have a lot to
contribute, but they don't feel they are being
utilized well.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 18
...I feel like we plan and discuss a lot of things, but there is
not much happening.
...We haven’t done much of action or community work.
..We share our input with staff, but we don't know where
that goes or if it's used.
...It feels more like I’m just being told what’s happening as
opposed to being a part of any decision making. More of a
rubber stamp than a part of the process.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 19
Theme # 7: Staff is amazing, but they
don’t have capacity.
Universally, Commissioners rave about their staff
liaisons and feel that they go over and above in terms
of effort. However, staff and commissioners alike note
that this is a tiny piece of the staff liaison's overall job,
and they are stretched thin.
In terms of supporting staff liaisons, they don't have
consistent onboarding when they start the role, they
don't have mechanisms for connecting with one
another to compare notes, and there are not
opportunities to think broadly about how
Commissions can serve the strategic priorities of the
City.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 20
...Staff is incredibly organized. As someone who is usually
the organizer in my professional and personal life, it feels
really good to just be able to show up and have really
competent people organizing things for us.
...It is so much work: attending 2 hour monthly meetings at
night, plus workgroups meetings; logistical recording,
coordination, contacts list, reserving meeting spaces,
tracking attendance, orientation, annual 4 hour retreat,
draft agendas...
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 21
There is not cohesion or sense of connection across
Boards and Commissions.
There is not consistency in how commissions operate.
There is not a well articulated overall strategy.
No one is responsible for seeing the whole, bringing it
all together, and directly linking it to strategic
priorities of the city.
How Boards and Commissions are managed shifts
based on the inclinations of whoever is on Council and
whoever is city manager. This is natural, but there is
not a sense of what needs to remain consistent.
Theme # 8: It’s not a cohesive program.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 22
Respondents believe that appointment to
commissions is based on who you know, and
that the people that are most actively
recruited are the people Council and staff
already know.
This mutually reinforces a limited
demographic.
There is little active engagement or
relationship-building to widen the pool.
Theme # 9 It’s who you know…and you don't know
us [community members of groups currently
underrepresented]
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 23
I will put in my time, because you are giving me time.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 24
Virtual participation is prohibited by law.
There is no food, transportation, or child care
considerations.
The way the meetings are run and set up are not
community centric.
Open Meeting law is cited as a reason for obstacles.
The overall expectation of the city is that residents
should and will come to them, and if they don't, it's
assumed that it's because they're not interested or
able.
Theme # 10: Participation is not easy…
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 25
...Robert's Rules [standard parliamentary procedure] is
exclusionary and confusing and makes it difficult to know when
and how to speak up. I don’t always know when is appropriate
for me to challenge or ask questions.
...It's frustrating that there's no virtual option.
...I'm guessing some people don't participate because of the
time of the meetings (mealtimes, evenings), they have kids and
need child care.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 26
Investing in community relationship building.
Housed with community engagement manager with dedicated
staff
Full-time staff dedicated to supporting commission and liaisons
Going to events and community gatherings
Run meetings in rounds to ensure equal participation.
Cities we spoke with were actively seeking to build programs that are
relevant and compelling for the social and demographic shifts that
are underway across the country.
Unified, systematic, and consistent way to run the selection process,
including a standard scoring rubric.
Peer City Reviews--Promising Practices from
Robust Programs
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 27
Work closely with school staff--for instance, a government
class teacher includes board/commission service as an option
for satisfying class requirements
Chair takes active role in mentoring youth--orients, answers
questions, seats on either side of the chair at every meeting.
Youth members are voting members
Youth terms are synchronized with school year, terms are one
year
Peer City Reviews--Youth Engagement
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 28
Implications
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 29
Engagement requires resources--human and financial.
Engagement is not transactional or passive—it’s personal and relationship-
centered
If you’re not getting people with a variety of backgrounds, you’re not asking
people with a variety of backgrounds. They aren’t going to come to you.
Programs require:
Overarching purpose
Cohesive strategy
Clear, regular communication lines
Action and impact
Implications
Action & Impact
Communication
Strategy
Purpose
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 30
Implications
Community-centric programming requires
community-friendly practices, using
methods that don't feel intimidating, with
supports that make it easy to participate.
There is a tremendous opportunity for St.
Louis Park to stand out as Best in Class when
it comes to leveraging Boards and
Commissions to engage residents in the
strategic priorities of the city.
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 31
Recommendations
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 32
In addition, the City should develop a set of considerations that guide their decisions
about creating, combining, sunsetting, or changing the purpose of all of the
Commissions on a regular basis.
Focus On Purpose
What is the purpose of
engagement? Why does the
city want residents engaged?1 What is the purpose of a
Boards and Commissions
Program? How does it tie to
Strategic Priorities?2
What is the purpose of each
Board or Commission?3
Changes and adjustments should be grounded in answers to the following questions;
These questions should be revisited at regular intervals.
How can a Boards &
Commissions Program tie
together/ feel cohesive for
staff, Council, and residents? 4
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 33
For example, if you want them to…Then you need to….
Advise council, research issues council is
considering, provide input on policy
Have regular interaction with the commissions,
identify priorities that you want them to give input
on, and resource the commission to do the
legwork they need to do to be effective; have
mechanisms for regular dialogue
Act as a bridge/ambassador to
community members, both providing
information to community and getting
input from community on priority
issues
Resource and support commissioner activities that
give information and gather input on a regular
basis; build in regular feedback loops directly
between commissions and Council
Come up with their own activities and
implement them
Provide clear parameters for what fits in their
scope, resource and support their activities
sufficiently
Design Supports That Match Purpose (Form
Follows Function)
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 34
In order to have a pool of candidates from diverse communities, it is necessary to
be intentional about and committed to building relationships with them.
Consider:
Tabling at community events and school open houses
Partnering with school and community leaders who are connected with
communities to build awareness of the program; work with school cultural
liaisons
Establish clear measures for tracking diversity (race, gender, age, occupation,
location in the city) at each point in the recruitment and appointment process.
You measure what you treasure.
Establish a common appointment rubric that demonstrates the need and value
of having better representation and reduces unconscious bias (who you know,
favoring those who are most like yourself). A rubric could include a combination
of characteristic related to the purpose of the commission, along with racial and
economic diversity considerations.
Expand the Pool
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 35
Provide support for communities to participate. This can include providing child care or
child care stipends for parent participation; snacks; transit cards; or honorariums to help
reimburse participation related expenses.
Include money in the city budget for the program and be clear and transparent about
the resources available. Be explicit about these supports during recruitment and
appointment.
Make meetings more welcoming and comfortable by running them in ways that put
people at ease, such as:
Explore other facilitation methods such as consensus methods and round robins to
ensure equal participation
Establish mentoring between commissioners, especially youth members
Revisit meeting times, dates, and locations on a regular basis
Develop standard orientation process, that includes training on how the city functions.
Make The Experience Comfortable and Community-
Friendly
Study session meeting of June 12, 2023 (Item No. 1)
Title: Advisory boards and commissions program analysis Page 36
Create a structure for the work that elevates its profile and positions it to support
city work across departments and levels.
Creates synergy between strategic priorities and relationships with residents
Aligns Boards and Commissions with other community oriented aspects of
the city's work
Hire dedicated community engagement staff who:
Supports Boards and Commissions and staff liaisons
Cultivates relationships in the community and personally recruits Board and
Commission candidates
Supports the recruitment and appointment process, including streamlining
the steps; builds consistent onboarding and training practices
Ensures that the program is cohesive, impactful, meaningful, and tied to
strategic priorities
Establish a budget that includes funds for both Commission activities and
community outreach.
Staff and Structure for the Long Term
Study session meeting of June 12, 2023 (Item No. 1)
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Meeting: Study session
Meeting date: June 12, 2023
Discussion item: 2
Executive summary
Title: Body worn camera annual update
Recommended action: Review the body worn camera program policies and audit summary.
Policy considerations:
•Does the council approve of the direction of the body worn camera program?
•Should annual presentations to the council be provided every two years to match the
state biennial audit requirement and supplemented with reports in the off-year?
Summary: Council affirmed the police department body worn camera policy on September 4,
2018, and approved Resolution no. 18-134 directing the police department to report back to
council in six months and annually thereafter regarding:
1.General reflections and learnings from the police department on the implementation
and use of BWC’s
2.Criteria tracked to include, at a minimum, hours of utilization, officer compliance, how
often reports are filed to document when cameras are not turned on, how often and
under what circumstances officers review footage prior to writing reports, requests to
view footage and police department response
3.Any police department proposed changes or updates to the use of BWC's policy
4.Other information that would be useful to the city council and the public to help
understand and evaluate this initial trial and implementation.
The report includes information as directed by Resolution no. 18-134 and is based upon the use
of the body worn cameras from January 1, 2022, through December 31, 2022.
Financial or budget considerations: Body worn/squad camera system costs (including software
and data storage) are approximately $200,000 annually since the start of the program. This cost
is expected to remain stable for the fo reseeable future.
Strategic priority consideration: St. Louis Park is committed to creating opportunities to build
social capital through community engagement.
Supporting documents: Resolution 18-134
Body worn camera policy
In-Car Camera Policy
LOGIS 2023 audit summary
Prepared by: Mikael Garland, police lieutenant
Approved by: Bryan Kruelle, police chief
Approved by: Kim Keller, city manager
Study session meeting of June 12, 2023 (Item No. 2) Page 2
Title: Body worn camera annual update
Discussion
Background
In 2017, the police department began a deliberative process to develop its BWC program. A
defining characteristic of that development effort was the responsibility to create a BWC policy
that reflected the needs of the community. As a demonstration of that commitment, and with
the support of the council, the police department began collaborating with the Human Rights
Commission (HRC), the Police Advisory Commission (PAC) and the Police Multicultural Advisory
Committee (PMAC) to seek input, conduct research and review policy drafts. In addition to its
policy work, the HRC met with department leaders in March 2018 and hosted a community
listening session with the PAC in April 2018. The purpose of this session was to gather public
input and provide a space for important concerns to be raised. An outcome of this engagement
was a recommendation from the HRC for strong BWC policies that emphasized an intention to
protect the community and prevent BWC technology from becoming an intrusive surveillance
tool for government and law enforcement – concerns that helped to serve as a guide for the
eventual policies created.
During policy review and engagement sessions with department leadership, the PAC
emphasized the importance of required audits, and making them public as a demonstrated
commitment to transparency. The PMAC emphasized that ample education about the program
be extended to community members, resulting in the creation of an informational brochure
and online content. The department’s collaboration with the HRC, the PAC and PMAC, led to
the BWC program and its policies earning the trust and support of three critical stakeholder
groups that help shape the police-community relationship.
The council affirmed the BWC policy on September 4, 2018, and passed Resolution no. 18-134
directing the chief of police to report back to council in six months and annually thereafter. The
police department BWC program went live on April 10, 2019, utilizing approximately 60 body
worn cameras and 19 fleet cameras.
2022 results
The information provided in the following three sections is based upon the use of the body
worn cameras in calendar year 2022 (with comparison to previous years where applicable) and
corresponds to the information requested by council in Resolution no. 18-134.
General reflections and learnings from the police department on the implementation and use
of body worn cameras.
Since implementation, police department staff noted the following reflections and learnings
while utilizing the body worn and fleet cameras:
• Use: Officers activate body worn cameras more often than required by policy.
• Records management: The current records management system on Evidence.com
offers streamlined information sharing between partner agencies and city/county
prosecutors. There has been no significant impact to date from public data requests.
• Internal compliance audits: The trimester supervisory audits were put in place at the
start of the program to ensure ongoing compliance with policy as well as proper
application of training. (More detail about audit results appears in the table below.)
Study session meeting of June 12, 2023 (Item No. 2) Page 3
Title: Body worn camera annual update
Criteria tracked to include, at a minimum, hours of utilization, officer c ompliance, how often
reports are filed to document when cameras are not turned on, how often and under what
circumstances officers review footage prior to writing reports, requests to view footage and
police department response.
Since implementation in 2019, department personnel have been consistently diligent in their
application of the policy.
Metric 2020 2021 2022
Number of calls for service 50,668 51,620 46,868
Number of police reports written 7,607 7,894 7,869
Hours of data collected 11,322 12,944 13,240
Number of videos collected 43,919 47,925 47,355
Number of times video reviewed prior to report writing 238 193 223
Policy compliance rate 99.97% 99.97% 99.96%
Number of failure to activate incidents, self-reported 13 14 10
Audited failure to activate rate 0.07% 0.13% 0.67%
Number of public information requests received 6 6 7
Any police department proposed changes or updates to the policy or procedures on body worn
cameras.
The police department completed a required biennial audit of its BWC program in March 2023.
LOGIS was contracted to perform the audit.
Minnesota Statute §13.825 requires law enforcement agencies that use body-worn
cameras to conduct biennial independent audits of the data to determine whether data
are appropriately classified according to this section, how the data are used, whether
the data are destroyed as required under this section, and to verify compliance with the
law. Law enforcement must forward a report summarizing the results of the audit to
the governing body within the jurisdiction and to the Legislative Commission on Data
Practices and Personal Data Privacy.
LOGIS completed their audit and found the police department to be compliant with statute and
reported their results as required. LOGIS made no recommendations and reported no issues
with the police department’s BWC program.
Next steps
Since 2018, the established BWC tracking criteria have recorded consistent results,
demonstrating program effectiveness. As a result, police department leadership recommends
annual presentations to the council change from every year to every other year, to match the
state biennial audit requirement. Staff further recommends supplementing these biennial
presentations with a report to council in the off-year.
Resolution No. 18-134
Resolution prescribing the reporting requirements of the city manager to the
city council regarding the St. Louis Park police departments use of body worn
cameras
Whereas, on September 4, 2018 the city council affirmed the body worn camera (BWC)
policy and directed staff to continue to move forward with the implementation of the BWC
initiative; and
Whereas, transparency and accountability regarding the police departments use of BWC's
is important in order to help maintain the public's trust in the department; and
Whereas, the city of St. Louis Park values continuous learning and improvement as it goes
about providing services to the community.
Now therefore be it resolved by the city council of the city of St. Louis Park that in
addition to the audit and reporting requirements required by state statute for an agencies use
of BWC's, the city manager, with the assistance of the police chief, is directed to provide a
report to the city council within six months of the city council's affirmation of the BWC policy
and annually thereafter that includes, but is not limited to, the following:
General reflections and learnings from the police department on the implementation
and use of BWC's;
Criteria tracked to include, at a minimum, hours of utilization, officer compliance, how
often reports are filed to document when cameras are not turned on, how often and
under what circumstances officers review footage prior to writing reports, requests to
view footage and police department response;
Any police department proposed changes or updates to the "Use of BWC's Policy";
a\ Other information that would be useful to the city council and the public to help
understand and evaluate this initial trial and implementation."
Revi5 ed l9f administration: meted by the City Council September 4, 2018
Thomas K. Harmening, City Manager
Attest:
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Body-Worn Cameras Policy Page 1
City of St. Louis Park, Minnesota
Use of Body‐Worn Cameras Policy
Purpose
The primary purpose of using body‐worn‐cameras (BWCs) is to:
A.Capture evidence arising from a police‐citizen contact.
B.Assist with accurate report writing.
C.Allow for transparency and accountability in policing and protect the civil rights of
the community.
This policy sets forth guidelines governing the use of BWCs and administering the data that
results. Compliance with these guidelines is mandatory, but it is recognized that officers must
also attend to other primary duties and the safety of all concerned, sometimes in circumstances
that are tense, uncertain, and rapidly evolving.
Objectives
The St. Louis Park Police Department has adopted the use of portable audio/video recorders to
accomplish the following objectives:
A.To enhance officer safety.
B.To document statements and events during the course of an incident.
C.To enhance the officer’s ability to document and review statements and actions for
both internal reporting requirements and for courtroom preparation/presentation.
D.To preserve audio and visual information for use in current and future
investigations.
E.To enhance the public trust by preserving factual representations of officer‐citizen
interactions in the form of audio‐video recording.
F.To promote the civility of police‐civilian encounters
G.To provide objective evidence to help resolve civilian complaints against police
officers and the City of St. Louis Park.
H.To protect the civil rights of the community.
I.To assist with training and evaluation of officers.
Policy
It is the policy of this department to authorize and require the use of department‐issued BWCs
as set forth below, and to administer BWC data as provided by law.
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Body-Worn Cameras Policy Page 2
Scope
This policy governs the use of BWCs in the course of official duties. It does not apply to the use
of squad‐based (dash‐cam) recording systems. The Chief of Police or the chief’s designee may
supersede this policy by providing specific instructions for BWC use to individual officers, or
providing specific instructions pertaining to particular events or classes of events, including but
not limited to political rallies and demonstrations where their use might be perceived as a form
of political or viewpoint‐based surveillance. The chief or designee may also provide specific
instructions or standard operating procedures for BWC use to officers assigned to specialized
details, such as carrying out duties in courts or guarding prisoners or patients in hospitals and
mental health facilities. In the event the chief does supersede policy by providing specific
instructions for use, a written report will be submitted to the City Manager.
Definitions
The following phrases have special meanings as used in this policy:
A.MGDPA or Data Practices Act refers to the Minnesota Government Data Practices Act,
Minn. Stat. § 13.01, et seq.
B.Records Retention Schedule refers to the General Records Retention Schedule for
Minnesota Cities.
C.Law enforcement‐related information means information captured or available for
capture by use of a BWC that has evidentiary value because it documents events with
respect to a stop, arrest, search, citation, or charging decision.
D.Evidentiary Value means that the information may be useful as proof in a prosecution
or defense of a criminal action, related civil or administrative proceeding, further
investigation of an actual or suspected criminal act, or in considering an allegation
against a law enforcement agency or officer.
E.General Citizen Contact means an informal encounter with a citizen that is not and does
not become law enforcement‐related or adversarial, and a recording of the event would
not yield information relevant to an ongoing investigation. Examples include, but are not
limited to, assisting a motorist with directions, summoning a tow truck, or receiving
generalized concerns from a citizen about crime trends in his or her neighborhood.
F.Adversarial means a law enforcement encounter with a person that becomes
confrontational, during which at least one person expresses anger, resentment, or
hostility toward the other, or at least one person directs toward the other verbal
conduct consisting of arguing, threatening, challenging, swearing, yelling, or shouting.
Encounters in which a citizen demands to be recorded or initiates recording on his or
her own are deemed adversarial.
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G.Unintentionally recorded footage is a video recording that results from an officer’s
inadvertence or neglect in operating the officer’s BWC, provided that no portion of the
resulting recording has evidentiary value. Examples of unintentionally recorded footage
include, but are not limited to, recordings made in station house locker rooms,
restrooms, and recordings made while officers were engaged in conversations of a non‐
business, personal nature with the expectation that the conversation was not being
recorded.
H.Official duties, for purposes of this policy, means that the officer is on duty and
performing authorized law enforcement services on behalf of this agency.
Training
All users of a BWC will be trained on the cameras operation and this policy prior to deploying
one.
Use and Documentation
A.Officers may use only department‐issued BWCs in the performance of official duties for
this agency or when otherwise performing authorized law enforcement services as an
employee of this department.
B.All officers working uniform patrol, uniform special details, traffic duties, and uniform
school resource officer duties shall use a BWC unless permission has been granted by a
supervisor to deviate from this clause. Plain clothes investigators/officers and
administrators are allowed to use BWC when interacting with citizens, when
appropriate.
C.Officers who have deployed a BWC shall operate and use them consistent with this
policy. Officers shall conduct a function test of their issued BWCs at the beginning of
each shift to make sure the devices are operating properly. Officers noting a
malfunction during testing or at any other time shall promptly report the malfunction to
the officer’s supervisor. As soon as is practical, the malfunctioning BWC shall be put
down for service and the officer should deploy a working BWC. If a BWC malfunctions
while recording, is lost, or damaged the circumstances shall be documented in a police
report and a supervisor shall be notified. Supervisors shall take prompt action to
address malfunctions and document the steps taken in writing.
D.Officers should wear their BWC in a conspicuous manner at the location on their body
and manner specified in training.
E.Officers must document BWC use and non‐use as follows:
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1.Whenever an officer makes a recording, the existence of the recording shall be
documented in the records management system, an incident report, or a citation if
completed.
2.Whenever an officer fails to record an activity that is required to be recorded under
this policy or captures only a part of the activity, the officer must document the
circumstances and reasons for not recording in the records management system or
incident report. Supervisors shall review these reports and initiate any corrective
action deemed necessary.
F.The department will maintain the following records and documents relating to BWC use,
which are classified as public data:
1.The total number of BWCs owned or maintained by the agency;
2.A daily record of the total number of BWCs actually deployed and used by officers
and, if applicable, the precincts in which they were used;
3.The total amount of recorded BWC data collected and maintained; and
4.This policy, together with the Records Retention Schedule.
General Guidelines for Recording
A.This policy is not intended to describe every possible situation in which the BWC should
be activated, although there are many situations where use of the BWC is appropriate.
Officers should activate the BWC any time the user believes it would be appropriate or
valuable to record an incident.
B.Officers shall activate their BWCs when anticipating that they will be involved in,
become involved in, or witness other officers of this agency involved in a pursuit, Terry
frisks, a traffic stop of a motorist, an investigative stop of a pedestrian, searches,
seizures, arrests, response to resistance incidents, any encounter that becomes in any
way hostile, confrontational, or adversarial, and during other activities likely to yield
information having evidentiary value. However, officers need not activate their cameras
when it would be unsafe, impossible, or impractical to do so, but such instances of not
recording when otherwise required must be documented as specified in the Use and
Documentation guidelines, part (E)(2) (above).
C.Officers have discretion to record or not record general citizen contacts.
D.Officers will wear their camera in a conspicuous manner as specified in training. Officers
have no affirmative duty to inform people that a BWC is being operated or that the
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individuals are being recorded. Officers may make an announcement that BWCs are
being used.
E.Once activated, the BWC should continue recording until the conclusion of the incident
or encounter, or until it becomes apparent that additional recording is unlikely to
capture information having evidentiary value. The supervisor having charge of a scene
shall likewise direct the discontinuance of recording when further recording is unlikely
to capture additional information having evidentiary value. If the recording is
discontinued while an investigation, response, or incident is ongoing, officers shall state
the reasons for ceasing the recording on camera before deactivating their BWC. If
circumstances change, officers shall reactivate their cameras as required by this policy
to capture information having evidentiary value. Any decision to discontinue recording
shall be made with respect to the nine policy objectives.
F.Officers shall not intentionally block the BWC’s audio or visual recording functionality to
defeat the purposes of this policy. This does not prevent an officer from temporarily
blocking the visual recording while ensuring audio data is collected during an encounter
with persons who are nude or when sensitive human areas are exposed.
G.Notwithstanding any other provision in this policy, officers shall not use their BWCs or
any other device to record other agency personnel during non‐enforcement related
activities, such as during pre‐ and post‐shift time in locker rooms, during meal breaks, or
during other private conversations, unless recording is authorized as part of a criminal
investigation.
Special Guidelines for Recording
Officers may, in the exercise of sound discretion, determine:
A.To use their BWCs to record any police‐citizen encounter if there is reason to believe the
recording would potentially yield information having evidentiary value, unless such
recording is otherwise expressly prohibited.
B.To use their BWCs to take recorded statements from persons believed to be victims of
and witnesses to crimes, and persons suspected of committing crimes, considering the
needs of the investigation and the circumstances pertaining to the victim, witness, or
suspect. The preferred method of recording a formal statement from a victim, witness
or suspect is using currently approved audio recording devices/software compatible
with records management dictation software.
In addition,
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C.Officers need not record persons being provided medical care unless there is reason to
believe the recording would document information having evidentiary value. When
responding to an apparent mental health crisis or event, BWCs shall be activated as
necessary to document any response to resistance and the basis for it, and any other
information having evidentiary value, but need not be activated when doing so would
serve only to record symptoms or behaviors believed to be attributable to the mental
health issue.
D. Officers should use their BWC and/or squad‐based audio/video systems to record their
transportation and the physical transfer of persons in their custody to hospitals, detox
and mental health care facilities, juvenile detention centers, and jails, but otherwise
should not record in these facilities unless the officer anticipates witnessing a criminal
event or being involved in or witnessing an adversarial encounter or response to
resistance incident.
School Resource Officers
The St. Louis Park Police Department recognizes that the duties and working environment for
School Resource Officers (SRO) are unique within policing. It recognizes the SROs are required
to maintain school safety while keeping the sanctity of the learning environment that the
school provides. SROs are expected to continuously build trusting relationships with students
and staff. SROs often have impromptu interventions with students to deescalate arguments
and/or conflicts. It is with this understanding that the St. Louis Park Police Department provide
special guidelines for SROs and their BWC.
The BWC should be activated in any of the following situations:
(a)When summoned by any individual to respond to an incident where it is likely that law
enforcement action will occur when you arrive.
(b)Any self‐initiated activity where it is previously known that you will make a custodial
arrest.
(c)Any self‐initiated activity where it is previously known that you’re questioning /
investigation will be used later in a criminal charge.
(d)When feasible an SRO shall activate the BWC when the contact becomes adversarial or
the subject exhibits unusual behaviors.
Nothing in the policy undermines the fact that in many instances SROs are suddenly forced to
take law enforcement action and have no opportunity to activate the BWC. It is also recognized
that SROs have private (confidential) conversations with juveniles. It is not always appropriate
to record these conversations as it diminishes the trust between the individual and the SRO.
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Downloading and Categorizing Data
A.Each officer using a BWC is responsible for transferring or assuring the proper transfer
of the data from their camera to the BWC server by the end of that officer’s shift.
However, if the officer is involved in a shooting, in‐custody death, or other law
enforcement activity resulting in death or great bodily harm, a supervisor or investigator
shall take custody of the officer’s BWC and consult with their supervisor.
B.Officers shall categorize the BWC data files of each video capture and should consult
with a supervisor if in doubt as to the appropriate category. The selected category(ies)
shall determine the retention times per the general records retention schedule
established by the Minnesota Clerks and Finance Officers Association (MCFOA).
C.In addition, officers shall categorize each file appropriately, in the manner specified in
training, with the appropriate category to indicate the information it contains. Some
data subjects may have rights under the MGDPA limiting disclosure of information
about them. These individuals include:
1.Victims and alleged victims of criminal sexual conduct and sex trafficking.
2.Victims of child abuse or neglect.
3.Vulnerable adults who are victims of maltreatment.
4.Undercover officers.
5.Informants.
6.When the video is clearly offensive to common sensitivities.
7.Victims of and witnesses to crimes, if the victim or witness has requested not to be
identified publicly.
8.Individuals who called 911, and services subscribers whose lines were used to place
a call to the 911 system.
9.Mandated reporters.
10.Juvenile witnesses, if the nature of the event or activity justifies protecting the
identity of the witness.
11.Juveniles who are or may be delinquent or engaged in criminal acts.
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12.Individuals who make complaints about violations with respect to the use of real
property.
13.Officers and employees who are the subject of a complaint related to the events
captured on video.
14.Other individuals whose identities the officer believes may be legally protected from
public disclosure.
D.Category and flag designations may be corrected or amended based on additional
information.
Administering Access to BWC Data
A.Data subjects. Under Minnesota law, the following are considered data subjects for
purposes of administering access to BWC data:
1.Any person or entity whose image or voice is documented in the data.
2.The officer who collected the data.
3.Any other officer whose voice or image is documented in the data, regardless of
whether that officer is or can be identified by the recording.
B.BWC data is presumptively private. BWC recordings are classified as private data about
the data subjects unless there is a specific law that provides differently. As a result:
1.BWC data pertaining to people is presumed private, as is BWC data pertaining to
businesses or other entities.
2.Some BWC data is classified as confidential (see C. below).
3.Some BWC data is classified as public (see D. below).
C.Confidential data. BWC data that is collected or created as part of an active criminal
investigation is confidential. This classification takes precedence over the “private”
classification listed above and the “public” classifications listed below.
D.Public data. The following BWC data is public:
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1.Data documenting the discharge of a firearm by a peace officer in the course of
duty, other than for training or the killing of an animal that is sick, injured, or
dangerous.
2.Data that documents the use of force by a peace officer that results in substantial
bodily harm.
3.Data that a data subject requests to be made accessible to the public, subject to
redaction. Data on any data subject (other than a peace officer) who has not
consented to the public release must be redacted [if practicable]. In addition, any
data on undercover officers must be redacted.
4.Data that documents the final disposition of a disciplinary action against a public
employee.
However, if another provision of the Data Practices Act classifies data as private or
otherwise not public, the data retains that other classification. For instance, data that
reveals protected identities under Minn. Stat. § 13.82, subd. 17 (e.g., certain victims,
witnesses, and others) should not be released even if it would otherwise fit into one of
the public categories listed above.
E.Access to BWC data by non‐employees. Officers shall refer members of the media or
public seeking access to BWC data to the administrative lieutenant or their designee,
who shall process the request in accordance with the St. Louis Park Police Department’s
applicable processes and policies and other governing laws. In particular:
1.An individual shall be allowed to review recorded BWC data about themselves and
other data subjects in the recording, but access shall not be granted:
a.If the data was collected or created as part of an active investigation.
b.To portions of the data that the agency would otherwise be prohibited by
law from disclosing to the person seeking access, such as portions that would
reveal identities protected by Minn. Stat. § 13.82, subd. 17.
2.Unless the data is part of an active investigation, an individual data subject shall be
provided with a copy of the recording upon request, but subject to the following
guidelines on redaction:
a.Data on other individuals in the recording who do not consent to the release
must be redacted.
b.Data that would identify undercover officers must be redacted.
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c.Data on other officers who are not undercover, and who are on duty and
engaged in the performance of official duties, may not be redacted.
F.Access by peace officers and law enforcement employees. No employee may have
access to the department’s BWC data except for legitimate law enforcement or data
administration purposes:
1.Officers may access, share, view and download stored BWC video only when there is
a business need for doing so, including the need to defend against an allegation of
misconduct or substandard performance. Officers may review video footage of an
incident in which they were involved prior to preparing a report, giving a statement,
or providing testimony about the incident. Officers shall not use the fact that a
recording was made as a reason to write a less detailed report.
2.Personal devices shall not be used to capture, record, transfer, store or view any
BWC videos, photos or other evidence.
3.Supervisors may view recordings at any time they are making inquiry into an alleged
complaint, performance issue, or policy violation.
4.Agency personnel are prohibited from accessing BWC data for non‐business reasons
and from sharing the data for non‐law enforcement related purposes, including but
not limited to uploading BWC data recorded or maintained by this agency to public
and social media websites. All incidents of access to BWC data are digitally logged.
Allegations of inappropriate access to BWC data will be investigated and based on
the finding, discipline may result.
5.Employees seeking access to BWC data for non‐business reasons may make a
request for it in the same manner as any member of the public.
G.Other authorized disclosures of data. Officers may display portions of BWC footage to
witnesses as necessary for purposes of investigation as allowed by Minn. Stat. § 13.82,
subd. 15, as may be amended from time to time. These displays will generally be limited
in order to protect against the incidental disclosure of individuals whose identities are
not public. Any displays will take place at the St. Louis Park Police Department with the
approval of a supervisor. Protecting against incidental disclosure could involve, for
instance, showing only a portion of the video, showing only screen shots, muting the
audio, or playing the audio but not displaying video. In addition,
1.An officer may request a supervisor respond to the scene and request approval for a
display to take place outside the St. Louis Park Police Department.
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2.BWC data may be shared with other law enforcement agencies only for legitimate
law enforcement purposes that are documented in writing at the time of the
disclosure.
3.BWC data shall be made available to prosecutors, courts, and other criminal justice
entities as provided by law.
Data Security Safeguards
A.Department members shall not intentionally edit, alter, or erase any BWC recording
unless otherwise expressly authorized by the Chief of Police or the Chief’s designee.
B.As required by Minn. Stat. § 13.825, subd. 9, as may be amended from time to time, this
agency shall obtain an independent biennial audit of its BWC program.
Agency Use of Data
A.To ensure compliance with this policy and to identify any performance areas in which
additional training or guidance is required supervisors will review each officer’s BWC
recordings during each officer’s trimester evaluation or more frequently if there is
reason to do so.
B.In addition, supervisors and other assigned personnel may access BWC data for the
purposes of reviewing or investigating a specific incident that has given rise to a
complaint or concern about officer misconduct or performance.
C.When a video is accessed or reviewed via Evidence.com, a notation shall be entered
into the “Notes” section of the screen stating the reason for access.
D.Nothing in this policy limits or prohibits the use of BWC data as evidence of
misconduct or as a basis for discipline.
E.Officers should contact their supervisors to discuss retaining and using BWC footage
for training purposes. Officer objections to preserving or using certain footage for
training will be considered by the chief of Police on a case‐by‐case basis. Field training
officers may utilize BWC data with trainees for the purpose of providing coaching and
feedback on the trainees’ performance.
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Data Retention
A.All BWC data shall be retained for a minimum period of 90 days. There are no
exceptions for erroneously recorded or non‐evidentiary data.
B.Data documenting the following incidents must be maintained for a minimum period of
one year:
1.Discharge of a firearm by a peace officer in the course of duty, other than for
training or the killing of an animal that is sick, injured or dangerous.
2.The use of deadly force by a peace officer, or force of a sufficient type or degree to
require a response to resistance report or supervisory review.
3.Circumstances that have given rise to a formal complaint against an officer.
C.Other data having evidentiary value shall be retained for the period specified in the
Records Retention Schedule. When a particular recording is subject to multiple
retention periods, it shall be maintained for the longest applicable period.
D.Subject to Part F (below), all other BWC footage that is classified as non‐evidentiary,
becomes classified as non‐evidentiary, or is not maintained for training shall be
destroyed after 90 days.
E.Upon written request by a BWC data subject, the agency shall retain a recording
pertaining to that subject for an additional time period requested by the subject of up to
1 year. The agency will notify the requestor at the time of the request that the data will
then be destroyed unless a new written request is received.
F.The department shall maintain an inventory of BWC recordings having evidentiary value.
G.The department will post this policy, together with a link to its Records Retention
Schedule, on its website.
H.In the event that a BWC data file is inaccurately categorized by an officer, or additional
information is gained that suggests a data file category should be changed, the officer
shall notify their immediate supervisor of the required change(s).
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Compliance
Supervisors shall monitor for compliance with this policy. Depending on the circumstances,
violations of the policy may result in coaching and counseling, oral reprimand, written
reprimand, suspension or termination. The unauthorized access to or disclosure of BWC data
may constitute misconduct and subject individuals to disciplinary action and criminal penalties
pursuant to Minn. Stat. § 13.09.
BCA Notification
Notification will be made to the MN Bureau of Criminal Apprehension within ten days of
obtaining new surveillance technology that expands the type or scope of the agency's portable
recording system.
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In-Car Camera Policy Page 1
City of St. Louis Park, Minnesota
In-Car Camera Policy
Purpose
The primary purpose of using body-worn-cameras (ICCs) is to:
A. Capture evidence arising from a police-citizen contact.
B. Assist with accurate report writing.
C. Allow for transparency and accountability in policing and protect the civil rights of
the community.
This policy sets forth guidelines governing the use of ICCs and administering the data that
results. Compliance with these guidelines is mandatory, but it is recognized that officers must
also attend to other primary duties and the safety of all concerned, sometimes in circumstances
that are tense, uncertain, and rapidly evolving.
Objectives
The St. Louis Park Police Department has adopted the use of portable audio/video recorders to
accomplish the following objectives:
A. To enhance officer safety.
B. To document statements and events during the course of an incident.
C. To enhance the officer’s ability to document and review statements and actions for
both internal reporting requirements and for courtroom preparation/presentation.
D. To preserve audio and visual information for use in current and future investigations.
E. To enhance the public trust by preserving factual representations of officer-citizen
interactions in the form of audio-video recording.
F. To promote the civility of police-civilian encounters
G. To provide objective evidence to help resolve civilian complaints against police
officers and the City of St. Louis Park.
H. To protect the civil rights of the community.
I. To assist with training and evaluation of officers.
Policy
It is the policy of this department to authorize and require the use of department-issued ICCs as
set forth below, and to administer ICC data as provided by law.
Scope
This policy governs the use of ICCs in the course of official duties. The Chief of Police or the
chief’s designee may supersede this policy by providing specific instructions for ICC use to
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In-Car Camera Policy Page 2
individual officers, or providing specific instructions pertaining to particular events or classes of
events, including but not limited to political rallies and demonstrations where their use might be
perceived as a form of political or viewpoint-based surveillance. The chief or designee may also
provide specific instructions or standard operating procedures for ICC use to officers assigned to
specialized details, such as carrying out duties in courts or guarding prisoners or patients in
hospitals and mental health facilities. In the event the chief does supersede policy by providing
specific instructions for use, a written report will be submitted to the City Manager.
Definitions
The following phrases have special meanings as used in this policy:
A.MGDPA or Data Practices Act refers to the Minnesota Government Data Practices Act,
Minn. Stat. § 13.01, et seq.
B.Records Retention Schedule refers to the General Records Retention Schedule for
Minnesota Cities.
C.Law enforcement-related information means information captured or available for
capture by use of an ICC that has evidentiary value because it documents events with
respect to a stop, arrest, search, citation, or charging decision.
D.Evidentiary Value means that the information may be useful as proof in a prosecution or
defense of a criminal action, related civil or administrative proceeding, further
investigation of an actual or suspected criminal act, or in considering an allegation
against a law enforcement agency or officer.
E.General Citizen Contact means an informal encounter with a citizen that is not and does
not become law enforcement-related or adversarial, and a recording of the event would
not yield information relevant to an ongoing investigation. Examples include, but are not
limited to, assisting a motorist with directions, summoning a tow truck, or receiving
generalized concerns from a citizen about crime trends in his or her neighborhood.
F.Adversarial means a law enforcement encounter with a person that becomes
confrontational, during which at least one person expresses anger, resentment, or hostility
toward the other, or at least one person directs toward the other verbal conduct consisting
of arguing, threatening, challenging, swearing, yelling, or shouting. Encounters in which
a citizen demands to be recorded or initiates recording on his or her own are deemed
adversarial.
G.Unintentionally recorded footage is a video recording that results from an officer’s
inadvertence or neglect in operating the officer’s ICC, provided that no portion of the
resulting recording has evidentiary value. Examples of unintentionally recorded footage
include, but are not limited to, recordings made in station house locker rooms, restrooms,
and recordings made while officers were engaged in conversations of a non-business,
personal nature with the expectation that the conversation was not being recorded.
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H.Official duties, for purposes of this policy, means that the officer is on duty and
performing authorized law enforcement services on behalf of this agency.
Training
All users of an ICC will be trained on the cameras operation and this policy prior to deploying
one.
Use and Documentation
A. Officers may use only department-issued ICCs in the performance of official duties for
this agency or when otherwise performing authorized law enforcement services as an
employee of this department.
B. All officers working uniform patrol, uniform special details, traffic duties, and uniform
school resource officer duties shall use an ICC unless permission has been granted by a
supervisor to deviate from this clause. Plain clothes investigators/officers and
administrators are allowed to use ICC when interacting with citizens, when appropriate.
C. Officers who have deployed an ICC shall operate and use them consistent with this
policy. Officers shall conduct a function test of their ICCs at the beginning of each shift
to make sure the devices are operating properly. Officers noting a malfunction during
testing or at any other time shall promptly report the malfunction to the officer’s
supervisor. As soon as is practical, the malfunctioning ICC shall be put down for service
and the officer should deploy a vehicle with a working ICC. If an ICC malfunctions while
recording or is damaged the circumstances shall be documented in a police report and a
supervisor shall be notified. Supervisors shall take prompt action to address malfunctions
and document the steps taken in writing.
D. Officers must document ICC use and non-use as follows:
1. Whenever an officer makes a recording, the existence of the recording shall be
documented in the records management system, an incident report, or a citation if
completed.
2. Whenever an officer fails to record an activity that is required to be recorded under
this policy or captures only a part of the activity, the officer must document the
circumstances and reasons for not recording in the records management system or
incident report. Supervisors shall review these reports and initiate any corrective
action deemed necessary.
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General Guidelines for Recording
A. This policy is not intended to describe every possible situation in which the ICC should
be activated, although there are many situations where use of the ICC is appropriate.
Officers should activate the ICC any time the user believes it would be appropriate or
valuable to record an incident.
B. Officers shall activate their ICCs when anticipating that they will be involved in, become
involved in, or witness other officers of this agency involved in a pursuit, Terry frisks, a
traffic stop of a motorist, an investigative stop of a pedestrian, searches, seizures, arrests,
response to resistance incidents, any encounter that becomes in any way hostile,
confrontational, or adversarial , and during other activities likely to yield information
having evidentiary value. However, officers need not activate their cameras when it
would be unsafe, impossible, or impractical to do so, but such instances of not recording
when otherwise required must be documented as specified in the Use and Documentation
guidelines, part (D)(2) (above).
C. When it is reasonable to expect that the citizen contact will occur outside the camera’s
field of view, such as in a home or building or other location distant from the patrol car,
officers need not activate their ICCs if the officer is using a BWC to document the event.
D. Officers have discretion to record or not record general citizen contacts.
E. Officers have no affirmative duty to inform people that an ICC is being operated or that
the individuals are being recorded. Officers may make an announcement that ICCs are
being used.
F. Once activated, the ICC should continue recording until the conclusion of the incident or
encounter, or until it becomes apparent that additional recording is unlikely to capture
information having evidentiary value. The supervisor having charge of a scene shall
likewise direct the discontinuance of recording when further recording is unlikely to
capture additional information having evidentiary value. If the recording is discontinued
while an investigation, response, or incident is ongoing, officers shall state the reasons for
ceasing the recording on camera before deactivating their ICC. If circumstances change,
officers shall reactivate their cameras as required by this policy to capture information
having evidentiary value. Any decision to discontinue recording shall be made with
respect to the nine policy objectives.
G. Officers shall not intentionally block the ICC’s visual recording functionality to defeat
the purposes of this policy. This does not prevent an officer from temporarily blocking
the visual recording during an encounter with persons who are nude or when sensitive
human areas are exposed.
H. Notwithstanding any other provision in this policy, officers shall not use their ICCs or
any other device to record other agency personnel during non-enforcement related
activities, such as during pre- and post-shift time in locker rooms, during meal breaks, or
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during other private conversations, unless recording is authorized as part of a criminal
investigation.
Special Guidelines for Recording
Officers may, in the exercise of sound discretion, determine:
A. To use their ICCs to record any police-citizen encounter if there is reason to believe the
recording would potentially yield information having evidentiary value, unless such
recording is otherwise expressly prohibited.
In addition,
B. Officers need not record persons being provided medical care unless there is reason to
believe the recording would document information having evidentiary value. When
responding to an apparent mental health crisis or event, ICCs shall be activated as
necessary to document any response to resistance and the basis for it, and any other
information having evidentiary value, but need not be activated when doing so would
serve only to record symptoms or behaviors believed to be attributable to the mental
health issue.
C. Officers should use their BWC and ICC to record their transportation and the physical
transfer of persons in their custody to hospitals, detox and mental health care facilities,
juvenile detention centers, and jails, but otherwise should not record in these facilities
unless the officer anticipates witnessing a criminal event or being involved in or
witnessing an adversarial encounter or response to resistance incident.
Downloading and Categorizing Data
A. Each officer using an ICC is responsible for transferring or assuring the proper transfer of
the data from their camera to the ICC server by the end of that officer’s shift. However, if
the officer is involved in a shooting, in-custody death, or other law enforcement activity
resulting in death or great bodily harm, a supervisor or investigator shall take custody of
the officer’s ICC system and consult with their supervisor.
B. Officers shall categorize the ICC data files of each video capture and should consult with
a supervisor if in doubt as to the appropriate category. The selected category(ies) shall
determine the retention times per the general records retention schedule established by
the Minnesota Clerks and Finance Officers Association (MCFOA).
C. In addition, officers shall categorize each file appropriately, in the manner specified in
training, with the appropriate category to indicate the information it contains. Some data
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subjects may have rights under the MGDPA limiting disclosure of information about
them. These individuals include:
1. Victims and alleged victims of criminal sexual conduct and sex trafficking.
2. Victims of child abuse or neglect.
3. Vulnerable adults who are victims of maltreatment.
4. Undercover officers.
5. Informants.
6. When the video is clearly offensive to common sensitivities.
7. Victims of and witnesses to crimes, if the victim or witness has requested not to be
identified publicly.
8. Individuals who called 911, and services subscribers whose lines were used to place a
call to the 911 system.
9. Mandated reporters.
10. Juvenile witnesses, if the nature of the event or activity justifies protecting the
identity of the witness.
11. Juveniles who are or may be delinquent or engaged in criminal acts.
12. Individuals who make complaints about violations with respect to the use of real
property.
13. Officers and employees who are the subject of a complaint related to the events
captured on video.
14. Other individuals whose identities the officer believes may be legally protected from
public disclosure.
D. Category and flag designations may be corrected or amended based on additional
information.
Administering Access to ICC Data
A. Data subjects. Under Minnesota law, the following are considered data subjects for
purposes of administering access to ICC data:
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1. Any person or entity whose image or voice is documented in the data.
2. The officer who collected the data.
3. Any other officer whose voice or image is documented in the data, regardless of
whether that officer is or can be identified by the recording.
B.ICC data is presumptively private. ICC recordings are classified as private data about
the data subjects unless there is a specific law that provides differently. As a result:
1. ICC data pertaining to people is presumed private, as is ICC data pertaining to
businesses or other entities.
2. Some ICC data is classified as confidential (see C. below).
3. Some ICC data is classified as public (see D. below).
C.Confidential data. ICC data that is collected or created as part of an active criminal
investigation is confidential. This classification takes precedence over the “private”
classification listed above and the “public” classifications listed below.
D.Public data. The following ICC data is public:
1. Data documenting the discharge of a firearm by a peace officer in the course of duty,
other than for training or the killing of an animal that is sick, injured, or dangerous.
2. Data that documents the use of force by a peace officer that results in substantial
bodily harm.
3. Data that a data subject requests to be made accessible to the public, subject to
redaction. Data on any data subject (other than a peace officer) who has not consented
to the public release must be redacted [if practicable]. In addition, any data on
undercover officers must be redacted.
4. Data that documents the final disposition of a disciplinary action against a public
employee.
However, if another provision of the Data Practices Act classifies data as private or
otherwise not public, the data retains that other classification. For instance, data that
reveals protected identities under Minn. Stat. § 13.82, subd. 17 (e.g., certain victims,
witnesses, and others) should not be released even if it would otherwise fit into one of the
public categories listed above.
E.Access to ICC data by non-employees. Officers shall refer members of the media or
public seeking access to ICC data to the administrative lieutenant or their designee, who
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shall process the request in accordance with the St. Louis Park Police Department’s
applicable processes and policies and other governing laws. In particular:
1. An individual shall be allowed to review recorded ICC data about themselves and
other data subjects in the recording, but access shall not be granted:
a. If the data was collected or created as part of an active investigation.
b. To portions of the data that the agency would otherwise be prohibited by law
from disclosing to the person seeking access, such as portions that would
reveal identities protected by Minn. Stat. § 13.82, subd. 17.
2. Unless the data is part of an active investigation, an individual data subject shall be
provided with a copy of the recording upon request, but subject to the following
guidelines on redaction:
a. Data on other individuals in the recording who do not consent to the release
must be redacted.
b. Data that would identify undercover officers must be redacted.
c. Data on other officers who are not undercover, and who are on duty and
engaged in the performance of official duties, may not be redacted.
F.Access by peace officers and law enforcement employees. No employee may have
access to the department’s ICC data except for legitimate law enforcement or data
administration purposes:
1. Officers may access, share, view and download stored ICC video only when there is a
business need for doing so, including the need to defend against an allegation of
misconduct or substandard performance. Officers may review video footage of an
incident in which they were involved prior to preparing a report, giving a statement,
or providing testimony about the incident. Officers shall not use the fact that a
recording was made as a reason to write a less detailed report.
2. Personal devices shall not be used to capture, record, transfer, store or view any ICC
videos, photos or other evidence.
3. Supervisors may view recordings at any time they are making inquiry into an alleged
complaint, performance issue, or policy violation.
4. Agency personnel are prohibited from accessing ICC data for non-business reasons
and from sharing the data for non-law enforcement related purposes, including but
not limited to uploading ICC data recorded or maintained by this agency to public and
social media websites. All incidents of access to ICC data are digitally logged.
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Allegations of inappropriate access to ICC data will be investigated and based on the
finding, discipline may result.
5. Employees seeking access to ICC data for non-business reasons may make a request
for it in the same manner as any member of the public.
G.Other authorized disclosures of data. Officers may display portions of ICC footage to
witnesses as necessary for purposes of investigation as allowed by Minn. Stat. § 13.82,
subd. 15, as may be amended from time to time. These displays will generally be limited
in order to protect against the incidental disclosure of individuals whose identities are not
public. Any displays will take place at the St. Louis Park Police Department with the
approval of a supervisor. Protecting against incidental disclosure could involve, for
instance, showing only a portion of the video, showing only screen shots, muting the
audio, or playing the audio but not displaying video. In addition,
1. An officer may request a supervisor respond to the scene and request approval for a
display to take place outside the St. Louis Park Police Department.
2. ICC data may be shared with other law enforcement agencies only for legitimate law
enforcement purposes that are documented in writing at the time of the disclosure.
3. ICC data shall be made available to prosecutors, courts, and other criminal justice
entities as provided by law.
Data Security Safeguards
A. Department members shall not intentionally edit, alter, or erase any BWC recording
unless otherwise expressly authorized by the Chief of Police or the Chief’s designee.
B. As required by Minn. Stat. § 13.825, subd. 9, as may be amended from time to time, this
agency shall obtain an independent biennial audit of its ICC program.
Agency Use of Data
A. To ensure compliance with this policy and to identify any performance areas in which
additional training or guidance is required supervisors will review each officer’s ICC
recordings during each officer’s trimester evaluation or more frequently if there is
reason to do so.
B. In addition, supervisors and other assigned personnel may access ICC data for the
purposes of reviewing or investigating a specific incident that has given rise to a
complaint or concern about officer misconduct or performance.
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C. When a video is accessed or reviewed via Evidence.com, a notation shall be entered
into the “Notes” section of the screen stating the reason for access.
D. Nothing in this policy limits or prohibits the use of ICC data as evidence of misconduct
or as a basis for discipline.
E. Officers should contact their supervisors to discuss retaining and using ICC footage for
training purposes. Officer objections to preserving or using certain footage for training
will be considered by the chief of Police on a case-by-case basis. Field training officers
may utilize ICC data with trainees for the purpose of providing coaching and feedback
on the trainees’ performance.
Data Retention
A. All ICC data shall be retained for a minimum period of 90 days. There are no exceptions
for erroneously recorded or non-evidentiary data.
B. Data documenting the following incidents must be maintained for a minimum period of
one year:
1. Discharge of a firearm by a peace officer in the course of duty, other than for training
or the killing of an animal that is sick, injured or dangerous.
2. The use of deadly force by a peace officer, or force of a sufficient type or degree to
require a response to resistance report or supervisory review.
3. Circumstances that have given rise to a formal complaint against an officer.
C. Other data having evidentiary value shall be retained for the period specified in the
Records Retention Schedule. When a particular recording is subject to multiple retention
periods, it shall be maintained for the longest applicable period.
D. Subject to Part F (below), all other ICC footage that is classified as non-evidentiary,
becomes classified as non-evidentiary, or is not maintained for training shall be destroyed
after 90 days.
E. Upon written request by a ICC data subject, the agency shall retain a recording pertaining
to that subject for an additional time period requested by the subject of up to 1 year. The
agency will notify the requestor at the time of the request that the data will then be
destroyed unless a new written request is received.
F. The department shall maintain an inventory of ICC recordings having evidentiary value.
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G. In the event that a ICC data file is inaccurately categorized by an officer, or additional
information is gained that suggests a data file category should be changed, the officer
shall notify their immediate supervisor of the required change(s).
Compliance
Supervisors shall monitor for compliance with this policy. Depending on the circumstances,
violations of the policy may result in coaching and counseling, oral reprimand, written
reprimand, suspension or termination. The unauthorized access to or disclosure of ICC data may
constitute misconduct and subject individuals to disciplinary action and criminal penalties
pursuant to Minn. Stat. § 13.09.
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St.Louis Park Police De part m ent
Portable Recording System Biennial A udit
Execut ive Sum mary
A pril 5,2023
At the request of the St.Louis Park Police De partment,LOGIS has conducted the biennial audit ofthe St.Louis Park
Police Department Portable Recording System pursuant to Minnesota Statute §13 .825 Subd 9.
Minnesota Statute $13.825 data elements include:
•Data Classification
•Retention of Data
•Access by Data Subjects
•Inventory of Portable Recording System Technology
•Use of Agency-Issued Portable Recording Systems
•Authorization to Access Data
•Sharing Among Agencies
•Biennial Audit
•Notification to the BCA
•Portable Recording System Vendor
After analysis of the statutory requirements and evaluation of St.Louis Park Police Department's management and use
of Portable Recording System (PRS)technology LOGIS has found the St.Louis Park Police Departm ent (SLPPD)to be in
compliance with Minnesota Statute §13.825 bas ed on the following findings:
P:763-5443-2600 F;763-543-2699 5750 Duluth Street,Golden Valley,MN 55422-4036 '--
WWW.LOGIS.ORG '
St.Louis Park Police Department
Portable Recording System Biennial Audit
April 5,2023 -Page 1
Study session meeting of June 12, 2023 (Item No. 2)
Title: Body worn camera annual update Page 29
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Control#Statute Subd Control Testing Procedure Testing Result
Objective
ltem#l $13.825 Subd 2 Data collected Reviewed SLPPD Body Policy covers the process for
is classified per Worn Camera Policy classification a data when
statute 707.11:Downloading and entered into the PRS
Categorizing Data
Axon PRS configuration settings
Reviewed Axon PRS data are properly applied
classification
configurations
ltem#2 513.825 Subd 3 Retention of Reviewed SLPPD Body Policy covers the process for
data Worn Camera Policy retention of data based upon
707.16:Data Retention its classification
Reviewed Axon PRS data Data is retrained for a
retention configurations minimum of 90 days unless
otherwise classified by statute
PRS is configured to retain data
for specified periods based
upon it's classification
Item #3 §13.825 Subd 4 Access by data Reviewed SLPPD Body Policies cover the procedures
subjects Worn Camera Policy for releasing data to subjects
707.12:Administering when request from the SLPPD
Access to BWC Doto Custodian of Records
ltem#4 513.825 Subd 5 Inventory of Reviewed SLPPD Body SLPPD maintains an inventory
PRS technology Worn Camera Policy of 62 cameras,each camera is
707.7:Useand assigned to a unique member
Documentation oftheSLPPD
Reviewed PRS Procedures for using the PRS is
configuration for camera provided thru the SLPPD Field
inventory and unique Training Manual
assignment to individuals
p:763-543-2600 F.763-543-2699 5750 Duluth Street,Golden Valley,MN 55422-4036
WWW L0GI5.ORG
St.Louis Park Police Department
Portable Recording System Biennial Audit
April 5,2023 -Page 2
Study session meeting of June 12, 2023 (Item No. 2)
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Item #5 §13.825 Subd 6 Use of agency-Reviewed SLPPD Body SLPPD has a specific policy
issued devices Worn Camera Policy prohibiting personal devices
707.7:Use and from being worn by members
Documentation and used for agency purpose
ltem#6 513.825 Subd 7 Authorization Reviewed SLPPD Body SLPPD policy prohibits access to
to access data Worn Camera Policy data unless there is a specific
707.12:Administering need to know
Access to BWC Data
ltem#7 §13.825 Subd 8 Sharing among Reviewed SLPPD Body SLPPD Policies includes
agencies Worn Camera Policy guidance and procedures for
707.13:Access to Dato by sharing data with other
Non-Employees,agencies
Department Members
and Other Disclosures
Item #8 $13.825 Subd 9 Biennial audit Reviewed SLPPD Body SLPPD Policy indicates that a
Worn Camera Policy biennial audit must be done
707.14:Doto Security pursuantto MN Statute
Safeguards $913.825
ltem#9 $13.825 Subd 10 Notification to Reviewed SLPPD Body SLPPD Policy indicates that BCA
the BCA Worn Camera Policy notification must occur when
707.17:Compliance new equipment is purchased
that would expand the
departments use of PRS
Item #10 13.825 Subd 11 PRSvendor SLPPD has implemented N/A
the Axon software
application Evidence.com
version 3.21.3
p:763-543-2600 F:763-543-2699 5750 Duluth Street,Golden Valley,MN 55422-4036
WWW L0GI5.0RG
St.Louis Park Police Department
Portable Recording System Biennial Audit
April 5, 2023 -Page 3
Study session meeting of June 12, 2023 (Item No. 2)
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This executive summary is exclusively for the St.Louis Park Police Department.The findings in the Portable Recording
Systems Audit are impartial and based on Information and documentation provided by the St.Louis Park Police
Department and examined by LOGIS lnfonnation Security staff and management.
Local Government Information Systems (LOGIS)attested this audit on April 5, 2023.
Respectfully submitted to the following:
Mikael Garland,Lieutenant,Administration Division
Subcommittee on Data Practices
Legislative Law Library
p:763-543-2600 ,763-543-2699 5750 Duluth Street,Golden Valley,MN 55422-4036
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St.Louis Park Police Department
Portable Recording System Biennial Audit
April 5,2023 -Page 4
Study session meeting of June 12, 2023 (Item No. 2)
Title: Body worn camera annual update Page 32
Meeting: Study session
Meeting date: June 12, 2023
Written report: 3
Executive summary
Title: Annual Stormwater Pollution Prevention Program report
Recommended action: This report is intended to provide the council with a summary of
activities undertaken by the city in 2022 to meet the city’s Municipal Separate Storm Sewer
System (MS4) permit and Stormwater Pollution Prevention Program (SWPPP) requirements.
Policy consideration: None
Summary: The City of St. Louis Park is permitted by the Minnesota Pollution Control Agency
(MPCA) for the discharge of stormwater from the city’s storm sewer system into waters of the
state, such as Minnehaha Creek. This permit is required based on an amendment to the
Environmental Protection Agency’s (EPA) Clean Water Act (CWA) and the creation of the
National Pollutant Discharge Elimination System (NPDES). St Louis Park, along with over 200
other Minnesota cities, are permitted as MS4 communities.
Each year, as a condition of the permit, the city conducts a review of its SWPPP to determine
program compliance, the appropriateness of best management practices (BMPs) and progress
toward achieving the identified goals. City staff completed an annual review of the activities to
ensure compliance. However, the MPCA is in the process of updating their electronic reporting
platform; due to this, MS4 permittees covered by the 2020 MS4 General Permit, are not
required to submit an annual report for the calendar year 2022 by June 30, 2023. When MPCA
releases its new e-service submittal program, sometime in 2024, the city will report MS4
activities for the previous years (e.g., calendar years 2022 and 2023).
To provide the public with opportunities to offer input on the adequacy of the SWPPP, it and
the annual report are located on the city’s stormwater management webpage , along with a link
to submit questions or add comments about the program. Staff also held a public open house
to share the city’s stormwater program activities on April 20 at the Westwood Hills Nature
Center.
Financial or budget considerations: Not applicable at this time.
Strategic priority consideration: St. Louis Park is committed to continue to lead in
environmental stewardship.
Supporting documents: Discussion
2022 SWPPP Stormwater Activity Highlights
Prepared by: Erick Francis, water resources manager
Reviewed by: Debra Heiser, engineering director
Approved by: Kim Keller, city manager
Study session meeting of June 12, 2023 (Item No. 3) Page 2
Title: Annual Stormwater Pollution Prevention Program report
Discussion
Background
The National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer
System (MS4) permit establishes conditions for discharging stormwater and other related
discharges into the waters of the state. Operators of regulated small MS4s are required to
design their Storm Water Pollution Prevention Program (SWPPP) to:
• Reduce the discharge of pollutants to the “maximum extent practicable” (MEP)
• Protect water quality
• Satisfy the appropriate water quality requirements of the Clean Water Act
The EPAs Phase II Rule defines a small MS4 stormwater management program as a program
comprising six elements that, when implemented in concert, are expected to result in
significant reductions of pollutants discharged into receiving water bodies. The SWPPP is
broken out into six program elements, termed Minimum Control Measures (MCMs). These are:
MCM 1 Public education and outreach
Distributing educational materials and performing outreach to inform citizens about
the impacts polluted stormwater runoff discharges can have on water quality.
MCM 2 Public participation/ involvement
Providing opportunities for citizens to participate in program development and
implementation, including effectively publicizing public hearings and/or encouraging
citizen representatives on a stormwater management panel.
MCM3 Illicit discharge detection and elimination
Developing and implementing a plan to detect and eliminate illicit discharges to the
storm sewer system (includes developing a system map and informing the
community about hazards associated with illegal discharges and improper disposal of
waste).
MCM 4 Construction site runoff control
Developing, implementing, and enforcing an erosion and sedi ment control program
for construction activities that disturb one or more acres of land (controls could
include silt fences and temporary stormwater detention ponds).
MCM 5 Post-construction runoff control
Developing, implementing, and enforcing a program to address discharges of post-
construction stormwater runoff from new development and redevelopment areas.
Applicable controls could include preventative actions such as protecting sensitive
areas (e.g., wetlands) or the use of structural BMPs.
MCM 6 Pollution prevention/ good housekeeping
Developing and implementing a program with the goal of preventing or reducing
pollutant runoff from municipal operations. The program must include municipal
staff training on pollution prevention measures and techniques (e.g., regular street
sweeping, reduction in the use of pesticides or street salt, or frequent catch-basin
cleaning).
Implementation of the MEP standard will typically require the development and
implementation of best management practices (BMPs) and the achievement of measurable
goals to satisfy each of the six MCMs.
Study session meeting of June 12, 2023 (Item No. 3) Page 3
Title: Annual Stormwater Pollution Prevention Program report
BMPs are practices, techniques and measures that prevent or reduce water pollution from
nonpoint sources by using the most effective and practicable means of achieving water quality
goals. BMPs include but are not limited to, official controls, structural and nonstructural
controls and operation and maintenance procedures.
Each year, as a condition of the permit, the city conducts a review of its SWPPP to determine
program compliance, the appropriateness of BMPs and progress toward achieving the
identified goals. To achieve this, staff performs an annual review of the activities completed to
ensure compliance.
Updates to the MS4 annual report process
The MPCA is in the process of developing a new e-service for the MS4 annual report. In
addition, the MPCA is revising/ updating many annual report questions to align with the
requirements in the 2020 MS4 General Permit and meet the requirements of the federal
National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule . This means
MS4 permittees that have coverage under the 2020 MS4 General Permit do not need to submit
an annual report for the calendar year 2022 by June 30, 2023. Instead, when the e-service is
released, MS4 permittees will be expected to report MS4 activities for each previous reporting
year (e.g., calendar years 2022 and 2023). The MPCA will communicate to MS4 permittees
when the new e-service becomes available but tentatively anticipates the e-service will be
released in 2024.
SWPPP review
St. Louis Park is covered by the 2020 MS4 General Permit and is therefore not required to
submit an annual report for the calendar year 2022 by June 30, 2023. However, staff completed
its assessment of St. Louis Park’s SWPPP to stay on top of progress.
The city’s SWPPP is located on the city’s stormwater management webpage:
https://www.stlouisparkmn.gov/government/departments -divisions/engineering/stormwater-
management/stormwater-pollution-prevention-program-swppp
The information requested by the MPCA in the report is meant to provide the basis for an
assessment of the appropriateness of the BMPs and the progress that has been made toward
achieving the identified goals for each of the MCMs. This assessment is based on results
collected and analyzed from inspection findings and public input received during the reporting
period.
The city provides the public with opportunities to offer input on the adequacy of the SWPPP. In
addition to providing this report to the council, staff actively promotes the stormwater
management program using city publications, social media, and events, as well as having a
dedicated public meeting each year, which was held at the Westwood Hills Nature Center on
April 20, from 6:00 to 7:00 p.m.
Staff is committed to implementing the SWPPP and maintaining a high level of compliance with
our MS4 permit. This includes continuing to review and refine 1) city process to reduce
pollutants from entering surface waters and 2) record-keeping procedures.
The following outlines the Stormwater Pollution Prevention Program (SWPPP) Minimum Control Measure (MCM)
assessment of the activities that have been completed in 2021. These MCMs are included in the Municipal
Separate Storm Sewer System (MS4) permit issued by the Minnesota Pollution Control Agency (MPCA).
MCM ACTIVITIES COMPLETED
Installed 35 rain gardensInstalled 35 rain gard Sold 156 rain barrelsSold 156 rain barrels Adopt a storm drain: 206 participants, Adopt a storm drain: 206 participants,
387 adoptions387 adoptions
Hosted 39,947 Students at Hosted 39,947 Students at
Westwood Hills Nature CenterWestwood Hills Nature Center
Level 4 Green Step City Level 4 Green Step City Received $16,800 in grant funding from the Received $16,800 in grant funding from the
Clean Water Land & Legacy AmendmentClean Water Land & Legacy Amendment
for rain garden installationfor rain garden installation
Inspected ponds and lakes and storm Inspected ponds and lakes and storm
sewer infrastructure sewer infrastructure
2021
MCM
The following outlines the Stormwater Pollution Prevention Program (SWPPP) Minimum Control Measure (MCM)
assessment of the activities that have been completed in 2021. These MCMs are included in the Municipal
Separate Storm Sewer System (MS4) permit issued by the Minnesota Pollution Control Agency (MPCA).
MCM ACTIVITIES COMPLETED
Installed 35 rain gardensInstalled 35 rain gard Sold 156 rain barrelsSold 156 rain barrels Adopt a storm drain: 206 participants, Adopt a storm drain: 206 participants,
387 adoptions387 adoptions
Hosted 39,947 Students at Hosted 39,947 Students at
Westwood Hills Nature CenterWestwood Hills Nature Center
Level 4 Green Step City Level 4 Green Step City Received $16,800 in grant funding from the Received $16,800 in grant funding from the
Clean Water Land & Legacy AmendmentClean Water Land & Legacy Amendment
for rain garden installationfor rain garden installation
Inspected ponds and lakes and storm Inspected ponds and lakes and storm
sewer infrastructure sewer infrastructure
2021
MCM
The following outlines the Stormwater Pollution Prevention Program (SWPPP) Minimum Control Measure (MCM)
assessment of the activities that have been completed in 2021. These MCMs are included in the Municipal
Separate Storm Sewer System (MS4) permit issued by the Minnesota Pollution Control Agency (MPCA).
MCM ACTIVITIES COMPLETED
Installed 35 rain gardensInstalled 35 rain gard Sold 156 rain barrelsSold 156 rain barrels Adopt a storm drain: 206 participants, Adopt a storm drain: 206 participants,
387 adoptions387 adoptions
Hosted 39,947 Students at Hosted 39,947 Students at
Westwood Hills Nature CenterWestwood Hills Nature Center
Level 4 Green Step City Level 4 Green Step City Received $16,800 in grant funding from the Received $16,800 in grant funding from the
Clean Water Land & Legacy AmendmentClean Water Land & Legacy Amendment
for rain garden installationfor rain garden installation
Inspected ponds and lakes and storm Inspected ponds and lakes and storm
sewer infrastructure sewer infrastructure
2021
MCM2022
MCM
Installed 40 rain gardens Sold 156 rain barrels Adopt a storm drain: 260 participants,
481 adoptions
Hosted 64,443 students at
Westwood Hills Nature Center
Level 4 Green Step City Inspected ponds and lakes and
storm sewer infrastructure
Received $18,600 in grant funding from the
Clean Water Land & Legacy Amendment for
rain garden installation
The following outlines the Stormwater Pollution Prevention Program (SWPPP) Minimum Control Measure (MCM)
assessment of the activities that have been completed in 2022. These MCMs are included in the Municipal Separate
Storm Sewer System (MS4) permit issued by the Minnesota Pollution Control Agency (MPCA).
MCM ACITIVITIES COMPLETED
Study session meeting of June 12, 2023 (Item no. 3) Title: Annual stormwater pollution prevention program report Page 4
Presented to city council June 21, 2021 Presented to city council June 21, 2021
Aug. 12, 2021, open house had 14 attendeesAug. 12, 2021, open house had 14 attendees
Held the Metro Blooms Held the Metro Blooms
Resilient Yard WorkshopResilient Yard Workshop
Maintained Maintained
Oregon PondOregon Pond
Replaced outfall on Replaced outfall on
Powell Road Minnehaha CreekPowell Road Minnehaha Creek
1,925 miles of roads, alley swept, removed 1,925 miles of roads, alley swept, removed
approx. 6,996 cubic yards of materialapprox. 6,996 cubic yards of material
Performed over 400 Performed over 400
construction site inspections construction site inspections
Held Turf Alternative Workshop, and Healthy Held Turf Alternative Workshop, and Healthy
Soils Workshop with a total of 87 attendeesSoils Workshop with a total of 87 attendees
2021
MCM
2022
MCM
Held annual open house, presented to city council,
held annual rain barrel pick up event, attended the
State of the City event and Ecotacular
Performed over 300
construction site inspections
Maintained storm sewer infrastructure
Held the Metro Blooms Resilient Yard
Workshop with 39 attendees
Partnered with the middle school’s
MN Outdoor science students on the
Lamplighter Pond fish survey
University of Minnesota Environmental
Sciences program and their capstone projects
for the Rainwater Rewards Program and the
Effective Yard Waste Management
1,374 miles of streets and alleys swept
with 6,478 cubic yards of material removed
Study session meeting of June 12, 2023 (Item no. 3)
Title: Annual stormwater pollution prevention program report
Page 5Study session meeting of June 12, 2023 (Item no. 3) Title: Annual stormwater pollution prevention program report
Meeting: Study session
Meeting date: June 12, 2023
Written report: 4
Executive summary
Title: Connected infrastructure system wrap-up
Recommended action: None.
Policy consideration: The purpose of this report is to summarize the outcomes of the recent
discussions within the connected infrastructure system study sessions.
Summary: On May 8, the council completed a series of discussions focused on advancing the
city's strategic priority related to connected infrastructure. These discussions primarily focused
on public policy and construction, operations, and maintenance of connected infrastructure.
The study session system started on March 13, 2023. Since that time, staff has provided the
council with information and there have been several policy discussions on topics related to
connected infrastructure. This report serves as a summary of all the discussions and includes
the council direction provided.
Financial or budget considerations: Funds are budgeted in the CIP for connected infrastructure
projects. The additional funds to implement the changes discussed during this system will be
brought forward to council as a part of the 2024 budget discussions.
Strategic priority consideration: St. Louis Park is committed to providing a variety of options for
people to make their way around the city comfortably, safely and reliably.
Supporting documents: Discussion
Prepared by: Debra Heiser, engineering director
Reviewed by: Jack Sullivan, engineering project manager
Mike Okey, operations superintendent
Brian Hoffman, building and energy director
Jay Hall, public works director
Cindy Walsh, deputy city manager
Approved by: Kim Keller, city manager
Study session meeting of June 12, 2023 (Item No. 4) Page 2
Title: Connected infrastructure system wrap-up
Discussion
Background
This system included study sessions covering a range of topics relating to connected
infrastructure. Topics were grouped, and each meeting built on the previous discussion and had
self-contained outcomes based on various policy and practice questions. Reports on these
topics were considered and discussed by the city council and, where appropriate, direction on
future expectations and outcomes was provided to staff for implementation. A summary of the
topics covered in this system includes:
Discussion: Connected infrastructure system introduction
Date: 3/13/2023
Overview: Staff introduced the system, including an overview of the connected infrastructure
capital planning process and guiding documents. The proposed topics included in the system all
center on connected infrastructure policy and provide opportunities to consider how connected
infrastructure is planned for, constructed and maintained in the city. The topics examined
current programs and offered opportunities, identified by both council and staff, for expansion
or adjustment where applicable.
Outcomes of the discussion: The council generally approved of the topics included in the
system.
Discussion: Winter parking restrictions
Date: 3/20/23
Overview: We are seeing higher-than-average snow totals and more frequent snow events.
According to the MnDNR's climate data of the top 20 snow total years, six (6) have occurred
since 2000. Last winter is the fourth time since the 2010-2011 winter that the city has
implemented winter parking restrictions.
The streets where staff posts these restrictions are mostly the same each time the restrictions
are implemented.
Due to the amount of effort it takes to implement these restrictions, staff has been considering
ways to adapt efforts to promote climate resilience.
Outcomes of the discussion: The council supported Option 2: Studying the impacts of installing
permanent signage. The next steps will be:
• Analyze the street network to identify potential streets to sign, along with
recommended time period. Metrics such as street width, available off-street parking,
existing on-street parking restrictions, surrounding land use, snow emergency parking
exemptions and demographics, will be used.
• Develop a more refined cost estimate, along with potential funding, implementation,
and communication strategies.
• Consult the attorney to understand if city code changes are needed to implement.
This topic will be brought back to council for consideration on applicable items.
Study session meeting of June 12, 2023 (Item No. 4) Page 3
Title: Connected infrastructure system wrap-up
Report: Snow emergency exempt parking streets
Date: 3/20/23
Overview: City code allows the city manager or designee to establish a list of public streets
which are not subject to the snow emergency parking ban. The exempted streets will generally
be high-density residential streets without or very limited off-street parking.
During the 2022-2023 snow season, public works staff observed the parking usage in these
areas during snow emergencies to understand if there is a need to have the exemptions remain
in place. In addition, staff has reviewed the city's snow removal practice and how it aligns with
streets currently designated with exempt parking status.
Based on this review, staff shared recommended updates to the streets designated as exempt.
Outcomes: The council was supportive of staff's recommendation to update the city process for
identifying snow emergency exempt parking streets for plowing to be consistent with city code.
Prior to the 2023-2024 snow season, the next steps will be:
• The snow emergency exempt list will be updated to reflect the changes on the approved
map.
• Information will be shared with the residents along these streets about the changes.
• A council action will be brought forward to rescind the current resolution.
Moving forward, this list will be managed by the public works director. Annual reviews will still
be conducted to ensure that the list reflects new on-street parking restrictions and land use
changes that have been approved by council and are in conflict.
Report: Status of items from last year
Date: 4/3/23
Overview: This report provided the council with an update on topics/initiatives discussed with
council during the 2022 connected infrastructure council discussions. Council direction on the
following items resulted in requests for funding in the 2023 budget. Although council supported
these items, they were not included in the 2023 budget. Prior to bringing them forward for
consideration in the 2024 Capital Improvement Plan (CIP) budget process , staff wanted to check
in with the council to see if they still supported the work . The estimated costs for the items are
as follows:
2024 Budget/
CIP Cost
Ongoing
capital costs*
Bollard protected bikeways $65,000 $70,000
Wayfinding (signal cabinet wraps) $15,000
Bicycle and Pedestrian Counts $350,000
Municipal parking lots $50,000
Total $421,500 $70,000
*Every six (6) years as bollards need to be replaced
An update on the Comprehensive safety action plan was provided as well. The cost is estimated
to be $200,000. The re are no additional funds needed for this. The city will receive 80% of the
Study session meeting of June 12, 2023 (Item No. 4) Page 4
Title: Connected infrastructure system wrap-up
funding, or $160,000, as a federal grant. The remaining $40,000 will be paid for using the 2023
engineering operating budget.
Outcomes: Staff will submit requests for funding these items as a part of the 2024 budget
discussions. Final determination as to whether they will be recommended as part of the
proposed 2024 budget is pending.
Report: Watermain vulnerability assessment update
Date: 4/03/23
Overview: This report provided an update on the i nitiatives that staff has been working on to
better understand the condition of the watermain and plan for replacement.
Outcomes: There are three initiatives that staff has been working on:
• Minnetonka Boulevard watermain break evaluation – this is complete.
• Assess citywide vulnerabilities – a study will be completed in late 2023. The information
provided in the study will be used to inform the 10-year CIP starting in 2025.
• Watermain pipe inspection pilot project – this work is scheduled to be completed on
June 9, with a report of the findings by the end of June.
Report: No truck signage
Date: 4/03/23
Overview: The report provided the council background on three local street segments that
have been designated “No Trucks” by council resolution. The signs prohibit the operation of all
trucks on these roads, including trucks that may have a purpose to drive on the s treet for
delivery. Staff has investigated the history of these restrictions on these road segments and
recommends that they be removed.
Outcomes: Council generally supported staff's recommendation. Staff will work on the
following steps to implement this recommendation:
• Information will be shared with the residents along the following streets , informing
them about the change.
o Vernon Avenue, north of Minnetonka Boulevard
o 27th Street between Utica Avenue and Vernon Avenue
• Council actions will be brought forward to rescind the current resolutions for:
o Vernon Avenue, north of Minnetonka Boulevard
o 27th Street between Utica Avenue and Vernon Avenue
o Princeton Avenue between Old Cedar Lake Road and 16th Street
• “No Truck” signage on Vernon Avenue a nd 27th Street will be removed.
Report: Minnehaha Greenway – Cedar Lake regional trail connection
Date: 4/10/23
Overview: This report shared information on the proposed trail connection that connects
Meadowbrook Road to the Cedar Lake Regional Trail and Minnehaha Creek Watershed
District's (MCWD) application for Hennepin County’s Transit Orientated Development grant.
Outcomes: Staff will continue to work with MCWD over the coming months to develop
preliminary design plans for the Minnehaha Greenway trail connection. If MCWD is successful
with receiving grant funding from Hennepin County, they have asked the city to move the
Study session meeting of June 12, 2023 (Item No. 4) Page 5
Title: Connected infrastructure system wrap-up
project up in the CIP for construction in 2025. Staff will update the council after Hennepin
County's Transit Orientated Development awarded grants are identified later this summer.
Discussion: Public sewer and water utilities protection program
Date: 4/10/23
Overview: This discussion was regarding the implementation of two programs that protect
aspects of utility infrastructure by:
1. Reducing the potential for sewer backups by limiting fats, oils and grease (FOG)
generated by food service businesses from entering sanitary sewer lines; and
2. Testing of water backflow devices to verify they are operational in preventing public
water supply contamination from private building processes.
Outcomes: The council provided staff direction that they continue to support the
implementation of these programs. Staff will move forward with the ordinance to establish
these programs and associated fees. The programs would ideally become effective in January
2024 to coincide with licensing renewals.
Discussion: Bulk material containers in the right of way
Date: 4/10/23
Overview: City code was changed in 2003 to prohibit bulk material containers from being
placed in the right of way. Due to this, property owners are required to put them on their
property. Staff has received feedback that this code does not meet community needs. There
are parcels in the city that do not have space to pl ace bulk material containers on private land.
Due to this, staff wanted to discuss potential options to allow bulk material containers in the
right of way.
Outcomes: The majority of the council provided staff direction that they would support
allowing bulk material containers in right of way, under certain circumstances. In addition, the
council expressed concern regarding soft-sided material containers in the right of way,
duration, seasonality and potential damage to the street .
Over the coming year, the following steps will be completed:
• Staff from engineering, fire, police, public works and building and energy will begin the
process of analyzing the conditions under which bulk material containers would be
allowed in the right of way.
• A draft policy will be developed, along with costs and implementation.
• The attorney will be consulted to understand the city code changes that would be
needed to implement.
This information will be brought back to council for review and consideration.
Discussion: Semi-truck parking restrictions
Date: 4/17/23
Overview: Staff provided the council background on semi-truck parking and shared the impact
of current regulations. The goal of this discussion was to determine if the council would like to
take a systems approach to on-street semi-truck parking.
Study session meeting of June 12, 2023 (Item No. 4) Page 6
Title: Connected infrastructure system wrap-up
Outcomes of the discussion: The majority of the council indicated that they are not ready to
ban on-street semi-truck parking in the city. They would like to better understand where and
how semi-trucks might be accommodated in the community. To understand this, staff will
complete the following steps:
• Engage truck drivers: There is a desire to better understand the needs of the truck
drivers who are St. Louis Park residents and how current on-street semi-truck
restrictions are impacting them.
• Reach out to property owners with larger under-utilized parking lots to see if they are
interested in allowing trucks to park there.
• Staff from engineering, fire, police and public works will begin the process of reviewing
the city’s street network. Determining the location and conditions under which trucks
would be allowed unrestricted access to park on the street.
This information can be brought back to council for review and consideration during the next
Connected infrastructure study session system.
Report: Speed limit update - Utica Avenue south of Westside Drive
Date: 5/8/23
Overview: During the citywide speed limit implementation process that occurred in 2021, the
original recommendation was to lower the speed limit on Utica Avenue from 30 mph to 25
mph. However, after an in-depth review of the available speed data, the speed limit for this
segment of roadway was recommended to remain at 30 mph due to the higher speed data that
was available. Data collected in 2018-2020 indicated average speeds ranged from 5 to 15 mph
above the posted 30 mph speed limit.
During the May 24, 2021 study session, the council expressed concerns regarding these high
speeds on Utica Avenue and requested that staff complete additional analysis.
Outcomes: Staff completed this additional analysis and determined that the posted speed limit
of 30 mph on Utica Avenue south of Westside Drive is appropriate. The average speed is within
5 mph of the posted speed; due to this, there are no interim traffic management measures to
influence driver speed that staff would recommend.
Staff will re-evaluate Utica Avenue with the larger citywide speed limit review that was
recommended to be completed within three years of implementation.
Report: CP rail regional trail – Golden Valley and St. Louis Park
Date: 5/8/23
Overview: Three Rivers Park District‘s Canadian Pacific (CP) rail regional trail is a planned 21-
mile regional trail corridor that traverses six communities in Hennepin County – Bloomington,
Edina, St. Louis Park, Golden Valley, New Hope and Crystal. This corridor is broken into four
segments. The master plan for segment A in Bloomington was recently completed.
Three Rivers Park District is kicking off a planning study for the CP rail regional trail Segment C
in St. Louis Park and Golden Valley.
Their six-month study of the trail corridor will include input from city staff, the Park and
Recreation Advisory Commission and community members through numerous public
engagement events.
Study session meeting of June 12, 2023 (Item No. 4) Page 7
Title: Connected infrastructure system wrap-up
The final master plan for the segment in St. Louis Park is expected to be completed at the end
of the year and have an official public comment period in January 2024. Three Rivers Park
District will present the final plan to the council in the spring of 2024 for review and support.
Outcomes: Staff will continue to work with Three Rivers Park District in the planning process to
identify and study alternative routes for the regional trail through St. Louis Park.
Discussion: New sidewalk construction planning
Date: 5/8/23
Overview: Staff recommends that the city take a consistent approach to identifying sidewalks
to be evaluated as a part of transportation projects. The New sidewalk planning framework was
developed to lay out how staff will identify the location of new sidewalk segments to be
evaluated for construction.
Inclusion at the planning stage in the process does not predetermine final recommendations.
The decision on whether to construct proposed sidewalk segments will be made by the city
council as a part of the project approval process.
Outcomes of the discussion: In general, the council was supportive of using the framework to
plan for new sidewalks. Staff will add the additional sidewalk cost to the 10-year CIP for
discussion during the 2024 budget/CIP process.
Report: A systems approach to public streetlights
Date: 5/8/23
Overview: This report provided additional background information on current practices and
outlined staff’s recommendation for a systems approach to public street lighting.
Outcomes: In general, the council was supportive of staff’s recommendation. Moving forward,
staff will update its procedures and begin the analysis to identify gaps in the streetlighting grid.
Through future budgeting processes, staff and council will work together on an implementation
plan that balances community needs with the availability of capital funds.